Coinchange Privacy Policy

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We at Coinchange (defined below) respect and protect the privacy of visitors to our websites and our customers. This Privacy Policy describes our information handling practices when you access our services, which include our content on the websites located at Coinchange.io or any other websites, pages, features, or content we own or operate (collectively, the "Site(s)") or when you use the Coinchange mobile app, any Coinchange API or third party applications relying on such an API, and related services (referred to collectively hereinafter as "Services").

Please take a moment to read this Privacy Policy carefully. If you have any questions
about this Policy, please submit your request via email to support@coinchange.io

1. ACCEPTANCE OF THIS PRIVACY POLICY

By accessing and using our Services, you signify acceptance to the terms of this
Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal
information as described further below. We may provide additional "just-in-time"
disclosures or information about the data processing practices of specific Services.
These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data.

If you do not agree with or you are not comfortable with any aspect of this Privacy
Policy, you should immediately discontinue access or use of our Services.

2. CHANGES TO THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time which will be indicated by changing the date at the top of this page. If we make any material changes, we will notify you by email (sent to the email address specified in your account), by means of a notice on our Services prior to the change becoming effective, or as otherwise required by law.

3. PERSONAL INFORMATION WE COLLECT

Personal information is typically data that identifies an individual or relates to an
identifiable individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties. The definition of personal information depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Privacy Policy.

3.1. Information you provide to us

To establish an account and access our Services, we'll ask you to provide us with some important information about yourself. This information is either required by law (e.g. to verify your identity), necessary to provide the requested services (e.g. you will need to provide your bank account number if you'd like to link that account to Coinchange), or is relevant for certain specified purposes, described in greater detail below. As we add new features and Services, you may be asked to provide additional information.

Please note that we may not be able to serve you as effectively or offer you our
Services if you choose not to share certain information with us. Any information you
provide to us that is not required is voluntary.

We may collect the following types of information from you:

⮚ Personal Identification Information: Full name, date of birth, nationality, gender,
signature, utility bills, photographs, phone number, home address, and/or email.

⮚ Formal Identification Information: Government issued identity document such as
Passport, Driver's License, National Identity Card, State ID Card, Tax ID number,
passport number, driver's license details, national identity card details, visa
information, and/or any other information deemed necessary to comply with our
legal obligations under financial or anti-money laundering laws.

⮚ Institutional Information: Employer Identification number (or comparable number
issued by a government), proof of legal formation (e.g. Articles of Incorporation),
personal identification information for all material beneficial owners.

⮚ Financial Information: Bank account information, payment card primary account
number (PAN), transaction history, trading data, and/or tax identification.

⮚ Transaction Information: Information about the transactions you make on our
Services, such as the name of the recipient, your name, the amount, and/or
timestamp.

⮚ Employment Information: Office location, job title, and/or description of role.

⮚ Correspondence: Survey responses, preferences selection, settings options,
information provided to our support team or user research team.

3.2. Information we collect from you automatically

To the extent permitted under the applicable law, we may collect certain types of
information automatically, such as whenever you interact with the Sites or use the
Services. This information helps us address customer support issues, improve the
performance of our Sites and applications, provide you with a streamlined and
personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:

Online Identifiers: Geo location/tracking details, browser fingerprint, operating
system, browser name and version, and/or personal IP addresses.

Usage Data: Authentication data, security questions, click-stream data, public
social networking posts, and other data collected via cookies and similar
technologies. Please read our cookie policy for more information.

For example, we may automatically receive and record the following information on our server logs:

⮚ How you came to and use the Services;

⮚ Device type and unique device identification numbers;

⮚ Device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL);

⮚ How your device interacts with our Sites and Services, including pages accessed
and links clicked;

⮚ Broad geographic location (e.g. country or city-level location); and

⮚ Other technical data collected through cookies, pixel tags and other similar
technologies that uniquely identify your browser.

We may also use identifiers to recognize you when you access our Sites via an external link, such as a link appearing on a third party site.

