Administrator – it should be understood as TRDX limited liability company based in Gdańsk, at Uphagena 18 Street, 80 – 237 Gdańsk, NIP: 5842736023, REGON: 222100296, entered into the Register of Entrepreneurs kept by the Gdańsk-Północ District Court in Gdańsk under KRS number: 0000512705, with a fully paid-up share capital of PLN 10.000;
Service – it should be understood as a web-based product named Kanga University, maintained by the Service Provider and available at the Internet address: https://kanga.university/;
User – it should be understood as a natural person with full legal capacity, to whom the Admnistrator makes the Service available and who has access to the User Account;
Guest – it should be understood as a natural person who uses the Service without access to the User Account or who has not logged in;
Virtual currencies or Cryptocurrencies – it should be understood as virtual currencies within the meaning of the provisions of the Act of 1 March 2018 on counteracting money laundering and terrorism financing;
GDPR (”RODO”) – it should be understood as the Regulation (EU) 216/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons in connection with personal data processing and the free movement of such data and the repeal of Directive 95/46/WE and all related legislation;
Regulations – it should be understood as these Regulations, available on website https://kanga.university/;
Cryptostudent.io – the website maintained by Cryptostudent limited liability company based in Białystok, at Zurawia 71 Street, 15 – 540 Białystok, entered into the National Court Register by the Local Court in Białystok, 12th Commercial Division, under the number KRS 0000856805, NIP 9662142695, REGON: 386854042, share capital of PLN 10.000, available at the Internet address: cryptostudent.io.
This document (hereafter referred to as the ”Regulations”) defines the principles of Service availability and the manner of provision of services electronically via the Service.
The Administrator reserves the right to display advertisements and sponsored content in the Service. However, the Administrator shall not be liable for the content of advertisements published in the Service, subject to the mandatory provisions of law.
Every Guest and User is obliged to familiarise themselves with the Regulations. Guests have access to limited features of the Service consisting of free browsing and using the site content with due regard to the terms and conditions of the Service use specified in the Regulations.
The absolute condition to use the full Service features is having an active User Account and logging in to the User Account.
Using the Service by the User and the Guest requires the possession of a device with access to the Internet software that meets the minimum technical requirements necessary for the display of the Service, i.e. standard Internet browser or standard operating system.
The Administrator informs, that investing in Cryptocurrencies is associated with the risk of losing the value of the invested financial resources. At the same time, the User and the Guest declare, that they got acquainted with the KNF announcement available at: http://www.knf.gov.pl/komunikat_mobilny?articleId=57363&p_id=18. The Administrator is neither encouraging nor persuading anyone to purchasing any Virtual currencies, and the Service is intended for educational purposes only.
The Administrator shall make every effort to ensure 24 hours a day Service availability. The use of the Service is free of charge, except for the expenses of the Internet access, enabling the Service use.
It is forbidden to enter illegal content in the Service by the User and the Guest, and to perform actions that could cause disturbance, malfunction or discontinuity of services in the Administrator’s ICT system.
The Service, including in particular all content, source code, graphic signs, is protected by the copyright law. Any copying or using it in a manner contrary to the Regulations is forbidden.
The Administrator provides the Service to the User and the Guest by electronic means. The Service contains educational content related to blockchain and Virtual currencies, as well as other cryptoassets. The Service is provided for educational purposes.
The use of the Service is voluntary and free of charge, except for the expenses of the Internet access, however, it requires knowledge and acceptance of the provisions of the Regulations.
Within the provided Service, the Administrator shares with the User and the Guest thematically divided lessons on Cryptocurrencies and blockchain technology at three levels: basic, intermediate and advance, in two languages: Polsih and English.
The Administrator provides to the Users who are logged in, within the full Service functionality, the possibility to track the learning progress and the opportunity to obtain a certificate upon successful completion of the course under the conditions described in the Service. The completion of the course does not give any entitlement to additional gratuities; there is also no possibility to exchange the certificate of the course completion for another item or benefit. The certificate does not entitle the User to any benefits, nor can it be accepted as any proof of User’s qualifications. The User is obliged to refrain from making any use of the certificate, in particular to prove quaifications towards any third parties.
