PRIVACY NOTICES
Privacy Notice for Employees & Applicants
BAM Trading Services Inc. d/b/a Binance.US and its affiliates (collectively, “BAM” or “Binance.US”) are committed to respecting your privacy and protecting your personal information, whether you are a customer, potential customer, or other user of our web services (collectively, “you”). This Privacy Policy (this “Policy”) describes how BAM collects, uses, and discloses personal information, and your choices regarding this information.
This Policy applies to our services, which include the services we provide on https://www.binance.us or any other websites, pages, features, or content we own or operate (collectively, the “Sites”) or when you use our mobile app, any BAM API or third-party applications relying on such an API, and related services (collectively, the “Services”).
Please read this Policy carefully and contact us with any questions at privacy@binance.us. By using or accessing the Sites or Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we may collect, use, and disclose your personal information as set forth below.
Table Of Contents
- Applicability Of This Policy
- When and How We Collect Information
- What Information We Collect
- How We Use Information
- How and Why We Disclose Information
- International Transfers
- Security
- Data Retention
- Your Privacy Rights
- U.S. State-Specific Notice(s)
- Online Tracking Opt-Out Guide
- Mobile Privacy
- GLBA Disclosure
- Children’s Privacy
- Links to Third-Party Sites
- Changes To This Policy
- Contact Us
Applicability Of This Policy
This Policy applies to BAM’s processing of any information or data that could potentially identify a specific individual (“Personal Information”) when using our Sites or Services.
If you do not agree with the terms of this Policy, do not access or use the Services, Sites, or any other aspect of our business.
When and How We Collect Information
We may collect the following information or data, which may be considered Personal Information, from you when:
| Data you provide | Data we collect |
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What Information We Collect
We collect the following categories of personal information:
| Data you provide | Data we collect |
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How We Use Information
We use your information, including your Personal Information, in accordance with your instructions, including any applicable terms you agree to in our Terms of Use, and as required or restricted by applicable law. We may also use the information we collect for:
- Providing Our Sites, Services and Features.We may use the information we collect to provide, personalize, maintain, and improve our products, Sites and Services, including as described in the Terms of Use. This includes using information to:
- operate, maintain, customize, measure, and improve our Sites and Services, and manage our business;
- create and update users’ accounts;
- process transactions;
- send information including confirmations, notices, invoices, technical notices, updates, security alerts, and support and administrative messages; and
- to create de-identified or aggregated data.
- Safety and Security. We may use your information to help maintain the safety, security, and integrity of our Sites and Services, including to:
- protect, investigate, respond to, and deter against fraudulent, unauthorized, or illegal activity;
- monitor and verify identity or service access;
- protect against spam, malware, or security risks;
- perform internal operations necessary to provide our Services, including to troubleshoot software bugs and operational issues;
- enforce our agreements with third parties, and address violations of our Terms of Use or agreements for other services; and
- comply with applicable laws and regulations.
- Customer Support. We may use information we collect to provide customer support, including to:
- direct questions to the appropriate customer support person;
- communicate with you, including via social media channels;
- investigate and address user concerns; and
- monitor and improve our customer support responses and processes.
- Research and Development. We may use the information we collect for testing, research, analysis, and product development to improve your experience, enhance the safety and security of our Sites and Services, improve our ability to prevent the use of our Sites or Services for illegal or improper purposes, develop new features and products, and facilitate payment solutions in connection with our Sites and Services.
- Legal and Regulatory Compliance. Many of our Sites and Services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. For example, we must identify and verify customers using our Sites or Services in order to comply with anti-money laundering and anti-terrorism laws. This may include collection and storage of your photo identification. We also use third parties to verify your identity by comparing the personal information you provide against third party, authoritative sources and databases, including public records. When you attempt to link a bank account to your account, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk as required under applicable law. If you do not provide information required by law, we will have to close your account. We may also use the information we collect to investigate or address claims or disputes relating to use of our Sites and Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
- Direct Marketing. We may use the information we collect to market our Sites and Services to you. This may include sending you communications via emails or mobile app notifications about our Sites, Services, features, promotions, surveys, news, updates, and events; managing your participation in these promotions and events; and to deliver targeted marketing. Our marketing will be conducted according to your advertising and marketing preferences and as permitted by applicable law.