3.3. Information collected from third parties

From time to time, we may obtain information about you from third party sources as
required or permitted by applicable law. These sources may include:

Public Databases, Credit Bureaus & ID Verification Partners: We obtain
information about you from public databases and ID verification partners for
purposes of verifying your identity in accordance with applicable law. ID
verification partners use a combination of government records and publicly
available information about you to verify your identity. Such information may
include your name, address, job role, public employment profile, credit history,
status on any sanctions lists maintained by public authorities, and other relevant
data. We obtain such information to comply with our legal obligations, such as
anti-money laundering laws. In some cases, we may process additional data
about you to assess risk and ensure our Services are not used fraudulently or for
other illicit activities. In such instances, processing is necessary for us to
continue to perform our contractual obligations with you and others.

Blockchain Data: We may analyze public blockchain data to ensure parties
utilizing our Services are not engaged in illegal or prohibited activity under our
Terms, and to analyze transaction trends for research and development
purposes.

Joint Marketing Partners & Resellers: For example, unless prohibited by
applicable law, joint marketing partners or resellers may share information about
you with us so that we can better understand which of our Services may be of
interest to you.
Advertising Networks & Analytics Providers: We work with these providers to
provide us with de-identified information about how you found our Sites and how
you interact with the Sites and Services. This information may be collected prior
to account creation - for more information on how you can manage collection of
this data, please see our Cookie Policy.

4. ANONYMIZED AND AGGREGATED DATA

Anonymization is a data processing technique that modifies personal information so that it cannot be associated with a specific individual. Except for this section, none of the other provisions of this Privacy Policy applies to anonymized or aggregated customer data (i.e. information about our customers that we combine together so that it no longer identifies or references an individual customer).

Coinchange Financials may use anonymized or aggregate customer data for any
business purpose, including to better understand customer needs and behaviors,
improve our products and services, conduct business intelligence and marketing, and
detect security threats. We may perform our own analytics on anonymized data or
enable analytics provided by third parties.

Types of data we may anonymize include, transaction data, click-stream data,
performance metrics, and fraud indicators.

5. HOW YOUR PERSONAL INFORMATION IS USED

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We generally use personal information to comply with applicable law and regulatory requirements; to create, develop, operate, deliver, and improve our Services, content and advertising; and for loss prevention and anti-fraud purposes.

We may use this information in the following ways:

5.1. To maintain legal and regulatory compliance

Most of our core Services are subject to laws and regulations requiring us to collect,
use, and store your personal information in certain ways. For example, Coinchange
Financials must identify and verify customers using our Services in order to comply with anti-money laundering laws across jurisdictions. This includes collection and storage of your photo identification. In addition, we use third parties to verify your identity by comparing the personal information you provide against third-party databases and public records. When you seek to link a bank account to your Coinchange Financials 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 personal information required by law, we will have to close your account.

5.2. To enforce our terms in our user agreement and other agreements

Coinchange Financials handles sensitive information, such as your identification and
financial data, so it is very important for us and our customers that we actively monitor, investigate, prevent, and mitigate any potentially prohibited or illegal activities, enforce our agreements with third parties, and/or prevent and detect violations of our posted user agreement or agreements for other Services. In addition, we may need to collect fees based on your use of our Services. We collect information about your account usage and closely monitor your interactions with our Services. We may use any of your personal information collected for these purposes. The consequences of not processing your personal information for such purposes is the termination of your account.
5.3. To detect and prevent fraud and/or funds loss

We process your personal information in order to help detect, prevent, and mitigate
fraud and abuse of our services and to protect you against account compromise or
funds loss.

5.4. To provide Coinchange's Services

We process your personal information to provide the Services to you. For example,
when you want to store funds on our platform, we require certain information such as
your identification, contact information, and payment information. We cannot provide
you with Services without such information. Third parties such as identity verification
services may also access and/or collect your personal information when providing
identity verification and/or fraud prevention services.

5.5. To provide Service communications

We send administrative or account-related information to you to keep you updated
about our Services, inform you of relevant security issues or updates, or provide other
transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our Services. You may not opt-out of receiving critical service communications, such as emails or mobile notifications sent for legal or security purposes.

5.6. To provide customer service

We process your personal information when you contact us to resolve any questions,
disputes, collect fees, or to troubleshoot problems. Without processing your personal
information for such purposes, we cannot respond to your requests and ensure your
uninterrupted use of the Services.

5.7. To ensure quality control

We process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the Services such as inaccurate transaction records or other interruptions.

5.8. To ensure network and information security

We process your personal information in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations. The threat landscape on the
internet is constantly evolving, which makes it more important than ever that we have
accurate and up-to-date information about your use of our Services. Without processing your personal information, we may not be able to ensure the security of our Services.

