Privacy Notice

Version: 1.0

Last updated: May 29, 2023

We are dedicated to safeguarding the privacy of our customers.

This Privacy Notice describes how we collect and process your personal data through our website (https://crptchange.com/) and any related applications (referred to collectively as the “Website”).

This Privacy Notice applies to all the activities involving the processing of Personal Data conducted by us. Even if you are not directly engaged as a customer or user of our Services, but are accessing our Website, this Privacy Notice also applies to you.

1. Definitions

As used herein, the following terms are defined as follows:

Term	Definition
Data Controller	A natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
Personal Data	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 may obtain from third parties.
Services	Services provided by us as described in the relative Terms and Conditions of the Website.

2. Who we are

CRYPTOCHANGENOW SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ (“we”, “us” or “our”) determines the means and purposes of processing of your Personal Data in relation to the Services provided to you (typically referred to as a “Data Controller”). Our registration number is 0001004762. You can contact us:

By mail: UL. HOŻA 86 / 210, 00-682 WARSZAWA, Poland

By email: [email protected]

3. What personal data we process

3.1. Information you provide to us

In order to create an account and access our Services, we will kindly request certain information from you. This data is either legally mandated (e.g., for identity verification) or essential to provide the Services (e.g., your email address is needed to open an account).

Please note that if you fail to provide the required data, we will be unable to offer you our Services.

The following types of data may be collected from you:

Category of Personal Data	Types of Personal Data
Account Data	Full name, email address, username, password. We may also ask for your utility bills or photographs of you.
Government Data	We may ask for government issued identity documents such as passport, national identification number, national identity card details, drivers licenses.
Financial Data	Limited bank account or payment card information, source of funding, source of wealth.
Transaction Data	Information about the transaction you make on our Services, such as the name of the recipient, your name, and email.
Data from Cookies	See “What About Cookies?” section of this Privacy Notice for more information.
Communications	Your communications with our customer support team and with us.

3.2. Information we collect from you automatically

We may collect certain types of data automatically when you engage with us or our Services. The following types of data may be collected:

Category of Personal Data	Types of Personal Data
Browsing Data	Device ID, browsing information such as version, IP address, operating system.
Usage Data	Authentication data and other relevant information through the use of cookies or similar technologies. This includes data on the performance of our Services, such as any error messages encountered and information regarding the performance of the Website.
Marketing and Research Data	We collect various types of information, including identifiers like IP addresses or other online identifiers, as well as email addresses used for direct marketing purposes. Additionally, we collect data about your web browsing activities and preferences, such as the services and content you select or view. We use this data to perform analytics and derive insights.

4. How we use personal data

Below we provide an explanation of how we use your Personal Data.

Purpose of processing	Legal basis
Managing our contractual relationship with you. This also involves using your Personal Data to process payments. The categories of Personal Data processed:Account Data;Financial Data.	Performance of a contract
Providing our Services. For example, when you want to exchange cryptocurrencies. The categories of Personal Data processed:Account Data;Financial Data;Transaction Data;Browsing Data;Usage Data.	Performance of a contract
Maintaining compliance with legal and regulatory requirements. For instance, we collect and use your Personal Data to fulfill our obligations related to Know Your Customer (KYC) and Anti-Money Laundering (AML) laws and regulations. The categories of Personal Data processed:Account Data;Government Data;Financial Data;Transaction Data.	Compliance with our legal obligations
Communicating with you regarding Services. This includes notifying you about security issues, updates, or providing transaction-related information to keep you informed. The categories of Personal Data processed:Account Data;Financial Data;Transaction Data.	Performance of a contract
Providing customer support. This includes assisting you with inquiries, resolving disputes, addressing complaints, and troubleshooting problems to ensure a satisfactory customer experience. The categories of Personal Data processed:Account Data;Financial Data;Transaction Data;Communications;Browsing Data;Usage Data.	Performance of a contractLegitimate interests (e.g., to improve our Services and enhance user experience)
Promoting the safety, security, and integrity of our Website. We use your Personal Data to enhance security measures, verify identities, control Services access, and adhere to applicable laws and regulations. The categories of Personal Data processed:Account Data;Financial Data;Transaction Data;Browsing Data;Usage Data.	Performance of a contract Legitimate interests (e.g., to ensure information security)
Investigating suspicious activity and combating fraud. We use your Personal Data to investigate any suspicious activities, detect, prevent, and combat fraudulent activities and money laundering. This helps us maintain the integrity of our Services and ensure a secure environment for our users. The categories of Personal Data processed:Account Data;Financial Data;Transaction Data;Browsing Data;Usage Data.	Compliance with our legal obligationsLegitimate interests (for example, to detect and prevent fraud)
Improving our Services. For example, to improve our Website and for you to have a better user experience. The categories of Personal Data processed:Account Data;Transaction Data;Browsing Data;Usage Data.	Legitimate interests (e.g., to understand our audience and provide customized experience for the users)
Providing you with promotions. This includes offering rewards and other incentives as a way to encourage your usage of our Services. The categories of Personal Data processed:Account Data;Transaction Data;Browsing Data;Usage Data.	Legitimate interest (for example, to reward customer loyalty)
Conducting research and driving innovation. We use your Personal Data to conduct research and enhance our Services, driving innovation to improve your experience. The categories of Personal Data processed:Account Data;Transaction Data;Usage Data;Marketing and Research Data.	Legitimate interest (for example, to improve our Website)
Delivering marketing communications. We may use your Personal Data to provide you with marketing communications, keeping you informed about our latest offerings, updates, and relevant information. The categories of Personal Data processed:Account Data;Transaction Data;CommunicationsBrowsing Data;Usage Data;Marketing and Research Data.	Consent (where required by applicable law)Legitimate interest (for instance, to create promotions you may be interested in)

5. Automated processing and profiling

We do not use automated processing and profiling which produces legal effects concerning you or similarly significantly affects you.