How and Why We Disclose Information
We may disclose your information, including your Personal Information, in the following circumstances:
- With Your Consent. You may permit us to disclose your personal information with others for any other purposes disclosed to you with your consent.
- With Our Affiliates. Where appropriate, we may disclose your information with BAM Management US Holdings Inc, and its wholly-owned subsidiaries and/or affiliates in the course of conducting business and offering our Services to you. Please be advised that BAM Trading and its affiliated companies are separate and distinct legal entities from Binance Holdings Limited (“BHL”). BAM Trading does not have any records for, and cannot respond to record requests, addressed to BHL. For more information, please refer to our Law Enforcement Guide.
- To Comply With Our Legal Obligations. We may disclose your information with courts, law enforcement authorities, regulators, attorneys or other parties: (A) to comply with laws and legal obligations; (B) for the establishment, exercise, or defense of a legal or equitable claim; (C) to respond to law enforcement and regulatory requests, including (1) when we are compelled to do so by a subpoena, court order, search or seizure warrant, or similar legal procedure, or (2) for international law enforcement requests, pursuant to a mutual legal assistance treaty or letter rogatory; (D) to comply with one or more forms of “travel rules” that require our transmitting of your information to another financial institution; (E) when we believe in good faith that the disclosure of personal information is necessary to protect the rights, property or safety of our customers, us, or others, including to prevent imminent physical harm or material financial loss; (F) to investigate violations of our Terms of Use or other applicable policies; or (G) to report suspected illegal activity or to assist law enforcement in the investigation of suspected illegal or wrongful activity.
- With Third-Party Identity Verification Services. We may disclose your information with third party identity verification service providers for the purposes of identity verification, fraud prevention, and denial of service to persons presenting an unacceptable level of money-laundering or terrorism-financing risks. These service providers confirm your identity by comparing the information you provide us to public records and other authoritative third-party databases (e.g., credit bureaus). These providers may create derivative data based on your personal information that they can use in connection with provision of identity verification and fraud prevention services. We do not control these providers’ privacy policies and we contractually require these service providers to only use your information in accordance with our legal agreements.
- For example, we use Plaid, Inc. (“Plaid”) for identity verification services to identify and authenticate you when you create or reactivate an account with us. Specifically, Plaid will verify that the selfie you provide matches the photo on your government-issued ID. The information collected during this process may constitute biometric data (to learn more about our Biometric Data Practices, please review our Biometric Data Privacy Policy). To learn more about Plaid’s privacy practices, please visit the Plaid End User Privacy Policy. By submitting your information, you agree to Plaid’s Privacy Policy.
- For Regulatory Compliance Purposes. Binance.US is subject to Anti-Money Laundering (‘AML’) and Know Your Customer (‘KYC’) laws in order to prevent fraud, money laundering, and other potential illegal activities. We may disclose your information to comply with these obligations, including with service providers who use your personal information to determine whether or not to provide their services, and to provide their services. Specifically, if you are a customer who is onboarding United States Dollars (a.k.a. fiat currency), your information may be shared with third-party service providers for compliance purposes.
- With Service Providers. We may disclose your information on a confidential basis with service providers who help facilitate business operations such as payment processing, marketing, security, or information technology services. Our legal agreements require these service providers to only use your information according to our instructions.
- For example, we may disclose your information with our support platform provider, Intercom, Inc. Intercom may receive information about you, your account and the contents of your communication as well as metadata including cookie data uniquely associated with you. Such information will not be used for any purpose other than to support us, but are also subject to Intercom’s applicable terms of service, privacy policy, cookie policy, and other policies.
- For Advertising Purposes. Some U.S. state laws classify service providers engaged in select advertising services as ‘third party businesses’ or ‘independent controllers.’ As noted below in our ‘Online Tracking Opt-Out Guide’, you have the right to restrict these types of advertising services providers’ use of your personal information. For clarity, Binance.US does not ‘sell’ personal information with these advertising services for monetary consideration, but disclosure may be classified as a ‘sale’ under various state privacy laws.
