We undertake measures to implement advanced data protection policies and procedures and to update them from time to time for the purpose of safeguarding your data. Your data is protected by the legal, administrative and technical measures that we take to ensure the privacy, integrity and accessibility of data. To prevent security incidents with your data, we use a mixed organizational and technical approach based on the results of risk assessment.
We will not divulge any of your private information unless you approve in writing such disclosure or unless such disclosure is required under applicable law or is required in order to verify your identity.
INFORMATION WE COLLECT FROM YOU
The information that we may collect about you through the Services broadly falls into the following categories:
- Identity Data includes first name, last name, and patronymic (if available), date of birth, gender, passport, ID.
- Contact Data includes billing address, email address and telephone numbers.
- Financial Data includes virtual currency wallet address and payment details.
- Transaction Data includes details about the transactions performed by you, details about payments, withdrawals, exchanges, profit, deposited and withdrawal amount methods, and any other details in relation to the services you have made use of through our Website.
- Usage Data includes information about how you use the Website, products and services, number of complaints, number of requests filed and IP history.
- Marketing and Communication Data includes your preferences in receiving marketing from us and your communication preferences.
- Data in KYC (Know your customer) includes identity document information, including copies of recent dated Utility Bills, Identity Card, Passport, and/or Driver’s License.
- Location Data includes details on your actual location when interacting with our Website (for example, a set of parameters that determine regional settings of your interface, namely residency country, time zone, and the interface language).
- Aggregated Data includes statistical or demographic data for any purpose. Such data can be derived from your data but may not be considered personal data in law as it will not directly or indirectly reveal your identity.
We may also ask for mobile/phone verification from user while creating transactions for some exchanges and store this information to provide a better experience to our users. Phone numbers that end users provide for authentication will be sent and stored by third party phone verification services to improve their spam and abuse prevention.
We and our service providers collect information about your use of our website from cookies. A cookie is a small file which asks permission to be placed on your computer's hard drive. Once it is it helps analyse website traffic or lets us know when you visit a particular site. Cookies allow website applications to respond to you as an individual. The website application can tailor its operations to your needs, likes, and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which of our website pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from our system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
Any sensitive information in these cookies is encoded so that only we can interpret the information stored on them. The cookies are placed for the following purposes:
- Recognize You as a SwapSpace User,
- Collect information about Your computer to mitigate risk and help prevent fraud,
- Customize Your experience, content, and advertising, and
- Measure promotional effectiveness.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
HOW WE COLLECT INFORMATION FROM YOU
We use different methods to collect data from and about you including through:
- Direct Interactions. You will provide to us you’re your information online through the Website and/or by filling in online forms and/or by corresponding with us by emails or otherwise.
- We require to collect the above data in order that we are able to (i) provide our services efficiently,(ii) to comply with our ongoing legal and regulatory obligations, including, inter alia, (a) to prevent fraud and money laundering acts and/ or (b) conduct the assessment of suitability and appropriateness test.
- Automated Technologies or Interactions. When using our services, your device automatically transmits to us its technical characteristics. Locale (a set of parameters that determine regional settings of your interface, namely, residence country, time zone and the interface language) is used for the purpose of providing you with the best possible service within our platform. Using the information about IP address, cookies files, information about browser and operating system used, the date and time of access to the site, and the requested pages addresses allows us to provide you with the optimal operation on our web application, mobile and/or desktop versions of our application and monitor your behaviour for the purpose of improving the efficiency and usability of our Services. We use web analytics tools to track performance of our website and marketing source of user by cookies in order to optimize our marketing costs and provide users with better experience. You may at any time request that we refrain from any such transmissions (to the degree this is possible and subject to any of our legal obligations) by sending your request using our details below. We will address your request within 30 business days.
How we use your information
We use the information we collect about you/your device to deliver Services to you and to operate our business. We use it also for improving our Services, for enhancing security and for analytics and research purposes to make sure we provide you with the best experience. In addition, we use your information to promote our Services and also in other publisher’s apps and to display third-party advertisements to you. We use your information also for tracking and fraud prevention for advertising purposes, for complying with our legal obligations and for our legitimate interests.
Where you have requested that we provide a specific product or service to you, or you otherwise make use of those products or services, we will process your personal data in order to perform our contract with you and provide that product or service.
