OUR SITES, directly or indirectly passing though , collect some Personal Data from its Users. This Privacy Statement constitutes a part of Terms and Conditions of CruzCoins Tokens Offering.


“We”, “CRUZ MEDIKA”, “OUR FIRM”,”CRUZCOIN” legally refers to:

Cruz Medika LLC

5900 Balcones Drive Suite 100,

Austin, Texas, 78731, U.S.


*Privacy Statement (last update February 2022), this is subject to changes in relation to requirements based on laws and regulations to be implemented.

1. Introduction and background.

– Introduction.
In the context of our cryptocurrency available in pre sale, when you visit OUR SITES direct or indirectly, OUR SITES process your personal data. Personal data refers to any information that identifies or links to a person. OUR SITES respect your privacy and ensures due care when processing and protecting personal data. Please carefully read this Privacy Statement as your use of OUR SITE and purchase of CRUZCOINS will be regarded as you have read, understood and provided your consent to OUR FIRM under this Privacy Statement to use your personal data in order to facilitate your purchase of CRUZCOINS.

This Privacy Statement explains what types of personal data we collect, how we collect it, why we use it, how we deal with it and what your rights are. OUR FIRM ensures to process your personal data in line with applicable privacy regulations. We encourage you to read this Statement carefully as it forms a relevant part of OUR SITES’ User agreement and Terms and Conditions.

– Application of the Statement.
OUR SITES follow the data protection obligations as set out in the EU General Data Protection Regulation 2016/679 (“GDPR”). To comply with “GDPR”, We have implemented data protection principles and acts as (joint) controller when processing your personal data.

OUR SITES and our systems in general may contain links to other third party websites. If you follow these links, please note that they have their own privacy policies and we do not accept any responsibility or liability for their policies or processing of your personal data.

We reserve the right to modify this Statement. We recommend that you review this Statement regularly, so that you remain informed of any possible changes.

2. Personal information we collect.

We collect personal information when you use our website and mobile application, when you communicate with us, complete a form, or use one of OUR SITES services that requires your personal data. This can be personal information that you provide to us and is required for OUR SYSTEMS, or information that OUR SITES and other systems collect about you.

Categories of personal information.

The following categories of personal data and information may be processed:
• Name
• Address
• Country of residence
• Telephone number
• Email address
• Login details
• Copy of Passport or Identification’s card
• Date of Birth
• Place of Birth
• Nationality
• Address of your cryptocoins wallet
• Bank account number
• Employment information
• Verification documents, like an utility bill

– Source of wealth.
OUR SITES may also ask information about your experience with trading, source of income, investment aims and risk appetite. For compliance and business purposes, OUR FIRM may need to review your personal data and information on a periodic basis.

To comply with international AML/CTF (anti-money laundering and counter-terrorism financing) measures and regulation, our project undertakes to cooperate with any state or regulatory body or supervisory authority of any country, as well as with all authorized financial institutions, and strictly abide by AML/CTF (anti-money laundering and counter-terrorism financing), KYC (Know Your Client), and other banking or governmental rules and regulations, in connection with which any User undertakes to provide OUR FIRM all necessary information, including but not limited to personal data, in order comply with Token acquiring procedure of the applicable legislation, if such information is requested from the User or OUR WEBSITE by the authorized body. We have the right to request information about the name, proof of identity, address of residence, proof of address, phone number and email address, data on transactions made, source of funds, source of wealth, or any other information we may be required by law, and etc. The responsibility for refusing to provide this information lies solely with You. Personal information received from registered Users and holders of OUR CRYPTOCOINS, information on the number of ‘TOKENS’ held, addresses of used wallets and other relevant information may be disclosed to law enforcement and government authorities and other third parties if OUR FIRM is required to disclose such information by law, by the subpoena or court order. Under no circumstances shall OUR FIRM be liable for such disclosure.

– Information we may receive from third parties.

OUR SITES may also collect personal information from third parties, for example from business partners to be able to meet regulatory requirements with regard to Anti Money Laundering and Anti-Terrorist Financing.

– Information we may collect from open sources.
We may also obtain information about you from open sources such as and analyze public blockchain data to obtain information about your transactions from Blockchain analysis providers.

– Purposes of processing personal information.

• To create an account and provide services within OUR SYSTEMS, we process your personal information to provide services to you. When we use your personal information for this purpose, we base such on contractual necessity.
• To buy, sell and trade crypto currencies, we will process your personal information when you use our trading platform. When we use your personal information for this purpose, we base such on contractual necessity and compliance with a legal obligation.
• To provide customer services, we might process your personal information to effectively respond when you contact us. When we use your personal information for this purpose, we base such on your prior and informed consent or legitimate interest.
• To provide communications on our services, we send administrative or account related information to keep you informed on our products and services and inform you of relevant security information. When we use your personal information for this purpose, we base such use on contractual necessity or legitimate interest.
• To engage in marketing activities, where you have chosen to receive this, we may send you marketing communications. When we use your personal information for this purpose, we base such on prior and informed consent.
• To operate, manage, develop and promote our business, we use your personal information for research and development purposes. For example to improve our services and the content of our website and mobile application. When we use your information for this purpose, we base such on legitimate interest.
• To monitor content posted on OUR SITES, OUR FIRM will monitor any communication posted on the platform. When we process your personal information for this purpose, we base such on legitimate interest.
• To prevent fraud or misuse, we process your personal information to prevent fraudulent conduct or behavior. When we use your personal information for this purpose, we base such on legitimate interest.
• To comply with laws and regulations, we use your personal information to comply with laws and regulations that apply to OUR FIRM such as Know Your Customer (KYC) and transaction monitoring requirements from anti money laundering regulations. When we process your personal information for this purpose, we base such on compliance with a legal obligation.