- With Financial Institutions. We may disclose your information with financial institutions to process payments you have authorized.
- For example, we use Plaid to connect your Binance.US account with your bank account, verify your bank account, and confirm your bank account balance prior to approving a transaction. Information disclosed to Plaid is treated by Plaid in accordance with the Plaid End User Privacy Policy. By linking your bank account through Plaid, you consent to Plaid’s Privacy Policy.
- With Our Professional Advisors. We may disclose your information with our professional advisors such as accountants, auditors, lawyers, insurers, bankers, and blockchain forensic services in order to complete third party audits and/or to comply with our legal and regulatory obligations.
- With Other Binance.US Users (Pay and Crypto Box). We may disclose your information with other users when you redeem a Crypto Box or use our Pay feature to send, request, or receive cryptocurrency. For example, when you redeem a Crypto Box, your first name, last initial, and amount received will be visible to other recipients of that particular Crypto Box. If you do not wish your Binance.US account to be searchable by other users, you may go to Account Settings → Security and toggle off the “Discoverable” option.
- During A Change To Our Business. If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of our assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all of your information may be disclosed or transferred.
- Aggregated or De-identified Data. We may create de-identified or anonymous data from Personal Information by removing certain data components (such as your name or email address) that makes the data personally identifiable to you, or through obfuscation. We may disclose aggregated and/or anonymized data with third parties for their own uses.
International Transfers
Our retail Services are directed and offered only to individuals within supported regions in the United States. Our institutional Services are available to companies, or companies with beneficial owners, that may be located outside of the United States. All data is stored in the United States using Amazon Web Services (“AWS”). As such, if you are a resident of the European Economic Area (“EEA”) or the United Kingdom (“UK”), we may transfer to, and store the data we collect about you, to countries other than the country in which the data was originally collected, including the United States. Those countries may not have equivalent data protection laws as the country in which you provided the data. When we transfer your data to other countries, we will protect the data as described in this Privacy Policy and comply with applicable legal requirements providing adequate protection for the transfer of data to countries outside the EEA and UK. We rely on Standard Contractual Clauses (“SCCs”) for the transfer of personal data (as defined by the General Data Protection Regulation, or “GDPR”) to countries that have not received an applicable adequacy decision, as well as the UK’s International Data Transfer Addendum to the SCCs. By using the Site and Services you agree to the privacy practices laid out in this Policy.
For more information on cross-border transfers of your Personal Information, the appropriate safeguards in place, please refer to the Supplemental EEA/UK Privacy Policy.
Security
We maintain administrative, technical, and physical safeguards (“Security Controls”) designed to protect the personal information we maintain against unauthorized access or disclosure. While no system is completely secure due to real-time and emerging cyber threats and bad actors, we take reasonable steps to secure your information. When registering for our Sites or Services, choose a complex password and turn on advanced security features, such as two-factor authentication. Never share your account credentials with third-parties and submit a Customer Support ticket here if you become aware of unauthorized access to or use of your account.
You are responsible for all activity on the account that is associated with your login credentials.
Data Retention
BAM retains your Personal Information for as long as is necessary for the purposes set out in this Privacy Policy and to the extent necessary to comply with our legal and regulatory obligations (i.e., if we are required to retain your data or the information you provided to us to comply with applicable laws, including anti-money-laundering, anti-terrorism, or other financial laws and regulations). In addition, we will retain and use your personal information to resolve disputes and enforce our legal agreements and policies.
To determine how long we will retain your personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, and applicable legal, regulatory, tax, accounting, or other requirements.
BAM will retain your Personal information for marketing purposes, where applicable, until you unsubscribe from our marketing communications. At that time, we may retain the Sites and Services’ usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Sites and Services, or we are legally obligated to retain this data for longer periods.
