Date of Last Revision: 17.03.2020
This Privacy Policy applies to the Site and all products and services offered by Vesvis OÜ
We would like to inform you about the management of your personal data in accordance with Art. 13 General Data Protection Regulation (GDPR).
This Privacy Policy regulates the order in which Vesvis OÜ and / or its affiliates (including aexchanger.com collects, uses, maintains and discloses information collected from users of the aexchanger.com website (“Site”), aexchanger.com mobile app (“App”) and other products (hereinafter collectively referred to as the “Services”).
Vesvis OÜ is a company registered in Estonia with the registry code 14771190.
Our address Harju maakond, Tallinn, Lasnamäe linnaosa, Majaka tn 26, 11412
Vesvis OÜ operates under 2 financial licenses:
Operating license: Financial services, “Providing services of exchanging a virtual currency against a fiat currency”. Number FVR001165 issued on 24.10.2019.
Operating license: Financial services, “Providing a virtual currency wallet service”. Number FRK001052 issued on 24.10.2019.
This Privacy Policy applies to the Site, App, all products and Services offered by us.
The purpose of this Privacy Policy is to explain how we collect and use personal information.
We may update our Privacy Policy from time to time. When we do, we will post a notification on the main page of our Site.
Please read the following carefully to understand what data we collect, how that data is used and the ways it can be shared by us. If you do not wish for your Personal Information to be used in the ways described within this Privacy Policy, then you should not access or use the Site or use any of the services.
If we, or a fraud prevention agency, determine that you pose a fraud, money laundering or other criminal risks, we may refuse to provide the services you have requested, or we may stop providing existing services to you.
CONTROLLER
The controller responsible for the described data collection and processing is the Vesvis OÜ (Harju maakond, Tallinn, Estonia Lasnamäe linnaosa, Majaka tn 26, 11412)
1. The information we collect
1.1. Personal identification information
The personal identification information is collected from users only if they voluntarily submit such information to us. Users may refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities.
We collect and process various categories of personal information at the start of, and for the duration of, your relationship with us.
Users will be asked to provide the following data:
name; email address (must be provided during the process of registration on the website, e-mail address will be also used to Login).
the details of the identification document (ID) or a passport (due to the KYC policy identification document will be collected during the verification process).
When client uses aexchanger.com to send crypto funds to someone else, he will have to provide information related to that transaction, namely the address of the digital wallet of the recipient.
How we collect personal info?
We may collect personal identification information from users in a variety of ways: when users visit our Site, register on the Site, fill out a form, and in connection with services available on our Site. When you communicate with us for customer service or other purposes (e.g. by emails, chat etc.), or provide any feedback, we keep such information and our responses to you in the records of your account.
1.2. Identification information
We require identification information about users whenever they interact with our Site. Identification information includes the browser name and version, the type of computer and technical information, including the Internet protocol (IP) address used to connect your computer or other device to the Internet, time zone setting, browser plug-in types and versions, operating system and platform. Information about your visit, including the dates and times you use the Site length of visits to certain pages, page interaction information.
How we collect identification information?
When you use our Services using any device we will additionally collect and store device sign-on data (including but not limited to device ID) and geolocation data in order to provide the aexchanger.com Services.
Special categories of data.
We do not save credit card details (number, expiration, CVV/CVC). We do not ask for gate-to-gate integration or iframe.
We do not collect any information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health and genetic and biometric data.
1.3. We process aforementioned information on the following legal basis and purposes: name; email address (to identify you as a client and distinguish you from other users of our Service; to let you register on our platform; to provide you with customer and technical support, to provide you with advertising materials, provided, however, that we receive prior consent from you to perform such activity); the details of identification document (ID) or a passport; document containing MRZ code (due to the KYC policy we have to conduct the verification process). Financial information, including your bank account and transactional information and history (we need to verify that bank account belongs to you; you have to add a bank account if you are going to make fiat transactions: add and withdraw);
When you use aexchanger.com to send crypto funds to someone else, you will have to provide information related to that transaction, namely the address of the digital wallet of the recipient.
We, upon receiving your consent, may provide you with promotional messages and other information about products, events and services of ours, our affiliates, and third parties such as sponsors and notices and other information related to the Service and your interests. By selecting the checkbox “I agree to subscribe to promotional messages and other information about products, events and services of ours, our affiliates and third parties such as sponsors, and notices and other information related to the Service and my interests”, you consent that we may send all such aforementioned materials and information to your email. You are in your right to cancel your consent by selecting the checkbox “Unsubscribe from the promotional materials” and, as a result, you will no longer receive such aforementioned materials to your email.
We collect mentioned information to comply with legal and regulatory requirements, to carry out Know-Your-Customer policy; to prevent fraud, money laundering or unauthorized use of your account.
2. Cookie Policy
2.1. Web browser cookies
Our Site may use “cookies” to enhance User experience. Cookies, pixel tags and similar technologies (collectively ‘cookies’) are files containing small amounts of information which are downloaded to any internet enabled device – such as your computer, smartphone or tablet – when you visit the website or use the App.