Failure to comply with the terms above may result in failure to performance of contract, your purchase of CRUZCOINS, your use of OUR SITES, and may result against your legitimate interest.

3. Automated decision making.

OUR FIRM uses your personal information to create a risk profile. OUR SYSTEMS may assign a risk score based on the information you provided without human intervention. OUR FIRM monitors continuously if your risk profile corresponds with the information you provided and your behavior on OUR SITES. OUR SYSTEMS may run programs to screen your behavior and automatically update your risk profile.

This profiling feature helps us and allows us to identify any suspicious activities, fraudulent activities, money laundering practices, criminal activities in general and violation of any provision of this Privacy Statement or Terms and Conditions of CruzCoins Tokens Offering.

4. Transmission, security and storage of your personal information.

– Recipients.‍

OUR FIRM will not provide personal data to third parties without your consent unless it is necessary for the performance of the service or the agreement. For some parts of OUR SYSTEMS onboarding process we may contract specialized parties to do parts of it’s identification and verification process. In that context, personal data can be shared with these parties for meeting regulations.

If we share your personal data with third parties we sign appropriate agreements to guarantee the confidentiality of your personal information. OUR FIRM will not share, provide or transfer any of your personal data with any third parties where there is no equivalent level of data protection regulation or standards unless third parties guarantee with their data protection standards and applications, and shall be fully liable in case of a breach.  We may also need to share your personal data if it is required by law, including assisting law enforcement authorities and the Financial Intelligence Units (FIU).

– Protection of your personal data.

OUR FIRM takes appropriate technical and organizational security measures to protect personal information from unauthorized loss, misuse, alteration, or destruction. In this regard, all information you provide to us is stored on our or subcontractors’ secure servers and are subject to our security policies and standards. When you need to choose a password to access certain parts of OUR SITES, it is important that you keep your password confidential and notify us if you become aware of any unauthorized access to your account.

– Retention.

OUR FIRM will not keep your personal information longer as reasonably necessary for the purposes listed above. In this respect, OUR FIRM retains your personal information as long as we:

• Have an agreement with you
• Have your (explicit) consent
• Have a legitimate interest
• Have a legal obligation

OUR FIRM is legally required to retain your personal information for identification and verification purposes for a period of 5 years after a relationship has ended. Personal data related to transactions will be retained for a period of 7 years after the latest relevant calendar year.

After the retention period is finished or when the data is no longer necessary for the purpose for which the data were collected, the personal data will be deleted.

5. Your rights.

You may have various rights in relation to your personal information. 

In particular, you have:

• Right of access your personal data collected

• Right to rectify

• Correct personal information that is incorrect or incomplete

•  Request a copy of the personal information we hold about you

• Right to restrict processing where the accuracy of information may be in dispute, processing of your personal information is unlawful, where it is no longer necessary to store or process your information but you require your personal information in relation to a legal claim

• Object to the processing of your personal information

• Ask to delete of personal information we hold about you

• Right to withdraw your consent

If you wish to exercise one of these rights please change your profile or send an email to . If you wish to delete your personal information, please be aware that we may be required to keep your personal information for a certain period as required by regulations.

Where applicable, if you no longer wish to have your third party social network site account (e.g., Facebook, LinkedIn or Twitter) linked to your profile, please change the settings in your third-party social network site account.

6. Changes to this Privacy Statement.

OUR FIRM expressly reserve its right to make any changes or reflect changes in Law to this Privacy Statement when we deem appropriate. In case of a change, an updated version of this Privacy Statement will be sent to your last registered e-mail address at your account. Upon the changes, your continued use of OUR SITES or your purchase of CRUZCOINS shall constitute your acceptance to the updated Privacy Statement.

7. Cookies.

A ‘cookie’ is a small text file that is downloaded onto your access device when you visit a website and that enables the website to obtain certain information from your browser, such as your preferences. This website use cookies and similar technologies to provide personalized web pages and to tailor other content to reflect your specific needs and interests. You may configure your browser to block all cookies, including cookies associated with our services, or to indicate when a cookie is being set by us. However, it is important to remember that many of our services may not function properly if cookies are disabled. For further information on cookies, how they are used and how they apply to the use of your personal data, please visit

8. Contact details.

Questions, comments, requests or complaints concerning this privacy notice and the way we process your personal data are welcomed and can be addressed at