The Administrator is not responsible for any interruptions to the services provided by electronic means if they results from force majeure or the activity of third parties, for which the Administrator is not responsible.
The Administrator is not responsible for the content shared or distributed in the Service by other parties, subject to the mandatory provisions of law.
The User and the Guest are entitled to submit a compliant to the Administrator concerning the functioning of the Service.
Compliants should be submitted electronically via e-mail to the address: [email protected].
When submitting a compliant, the User and the Guest should give name and surname, a full description of the subject of complaint, a request to consider the compliant and indicate the way the Administrator shall submit the response to the compliant. If the User and the Guest wish to receive a reply in a written form, the User and the Guest are obliged to provide the address to which the written reply should be sent.
The Administrator shall provide an answer to the User’s and the Guest’s compliant within 14 days from the date of its receipt. The Administrator responses to the compliant on paper to the address indicated by the User or the Guest, or electronically, depending on the form of the complaint or the Users’ or Guest’s choice.
The User and the Guest are entitled to use the Online Dispute Resolution (ODR) platform under Regulation of the European Parliament and of the Council no 524/2013 of 21 May 2013 on online dispute resolution for consumer disputes and amending Regulation (EC) no 2004/2006 and Directive 2009/22/EC (Directive on consumer ADR). ODR platform can be accessed at the following Internet address: http://webgate.ec.europa.eu/odr/main/index.cfm?event=main.home.show&lng=PL
The Administrator reserves the right to amend these Regulations. In such case, the Administrator will notify the User and the Guest about providing a revised version of the Regulations via the Service.
In all matters not included in these Regulations, the provisions of generally applicable Polish law shall apply.
Unless the mandatory provisions of law state otherwise, the Polish law shall be the law applicable to the whole of agreement for the provision of services by electronic means under the conditions specified in the Regulations.
Controller – the Controller of personal data pursuant GDPR, which is Kanga Exchange;
Joint Controller – the joint controller of personal data pursuant to GDPR, which is Mosaico;
Kanga Exchange – Good Solution Investments Limited, Cromwell House, Ground-Floor, 117 Albert Street, Belize City, Belize;
Mosaico – Sapiency sp. z o.o. headquartered at ul. Lekarska 1, 31-203 Kraków, Poland, and registered under KRS number 789717;
Personal Data – Users’ personal data within the meaning of GDPR transferred in connection with using the Service;
Processing of personal data – all operations performed on personal data within the meaning of GDPR;
GDPR – Regulation of the European Parliament and of the Council (UE) 2016/679 of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/CE (J. o L. UE 2016 it. L119);
Website – website made available through the agency of Kanga.Exchange and subdomains;
Services – Services rendered by Kanga Exchange electronically that guarantee the possibility to associate the Users via the Service for the purpose of performing the purchase or sale of crypto currency available in the Website;
User – natural or legal persons, who accepted the Kanga Exchange’s Terms of Service and concluded the agreement for performance of the Service with Kanga Exchange.
All terms written with a capital letter and not defined above ought to be understood in conformity with the definitions included in Kanga Exchange’s Terms of Service.
II. Joint Agreements
Under the joint administration agreement concluded between the Controller and the Joint Controller, the scopes of responsibility regarding the fulfillment of obligations under the GDPR have been established as follows:
The Controller and the Joint Controller will jointly process the data provided by Users to the extent necessary for the intended purpose.
The Controller and the Joint Controller will jointly process the data provided by Users for marketing purposes, with the User’s prior consent, given separately to the Controller and the Joint Controller.
III. General Information
The Website performs the functions of obtaining information on the Users and their behavior as follows:
by entering information into forms;
by storing files (called “cookies”) on terminal devices;
by collecting web server logs and other information occurring in connection with or as a result of functioning of and using of the Service;
by recording and collecting personal data in the form of recording the User’s image obtained via a video communicator (e.g. skype).
