Contact us anytime via: [email protected]
Who We Are
The data controller in respect to SimpleSwap Ltd. ( or “we”).
Registration number: 108214
Registered address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Republic of Marshall Islands, MH 96960
What Data We Collect and How We Collect It
Personal data means any information capable of identifying you as an individual, such as your name, e-mail address, or that can be connected to you indirectly, such as your language or location. We collect personal data that you directly provide to us when registering at Website or App, expressing an interest in using our service or when participating in our activities or otherwise contacting us. The personal data we collect depends on the context of your interactions with us, the choices you make and the products and features you use. We also collect or generate personal data when third parties such as educational institutions provide information about you, when you provide or receive a course or other educational content, or in the course of providing our Services, and we may collect personal data from other sources, for example, to keep your information up to date using publicly available sources. The personal data we process can include the following:
|Category of Data||Description|
|Contact data||We collect your email address|
|Credentials data||We collect passwords and similar security data used for authentication and account access|
|Social Media Login Data||We provide you with the option to register and/or contact us via social media accounts. We may collect your social media account details like your Twitter Username, Telegram ID, Reddit Username. Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public.|
We will use the information we receive only for the purposes that are described in this Policy or that are otherwise made clear to you on Website or App. Please note that we are not responsible for the ways in which third party service providers process any of your personal data and invite you to read their privacy policies for further data on how they process your personal data.
All personal data that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal data.
Data automatically collected
We automatically collect certain information when you visit, use or navigate Website or App. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website or App and other technical information. This information is primarily needed to maintain the security and operation of our Website or App, and for our internal analytics and reporting purposes.
|Category of Data||Description|
|Browsing Data||Information about the device, operating system, and browser you’re using Other device characteristics or identifiers (e.g. plugins, the network you connect to) IP address Device name Country Location We may request access or permission to and track location-based data from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.|
|Usage Data||Activity information: Information about what you view or click on while visiting our Website and App and how you use our Services. Diagnostic and Troubleshooting Information: Information about how our Services are performing when you use them, i.e. service-related diagnostic and performance information, including timestamps, crash data, website performance logs, and error messages or reports.|
|Push Notifications||We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings|
How We Use Your Personal Data
We use your Personal data primarily for the following purposes on the following legal basis.
Legitimate interest: we may process your Personal data when it is reasonably necessary to achieve our legitimate business interests. In addition, we may disclose your Personal data where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
Performance of the contract:where we have entered into a contract with you, we may process your Personal data to fulfill the terms of our contract, and for the following purposes:
- to develop, improve and deliver our Services;
- to make our Services known and popular;
- to make the use of our Services secure for the Users.
|Purpose||Category of Data||Legal Basis|
|To contact user regarding any requests and information they provides||Contact data Credentials data Social Media Login Data||Consent Performance of the contract|
|To ensure timely and appropriate processing of user’s queries, requests, and replies||Contact data Credentials data Social Media Login Data Browsing Data||Consent Performance of the contract|
|To ensure smooth administration of the Website||Browsing Data Usage Data||Legitimate interest Performance of the contract|
|To ensure functionality of the Website and personalize it||Browsing Data Usage Data||Legitimate interest Performance of the contract|
|To diagnose and fix issues with Website and App||Contact data Browsing Data||Legitimate interest Performance of the contract|
|To enable us to perform statistical and other analysis by continuously improving the content of Website and App||Browsing Data Usage Data Cookies||Consent Legitimate interest|
|To directly advertise our Services||Contact data Social Media Login Data Usage Data||Consent|
|To analyze the Services and target ads||Contact data Social Media Login Data Browsing Data Usage Data||Consent|
|To comply with legal requirements and law enforcement requests||Contact data Social Media Login Data Usage Data||Legal obligations|
|To conduct business planning, reporting, and forecasting||Browsing Data Usage Data||Legitimate interest|
|To establish, exercise, or defend legal claims||Contact data||Legal obligations|
We may use your personal data for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Website or App, products, services, marketing, and your experience.
What About Cookies?
How We Share Your Personal Data
We may share your Personal data with the following categories of third parties:
|Vendors, Consultants, and Other Third-Party Service Providers||We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such personal data to do that work. Examples include data analysis, email delivery, hosting services, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on the Website or Apps, which will enable them to collect on our behalf data about how you interact with the Website or Apps over time. This data may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Notice, we do not share, sell, rent or trade any of your personal data with third parties for their promotional purposes.|
|Government authorities, auditors, consultants||To fulfill official requests, our tax, and other obligations;|
|Affiliates||We may share data with our affiliates to provide you the Services. Affiliates include our parent company and any subsidiaries or other companies that we control and/or connected to us and/or that are under common control with us.|
Our servers are located in the Netherlands in full compliance with the data protection regulation.