6. Children

Our Services are not intended for individuals under the age of 18, and we do not knowingly collect Personal Data from children under 18 years of age.

7. Cookies

We use cookies and similar tools to enhance your user experience, provide our Services, enhance our marketing efforts and understand how customers use our Services so we can make improvements.

We may use the following Cookies:

Category	Description
Essential Cookies	These Cookies are necessary for allowing users to navigate around our Website and access features. These Cookies do not collect information about you that could be used for marketing purposes and do not remember your browsing history on the internet.
Functional Cookies	These Cookies allow the Website to offer enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have included on our pages. If you do not allow these Cookies, some or all of these services may not work properly.
Performance Cookies	We may Cookies to gather information about how visitors use the Website. These cookies collect information in aggregate form to provide us with insight into how our Website is being used.
Marketing Cookies	These Cookies are used to deliver content that is more relevant to you and your interests. They may be used to deliver targeted advertisements as well as help measure the effectiveness of an advertising campaign.

Most modern web browsers offer an option to view the Cookies stored on your device, and also permit you to customize your preferences by accessing their Cookie settings.

Here is a list of links which will help you to understand how to manage your Cookies preferences:

8. Sharing of personal data

We may share your Personal Data with third parties if we believe that sharing your Personal Data is in accordance with, or required by, any contractual relationship with you or us, applicable law, regulation or legal process.

We may also share Personal Data with the following persons or in the following circumstances:

Category	Description
Third-party service providers	We employ other companies and individuals to perform functions on our behalf:Hosting providers: To store and transfer our content and data;Payment service providers: To process payment transactions;Analytics providers: To collect details of the Website use, including, but not limited to IP address, device information, etc.Consultants, lawyers, accountants and other professional service providers: To receive professional advice from them.
For legal reasons	In certain circumstances, we may be legally obligated or required by court order to disclose specific information about you. We will disclose information to legal authorities only to the extent mandated by law.
Other cases:	We may also share Personal Data in the following cases:For the establishment, exercise, or defense of a legal claim, including investigations or inquiries by competent regulatory authorities;If we contemplate selling or acquiring any business or assets, we may disclose your personal data to potential sellers or buyers involved in such transactions. Furthermore, in the event that a third party acquires us or a substantial portion of our assets, personal data may be among the transferred assets.

9. International data transfers

As a multinational business, we collaborate with service providers in various countries, including those outside the European Economic Area (EEA), UK, and Switzerland. To ensure an adequate level of data privacy protection, we implement the following measures:

Measure	Description
Adequacy	We may transfer Personal Data to a third country that has received an official determination of “adequacy” from the relevant regulatory authorities. For more information about “adequacy decisions”, click here.
Appropriate safeguards	We establish appropriate safeguards by utilizing binding, standard data protection clauses adopted by the relevant regulatory authorities. These clauses are enforceable by data subjects within the United Kingdom and/or the European Economic Area. For more information about Standard Contractual Clauses click here.
Derogations	Depending on the circumstances, we may also collect and transfer Personal Data based on specific derogations, such as explicit consent from the data subject, the necessity of performance under a contract involving the data subject, important public interest reasons, or the establishment, exercise, or defense of legal claims.

10. Security of your personal data

We implement necessary security measures to safeguard Personal Data from loss, misuse, unauthorized access, alteration, disclosure, or destruction. We have put in place measures to ensure the continuous confidentiality, integrity, and availability of the systems and Services that handle Personal Data.

11. Your rights

You have basic rights under privacy and data protection laws related to the Personal Data we process about you. If you want to exercise any of your rights, please contact us at [email protected].

Right	Description
Right to access	You have the right to obtain confirmation that your Personal Data are processed and to obtain a copy of it as well as certain information related to its processing.
Right to rectify	You can request the rectification of your Personal Data which are inaccurate.
Right to delete	You can, in some cases, have your Personal Data deleted.
Right to object	You can object, for reasons relating to your particular situation, to the processing of your Personal Data. For instance, where we process your data for direct marketing purposes.
Right to restrict processing	In specific cases, you have the right to temporarily restrict the processing of your Personal Data. However, we may continue processing your Personal Data if it is necessary for legal defense or falls within other exceptions permitted by applicable law.
Right to portability	You can request to receive your Personal Data, which you have provided to us, in a structured, commonly used, and machine-readable format. If feasible, we can also transfer your Personal Data to another Data Controller upon your request.
Right to withdraw your consent	For processing requiring your consent, you have the right to withdraw your consent at any time.
Right to lodge a complaint	We strive to address any inquiries you may have about how we handle your Personal Data. If, however, you have unresolved concerns, you have the right to lodge a complaint with the relevant data protection authority, particularly in the country where you habitually reside, work, or believe an infringement has occurred.

12. KEEPING YOUR PERSONAL DATA

We will retain Personal Data for the duration of our provision of Services to you and as long as we are addressing any concerns, questions, complaints, or requests you have submitted to us. The retention period will depend on our interactions with you, legal requirements, and the necessity to maintain information for purposes such as responding to investigations or legal proceedings.

In certain cases, we may retain data for a longer period if we have a legal obligation to do so or if it is necessary to maintain records for legal, financial, compliance, or reporting purposes.

If you have any questions regarding storage of your Personal Data, please contact us at [email protected].

13. Changes to this privacy notice

If you have any concerns about your privacy, please contact us, and we will try to resolve it.

Our business changes regularly, and our Privacy Notice may change also. You should check our websites frequently to see recent changes.