Privacy Policy

Undefined terms in this Privacy Policy have the same definition as in our Terms & Conditions.

We have put together this privacy policy to let you know:

  • who we are;
  • when we collect your personal data;
  • how we collect your personal data;
  • what personal data we collect about you;
  • why we process your personal data;
  • with whom we share your personal data;
  • for how long we store your personal data;
  • what your rights are;
  • Contact and complaints; and
  • Changes to this privacy policy.

1. WHO WE ARE

MYRENEGADE, UNIPESSOAL LDA is a company organised under the laws of Portugal with registration number 517780801, and having its registered address at Avenida Engenheiro Duarte Pacheco, N.º 19, R/c, S4, 1070 - 100 Lisboa, Portugal ("Renegade", "we", "us", "our").

Renegade has created the MyRenegade App and the Renegade web platform (jointly the “Platform”) through which customers in the European Economic Area can access and use a Virtual IBAN to deposit/withdraw euros and use crypto-asset services.

We have partnered with Striga Technology OÜ (16298772) ("Striga"), an Estonian fintech company that provides financial services.

You sign up with Renegade and within our Platform you apply to become a customer of Striga. Generally, you are provided with a Virtual IBAN and a crypto-asset account. You can read more about the financial services in the Renegade Terms and Conditions. You need to accept the Renegade Terms and Conditions and if you are onboarded as a customer of Striga in accordance with such terms and conditions, you will be able to access and use the financial services using our Platform.

Striga is the controller and responsible for the processing of your personal data when you use their financial services, as further described in Striga’s privacy policy.

2. WHEN WE COLLECT YOUR PERSONAL DATA

Renegade will start processing your personal data when you register your Renegade account.

3. HOW WE COLLECT YOUR PERSONAL DATA

We collect personal data about you from different sources, including:

  • (i) personal data received from you, such as when you sign up for a platform account, including contact information;
  • (ii) personal data about you received from external sources, e.g. third party service providers and partners, or if you sign up using Google or Apple;]
  • (iii) personal data that is shared with us by Striga, mainly customer support information which we need to be able to assist you with customer support matters but also personal data related to your use of Striga’s financial services;

4. WHAT PERSONAL DATA WE COLLECT

We have divided the personal data we process into the following categories:

  • (i) Contact information - such as name and other information about yourself (e.g. address, telephone number, e-mail address, etc.);
  • (ii) Information about how you interact with Renegade - for example how you use the Renegade account;
  • (iii) Device information - for example IP address, language settings, browser settings, time zone, operating system, platform and screen resolution;
  • (iv) Customer support information - information that you provide to our customer support so we can help you with resolving your enquiries.

5. WHY WE PROCESS YOUR PERSONAL DATA

According to the GDPR we need to have a purpose and a legal basis for the processing of your personal data. Read more about our purpose for processing your personal data below.

At Renegade, the legal basis for processing your personal data is either:

  • (i) the agreement you have, or is about to enter into, with us by accepting our terms and conditions or, the agreement you have, or is about to enter into, with Striga by accepting Striga’s terms and conditions;
  • (ii) our legitimate interest, such as providing customer support or keeping you informed about product updates.

In very rare cases we may also process your personal data if we have received your explicit consent to do so. In such a case you can always withdraw your consent at any time.

We use the personal data we collect for the following purposes:

the administration and management of our relationship with you, such as reviewing your application to become Renegade’s customer, setting up your platform account, conducting performance analytics and keeping you informed about product updates;

The legal basis for such processing is (i) the agreement you have entered into, or is about to enter into, with us or (ii) our legitimate interest. Our view is that keeping you up to date on the products and services available to you creates meaningful knowledge to you.

provision of our services, updates, security alerts and support and administrative messages, and otherwise facilitate your use of, and our administration and operation of, the Platform and to enforce our Terms & Conditions and other policies;

The legal basis for the provision of our services is the agreement you have entered into with us.

accounting and auditing requirements;

business development, such as compiling statistics and analysing the data in order to improve our services;

The legal basis for such processing is our legitimate interest in maintaining our relationship with you and to improve our services. Our view is that you as our customers benefit from improvements to the services;

Assess or defend legal claims against us or to protect ourselves from fraud and in connection with a reorganisation, transfer of business, merger, IPO or acquisition.