5.9. For research and development purposes

We process your personal information to better understand the way you use and
interact with Coinchange's Services. In addition, we use such information to customize, measure, and improve Coinchange' Services and the content and layout of our website and applications, and to develop new services. Without such processing, we cannot ensure your continued enjoyment of our Services.

5.10. To enhance your experience

We process your personal information to provide a personalized experience, and
implement the preferences you request. For example, you may choose to provide us
with access to certain personal information stored by third parties. Without such
processing, we may not be able to ensure your continued enjoyment of part or all of our Services.

5.11. To facilitate corporate acquisitions, mergers, or transactions

We may process any information regarding your account and use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate
transactions. You have the option of closing your account if you do not wish to have
your personal information processed for such purposes.

5.12. To engage in marketing activities

Based on your communication preferences, we may send you marketing
communications (e.g. emails or mobile notifications) to inform you about our events or
our partner events; to deliver targeted marketing; and to provide you with promotional
offers. Our marketing will be conducted in accordance with your advertising marketing preferences and as permitted by applicable law.

5.13. For any purpose

6. LEGAL BASES FOR PROCESSING YOUR INFORMATION

For individuals who are located in the European Economic Area, United Kingdom or
Switzerland (collectively "EEA Residents") at the time their personal data is collected,
we rely on legal bases for processing your information under Article 6 of the EU General Data Protection Regulation ("GDPR"). We generally only process your data where we are legally required to, where processing is necessary to perform any contracts we entered with you (or to take steps at your request prior to entering into a contract with you), for our legitimate interests to operate our business or to protect Coinchange's or your, property, rights, or safety, or where we have obtained your consent to do so. Below is a list of the purposes described in our policy with the corresponding legal bases for processing.


Introduction

Last Modified: July 6, 2021
Products
We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time, and as required under the applicable law, we may request your permission to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties, or allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to so limit the use of your personal information, certain features or Coinchange Services may not be available to you.


Below is a list of the purposes described in our policy with the corresponding legal bases for processing.

6.1. EEA Data Subjects

Below is a list of the purposes described in our policy with the corresponding legal bases for processing.
7. MARKETING

7.1. Direct Marketing.
Direct marketing includes any communications to you that are only based on advertising or promoting our products and services. We will only contact you by electronic means (email or SMS) based on our legitimate interests, as permitted by applicable law, or your consent. To the extent we can rely on legitimate interest under the applicable law, we will only send you information about our Services that are similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, we will contact you by electronic means for marketing purposes only if you have consented to such communication. If you do not want us to send you marketing communications, please go to your account settings to opt-out or submit a request via our support@coinchange.ca. You may raise such objection with regard to initial or further processing for purposes of direct marketing, at any time and free of charge. Direct marketing includes any communications to you that are only based on advertising or promoting our products and services.

7.2. Third Party Marketing. We will obtain your express consent before we share your personal information with any third parties for marketing purposes.

8. WHY WE SHARE PERSONAL INFORMATION WITH OTHER PARTIES

We take care to allow your personal information to be accessed only by those who require access to perform their tasks and duties, and to share only with third parties who have a legitimate purpose for accessing it. Coinchange Financials will never sell or rent your personal information to third parties without your explicit consent. We will only share your information in the following circumstances:
  • With third party identity verification services in order to prevent fraud. This allows Coinchange to confirm your identity by comparing the information you provide us to public records and other third party databases. These service providers may create derivative data based on your personal information that can be used in connection with the provision of identity verification and fraud prevention services. For example:
  • With financial institutions with which we partner to process payments you have authorized.
  • With service providers under contract who help with parts of our business operations. Our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else. Examples of the types of service providers we may share personal information with (other than those mentioned above) include:
  • Network infrastructure
  • Cloud storage
  • Payment processing
  • Transaction monitoring
  • Security
  • Document repository services
  • Customer support
  • Internet (e.g. ISPs)
  • Data analytics
  • Information Technology
  • Marketing
  • With companies or other entities that we plan to merge with or be acquired by. You will receive prior notice of any change in applicable policies.
  • With companies or other entities that purchase Coinchange assets pursuant to a court-approved sale or where we are required to share your information pursuant to insolvency law in any applicable jurisdiction.
  • With our professional advisors who provide banking, legal, compliance, insurance, accounting, or other consulting services in order to complete third party financial, technical, compliance and legal audits of our operations or otherwise comply with our legal obligations.
  • With law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our User Agreement or any other applicable policies.
  • If you establish a Coinchange Account indirectly on a third party website or via a third party application, any information that you enter on that website or application (and not directly on a Coinchange website) will be shared with the owner of the third party website or application and your information will be subject to their privacy policies
9. THIRD-PARTY SITES AND SERVICES