BAM will retain biometric data as part of customer identification information for the retention period required by financial laws and regulations. You can learn more about our biometric data practices in our Biometric Data Privacy Policy.
Your Privacy Rights
It is BAM’s policy to offer certain privacy rights to all individuals, regardless of whether a statutory right exists. The rights that BAM offers to all individuals include the following:
- Right to Know. You have the right to request what Personal Information we collect, use, disclose, or share about you, as applicable.
- Right to Access/Portability. You can request access to and/or a copy of the personal information that we maintain about you.
- Right to Delete. You can ask us to delete the Personal Information that we have collected or maintain about you, subject to exceptions. Please note that we are required to retain certain Personal Information and related data to comply with our legal obligations, including compliance with recordkeeping requirements contained in anti-money laundering, anti-terrorism, or other financial laws and regulations.
- Right to Correct. You can ask us to correct inaccurate personal information we maintain about you.
- To request updates or corrections to your personal information, please contact Customer Support at https://support.binance.us/hc/en-us/requests/new. You can also update certain account profile information by logging into your account.
- Right to Opt Out. You can opt out of certain uses of your personal information:
- Marketing and Promotional Communications. If you would like to stop receiving marketing or promotional messages, notifications, or updates, you may do so by following the unsubscribe instructions that appear in these email communications, or you may contact us at privacy@binance.us to opt out of direct marketing. Please be advised that you may not be able to opt out of receiving certain service or transactional messages from us, including legal notices.
- Targeted Advertising. You may opt out of targeted advertising (see Online Tracking Opt-Out Guide below).
You can exercise these rights by contacting us at privacy@binance.us. To protect your privacy and security, we may request specific information from you to help us verify your identity before complying with your request. We are not obligated to provide or to delete any information pursuant to your request if we are unable to adequately verify your identity.
We reserve the right to lawfully refuse to act on a request, or to charge a reasonable administrative fee when a request is either manifestly unfounded or excessive because of its repetitive character.
Some states provide their residents with additional privacy rights. Please review our U.S. State Specific Notice for more information about these rights.
U.S. State-Specific Notice(s)
Some U.S. states have enacted comprehensive privacy laws. For example, the California Consumer Privacy Act, as amended by the California Privacy Rights Act or “CPRA” (collectively, the “CCPA”), the Virginia Consumer Data Protection Act (“VCDPA”), Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), Utah Consumer Privacy Act (“UCPA”), the Oregon Consumer Privacy Act (“OCPA”), the Texas Data Privacy and Security Act (“TXDPSA”), the Montana Consumer Data Privacy Act (“MTCDPA”), the Iowa Consumer Data Protection Act (“IACDPA”), the Delaware Personal Data Privacy Act (“DEPDPA”), the Nebraska Data Privacy Act (“NEDPA”), the New Hampshire Privacy Act (“NHPA”), the New Jersey Data Privacy Act (“NJDPA”), the Tennessee Information Protection Act (“TNIPA”), the Minnesota Consumer Data Privacy Act (“MNCDPA”), and the Maryland Online Data Privacy Act (“MDODPA”) create additional privacy obligations for businesses and provide their residents with additional privacy rights. In addition to the rights granted above (see “Your Privacy Rights”), if you are a resident of these states you may have the right to:
- Information. For details about the personal information we have collected over the last 12 months, including the categories of sources, please see the What We Collect section above. We collect this information for the business and commercial purposes described in the How We Use Information section above. We share this information with the categories of third parties described in the How and Why We Disclose Information section above.
- Opt out of the “sale” or “share” of your personal information for targeted advertising. BAM does not ‘sell’ your personal information for monetary benefit. However, some third-party cookies placed on our website may be considered a ‘sale’ or a ‘share’ for the purposes of targeted advertising as defined under these privacy laws. Note, advertising partners are contractually restricted from using personal information collected by Binance.US for their own independent marketing purposes. You may opt out of such advertising cookies that may be classified as a ‘sale’ or ‘share’ for targeted advertising as detailed in the Online Tracking Opt-Out Guide below.