We also use the personal data we hold about you to pursue our legitimate interests in providing and marketing our products and services to you, improving our website, services, and interactions with you and other users of our products and services in the following ways:
- administer your account and relationship with us and to communicate with you by telephone, mail, email, text (SMS) message, instant messaging or other electronic means;
- verify your identity and detect fraud and crime and comply with any legal or regulatory requirements;
- provide you with information about the products and services that you request from us;
- provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about;
- provide you with information about products or services we feel may interest you or be best for you;
- your data may be shared with product or service providers to validate if you are an existing customer (which may affect whether you can be accepted for one of their products) or for fraud prevention purposes. The product or service provider does not have permission to use these data for any other purpose including marketing.
- notify you about changes to our services;
- ensure that content from our website is presented in the most effective manner for you and your device;
- to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to build up a picture of your interests so that you don’t miss information relevant to you when you visit our website;
- to improve the service we offer you and to try and ensure that you get the best from our website;
- to allow you to participate in interactive features of our website and services;
- as part of our efforts to keep our website safe and secure;
- to measure the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to send direct marketing to you;
- to make suggestions and recommendations about products or services that we think may be of interest based on usage patterns both on our website and on other channels (such as email and social media);
- to check any instructions you give to us and for the purposes of investigating any complaint you may make, or as evidence in any dispute or anticipated disputes between you and us.
- In some cases we may also use the personal data we hold about you to comply with our legal obligations, or enter into or perform a contract with you.
How we share your information
We may need to disclose your Personal Data to:
- third party service providers in order for us to facilitate your access to and use of our Website, Services, our APIs, token swap functionalities provided by third parties as made available on our Website, for us to contact you as you may have requested via our Website, email or telephone, for us to schedule and send on a regular basis to you our updates, for us to maintain and update your records to ensure that you receive our replies to your queries, for us to follow up on any delivery of products or services that you may have requested for, and to provide you with any other updates;
- our book-keepers, accounting firms, audit firms, corporate secretarial firms, law firms and/or other professional advisory firms who are maintaining our records in accordance with legal requirements;
- governmental, regulatory or law enforcement bodies who have a legal right to demand for your Personal Data;
- credit bureaus, credit rating agencies and fraud preventing companies for the purpose of minimizing fraudulent activities via your Personal Data; and
- our affiliated or related companies and/or third parties to whom we may sell, divest, transfer, assign, share or otherwise engage in a transaction that involves, some or all of our company’s assets (which may include your Personal Data), in the course of a corporate divestiture, corporate restructuring, merger, acquisition, joint venture, trade sale, bankruptcy, dissolution, reorganisation, or any other similar transaction or proceeding;
We reserve the right to disclose your information (including personally identifiable information) in response to law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, the disclosure is necessary or appropriate. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations, users or user experience. Additionally, in the event of a reorganization, merger or sale we may transfer any and all information (including personally identifiable information) we collect to the relevant third party.
You are advised to not utilizing SwapSpace to obscure transactions or assets in any way. Law enforcement has full access to blockchain information with respect to VCs that go in or out of SwapSpace’s system. You accept that SwapSpace will comply with all legal requests for information and reserves the right to share the information shared by You in its sole discretion.
Transferring personal data
Your information is stored on our secure servers in the EU. However, when we share your information with third parties it may involve transferring your information to a country outside the EU and the European Economic Area (EEA). This may include countries that do not have data protection laws which are as strong as those in EU. We will take the steps required under the Data Protection Legislation to ensure that your information is appropriately protected. You hereby agree and consent to the aforesaid transfer, on the understanding that the recipients of such Personal Data are also subject to applicable laws or contractual obligations.
When required by law, we will retain your information for as long as we are legally obligated to do so. If you request us to delete your data we will delete your data.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
Third party websites
Our website and other information we send to you (including any emails or direct marketing) may contain links to other websites. If you follow a link to any of these websites they may collect information from you. Please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies. Please check these policies before you submit any personal data to these websites.
Under the Data Protection Legislation, you have certain rights in respect of the personal data we hold about you. These may include rights to: request a copy of the personal data that we hold, request that we correct personal data if it is inaccurate, request that we erase or block your personal data, and to object to our processing of your personal data. These rights are limited in some situations. For example, if we have a legal requirement or a compelling legitimate ground we may continue to process your data even where you request its deletion.
If you would like to exercise any of these rights, please contact us using the details in the Contact section below.
You also have the right to make a complaint if you feel your personal data has been mishandled. We would encourage you to contact us in the first instance.
We have put in place appropriate security measures to prevent your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We have put in place procedures to deal with any suspected data breach and will notify you and the competent regulator of a breach where we are legally required to do so.