IV. Principles of Collection of Users’ Personal Data
Using Services is connected with the necessity to provide Personal Data by the Users. Failure to provide all Personal Data required by Kanga Exchange can lead to impossibility to provide Services by Kanga Exchange.
The Website collects information provided by the User.
The Website can moreover record information on the parameters of connection (determination of time, IP address etc.).
Data obtained from the Users is not made available to third parties unless:
the User expresses their consent;
it is justified by the provisions of law;
it is necessary for the purpose of providing Services, in particular in the technical scope of Services dealing with payments and also of other entities that Kanga Exchange cooperates with by performance of the Service.
V. Scope of Data Protection and processing thereof
In connection with the performance of the given Service, the Controller can request that the User provides Personal Data. In particular in case of:
a. a natural person: the features of the document stating the User’s identity as well as their name, surname, citizenship, address of residence, country of birth, information on tax residence and occupied exposed political position, telephone number, date of birth and ID Number. In case of foreign Users who have no National ID number, one should provide the equivalent of such number (the national identification number) (or file a statement on non-possession of National ID number number);
b. in case of an institutional User: to send a scan of extract from the Commercial Register, data concerning business activity, a scan of a confirmation of assigning it a tax identification number – unless the given number is shown in the transcript from the Trade Register, as well as, providing the features of the document stating the identity of the person authorized to represent the User, his/her name, surname, citizenship, address of residence, information on tax residence and occupied exposed political position, telephone number, date of birth and National ID number (personal identity number). The User is also obliged to provide the above information regarding all actual beneficiaries of the User up to the indication of natural persons.
For the purpose of verification of data the User must present to the Kanga Exchange employee an identity document or send a scan or photo thereof in the .jpg or .png format by means of the form on the Website. The scan/photo of the identity document must meet the following terms: data on the document must be clearly visible, all edges of the document must be visible, no data can be covered. The file cannot contain any signs of digital remake (e.g. painting over of an element using a graphic program). Placement of a water line is admissible. In case of doubts Kanga Exchange can ask the User to send the photo of their identity document made so that both the User’s face and their identity document can be seen simultaneously (the so-called selfie) or connect with the User via a video communicator (e.g. skype).
Confirmation of the User’s or User’s representative’s address can take place on the basis of a photo in the .jpg or .png format, a bill (for electricity, water, gas etc.), an agreement with a public trust institution or an official letter with the User’s address data with the name and surname as well as the date of preparation (not older than 6 months).
Personal data is processed pursuant to the provisions of the Regulation of the European Parliament and of the Council (UE) 2016/679 of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/CE (J. o.L. UE 2016, it. L119) and provisions of the hapter 373 of the Act on money laundering of September 23, 1994 (CAP 373).
The basis for the processing of data are the User’s consent or provisions of law that authorize to process personal data.
The provision of data by the User is voluntary, however indispensable for rendering the Services.
Personal data shall not be made available to other entities without the User’s knowledge except for the entities authorized under the provisions of law.
Each User has the right to inspect their personal data, amendment or removal thereof inasmuch it fails to violate the provisions of law and can be performed from the level of the user’s panel.
The Controller can deny the performance of the rights indicated in p.8 if it results so from the provisions of law, information is subject to the pending dispute or it is indispensable for explanation of circumstances of User’s violation of the Terms of Service.
The Controller has the right to take any actions to increase the security of the Services provided by the Controller.
VI. User’s Rights
The User has the right to access the content of Personal Data and amendment thereof.
The User is authorized to demand supplementation, updating, correction of personal data, temporary or permanent cessation of processing thereof or removal thereof if it is incomplete, outdated, untrue or has been collected contrary to the law or is useless for the performance of the purpose for which it was collected.
In case of amendment of Personal Data, the User is obliged to perform actions aiming at updating Personal Data on their Account.
