The data collected about you through the Services can be categorized into the following groups:

• Identity Data: This comprises first name, last name, patronymic (if available), date of birth, gender, passport, and ID.
• Contact Data: This includes billing address, email address, and telephone numbers.
• Financial Data: This encompasses the virtual currency wallet address and payment details.
• Transaction Data: Details about your transactions, including payments, withdrawals, exchanges, profits, deposited and withdrawal amounts, methods used, and other relevant information related to the services you have utilized through our Website.
• Technical Data: Information such as internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in type and versions, operating system and platform, and technologies on the devices you use to access the Website, along with the use of cookies stored on your device.
• Usage Data: Information about how you utilize the Website, products, and services, including the number of complaints, requests filed, and IP history.
• Marketing and Communication Data: Your preferences regarding receiving marketing communications from us and your communication preferences.
• KYC (Know Your Customer) Data: Information related to identity documents, including copies of recent dated Utility Bills, Identity Card, Passport, and/or Driver's License.
• Location Data: Details about your actual location when interacting with our Website, such as parameters determining regional settings (residency country, time zone, and interface language).
• Aggregated Data: Statistical or demographic data used for various purposes, derived from your data but not considered personal data in law, as it does not directly or indirectly reveal your identity.

Additionally, we may request mobile/phone verification from users when initiating transactions on certain exchanges and retain this information to enhance the overall user experience. The phone numbers provided by end users for authentication purposes will be transmitted to and stored by third-party phone verification services, contributing to the enhancement of their spam and abuse prevention measures.

We and our service providers gather information about your website usage through cookies. A cookie, a small file seeking permission to be stored on your computer's hard drive, aids in analyzing website traffic and recognizing your visits to specific sites. Cookies enable website applications to respond to you as an individual, tailoring their operations based on your preferences, likes, and dislikes.

We utilize traffic log cookies to identify the pages of our website in use, helping us analyze data on web page traffic and enhance our website to meet customer needs. This information is solely used for statistical analysis, and once analyzed, the data is removed from our system.

Cookies play a crucial role in offering you an improved website experience by allowing us to monitor which pages are useful to you. It's important to note that cookies do not provide access to your computer or any personal information unless voluntarily shared.

Any sensitive information stored in these cookies is encrypted, ensuring that only we can decipher the encoded data. These cookies serve the following purposes:

• Recognize you as a SwapEasy user.
• Gather information about your computer to manage risk and prevent fraud.
• Customize your experience, content, and advertising.
• Measure the effectiveness of promotional activities.

Additionally, the utilization of cookies and similar technologies may enable us and third parties to gather information about the user's browsing activities spanning various websites after utilizing our service.

Users have the option to accept or decline cookies. While most web browsers automatically accept cookies, users can typically adjust their browser settings to decline cookies if they wish. It's important to note that this action may limit the user's ability to fully benefit from the website.

We employ various methods to collect information from you, including:

1. Direct Interactions: You provide your information through the Website by filling in online forms or corresponding with us via emails or other means.
   • The collection of this data is essential for efficient service provision and compliance with ongoing legal and regulatory obligations. This includes preventing fraud and money laundering and conducting suitability and appropriateness assessments.
2. Automated Technologies or Interactions: When using our services, your device automatically transmits its technical characteristics to us. Locale, which comprises parameters determining regional settings such as residence country, time zone, and interface language, is utilized to enhance your experience within our platform.
   • Information about your IP address, cookie files, browser and operating system details, access timestamp, and requested page addresses helps optimize the operation of our web application, mobile, and desktop versions. Web analytics tools and cookies are employed to monitor user behavior, track website performance, and optimize marketing costs for an improved user experience.
   • If you wish to refrain from such transmissions, you can request this by contacting us using the details provided below, and we will address your request within 30 business days, to the extent permitted by our legal obligations.

The information we gather about you and your device serves various purposes to deliver our services, operate our business, and enhance your overall experience. Our usage includes:

1. Service Delivery and Business Operation: We use your information to provide services, improve their quality, enhance security, and conduct analytics and research for an optimal user experience.
2. Promotion and Advertisement: Your information is utilized for promoting our services, both within our platform and in other publishers' apps. Additionally, it aids in displaying third-party advertisements. Tracking and fraud prevention mechanisms are implemented for advertising purposes, legal compliance, and our legitimate interests.
3. Contractual Performance: When you request specific products or services, or engage with them, we process your data to fulfill our contractual obligations and deliver the requested product or service.
4. Legitimate Interests: We leverage your personal data to pursue our legitimate interests, including:
   • Administering your account, maintaining communication, and offering support through various channels.
   • Verifying identity, detecting fraud, complying with legal and regulatory requirements.
   • Providing information about requested products/services and similar offerings.
   • Notifying you about changes to our services and ensuring effective content presentation.
   • Administering our website, conducting internal operations, and troubleshooting.
   • Building a profile of your interests for personalized content and services.
   • Enhancing website functionality, facilitating interactive features, and ensuring safety.
   • Evaluating advertising effectiveness, delivering relevant ads, and conducting direct marketing.
   • Making suggestions based on your usage patterns and preferences.
   • Checking instructions, investigating complaints, and managing disputes.
5. Legal Obligations and Contractual Performance: In some instances, we use personal data to comply with legal obligations or fulfill contractual obligations with you.

