about this Policy, please submit your request via email to email@example.com
By accessing and using our Services, you signify acceptance to the terms of this
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
Personal information is typically data that identifies an individual or relates to an
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
⮚ 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
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
⮚ 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
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.