The Controller can deny removal of Personal Data in a justified case, and in particular if the User:
a. has not paid all amount due to the Controller, or
b. has violated the Terms of Service, or
c. has violated the effective provisions of law,
and the maintenance of Personal Data is indispensable for explanation of such circumstances and determination of the scope of User’s liability. In each case of denial of Personal Data removal, the Controller shall inform the User on the reasons of such denial along with the legal grounds thereof.
In case of doubts regarding the method of processing Personal Data, the User can receive explanation from the Controller and has the right to file an inquiry, a reservation or a complaint to the supervisory body.
Personal Data provided specifically for marketing purposes can be used for automated decision making and profiling.
The user has the right to lodge a complaint with the President of the Personal Data Protection Office on the terms set out in the GDPR.
The User has the right to object to the processing of Personal Data and to demand that such processing be restricted.
The User has the right to request the transfer of Personal Data.
The basis for processing data are in particular the effective regulations and provisions of law and the consent if it was given by the User.
Personal Data will be processed for the duration of the Agreement for rendering the Service.
The cookie files (the so-called “cookies”) constitute information data, in particular text files, which is stored on the User’s terminal device and is intended for the usage of the Website. Cookies usually contain the name of Website they come from, duration of storage thereof on the terminal device and a unique number.
The entity that places the cookie files on the User’s terminal device and receiving access thereto is Kanga Exchange.
The cookie files are used for the following purposes:
creation of statistics that help to understand in what way the Users use Website, which allows improvement of structure and content thereof;
up-keeping of the User’s session (after logging in) thanks to which the User does not have to write again the login and password on each subpage;
definition of the user’s profile for the purpose of displaying to him adjusted materials in advertising networks, in particular in the Google network.
Within the framework of the Website, two basic types of cookies are applied: session cookies and persistent cookies. “Session” cookies are temporary files that are stored on the User’s terminal device until they log out, leave the Website or disable the software (web browser). “Persistent” cookies are stored on the User’s terminal device for a period of time stipulated in the parameters of cookies files or until the User removes them.
Software for browsing websites (web browser) usually by default allows cookies to be stored on the User’s terminal device. The Users can change settings in this scope. The web browser enables to delete cookies. It is possible to automatically block cookies. Detail information on the subject can be found in the help section or documentation of the web browser.
Limitation of usage of cookies can affect some of the functionality available on the Website.
Cookies files are placed on the User’s final device and can be also used by advertisers and partners that cooperate with Kanga Exchange. We recommend reading the privacy protection policy of these companies and to become acquainted with the principles of using cookie files used in the statistics.
Cookie files can be used by advertising networks, in particular the Google network, to display advertisements matched to the way the User uses the Website. For this purpose they can retain information on the User’s navigation path or the time they stay on the page.
In terms of information on the User’s preferences stored by the Google Display Network, the User can view and edit information derived from cookie files with the tool: https://www.google.com/ads/preferences/
VIII. Server logs
Information on some actions of the Users are subject to log into the server layer. This data is only used to administrate the Website and to ensure the most efficient hosting services, also for evidential purposes in connection with committed crimes or due to circumstances connecte with seeking claims in civil proceedings.
Browsed resources are being identified by URLs. Moreover, the following data may be stored:
date of request,
time of reply,
name of User’s station – identification carried out by HTTP, HTTPS protocols,
information on errors that occurred during the HTTP, HTTPS transactions,
URL of the page previously visited by the User (referer link) – when the transition to the Website took place by reference,
information about the User’s browser,
IP address information.
Some of the above data is not associated with particular Users using the Website. The Controller does not associate this data with the User’s Personal Data and does not use it for User’s identification as it is only used for the purpose of server administration.
IX. Cookie Files Management – how to express and retract permission in practice?
If the User does not agree to receive cookie files, they can change the browser settings. We reserve that disabling cookies required for authentication, safety, maintenance of User’s preferences may hinder and in extreme cases prevent the use of the Website.
Information on management of cookies settings in the given browser can be found on the Website of editor thereof.
The User can anytime contact the Controller to obtain information under the following address: [email protected]