LAST UPDATED: 3 May 2019
PRIVACY NOTICE OF www.alphaswap.io
- through our social media pages (collectively, our “Social Media Pages”); and
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.
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/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|Providing the functionality of the Services and fulfilling your requests, including the following:||Identity Data, Contact Data, Technical Data, Profile Data, Usage Data, Marketing and Communications Data|
|Providing you with our newsletter and/or other marketing materials, including:||Identity Data, Contact Data, Profile Data, Marketing and Communications Data|
|Analysis of Personal Information for business reporting and providing personalised services, including:||Identity Data, Contact Data, Technical Data, Profile Data, Usage Data, Marketing and Communications Data|
|Aggregating and/or anonymising Personal Information, including:||Identity Data, Contact Data, Technical Data, Profile Data, Usage Data, Marketing and Communications Data|
|Accomplishing our business purposes, including:|
DISCLOSURE OF PERSONAL INFORMATION
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” 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.
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:
- 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.
- 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.
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.
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 email@example.com 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: firstname.lastname@example.org, 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.
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
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 email@example.com.
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:
- 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.