Privacy Policy

This notice together with Terms of Use and other documents referred to it sets the basis on which Personal Data we collect, process and use. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Personal data - means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

What information is being collected?

We collect Personal Information about you as described in this section. In summary, some information you provide to us. We also collect certain information automatically.

For example, when you use the Services we must collect certain data for the Services to work. This may include information like your email address which we may require for setting up an account for certain Services or your IP address (which we have to collect automatically for certain functionality). Please note that when creating a wallet with Hero, no email address is required.

When you visit the Services, we collect: (1) technical information that is used to deliver the contents and Services and for other purposes as described below, and (2) information that you provide to us.

We collect a variety of information that you provide to us. The specific types of information we collect will depend upon your engagement with the Services. Some Personal Information that you provide to us is required for the use of the Services. However other Personal Information is optional.

Who is collecting it?

Chief compliance officer of Hero is the person in charge of ensuring our company adheres to this Privacy Policy. This person is also the main contact for our Data Protection Supervisory Authority, the Information Commissioner’s Office.

How is it collected?

The main way how we get that kind of personal data is when you provide it to us such as when you sign up for a Hero account also when you communicate with us by email we collect the communication and any data provided in it. Moreover, when we obtain information from third parties such as identity verification services, credit reference agencies, and regulatory and enforcement agencies. When you use the Hero platform we collect information on your transactions and other use of your Hero account.

How will it be used?

We will process your Personal Information only for the purpose(s) of providing to you the service(s) that you ask us to provide and to satisfy the legal obligations stemming from regulatory obligations that arise from providing you the service(s).

• To create your account or profile, if required, for your use of the Services;
• To provide our Services, including to allow access to, operate and support our Services. Your Personal Information is required for the basic functionality of the Services, such as addressing and responding to your requests for the Services;
• For personalization to customize our Services to meet your specific needs, such as identifying your requests for regionality to improve your experience with the Service;
• For product improvement to improve the Services and to develop new products, services, and features;
• To communicate with you, by phone, text, email, or chat. This may include contacting you for administrative purposes such as security or support and maintenance advisories, to provide services and information that you request, to respond to comments and questions, to contact you regarding issues concerning your use of our Services, including changes to this Privacy Notice, and to otherwise provide customer support;
• Subject to any consent requirements, to send marketing materials, alerts about the latest developments and features or other promotional materials, and to develop new promotional materials that can be useful or relevant to you. You will always be provided with an opportunity to opt out of receiving marketing communications. For example, you can opt out by following the instructions located at the bottom of any commercial emails you may receive or by contacting us as described in the “Contact Us” section in this Privacy Notice;
• For customer relationship management including to track emails, phone calls, and other actions you have taken as a prospective customer;
• For aggregation or de-identifying of Personal Information which is a format that does not allow you to be personally identified. We use the resulting information for statistical analysis regarding the use of the Services, such as to better understand our customer base, or for other purposes;
• For administrative and legal purposes, such as for compliance purposes;
• For safety, security and integrity focused on investigating in good faith alleged violations of our Terms of Use, including unauthorized access and use. In order to protect the Services, and ensure your continued access to the Services, your Personal Information is collected to prevent malicious actors from attacking and disrupting the Services.

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns and will not be used to identify any individual unless that same individual.

Your data is only accessed internally on a need to know basis, and it will only be accessed or processed if absolutely necessary. We will delete data that is no longer required by any relevant law or jurisdiction in which we operate.

When you access Hero, we may make use of the standard practice of placing tiny data files called cookies, they are typically stored on your computer's hard drive. Information collected from cookies is used by us to evaluate the effectiveness of our Site, analyse trends, and administer the Platform.

The information collected from cookies allows us to determine such things as which parts of our website are most visited and difficulties our visitors may experience in accessing our website. With this knowledge, we can improve the quality of your experience on the Platform by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties. Similar technology - web bugs or clear gifs. They are typically stored in emails, we use it to help us confirm your receipt of, and response to, our emails and to provide you with a more personalized experience when using our Site.

To find out more about cookies and similar technology click here

Single Sign-On Through Internet Service Providers. When you decide to use single sign-in servers to connect to our Services, we may collect Personal Information from internet service providers. Your interactions with these tools are governed by the privacy notices of the corresponding platform.

Device and Usage Information. When you access and use the Services, including in limited circumstances when you engage with our relevant support platforms to make a request or where you require support from us, we may receive and store information about your interactions. This may include information such as date/time stamps, usage information and statistics, your internet protocol (IP) address, location (eg, city or state), hardware and software information (including operating system version and type), browser type, device identifiers, device event information, crash data, cookie data, and your interactions with the Services. This information could be used to identify you or your device.

