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Privacy Policy

Privacy Policy

LAST UPDATED: 3 May 2019

PRIVACY NOTICE OF www.alphaswap.io

AlphaSwap (as defined below) is committed to ensuring that your privacy is protected and wants you to be familiar with how we collect, process, use and disclose personal information. This notice (the “Privacy Policy”) describes our practices in connection with any personal information we collect from you, or that you provide to us, and how we protect your information.

By visiting www.alphaswap.io or making use of any of the services listed below (the “Services”), you are accepting and consenting to this Privacy Policy:

  • websites operated by us from which you are accessing this Privacy Policy (the “Websites”);
  • through our social media pages (collectively, our “Social Media Pages”); and
  • through HTML-formatted email messages that we send to you that link to this Privacy Policy.

References to the terms “AlphaSwap”, “we” and “us” in this Privacy Policy refers to AlphaSwap Ltd, a private limited company incorporated in England and Wales.

COLLECTION OF PERSONAL INFORMATION

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual.”

We may collect, use, store and transfer different kinds of Personal Information about you which we have grouped together as follows:

  • Identity Data including first name, maiden name, last name, title, occupation, date of birth and gender.
  • Contact Data including postal address, email address and telephone numbers.
  • Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data including enquiries made by you, your interests, preferences, feedback and survey responses.
  • Usage Data including information about how you use our website, products and services.
  • Marketing and Communications Data including your preferences in receiving marketing from us and your communication preferences.

We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

AlphaSwap may also collect Personal Information from third party services providers such as credit reference agencies, or analytics providers to provide the Services. Furthermore, in accordance with typical market practice, AlphaSwap may keep records and monitor communications with you as evidence of engagement, for quality and training purposes or for internal security protocols.

USE OF PERSONAL INFORMATION

We and our service providers use Personal Information for the following purposes including:

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
Providing the functionality of the Services and fulfilling your requests, including the following:
  • To respond to your enquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Services.
  • To provide the Services’ functionality to you.
  • To send administrative information to you, such as changes to our terms, conditions and policies.
Identity Data, Contact Data, Technical Data, Profile Data, Usage Data, Marketing and Communications Data
  • Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud)
  • Performance of a contract with you
  • Necessary to comply with a legal obligation
Providing you with our newsletter and/or other marketing materials, including:
  • To send you marketing-related emails, with information about our services, new products and other news about our business.
Identity Data, Contact Data, Profile Data, Marketing and Communications Data
  • Necessary for our legitimate interests (to develop the Services and grow our business)
  • Consent
Analysis of Personal Information for business reporting and providing personalised services, including:
  • To analyse or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
  • To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
Identity Data, Contact Data, Technical Data, Profile Data, Usage Data, Marketing and Communications Data
  • Necessary for our legitimate interests (to study how users use the Services, to develop them, to grow our business and to inform our marketing strategy)
Where we provide personalized services:
  • Consent
  • Necessary for our legitimate interests (to define types of users for our Services, to keep our business relevant, to develop our business and to inform our marketing strategy)
Aggregating and/or anonymising Personal Information, including:
  • We may aggregate and/or anonymise Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.
Identity Data, Contact Data, Technical Data, Profile Data, Usage Data, Marketing and Communications Data
  • Necessary for our legitimate interests (to develop the Services and grow our business)
Accomplishing our business purposes, including:
  • For data analysis, for example, to improve the efficiency of our Services;
  • For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
  • For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
  • For developing new products and services.
  • For enhancing, improving, or modifying our current products and services.
  • For identifying usage trends, for example, understanding which parts of our Services are of most interest to users.
  • For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
  • For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.
Identity Data, Contact Data, Technical Data, Profile Data, Usage Data, Marketing and Communications Data
  • Necessary for our legitimate interests (for running our business, developing the Services, growing our business, the provision of administration and IT services, network security, to prevent fraud)
  • Performance of a contract with you
  • Necessary to comply with a legal obligation

AlphaSwap will not sell, trade or otherwise deal with your Personal Information in any way that contravenes this Privacy Policy (as may be updated from time to time).