- Limit the Use and Disclosure of Your Sensitive Personal Information. BAM only collects that sensitive personal information which is necessary for us to provide our Services. As such, limiting our use of your sensitive personal information would result in us not being able to provide our Services.
In addition to the mechanisms above, you can also exercise these rights by emailing us at privacy@binance.usor by contacting our customer support via live chat.
Some residents may have the right to empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.
Appeals
If we deny your privacy request, you may have the right to appeal that decision. You may appeal our decision by emailing us at privacy@binance.us. Will will respond to your appeal within a reasonable period of time and as required by law. If you are still unsatisfied with our response, depending on your state of residency, you may have the right to file a complaint with your state attorney general. Information about how to appeal will be provided to you in the event we deny your request.
Business/Controller Designation
BAM operates as a Controller (and a ‘Business’ under CCPA) on behalf of our users.
Online Tracking Opt-Out Guide
Like many companies, we use cookies, pixels, web beacons, SDKs, and other tracking technologies (“cookies”) to collect information about your browsing activities, your interactions with websites (including our Sites) and apps (including our mobile app), and to serve tailored ads. You can opt out of our use of cookies via our Cookie Preference Center.
To learn more about our use of cookies and similar tracking technologies, visit our Cookie Policy.
Mobile Privacy
The Binance.US app uses software code provided by our business partners (software development kits or SDKs) that let our software interact with the services those partners provide. Sometimes these interactions will involve that business partner collecting some information from the device on which the software is run.
To learn more, visit our Cookie Policy or email us at privacy@binance.us.
GLBA Disclosure
The Gramm-Leach-Bliley Act (“GLBA”) requires financial institutions to explain their information-sharing practices to their customers and to provide the customer the ability to opt out of certain disclosures of their personal information. In addition, the GLBA prescribes certain safeguards for sensitive data held by financial institutions. You can review our GLBA Consumer Privacy Notice here.
Children’s Privacy
We do not allow use of our Services and Sites by anyone younger than 18 years old. If you learn that anyone younger than 18 has unlawfully provided us with Personal Information, please contact us at privacy@binance.us and we will take steps to delete such information, close any such accounts, and prevent the user from continuing to use our Services.
Links to Third-Party Sites
Our Services or Sites may contain links to other websites or services. We do not exercise control over the information you provide or is collected by these third-party websites. We encourage you to read the privacy policies or statements of the other websites you visit.
Changes To This Policy
We may update this Privacy Policy from time-to-time as we update or expand our Services or Sites and to comply with applicable laws. If we make any changes, we will change the Last Updated date above. We encourage you to review this Policy to stay informed. If we make material changes, we will provide additional notice, such as via the email specified in your account or through the Services or Sites.
Contact Us
Please contact us if you have any questions about this Policy or if you are seeking to exercise any of your privacy rights. You may contact us at privacy@binance.us or at phone number +1 (844) 900-1450 or at our mailing address below:
Attn: Privacy
BAM Trading Services Inc.
252 NW 29th Street
10th Floor, Suite 1014
Miami, FL 33127
Privacy Notice for Employees & Applicants
Last Updated: October 30, 2025
This Privacy Notice for Employees & Applicants (the “Notice”) sets out the basis on which BAM Management US Holdings Inc. and its affiliates (collectively “BAM”, “we”, “us” and “our”) will Process the Personal Information of employees and applicants or candidates for employment (the “Employees” or “you”). For the purpose of this Notice, “Personal Information” means any information relating to an identified or identifiable person, and “Processing” means any operation or set of operations which is performed on that Personal Information.
Please read this Notice carefully because it explains important information about the Processing of your Personal Information by BAM, including your rights with respect to your Personal Information. We may amend this Notice from time to time and advise you to consult this Notice on a regular basis to ensure you stay informed of any such amendments. If you are a California, Europe, or UK resident, please be sure to review the relevant jurisdiction-specific information below.