The legal basis for such processing is our legitimate interest to defend us against legal claims, to protect our company from fraud, and to be able to reorganise or scale-up our business.

6. WITH WHOM WE SHARE YOUR PERSONAL DATA

We may share your personal data with our affiliates and trusted third party service providers in order to be able to provide our services. These trusted third party service providers may include services of delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your personal data. Where any of your personal data is required for such a purpose, we undertake steps to ensure that your personal data is processed in accordance with the requirements of the applicable data protection laws.

We also share data with our other trusted third party service providers, who act as our processors:

  • Suppliers of IT systems and cloud services
  • Payment providers
  • Third-party investigators, authorities, or law enforcement bodies when required

We have carefully reviewed our service providers and secured that their processing of your personal data is compliant with EU standards and the GDPR.

Your personal data will also, when applicable, be shared with the following parties which themselves are data controllers of the processing of personal data:

  • Striga, for the purposes of providing the second line customer support to you and also to otherwise provide the agreed-upon services to the you as the End User.

The legal basis is the agreement you have entered into with Striga

Striga, for any specific purpose as further described in Striga’s Terms and Conditions and Striga’s Privacy Policy.

We are sometimes required to share personal data with parties operating outside the EU. In these cases, we ensure that the data is transferred in accordance with the applicable requirements of the GDPR, primarily the standard contract clauses (SCC) and complementary safety measures, or if available, other means in compliance with the GDPR.

If Renegade engages in a merger, acquisition, reorganisation or sale of some or all of Renegade’s assets or shares, financing, initial public offering or similar transactions or proceedings, or steps in contemplation of such activities (such as due diligence), Renegade may share personal data with third parties, subject to standard confidentiality arrangements.

7. FOR HOW LONG?

We store your personal data for the purposes set out above during the term of our contractual relationship with you, for as long as we otherwise have a meaningful contact with you or as may otherwise be required by law.

When the purpose for which your personal data was collected is no longer relevant, we will stop processing your personal data and either delete or anonymise it in a secure manner. We may retain your personal data for a longer period of time to the extent required by law, by our automated disaster recovery backup systems or if we deem it necessary to assess or defend legal claims.

Under mandatory law, we are required to keep your personal data due to:

* Bookkeeping legislation, for a period of seven years.

8. YOUR RIGHTS

As a data subject, you have the right to request access to and information about the personal data that we process about you. Additionally, you may also request that we correct (rectify), complete, erase or restrict the processing of personal data regarding you. You also have the right to request a copy of the personal data we process regarding you free of charge. For any request in accordance with these rights email us at support@myrenegade.net

Where Renegade processes your personal data on the legal ground of consent or fulfilment of contract, you have the right to data portability which means that you can receive the personal data in a commonly used, structured and machine-readable format and you have the right to transfer it to another controller.

Where Renegade processes your personal data on the legal ground of consent or fulfilment of contract, you have the right to data portability which means that you can receive the personal data in a commonly used, structured and machine-readable format and you have the right to transfer it to another controller. You have an absolute right to object to personal data processing done for the purposes of direct marketing.

9. CONTACTS AND COMPLAINTS

If you have any cause for complaint about Renegade’s processing of your personal data, please contact us using the details provided in this Privacy Policy and we will do our best to address your concerns. Customer support is accessible via the platform chat. Customer support is open 24/7. all days. Customer support is available in the German and English language.

Please be informed that you have the possibility to lodge a complaint with a supervisory authority if you are not satisfied with our processing of your personal data. You may find your local supervisory authority by following this link:

https://edpb.europa.eu/about-edpb/board/members_en

10. CHANGES TO THIS PRIVACY POLICY

We may need to change this privacy policy, for example when we add features to the services, because of changes in law or regulations or due to evolving industry standards. You will be informed about such changes via email.

11. OUR CORPORATE ADDRESS

MYRENEGADE, UNIPESSOAL LDA
Avenida Engenheiro Duarte Pacheco, N.º 19, R/c, S4
1070 - 100 Lisboa
Portugal