As used herein, the following terms are defined as follows:
- “Digital Asset” means a digital representation of value that functions as a medium of exchange, a unit of account, a store of value, and/or other similar digital representations of rights, which is neither issued nor guaranteed by any country or jurisdiction and does not have legal tender status in any country or jurisdiction, typically including blockchain-based assets or rights including sovereign cryptocurrency or virtual currency.
- “dCoinswap Account” means a user-accessible account offered via the dCoinswap Services where Digital Assets are stored by dCoinswap.
- “dCoinswap Services” means dCoinswap-branded websites, applications, services, or tools operated by dCoinswap s.r.o..
- “Personal Information” or “Personal Data” refers to any information that may be used to identify you as a specific individual, including, without limitation, your name, an identification number, location data, or an online identifier.
3. How we protect your personal information
We take reasonable measures to protect your Personal Information from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. These measures include encryption with SSL, periodic reviews of our data storage, -collection and -processing practices, the use of technical safeguards to protect the infrastructure we use to store Personal Information and the availability of two-factor-authentication.
We limit access to your Personal Data only to those employees and other agents who have a legitimate business need for accessing that information. Our employees are being educated continuously about the importance of confidentiality and privacy of your Personal Data.
Despite best practices and technical safeguards, no online or electronic system is guaranteed to be secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data during transmission. Any transmission of Personal Data is therefore are at your own risk.
4. Information we may collect
4.1 Information we collect automatically through our services:
- Location Information including your IP address or domain, the external page that referred to us, your browser version, platform and operating system.
- Logged Metrics. This includes but is not limited to response times, length, number and date of page visits, information about your interaction with our pages and system activity.
- Account Activities. This includes but is not limited to, information regarding funding and disbursement, orders, trades, and account balances.
- Correspondence. Information that you provide to us in written form, particularly correspondence with respect to our customer support.
4.2 Information you provide to us:
- Your full legal name
- Your address, including country of residence
- Email address
- Date of birth
- Proof of identity (e.g. passport).
- Digital Asset Information including external wallet addresses.
- Other Information. Any other information we, in our own discretion, consider necessary to comply with our legal obligations under various anti-money laundering (AML) and know-your-customer (KYC) obligations, such as under the European Union’s 4th AML Directive.
4.3 Information from other sources:
- Information from search engine providers and analytics providers. We may collect anonymized information about you from search engine- and analytics providers (e.g. how you found our site).
5. Our uses Of Personal Data
- To provide, maintain, and improve the dCoinswap Services:
- Provide products and services as fulfillment of our contractual obligations. This includes, but is not limited to, processing orders and transactions and providing you with related information such as confirmations, receipts, and requests for authorizations.
- Notify you about technical changes, other updates, security alerts and to send you administrative messages.
- Perform necessary internal operations such as data analyzes, testing, trend- and usage monitoring.
- To comply with our legal obligations, including, but not limited to, our Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations.
- To provide customer service and to resolve problems.
- To prevent and investigate fraud:
- Verify your identity to prevent fraud, comply with applicable laws, and to verify that you qualify for the use of our services.
- Investigate violations of our Terms Of Service and protect the rights and property of dCoinswap and the users of the dCoinswap Services.
6. Disclosure of your personal information
In some circumstances it is necessary to disclose your Personal Data to other parties:
6.1 Disclosures to Legal Authorities
We may disclose your Personal Data to law enforcement, data protection authorities, government officials, and other authorities when:
- Imposed by court order, or other legal procedure.
6.2 Disclosures to third parties
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.
- Our group entities or subsidiaries.
We also may disclose your personal information to third parties when we sell or buy any portion of 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.
7. International Transfers of Personal Data
Our Services rely on a network of data centers, third-party service providers and other infrastructure around the world. Therefore it is necessary to store and process Personal Data wherever our facilities or service providers are located. Hence it is sometimes necessary to transfer your Personal Data outside of the European Union. Some of these countries do not benefit from an adequacy decision issued by the EU Commission which testifies an adequate level of personal data protection. More details about the adequacy decision can be found here.
By using our Services you consent to your Personal Data being transferred to countries outside of the EU and to countries that are not recognized in the adequacy decision mentioned above. In these cases, we ensure that both ourselves and our partners take adequate and appropriate technical, physical, and organizational security measures to protect your data.
8. Privacy when transferring Digital Assets on blockchains
Blockchain-based Digital Assets rely on a public, distributed ledger. This ledgers usually contain information about every transaction of the respective Digital Asset, including funding transactions related to the dCoinswap Services. This information can potentially be used to deanonymize the participants of Digital Asset transactions, especially if additional data about the participants is available for analysis.
Blockchains are decentralized networks which are not operated or controlled by us, therefore we are not able to delete or alter personal data stored on blockchains.
9. Data Retention
We are subject to several legal obligations such as anti-money-laundering (AML) obligations which require us to keep some of your data collected by us (e.g. your transaction data) beyond the closing of your dCoinswap Account.
Your Personal Data is only used internally if absolutely necessary. Data which is no longer required for the reasons outlined above will de deleted.
Cookies and similar technologies (herein "Cookies") are small files which are saved on your computer. These files are used by us to:
- Collect information about your use of our services.
- Enable certain features within the dCoinswap Services and to improve your user experience.
- Identify you as user.
- Collect device information for security reasons and to detect irregularities regarding dCoinswap Account activities.
11. Your choices
- Cookies and Local Storage. Most web browsers accept cookies and the use of local storage by default. You can choose to set your browser to remove browser cookies or clear local storage. Please note that if you choose to remove or decline the use of these technologies, it could affect the availability and functionality of the dCoinswap Services.
- Right of Rectification. You have the right to correct any personal information we hold on you that is inaccurate, incorrect or out of date. For this purpose, please consult the support section of your dCoinswap Account.
- Right of Erasure. You have the right to ask us to delete your data when it is no longer necessary, or no longer subject to a legal obligation to which we are subject to.
12. Access to information we hold about you
In accordance with applicable laws, you may have the right to access information we hold about you. Your right of access can be exercised in accordance with the relevant data protection legislation. For further information, please contact us at [email protected].