Your Personal Data may be disclosed to:

• Third-Party Service Providers: To facilitate your access to our Website, Services, APIs, and token swap functionalities, we may share your data with third-party service providers. This includes contacting you as requested, sending regular updates, maintaining and updating records, and ensuring the delivery of requested products or services.
• Professional Advisory Firms: Our bookkeepers, accounting firms, audit firms, corporate secretarial firms, law firms, or other professional advisory firms may receive your data for record-keeping purposes in compliance with legal requirements.
• Governmental, Regulatory, or Law Enforcement Bodies: We may share your Personal Data with entities possessing legal rights to demand such information, including governmental, regulatory, or law enforcement bodies.
• Credit Bureaus and Fraud Prevention Companies: Your data may be shared with credit bureaus, credit rating agencies, and fraud prevention companies to minimize fraudulent activities associated with your Personal Data.
• Corporate Transactions: In the course of corporate activities such as divestiture, restructuring, merger, acquisition, joint venture, trade sale, bankruptcy, dissolution, reorganization, or similar transactions, your data (including Personal Data) may be shared with affiliated or related companies, third parties, or entities involved in the transaction.

These disclosures are made in accordance with legal and regulatory requirements, ensuring the proper functioning of our services and compliance with applicable laws.

Except as explicitly stated above, we refrain from selling, renting, licensing, or otherwise revealing your Personal Data to external parties. Only our authorized personnel, bound by written confidentiality obligations, can securely access your Personal Data to provide the services you use or request from our company. We exercise caution in selecting third-party service providers, ensuring they are obligated to data protection requirements similar to those outlined in this Privacy Policy through contracts and/or applicable laws. Generally, our engaged third-party service providers collect, use, and disclose your information solely to perform the services they provide to us.

It's important to note that when using token swap functions on our Website, your virtual currency wallet address is exposed. Some Personal Data may also be shared with third-party providers of such swap functionalities and protocols based on or in connection with your token swap transaction. Although identity protection technologies may safeguard your identity, our association with or endorsement of third-party providers and their functionalities is not implied. We cannot guarantee or warrant any aspect of third-party token swapping and identification protection functionalities on our Website. Your use of such functionalities is subject to the respective terms and conditions of the third parties, who may collect and use your Personal Data in line with their privacy policies.

We retain the right to disclose your information, including personally identifiable information, in response to legal processes, litigation, requests from public and governmental authorities, both within and outside your country of residence. Information may also be disclosed for reasons of national security, law enforcement, public importance, or to enforce our terms and conditions, protect our operations, users, or user experience. In the event of reorganization, merger, or sale, we may transfer all information, including personally identifiable information, to the relevant third party.

It is strongly advised not to use SwapEasy to obscure transactions or assets. Law enforcement has access to blockchain information for Virtual Currencies (VCs) entering or leaving SwapEasy. By utilizing SwapEasy, you acknowledge our compliance with all legal requests for information and our discretion to share the information provided by you.

The details you provide are securely stored on our servers within the European Union (EU). Nevertheless, when we disclose this information to third parties, it may necessitate the transfer of your data to a country beyond the EU and the European Economic Area (EEA). Such countries may lack data protection laws that are as robust as those within the EU. We will undertake the necessary measures mandated by Data Protection Legislation to guarantee the proper safeguarding of your information. You hereby provide agreement and consent to the aforementioned transfer, with the understanding that the recipients of this Personal Data are also bound by relevant laws or contractual obligations.

We maintain your information for the duration necessary to provide our services to you. It is possible that we might retain information for an extended period, but it will be done in a manner that prevents its association with you. The deletion of information occurs promptly when it is no longer required for the purposes outlined in this Privacy Policy, and in any case, no later than five (5) years after the termination of your interaction with our services.

In adherence to legal requirements, we will keep your information for the duration mandated by law. Upon your request for data deletion, we will promptly erase your data.

Once the stipulated retention period concludes, Personal Data will be permanently deleted. Consequently, the enforcement of the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be pursued after the retention period elapses.

Our website and any communications we provide to you (including emails or direct marketing) might include links to external websites. If you choose to visit any of these websites, they may gather information from you. It's important to recognize that these websites maintain their own privacy policies, and we do not assume any responsibility or liability for their practices. We advise you to review these policies before providing any personal data to these external websites.

According to Data Protection Legislation, you possess specific entitlements regarding the personal data we possess about you. These entitlements may involve the right to: obtain a copy of the personal data in our possession, request corrections to inaccuracies in your personal data, ask for the erasure or blocking of your personal data, and object to our processing of your personal data. It's important to note that these rights may be restricted in certain situations. For instance, if there's a legal requirement or a compelling legitimate reason, we might continue processing your data even if you request its deletion.

If you wish to exercise any of these entitlements, kindly get in touch with us using the contact information provided in the Contact section below.

Additionally, you retain the right to file a complaint if you believe your personal data has been mishandled. We encourage you to reach out to us initially to address any concerns.

We have implemented suitable security measures to avoid unintentional loss, unauthorized use, access, alteration, or disclosure of your data.

Furthermore, we have established procedures to address any suspected data breaches. In cases where legal obligations dictate, we will promptly notify you and the relevant regulatory authority of any such breaches.

Any future revisions to our Privacy Policy will be published on this page and, if deemed appropriate, communicated to you via email. We encourage you to check this page regularly to stay informed about any updates or modifications to our Privacy Policy.

For inquiries, feedback, or requests related to this Privacy Policy, please reach out to [email protected].