If you authorize one or more third-party applications to access your Coinchange Services, then information you have provided to Coinchange may be shared with those third parties. A connection you authorize or enable between your Coinchange account and a non-Coinchange account, payment instrument, or platform is considered an "account connection." Unless you provide further permissions, Coinchange will not authorize these third parties to use this information for any purpose other than to facilitate your transactions using Coinchange Services. Please note that third parties you interact with may have their own privacy policies, and Coinchange is not responsible for their operations or their use of data they collect. Information collected by third parties, which may include such things as contact details, financial information, or location data, is governed by their privacy practices and Coinchange is not responsible for unauthorized third-party conduct. We encourage you to learn about the privacy practices of those third parties.

Examples of account connections include:
  • Merchants: If you use your Coinchange account to conduct a transaction with a third party merchant, the merchant may provide data about you and your transaction to us.
  • Your Financial Services Providers: For example, if you send us funds from your bank account, your bank will provide us with identifying information in addition to information about your account in order to complete the transaction.
Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party's privacy practices. Please review the privacy notice of any third-party that will gain access to your personal information. Coinchange is not responsible for such third party conduct.

10. HOW WE PROTECT AND STORE PERSONAL INFORMATION

Coinchange maintains (and contractually requires third parties it shares your information with to maintain) appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the personal information you entrust to us.

We may store and process all or part of your personal and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers, in the US and elsewhere in the world where our facilities or our service providers are located. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.

For example, we use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.

However, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. Please recognize that you play a vital role in protecting your own personal information. When registering with our Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.

Furthermore, we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us using the contact information provided in this Privacy Policy.

11. RETENTION OF PERSONAL INFORMATION

We store your personal information securely throughout the life of your Coinchange Account. We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your personal information are described below.

Personal information collected to comply with our legal obligations under financial or anti-money laundering laws may be retained after account closure for as long as required under such laws.

Contact Information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis until you unsubscribe. Thereafter we will add your details to our suppression list to ensure we do not inadvertently market to you.

Content that you post on our website such as support desk comments, photographs, videos, blog posts, and other content may be kept after you close your account for audit and crime prevention purposes (e.g. to prevent a known fraudulent actor from opening a new account).

Recording of our telephone calls with you may be kept for a period of up to six years.

Information collected via technical means such as cookies, webpage counters and other analytics tools is kept for a period of up to one year from expiry of the cookie.

12. CHILDREN'S PERSONAL INFORMATION

We do not knowingly request to collect personal information from any person under the age of 18. If a user submitting personal information is suspected of being younger than 18 years of age, Coinchange will require the user to close his or her account and will not allow the user to continue using our Services. We will also take steps to delete the information as soon as possible. Please notify us if you know of any individuals under the age of 18 using our Services so we can take action to prevent access to our Services.

13. CROSS BORDER TRANSFERS

To facilitate our global operations, Coinchange may transfer, store, and process your information within our family of companies, partners, and service providers based throughout the world. We contractually obligate recipients of your personal information to agree to at least the same level of privacy safeguards as required under applicable data protection laws. By communicating electronically with Coinchange, you acknowledge and agree to your personal information being processed in this way.

If you have a complaint about our privacy practices and our collection, use or disclosure of personal information please submit your request via support@coinchange.ca.

14. COOKIE POLICY

14.1 Use of Cookies

We use "cookies" to collect information about you and your activity across our site. A cookie is a small piece of data stored on your computer and accessed each time you visit our Website and Service, so we can understand how you use our Service and serve you content or save setting you have specified.

If you do not wish to accept cookies from us, you should instruct your browser to refuse cookies from our Website and Service, with the understanding that we may be unable to provide you with some of your desired service without them. This policy covers only the use of cookies between your computer and our Website and Service; it does not cover the use of cookies by any third-party advertisers.

