This Privacy Policy details how Dіgіtаl Оcеan s.r.o. (also referred to as “we”, “our”, or “us”) gathers, utilizes, and discloses information related to your interaction with our products, services, and website. This Policy complies with the European General Data Protection Regulation (“GDPR”) and is committed to ensuring the transparent, lawful, fair, and secure management of our customers' and users' personal data.

In this document, we explain the types of personal data we collect through our website and services, the methods and purposes of collection, how we use this data, and the third parties with whom we share it. Additionally, it outlines your rights concerning your personal data and provides guidance on how you can exercise these rights.

Our primary commitment is to the secure storage and management of the funds you entrust to us, alongside maintaining the fairness, competitiveness, authenticity, and transparency of the market, including your Orders and Transactions. While we may periodically update this Privacy Policy, we assure you that any changes will not undermine the integrity of our mission. Updates to this Policy (along with related policies like the Terms of Service and Cookie Policy) will be communicated to you via email and updated on this page.

You must read this Policy in order to stay informed about how your data is processed, your rights and obligations under this Policy. For any inquiries regarding this Privacy Policy, data collection and usage, data disclosure and sharing, or other concerns or requests related to your personal data, please reach out to us at: info@easyswapper.io .

The following terms are used in this Privacy Policy:

“Personal data” - any information that relates directly or indirectly to a specific or identifiable natural person (the subject of personal data).

“Processing of personal data” - any operation or series of operations carried out on personal data, with or without automated means, including collection, recording, organization, structuring, storage, modification (updating or alteration), retrieval, use, disclosure (by transmission, dissemination, or otherwise making available), anonymization, restriction, erasure, or destruction of personal data.

“Confidentiality of personal data” - the obligation of any operator or individual with access to personal data to prevent its unauthorized distribution, unless the data subject has given consent or there are other legal grounds.

“Cookies” - small pieces of data sent by a web server and stored on the user's device. These pieces of data are sent back to the web server by the web client or browser with each HTTP request when accessing a page on the related site.

“User” - any person who accesses and uses the Site via the Internet.

“Site” - a website available on the Internet at the domain address info@easyswapper.io

This section covers the information and content you provide when using our Services and Products. Dіgіtаl Осеаn s.r.o. will never request information regarding your racial or ethnic origin, sexual orientation, political views, religious or philosophical beliefs, biometric or genetic data, or trade union membership.

When you sign up for an account, we may ask you for your contact details such as your full name, residence address, email address, and phone number. Additionally, to comply with regulations acts such as Act No 253/2008 Sb. of 5 June 2008 on Selected Measures against Legitimisation of Proceeds of Crime and Financing of Terrorism of the Czech Republic (the “AML/CTF Act”), we may collect the following personal information:
- Identification information, including documents issued by government authorities in your country of residence or birth, such as a passport, national ID card, residence permit, driver’s license, birth certificate, visa details, and other documents necessary to verify your identity and comply with AML and anti-financial crime laws.
- Financial information, including bank account details, payment card information, transaction history, trading data, tax information, and other relevant financial details.
- Business information, including a certificate of incorporation from relevant authorities, extracts from commercial registries, tax or VAT numbers, Articles or Memorandum of Association, Certificates of Incumbency, personal identification of all ultimate beneficial owners (UBOs), shareholders, and board members, as well as information regarding the origin and source of funds.
- Employment information, including your job title, employer’s office location, and job description.
- Transaction information, including details about transaction amounts and recipients.

We use the personal information and data for following purposes (but not limited):
a. to provide, manage, and sustain our Services;
b. to Process payments and execute Orders, Trades, and Transactions in accordance with principles of market equity, transparency, competitiveness, and legitimacy.
c. to identify and prevent fund losses, including those arising from fraudulent activities and misuse of our Services.
d. to ensure compliance with applicable laws and regulations to prevent money laundering, terrorism financing, fraud, and other financial crimes.
e. to adhere to anti-financial crime regulations and obligations stipulated by Czech authorities, such as the Financial Analytical Office (Finanční analytický úřad hereinafter, the "FAO");
f. to engage in communication with you, whether directly or through our partners, for purposes such as providing customer support, notifying you of changes and updates related to the Services, disseminating important Service-related information, and conducting marketing and promotional activities.
g. to transmitte emails, including notifications, reminders, and confirmations.
h. to enhance the quality of our Services.
i. to conducte research and development to introduce innovative features and functionalities and launch new products and services.
j. to undertake measurement and analytics to understand user interaction with our Services and gain insights into user behaviors and preferences.
k. to advocate for the safety, security, and integrity of your funds, our Services, and data.

We deeply understand the critical importance of upholding the security and integrity of your personal data, as any breach could have severe repercussions for both you and your financial assets. Hence, we have implemented a comprehensive array of physical, technical, and administrative safeguards to ensure that your personal information remains protected.

To safeguard your personal data, we employ the Transport Layer Security (TLS) protocol, a robust encryption mechanism designed to thwart unauthorized access and maintain privacy. TLS encryption is utilized to secure all data exchanged between our website and servers, including emails and messages.

Furthermore, your personal and transactional data is stored in encrypted form, with assistance from trusted service providers who help maintain various safeguards. It's worth noting that some of these service providers may operate outside the EU/EEA zone.

While we have taken extensive measures to safeguard your data, it's important to recognize that no system is entirely invulnerable to breaches or unauthorized access. Therefore, we urge you to take an active role in safeguarding your personal information by using strong, unique passwords and verifying the security of your connection.

If you suspect any misuse of your personal information or have concerns about its security, please don't hesitate to reach out to us immediately. Your privacy and security are our top priorities, and we are committed to addressing any issues promptly and effectively.

Unless specified otherwise, we retain the information we collect for as long as necessary to fulfill our Services (including risk management aspects), adhere to legal and regulatory obligations, resolve disputes, and enforce agreements. These records are preserved for a minimum of five (5) years after the conclusion of a business relationship. At our discretion, we reserve the right to adjust, revise, or remove any inaccurate or incomplete data.

This privacy policy is subject to updates at any time by Dіgіtal Осеаn s.r.o. at its discretion. The date of revision at the top of the page is modified accordingly. Furthermore, users may be notified through alternative means, such as a notice posted on the Site's homepage. To remain informed about the protection of personal information, we recommend users regularly review the policy for any changes. By using our Services, users accept the responsibility of periodically reviewing this privacy policy and staying informed about any amendments.

Cookies play a vital role in helping us understand your interactions with our website and other services. By utilizing this website or any of our other services, you may consent to the storage of small files containing unique identification tags made up of alphanumeric characters on your device. These cookies empower us to enhance our website and distinguish your browsing activity from that of other visitors, thereby enabling a more personalized online experience.

To signify your acceptance of our cookie usage on your device, kindly click the appropriate button on our website.

While most web browsers are typically set to accept cookies, you may have the option to adjust your browser settings to either reject all cookies or prompt your computer to notify you whenever a cookie is sent, granting you the choice to accept or decline it. Nonetheless, such modifications could potentially impact the functionality of the services provided by the Organizations based on your account preferences.

Last revised: September 20, 2024