To ensure that the Personal data is safeguarded, stored, and processed in a secured way we use Standard contractual clauses (SCC) adopted by the European Commission as a mechanism to transfer data from the EU countries. Our partners established in countries with an inadequate level of protection of personal data have adopted SCC, as appropriate, to ensure confidentiality, security, and legality of the processing of your personal data.
How We Store Your Personal Data
- If there is an unresolved issue relating to your account, such as an outstanding credit on your account and/or an unresolved claim and/or dispute - we will retain the necessary Personal data until the said issue is resolved;
- Where necessary to comply with legal, tax, audit, and accounting obligations and/or any other legal obligation, we will retain the necessary Personal data for the period required by the applicable law;
- Where necessary to fulfill our legitimate interests such as fraud prevention and/or maintenance of our Users' security
How We Keep Your Personal Data Safe
We have implemented appropriate technical and organizational security measures designed to protect the security of any Personal data we process and to protect your Personal data from unauthorized access, use, disclosure, alteration or destruction. For instance, we follow industry leading practices for securing data using secure socket encryption (HTTPS) on transmission and utilizing encryption services provided by Google Cloud. We are covered by Google’s compliance certifications; Service Organization Control 1 (SOC 1), SOC 2, and SOC 3. However, please also remember that we cannot guarantee that the Internet itself is 100% secure. Although we will do our best to protect your Personal data, transmission of Personal data to and from our Website or Apps is at your own risk. You should only access the services within a secure environment.
What Are Your Rights?
- ACCESS - You may request a copy of your Personal data and/or the way we store your Personal data.
- RECTIFY - You may request to change some of your Personal data and/or correct your Personal data if this is inaccurate.
- ERASURE - You may request to delete all or some of your Personal data, for example, if:
- they are no longer needed for any processing purposes
- consent has been used as a legal basis for their processing
- there is no legitimate interest in the further processing of Personal data
- OBJECT - You may object to the processing of your Personal data on grounds relating to your particular situation and/or to object processing your Personal data for direct marketing purposes.
- NO AUTOMATED PROCESSING - You may object to a decision based on automated processing. This means that you may request to review your Personal data manually if you believe that automated processing of your Personal data may not consider your unique situation.
- DATA PORTABILITY - You may request to provide you a copy of your Personal data in a structured, commonly used, and machine-readable format (e.g. xml, csv). Furthermore, you have the right to request to transmit the said Personal data directly to another controller.
- COMPLAIN - You have the right to lodge a complaint with a supervisory authority, in particular to the member state of the European Union of your habitual residence, place of work, or place of the alleged infringement.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal data, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
What About California?
California Consumer Privacy Act (CCPA) provides our users who are California residents, with the right to request and obtain from us information about:
- The categories of Personal data we have collected about you; x
- The categories of sources from which we collected Personal data;
- The categories of Personal data about you we disclosed for a business purpose or sold;
- The categories of third parties to whom the Personal data was disclosed for a business purpose or sold;
- The business or commercial purpose for collecting or selling the Personal data;
- The specific pieces of your Personal data we have collected.
If you are a California resident under 18 years old, you may request to remove any content or information you have published or made available on the Website. We do not sell the data of users under 16 years of age, unless affirmatively authorized, as specified, to be referred to as the right to opt in. The act will prescribe requirements for receiving, processing, and satisfying these requests from consumers. The act will prescribe various definitions for its purposes and would define “personal information” with reference to a broad list of characteristics and behaviors, personal and commercial, as well as inferences drawn from this in
Please contact us by email at [email protected] to exercise your rights.
Personal Data Breach
A Personal data breach may, if not addressed in an appropriate and timely manner, result in a physical, material, or non-material risk to your rights and freedoms. Therefore, as soon as we become aware that a Personal data breach has occurred, we will notify the Personal data Breach to the Commissioner for Personal data Protection without undue delay and, where feasible, not later than 72 hours after having become aware of it, unless we are able to demonstrate, following the accountability principle, that the Personal data breach is unlikely to result in a risk to your rights and freedoms. Where such notification cannot be achieved within 72 hours, the reasons for the delay should accompany the notification without undue further delay.
What About Minors?
Nothing Lasts Forever