Cookies are used to enable certain features (eg. logging in), to track site usage (eg. analytics), to store your user settings (eg. timezone, notification preferences and usernames), and to personalise your content.

14.2. Types of cookies and how we use them

Cookies set by the website you are visiting are normally referred to as "first-party cookies", and typically only track your activity on that particular site. Cookies set by other sites and companies (ie. third parties) are called "third-party cookies" and can be used to track you on other websites that use the same third-party service.

14.3. Essential cookies

Essential cookies are crucial to your experience of a website, enabling core features like user logins, account management, and payment processing. We use essential cookies to enable certain functions on our Website and Service.

14.4. Performance cookies

Performance cookies are used in the tracking of how you use a website during your visit, without collecting personal information about you. Typically, this information is anonymous and aggregated with information tracked across all site users, to help companies understand visitor usage patterns, identify and diagnose problems or errors their users may encounter, and make better strategic decisions in improving their audience's overall website experience. These cookies may be set by the website you're visiting (first-party) or by third-party services. We use performance cookies on our Website and Service.

14.5. Functionality cookies

Functionality cookies are used in collecting information about your device and any settings you may configure on the website you are visiting (like language and time zone settings). With this information, websites can provide you with customised, enhanced or optimised content and services. These cookies may be set by the website you're visiting (first-party) or by third-party services. We use functionality cookies for selected features on our Website and Service.

14.6. Targeting/advertising cookies

Targeting/advertising cookies are used in determining what promotional content is more relevant and appropriate to you and your interests. Websites may use them to deliver targeted advertising or to limit the number of times you see an advertisement. This helps companies improve the effectiveness of their campaigns and the quality of content presented to you. These cookies may be set by the website you are visiting (first-party) or by third-party services. Targeting/advertising cookies set by third parties may be used to track you on other websites that use the same third-party services. We use targeting/advertising cookies on our site.

14.7. Third-party cookies on our site

We may employ third-party companies and individuals on our websites - for example, analytics providers and content partners. We grant these third parties access to selected information to perform specific tasks on our behalf. They may also set third-party cookies in order to deliver the services they are providing. Third-party cookies can be used to track you on other websites that use the same third-party service. As we have no control over third-party cookies, they are not covered by our cookie policy. You should disable cookies if you do not wish to permit third-party cookies to track your usage.

15. YOUR PRIVACY RIGHTS

Depending on applicable law where you reside, you may be able to assert certain rights related to your personal information identified below. If any of the rights listed below are not provided under law for your operating entity or jurisdiction, Coinchange has absolute discretion in providing you with those rights.

15.1. Your rights to personal information are not absolute. Depending upon the applicable law, access may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another's privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious, or for other reasons

15.2. Access and portability. You may request that we provide you a copy of your personal information held by us. This information will be provided without undue delay subject to a potential fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. In certain circumstances, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another data controller.

15.3. Rectification of incomplete or inaccurate personal information. You may request us to rectify or update any of your personal information held by Coinchange that is inaccurate. You may do this at any time through your account or by contacting support@coinchange.io

15.4. Erasure. You may request to erase your personal information, subject to applicable law. If you close your Coinchange Account, we will mark your account in our database as "Closed," but will keep certain account information, including your request to erase, in our database for a period of time as described above. This is necessary to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account, and to comply with Coinchange's legal obligations. However, if you close your account, your personal information will not be used by us for any further purposes, nor shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.

15.5. Withdraw consent. To the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time. Your withdrawal will not affect the lawfulness of Coinchange's processing based on consent before your withdrawal.

15.6. Restriction of processing. In some jurisdictions, applicable law may give you the right to restrict or object to us processing your personal information under certain circumstances. We may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.

15.7. Automated individual decision-making, including profiling. Coinchange relies on automated tools to help determine whether a transaction or a customer account presents a fraud or legal risk. In some jurisdictions, you have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.

16. HOW TO MAKE A PRIVACY REQUEST

You can make privacy rights requests relating to your personal information by contacting support@coinchange.io Only amendments which can be verified by us will be accepted. When we receive an individual rights request via other intake methods, we may take steps to verify your identity before complying with the request to protect your privacy and security.

17. HOW TO LODGE A COMPLAINT

If you believe that we have infringed your rights, you may contact support@coinchange.io

18. HOW TO CONTACT US
If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, please contact us at support@coinchange.io


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