Privacy Policy
This Privacy Notice applies to the processing activities performed
by FiatXchange to the personal information of its clients
and its potential clients and website visitors. We may amend this
Privacy Notice at any time by posting the amended version on this
site including the effective date of the amended version. We will
announce any material changes to this Privacy Notice on our
website.
Your Data Controller
We are your Data Controller, and are responsible for the
collection, use, disclosure, retention and protection of your
personal information in accordance with our global privacy
standards, this Privacy Notice, as well as any applicable national
laws. The Company uses encryption to protect your information and
store decryption keys in separate systems.
How do we protect personal information?
We respect the privacy of any users who access our website and are
therefore committed to taking all reasonable steps to safeguard
any existing or prospective clients, applicants and website
visitors. We keep any personal data of its clients and its
potential clients in accordance with the applicable privacy and
data protection laws and regulations
We have the necessary and appropriate technical and organisational
measures and procedures in place to ensure that your information
remains secure at all times. We regularly train and raise
awareness for all our employees to the importance of maintaining,
safeguarding and respecting your personal information and privacy.
We regard breaches of individuals’ privacy very seriously and will
impose appropriate disciplinary measures, including dismissal from
employment. We have also appointed a Group Data Protection
Officer, to ensure that our Company manages and processes your
personal information in compliance with the applicable privacy and
data protection laws and regulations, and in accordance with this
Privacy Notice.
Information we may collect about you
In order to open an account with us, you must first complete and
submit a “create account” form to us by completing the required
information. By completing this form, you are requested to
disclose personal information in order to enable the Company to
assess your application and comply with the relevant laws
(including their regulations).
The information that we collect from you is as follows:
-
Full name, residential address and contact details (e.g. email
address, telephone number, fax etc.)
- Date of birth, place of birth, gender, citizenship
-
Bank account information, credit card details, including details
about your source of funds, assets and liabilities, and OFAC
information;
-
Trading account balances, trading activity, your inquiries and
our responses;
-
Information on whether you hold a prominent public function
(PEP)
-
Verification information, which includes information necessary
to verify your identity such as a passport, driver’s licence or
Government-issued identity card
Information we collect about you automatically.
-
Browser Information – Information that is automatically
collected via analytics systems providers from your browser,
including your IP address and/or domain name and any external
page that referred you to us, your login information, browser
type and version, time zone setting, browser plug-in types and
versions, operating system, and platform;
-
Log Information – Information that is generated by your use of
FiatXchange Exchange Services that is automatically
collected and stored in our server logs. This may include, but
is not limited to, device-specific information, location
information, system activity and any internal and external
information related to pages that you visit, including the full
Uniform Resource Locators (URL) clickstream to, through and from
our Website or App including date and time; page response times,
download errors, length of visits to certain pages, page
interaction information (such as scrolling, clicks, and
mouse-overs), and methods used to browse away from the page
Information we receive about you from other sources.
We obtain information about you in a number of ways through your
use of our services, including through any of our websites, the
account opening process, webinar sign-up forms, event subscribing,
news and updates subscribing, and from information provided in the
course of on-going support service communications. We also receive
information about you from third parties such as your payment
providers and through publicly available sources. For example:
-
The banks you use to transfer money to us will provide us with
your basic personal information, such as your name and address,
as well as your financial information such as your bank account
details;
-
Your business partners may provide us with your name and
address, as well as financial information;
-
Advertising networks, analytics providers and search information
providers may provide us with anonymized or de-identified
information about you, such as confirming how you found our
website;
-
Credit reference agencies do not provide us with any personal
information about you, but may be used to corroborate the
information you have provided to us
Lawful basis for processing your personal information
We will process your personal information on the following bases
and for the following purposes:
Performance of a contract
We process personal data in order to provide our services and
products, as well as information regarding our products and
services based on the contractual relationship with our clients
(i.e. so as to perform our contractual obligations). In addition,
the processing of personal data takes place to enable the
completion of our client on-boarding process.
In view of the above, we must verify your identity in order to
accept you as our client and we will use your personal data in
order to effectively manage your trading account with us. This may
include third parties carrying out credit or identity checks on
our behalf. The use of your personal information is necessary for
us to know who you are, as we have a legal obligation to comply
with “Know Your Customer” and customer due diligence regulatory
obligations.
Compliance with a legal obligation
There are a number of legal obligations imposed by relevant laws
to which we are subject, as well as specific statutory
requirements e.g. anti-money laundering laws, financial services
laws, corporation laws, privacy laws and tax laws. There are also
various supervisory authorities whose laws and regulations apply
to us. Such obligations and requirements imposed on us necessary
personal data processing activities for identity verification,
payment processing, compliance with court orders, tax laws or
other reporting obligations and anti-money laundering controls.
These obligations apply at various times, including client
on-boarding, payments and systemic checks for risk management.
For the purpose of safeguarding legitimate interests
We process personal data so as to safeguard the legitimate
interests pursued by us or by a third party. A legitimate interest
is when we have a business or commercial reason to use your
information. Example of such processing activities include the
following:
-
Initiating legal claims and preparing our defense in litigation
procedures;
-
Means and processes we undertake to provide for the Company’s IT
and system security, preventing potential crime, asset security
and access controls;
-
Measures for managing the business and for further developing
products and services;
To provide you with products and services, or information about
our products and services, and to review your ongoing needs.