Table Of Contents
1. The Categories of Personal Information We Collect
The Personal Information that an Employee provides includes the following categories of information:
- Personal Details: Such as name, employee identification number, work and home contact details (email, phone numbers, physical address), languages(s) spoken, gender, date of birth, national identification number, social security number, marital/civil partnership status, dependants’ personal details, disability status, emergency contact information, and photograph;
- Documentation Required under Immigration Laws: Citizenship and passport data, details of residency or work permit
- Compensation and Payroll Data: For example, base salary, bonus benefits, compensation type, salary step within assigned grade, details on share options, share grants and other awards, currency, pay frequency, effective date of current compensation, salary reviews, banking details, working time records (including vacation and other absence records, leave status, hours worked and department standard hours), pay data, and termination date;
- Position: Including description of current position, job title, corporate status, management category, job code, salary plan, pay grade or level, job function(s) and sub-function(s), company name and code (legal employer entity), branch/unit/department, location, employment status and type, full-time/part-time, terms of employment, employment contract, work history, hire/re-hire and termination date(s) and reason, length of service, retirement eligibility, promotions and disciplinary records, date of transfers, and reporting manager(s) information;
- Talent Management Information: Such as details contained in letters of application and resume/CV (previous employment background, education history, professional qualifications, language and other relevant skills, certification, certification expiration dates), information necessary to complete a background check, details on performance management ratings, development programs planned and attended, e-learning programs, performance and development reviews, willingness to relocate, driver’s license information, and information used to populate employee biographies;
- Management Records: Details of any shareholding of common shares or directorships;
- Electronic communication information: Such as email envelopes and contents, video calls and recordings, file transmissions and other such internal or external interactions.
- System and Application Data: Information required to access company systems and applications such as System ID, LAN ID, email account, instant messaging account, mainframe ID, previous employee ID, previous manager employee ID, system passwords, employee status reason, branch state, country code, previous company details, previous branch details, and previous department details, and electronic content produced by you using our systems; and
- Sensitive Information: Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation, and criminal conviction data.
To the extent permitted by applicable law, BAM may compile Personal Information about an Employee obtained through a background check.
2. Why We Process Your Personal Information
BAM Processes the Personal Information of Employees for the following purposes:
- Managing Workforce: Managing work activities and personnel generally, including recruitment, appraisals, performance management, promotions and succession planning, rehiring, administering salary, payment administration and reviews, wages and other awards such as share options, share grants and bonuses (and administering your participation in such share option plans including communicating with you about your participation and collecting any tax and NICs due on any share option grants), healthcare, pensions and savings plans, training, leave, managing sickness leave, promotions, transfers, secondments, honoring other contractual benefits, providing employment references, loans, performing workforce analysis and planning, performing employee surveys, performing background checks, managing disciplinary matters, grievances and terminations, reviewing employment decisions, making business travel arrangements, managing business expenses and reimbursements, planning and monitoring of training requirements and career development activities and skills, and creating and maintaining one or more internal employee directories;
- Communications and Emergencies: Facilitating communication with you, ensuring business continuity, providing references, protecting the health and safety of employees and others, safeguarding IT infrastructure, office equipment and other property, facilitating communication with your nominated contacts in an emergency;
- Business Operations: Operating and managing the IT and communications systems, managing product and service development, improving products and services, managing company assets, allocating company assets and human resources, strategic planning, project management, business continuity, compilation of audit trails and other reporting tools, maintaining records relating to business activities, budgeting, financial management and reporting, communications, managing mergers, acquisitions, sales, re-organisations or disposals and integration with purchaser;
- Compliance: Complying with legal and other requirements, such as income tax and national insurance deductions, record-keeping and reporting obligations, conducting audits, compliance with government inspections and other requests from government or other public authorities, responding to legal process such as subpoenas, pursuing legal rights and remedies, defending litigation and managing any internal complaints or claims, conducting investigations and complying with internal policies and procedures; and
- Monitoring: Monitoring our IT and communications systems through manual and automated tools such as anti-malware software, website filtering and spam filtering, and monitoring our physical premises (i.e. by using CCTV and badge scans) to protect us, our employees, customers, and business partners. This is for general network operation and security, including the security of our IT systems and assets, and the optimal operation of our network and devices; for proof of business transactions and archiving; for training employees; for the protection of confidential information and intellectual property; for investigating breaches of internal policies, fraud or other unlawful or wrongful activity, or to respond to personnel or company incidents; for business continuity (such as monitoring business-related emails following an employee’s departure); and for physical security of our premises.