DISCLOSURE OF PERSONAL INFORMATION

AlphaSwap will only disclose Personal Information in accordance with this Privacy Policy (as may be updated from time to time).

We may disclose Personal Information:

 

  • o our third party service providers, to facilitate services they provide to us.
    • These can include providers of services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
    • We may also provide Personal Information to persons who provide professional, legal or accounting services to us.
  • To facilitate your instructions.
  • To entities related to AlphaSwap, to facilitate services to you.
OTHER USES AND DISCLOSURES

We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

  • To comply with applicable law and regulations.
    • This can include efforts to prevent fraud or other crimes as well as compliance with any relevant laws outside your country of residence. This may include carrying out background checks for the purposes of applicable anti-money laundering legislation or other regulatory obligations.
  • To cooperate with public and government authorities.
    • To respond to a request or to provide information we believe is important including to authorities outside of your country of residence.
  • To cooperate with law enforcement.
    • For example, responding to a writ or similar legal process, responding to law enforcement requests or to provide information we believe is important.
  • For other legal reasons.
    • To enforce our terms and conditions; and
    • To protect our rights, privacy, safety or property, and/or that of you or others.
OTHER INFORMATION

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. This includes:

  • browser and device information;
  • app usage data;
  • information collected through cookies, pixel tags and other technologies;
  • demographic information and other information provided by you that does not reveal your specific identity; and
  • information that has been aggregated in a manner such that it no longer reveals your specific identity.

If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy.

COLLECTION OF OTHER INFORMATION

We and our service providers may collect Other Information in a variety of ways, including:

  • Through your browser or device:
    • Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
  • Using cookies:
    • Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalise your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them. We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services.
  • Using pixel tags and other similar technologies
    • Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
    • Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyse information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/‌partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout’.
  • IP Address
    • Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.
USES AND DISCLOSURES OF OTHER INFORMATION

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

SENSITIVE INFORMATION

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., national insurance numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.

SECURITY

We seek to use reasonable organisational, technical and administrative measures to protect Personal Information within our organisation. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from receiving electronic communications from us. If you no longer want to receive marketing-related emails from us, you may opt-out by sending an email with “Unsubscribe” as subject to info@alphaswap.io or by clicking on the ‘Unsubscribe’ link featured at the bottom of such marketing-related emails.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative or service-related messages, from which you cannot opt-out.

HOW CAN YOU ACCESS, CHANGE OR DELETE YOUR PERSONAL INFORMATION

If you would like to:

  • request access to your Personal Information,
  • request correction of your Personal Information,
  • request erasure of your Personal Information,
  • object to us processing your Personal Information,
  • request restriction of processing your Personal Information,
  • request an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), or
  • withdraw consent to us processing your Personal Information,

you may contact us via: info@alphaswap.io, or AlphaSwap Ltd, 60 Sloane Avenue, 3rd Floor, London SW3 3DD, London, United Kingdom. We will respond to your request consistent with applicable law.

For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

We may ask you to provide further information about the basis for your request (and supporting documentation) before we respond. You should be aware that, due to the purposes for which the Services are provided, we may not be required to comply (or fully comply) with your request. In those circumstances, we will write to you explaining why we are unable to comply.

We do not charge you for accessing your personal information (or exercising your other rights) unless your request is clearly unfounded, repetitive or excessive, in which case a reasonable fee may be charged.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.

RETENTION PERIOD

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include:

 

  • he length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us.

JURISDICTION ANDCROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

Some of the non-EEA countries are recognised by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by contacting info@alphaswap.io.

UPDATES TO THIS PRIVACY POLICY

The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.

CONTACTING US

AlphaSwap Ltd, located at c/o BCS, Windsor House, 5 Station Court, Station Road, Great Shelford, Cambridge CB22 5NE, is the entity responsible for collection, use and disclosure of your Personal Information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at info@alphaswap.io, or AlphaSwap Ltd, 60 Sloane Avenue, 3rd Floor, London SW3 3DD, London, United Kingdom.

Because email communications are not always secure, please do not include credit card details or sensitive information in your emails to us.

ADDITIONAL INFORMATION REGARDING THE EEA

You may also:

  • Contact us at info@alphaswap.io with any questions about this Privacy Policy.
  • Lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.