Once you successfully open an account with us, or subscribe to
information, we must use your personal information to perform our
services and comply with our obligations to you. It is also in our
legitimate interests to try to ensure that we are providing the
best products and services so we may periodically review your
needs based on our assessment of your personal information to
ensure that you are getting the benefit of the best possible
products and services from us.
To help us improve our products and services, including support
services, and develop and market new products and services.
We may, from time-to-time, use personal information provided by
you through your use of the services and/or through client surveys
to help us improve our products and services. It is in our
legitimate interests to use your personal information in this way
to try to ensure the highest standards when providing you with our
products and services and to continue to be a market leader within
the cryptocurrency financial service industry.
To investigate or settle enquiries or disputes
We may need to use personal information collected from you to
investigate issues or to settle disputes with you because it is
our legitimate interest to ensure that issues and disputes get
investigated and resolved in a timely and efficient manner.
To comply with applicable laws, subpoenas, court orders, other
judicial process, or the requirements of any applicable regulatory
authorities
We may need to use your personal information to comply with any
applicable laws and regulations, subpoenas, court orders or other
judicial processes, or requirements of any applicable regulatory
authority. We do this not only to comply with our legal
obligations but because it may also be in our legitimate interest
to do so.
Legal Notifications
Often the law requires us to advise you of certain changes to
products or services or laws. We may need to inform you of changes
to the terms or the features of our products or services. We need
to process your personal information to send you these legal
notifications. You will continue to receive this information from
us even if you choose not to receive direct marketing information
from us.
Disclosure of your personal information
The Company will not disclose any of its clients’ confidential
information to a third party, except: (a) to the extent that it is
required to do so pursuant to any applicable laws, rules or
regulations; (b) if there is a duty to disclose; (c) if our
legitimate business interests require disclosure; (d) in line with
our Terms of Service; (e) at your request or with your consent or
to those described in this Privacy Notice. The Company will
endeavour to make such disclosures on a “need-to-know” basis,
unless otherwise instructed by a regulatory authority. Under such
circumstances, the Company will notify the third party regarding
the confidential nature of any such information.
As part of using your personal information for the purposes set
out above, the Company may disclose your personal information to
the following:
-
Any members of the Company, which means that any of our
affiliates and subsidiaries may receive such information;
-
Any of our service providers and business partners, for business
purposes, such as specialist advisors who have been contracted
to provide us with administrative, financial, legal, tax,
compliance, insurance, IT, debt-recovery, analytics, research or
other services;
If the Company discloses your personal information to service
providers and business partners, in order to perform the services
requested by clients, such providers and partners may store your
personal information within their own systems in order to comply
with their legal and other obligations.
We require that service providers and business partners who
process personal information to acknowledge the confidentiality of
this information, undertake to respect any client’s right to
privacy and comply with all relevant privacy and data protection
laws and this Privacy Notice.
Privacy when using digital assets
Your funding of bitcoin, XRP, ether, and other Digital Assets, may
be recorded on a public blockchain. Public blockchains are
distributed ledgers, intended to immutably record transactions
across wide networks of computer systems. Many blockchains are
open to forensic analysis which can lead to deanonymization and
the unintentional revelation of private financial information,
especially when blockchain data is combined with other data.
Cookies
When you use our products and services, we may make use of the
standard practice of placing tiny data files called cookies, flash
cookies, pixel tags, or other tracking tools (herein, “Cookies”)
on your computer or other devices used when engaging with us. We
use Cookies to (i) help us recognize you as a customer, collect
information about your use of our products and services, to better
customize our services and content for you, and to collect
information about your computer or other access devices to ensure
our compliance with our BSA and AML obligations. Because
blockchains are decentralized or third-party networks which are
not controlled or operated by Payward or its affiliates, we are
not able to erase, modify, or alter personal data from such
networks.
Your rights regarding your personal information
The rights that are available to you in relation to the personal
information we hold about you are outlined below
Information Access
If you ask us, we will confirm whether we are processing your
personal information and, if so, what information we process and,
if requested, provide you with a copy of that information within
30 days from the date of your request.
Rectification
It is important to us that your personal information is up to
date. We will take all reasonable steps to make sure that your
personal information remains accurate, complete and up-to-date. If
the personal information we hold about you is inaccurate or
incomplete, you are entitled to have it rectified. If we have
disclosed your personal information to others, we will let them
know about the rectification where possible. If you ask us, if
possible and lawful to do so, we will also inform you with whom we
have shared your personal information so that you can contact them
directly.
You may inform us at any time that your personal details have
changed by emailing us at support@fiatxchange.io. The Company
will change your personal information in accordance with your
instructions. To proceed with such requests, in some cases we may
need supporting documents from you as proof i.e. personal
information that we are required to keep for regulatory or other
legal purposes
Changes to this Privacy Notice
Our Privacy Notice is reviewed regularly to ensure that any new
obligations and technologies, as well as any changes to our
business operations and practices are taken into consideration, as
well as that it remains abreast of the changing regulatory
environment. Any personal information we hold will be governed by
our most recent Privacy Notice. If we decide to change our Privacy
Notice, we will post those changes to this Privacy Notice and
other places we deem appropriate.
Contact Information
Any questions, complaints, comments and requests regarding this
Privacy Notice are welcome and should be addressed to
support@fiatxchange.io. If you are not satisfied with our
response to your complaint, you have the right to submit a
complaint with our regulator. You can contact the appropriate
regulator direct from the details below:
Office No. 803, Level 8, Innovation One DIFC, Dubai, United Arab
Emirates