There may be more than one purpose that justifies our use of your Personal Information in any particular circumstance.
3. How We Disclose Your Personal Information
BAM may disclose your Personal Information with vendors or other parties who provide products or services to us, such as:
- Professional advisors: Accountants, auditors, lawyers, insurers, bankers, and other outside professional advisors in all of the countries in which BAM operates;
- Vendors: Companies that provide products and services to BAM such as payroll, pension scheme, benefits providers, human resources services, occupational health services, performance management, training, expense management, IT systems suppliers and support and background check providers, third parties assisting with equity compensation programs, credit card companies, medical or health practitioners, trade bodies and associations, claims handlers and loss adjusters, and hosting service providers, together with any necessary third party administrators, nominees, registrars and trustees for the purposes of administering the share option plans. Such service providers will only process personal information in accordance with our instructions;
- Public and governmental authorities: Entities that regulate or have jurisdiction over BAM such as regulatory authorities, public bodies, and judicial bodies, including to meet national security or law enforcement requirements;
- Third parties in corporate transactions: In connection with any proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of BAM’s business, assets or shares (including in connection with any bankruptcy or similar proceedings); and
- Your future employers and their vendors.
- Statistical demographic information for reporting purposes: We aggregate and create statistics from employee demographic data such as sex, age, and race to understand the demographic breakdown of our employees.
In addition, we may disclose your Personal Information to third parties where it is in our legal or business interest to do so, including to a potential buyer or seller of any business or assets, and to governmental agencies where we are under a duty to disclose or share your Personal Information in order to comply with a legal obligation.
4. California Consumer Disclosure
The California Consumer Privacy Act and its amendments and subsequent rulemaking, including but not limited to the California Privacy Rights Act (collectively, the “CCPA”) grants employees certain privacy rights. If you are a resident of California, you have the following rights:
- Right to know and access.
- Right to delete. An Employee requesting deletion will result in us not being able to evaluate your candidacy or employ you.
- Right to correct inaccurate information.
- Right to non-discrimination. You have the right to non-discrimination for exercising your CCPA rights.
- Opt out of the ‘sale’ or ‘share’ of your personal information. BAM does not ‘sell’ or ‘share’ your personal information as defined by the CCPA.
- Limit the Use and Disclosure of Your Sensitive Personal Information. BAM only collects Employee sensitive personal information which is necessary to evaluate candidacy and for employment purposes. As such, limiting our use of your sensitive personal information would result in us not being able to evaluate your candidacy or employ you.
You may exercise these rights at any time by contacting us at privacy@binance.us or by submitting an employee privacy rights request through our ‘Your Privacy Rights’ webform.
5. EEA and UK Residents Disclosure
Privacy in the European Union (“EU”) and, more broadly, the European Economic Area (“EEA”), is regulated by the General Data Protection Regulation (“GDPR”). In the United Kingdom (“UK”), privacy is regulated by the UK General Data Protection Regulation (“UK GDPR”). The laws of these jurisdictions provide EU and UK residents with certain privacy rights and governs an organization's collection, processing, and disclosing of personal information.
EEA and UK Residents’ Rights
If you are located in the European Union, the European Economic Area (EEA), or the UK you have the following rights:
- Right to be informed. You have the right to be informed about how your Personal Information is collected and processed.
- Right to access. You have the right to request copies of your personal information.
- Right to rectification. You have the right to request corrections with any information you believe is inaccurate.
- Right to erasure. An Employee requesting deletion will result in us not being able to evaluate your candidacy or employ you.
- Right to restriction or objection of processing. You have the right to request that BAM restrict the processing of your personal information. When submitting an application for employment to us, you consent to our collection and processing data for the purposes stated in this Notice.