Account Information – Information that is generated by your Hero account activity including, but not limited to, instructions regarding funding and disbursement, orders, trades, and account balances.

Cookies and Similar Technologies. When you access the Service, we may collect Personal Information via cookies, pixel tags, or similar technologies on the Services (collectively referred to as “Cookies”).

Location Information. When you use the Services, we may collect general location information (such as general location inferred from an IP address).

Information from Other Sources. We may collect information about you from third parties, such as marketing partners (for example, when you engage with our marketing campaigns) and researchers (for example, when you engage with our user experience research activities). We may combine this information with information we collect from you and use it as described in this Privacy Notice.

We collect information from other affiliated and non-affiliated third parties and we may associate that with the information we collect about you. For example, in connection with your creation of a Hero Account or to enable your transactions, Hero may work with third party service providers to conduct identity verification and other screening procedures, including screening to verify that you are eligible to use the Services.

We may share your personal information with selected third parties including:

• Affiliates, operational and business partners, suppliers and sub-contractors for the performance and execution of any contract we enter into with them or you;
• Analytics and search engine providers that assist us in the improvement and optimization of our site.
• We may disclose your personal information to third parties when: We sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets in order to continue the services for which you have contracted;
• We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms & Conditions and other applicable agreements. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
• We conduct or cooperate in investigations of fraud or other illegal activity whenever we believe it is reasonable and appropriate to do so;
• We seek to prevent and detect fraud and crime;
• We receive a lawful subpoena, warrant, court order, or as otherwise required by law;
• We seek to recover debt or in relation to your insolvency
• We seek information necessary to maintain or develop customer relationships, services and systems.

We do not maintain a published list of all of the third parties with whom we share your personal information with, as this would be heavily dependent on your specific use of our Services. However, if you would like further information about who we have shared your personal information with, or to be provided with a list specific to you, you can request this by writing to us here.

We have implemented technical and organisational security measures to ensure the confidentiality of your Personal Information and to protect your Personal Information from loss, misuse, alteration or destruction. Information will be kept in Google Cloud platform, which has been saved by SSL. Only authorised personnel of Hero have access to your Personal Information, and these personnel are required to treat the information as confidential.

Where you have consented to, or we are obliged to pass on Personal Information to third parties to provide you with a requested service or in the carrying out of a regulatory or legal obligation, we will request that the same levels of technical and organisational security measure be applied through contractual arrangements, where possible.

Technical and organisational security measures in place will, from time to time, be reviewed in line with legal and technical developments. In the event of a personal data breach or the failure of the measures of protection of such information we will immediately notify you without undue delay.

We may make automated decisions on certain matters. For example, we may do this to decide whether we can provide our services to you based on a credit check/risk profiling. Depending on the outcome of the credit check/risk profiling, a decision will be reached automatically as to whether we are able to provide products or services to you based on your credit worthiness.

If you disagree with the decision you are entitled to contest this by contacting us here.

There may be links from our Site to other sites and resources provided by third parties. This Privacy Policy applies only to our Site. Accessing those third-party sites or sources requires you to leave our Site.

We do not control those third party sites or any of the content contained therein and you agree that we are in no way responsible or liable for any of those third party sites, including, without limitation, their content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to or arising from those sites. We encourage you to review all policies, rules, terms and regulations, including the privacy policies, of each site that you visit.

• Email Communications – Subject to applicable laws and regulations, we may from time to time send communications promoting services or activities to you using information collected from you. We will provide you with an opportunity to opt-out of newsletter communications. Unfortunately, we are unable to allow you to opt-out of the emails we send you for certain legal or administrative purposes.
• Right of Rectification– You have the right to correct any personal information We hold on you that is inaccurate, incorrect, or out of date. If you want to correct - request this by writing to us here.
• Right to Erasure - Hero will retain Accounts and Personal Information for, at least, a period of five years after a user closes his account with us, because of the Anti-Money Laundering and Company legal obligations. After this period of time your personal information will be erased without undue delay.
• Right to justice - if you are not satisfied with how the personal data is processed, you have the right to lodge a complaint with a supervisory authority.
• Portability – You may have the right to transfer certain of your personal data between data controllers, for example, to move your account details from one online platform to another.
• Access – you are entitled to ask us if we are processing your information and, if we are, you can request access to your personal data. This enables you to receive a copy of the personal data we hold about you and certain other information about it to check that we are lawfully processing it.
• Restriction – you are entitled to ask us to suspend the processing of certain of your personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

Please contact us with questions, comments, or concerns regarding our Privacy Policy and/or practices.