- Right to data portability. You have the right to request that we transfer the information that we have collected to another organization, or directly to you, under certain conditions.
- Right to withdraw consent. If we collect your information through an affirmative consent mechanism, you may withdraw it at any time. This may result in our inability to evaluate your candidacy or employ you.
- Right to not be subject to a decision based solely on automated decision making. BAM does not envisage that you will be subject to decisions that will have a significant impact on you based solely on automated decision-making. We will notify you in writing if this position changes.
If you have questions, concerns, or complaints about our Notice, would like to report any security violations to use, or would like to exercise your privacy rights, please contact us via the following:
Should you wish to report a complaint or if you feel that BAM has not addressed your concern in a satisfactory manner, you may contact your local supervisory authority.
Legal Basis for EU/EEA/UK Personal Information Processing
We Process the Personal Information of Employees on the basis of several legal justifications:
- For Contractual Purposes. By submitting your personal information to BAM as an Employee, you are directing BAM to complete the processing of your Application.
- For our Legitimate Interests. BAM has a legitimate interest in recruiting, reviewing and hiring talented people who will support our vision and play a key role in our success. We may use Employee information to refine and improve our recruitment processes.
- To Fulfill a Legal Obligation. Certain laws and regulations may require BAM to Process or retain the Personal Information of Employees in order to comply with our legal or regulatory obligations.
We may also use your Personal Information in the following situations, which are likely to be rare:
- where it is necessary to protect your (or someone else's) vital interests (and, in the case of Sensitive Information, where you are incapable of consenting);
- where it is necessary for us to defend, prosecute or make a claim against you, us or a third party; and
- in the case of Sensitive Information, where you have made the information public.
In particular, we may use your Sensitive Information, such as health/medical information, in order to accommodate a disability or illness and to provide benefits or where you leave employment and under any share option plan operated by a group company the reason for leaving is determined to be ill-health, injury or disability, we may use information about your physical or mental health, or disability status in reaching a decision about your entitlements under the share option plan. We may use your diversity-related Personal Information (such as race or ethnicity) in order to comply with legal obligations relating to diversity and anti-discrimination, and your criminal conviction data only where it is appropriate (given your role) and we are legally able to do so.
Status as a Data Controller
BAM is the data controller of your personal information and is responsible for how your personal information is processed.
Transfers outside of the EU/EEA/UK
We may transfer your Personal Information outside of the EU/EEA/UK, to countries that do not offer an equivalent level of protection. Regardless of where your Personal Information is transferred, we shall ensure that relevant safeguards are in place to afford your Personal Information adequate protection. To ensure that your Personal Information is sufficiently protected, we will only transfer Personal Information to a recipient outside the EEA pursuant to a data transfer mechanism recognized by law as a lawful basis for such transfer, such as transferring Personal Information to a recipient: (i) in a country that is deemed to provide an adequate level of protection for Personal Information; or (ii) that has executed with BAM a data transfer agreement incorporating the EU’s Standard Contractual Clauses (“SCCs”) (and the UK’s International Data Transfer Addendum to the SCCs(“IDTA”) where necessary). Further details regarding the relevant safeguards can be obtained from us on request.
6. Security and Retention
We maintain administrative, technical and physical safeguards designed to protect the Personal Information you provide or we collect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
BAM stores all Employee’ Personal Information for as long as necessary to fulfill the purposes set out in the Notice, or for as long as we are required to do so by law or in order to comply with a regulatory obligation. For more information and specific retention periods, see the Binance.US HR Data Retention Policy.
7. Changes to this Notice
We may amend this Notice to be consistent with the global regulatory requirements or internal policy changes. When we update the Notice, we will also revise the ‘Last Updated’ date at the top of this document. Any material changes to this Notice will be communicated to you in advance of changes being implemented.
8. Contact US
If you have any questions about this Notice or wish to exercise your rights, you may contact us at privacy@binance.us or at our mailing address below:
Attn: Privacy
BAM Trading Services Inc.
252 NW 29th Street
10th Floor, Suite 1014
Miami, FL 33127