We use cookies and other technologies to facilitate your internet sessions and use of our App, offer you products and/or services according to your preferred settings, track use of our websites and Apps and to compile statistics about activities carried out on our websites. Users are free to decline our Cookies if your browser or browser add-on permits, unless our Cookies are required to prevent fraud or ensure the security of websites we control.
2.2. Different types of cookies
Session cookies are temporary cookies which only exist during the time you use the website (or sometimes, until you close the browser after using the website). Session cookies help our website remember what you chose on the previous page, avoiding the need to re-enter information and improve your experience whilst using the website.
Persistent cookies stay on your device after you’ve visited our website. Persistent cookies help us identify you as a unique visitor. The length of time a cookie stays on your device depends on its type.
The cookies on the Site may be from any of the following categories:
Necessary cookies – these are used for technical reasons and are necessary to enable the website to operate efficiently so that you can navigate the website with ease and use specific features.
Functionality cookies – these are used to improve the functionality of the website and make it easier to use. They help us to identify you as a repeat user of the website and help us remember your preferences (for example, your choice of language or region).
If you choose to disable or block our cookies on your computer or other device, you will need to do so in a pop-up window when you enter the website. If you block cookies, you may be unable to access certain areas of our website and certain functions and pages will not work in the usual way.
3. RECIPIENTS OF THE PERSONAL INFORMATION
Personal information may be shared with other recipients, such as:
– Authorities (such as law enforcement authorities, bailiffs, notary offices, tax authorities, supervision authorities and financial intelligence units);
– Auditors, legal and financial consultants, or any other processor authorized by the Vesvis OÜ;
– Third parties maintaining registers (such as governmental registers, population registers, commercial registers or other registers holding or intermediating Personal information);
– Debt collectors upon assignment of claims, courts, out-of-court dispute resolution body and bankruptcy or insolvency administrators);
– Rating agencies;
– Other persons who guarantee due discharge of the Client’s obligations to the Vesvis OÜ (such as sureties, guarantors, owners of collaterals);
– Participants and/or parties related to domestic, European and international payment systems, such as SEPA or SWIFT.
– Other credit institutions, financial institutions, payment card companies, financial services intermediaries;
– Other persons related to provision of services of the Vesvis OÜ such as providers of archiving, postal services, providers of services rendered to the Client.
As a general rule the Personal information is processed within the European Union/European Economic Area (EU/EEA) but in some cases transferred and processed to countries outside the EU/EEA.
Transfer and Processing of Personal information outside the EU/EEA can take place if a legal ground is provided, i.e. legal requirement conclusion or performance of an agreement or Client’s consent and appropriate safeguards are in place, such as:
– There is an agreement in place including the EU Standard Contractual Clauses or other approved clauses code of conducts, certifications etc., approved in accordance with the General Data Protection Regulation;
– The country outside of the EU/EEA where the recipient is located has adequate level of data protection as decided by the EU Commission;
– The recipient is individually certified.
Upon request the Client can receive further details on Personal information transfers to countries outside the EU/EEA.
4. DATA TRANSFER TO THIRD PARTIES AND STORAGE OF THE PERSONAL INFORMATION
We transfer your data to service providers who support us in the operation of our website and the associated processes. This transference is made under the scope of a data processing agreement in accordance to Art. 28 GDPR. Our service providers are bound to us by strict instructions and contractual obligations. In some cases, we may transfer personal data to third countries outside the EU. In each case, we ensure an appropriate level of data protection according to European standards. In the case of Google Analytics (USA), an appropriate level of data protection is ensured by the corresponding participation in the Privacy Shield Agreement (Art. 45 para. 1 GDPR).
The data that we collect from users may be transferred to, and stored at, a destination outside of the European Economic Area (“EEA”). It may be processed by a staff member operating outside the EEA who work for the Company or its contractors. By submitting your Personal information, you agree to this policy and every its provision. The company takes all the necessary steps to ensure that users data is treated securely and in accordance with this privacy policy.
Any leakage of the information occurred upon transmission of the information, which was caused by any error, third party actions or accident may not be subject of any suites or claims with regard to the Company.
5.Rights of users
You have the right to obtain confirmation whether or not personal data concerning you is being processed, and, where that is the case of access to the personal data and the information specified in Art. 15 GDPR.
The right to access above mentioned information may be exercised upon contacting with the company. Any access request may be subject to a fee to cover the costs in extracting and providing the requested data.
You also have the right to obtain an erasure of the personal data concerning you, if one of the reasons listed in Art. 17 GDPR applies. In certain situations, listed in Art. 20 GDPR, you have the right to data portability. If the data is processed pursuant to Art. 6 para. 1 point f GDPR (data processing for the purposes of the legitimate interests), you have the right to object to the processing at any time for reasons arising out of your particular situation. We will then no longer process personal data, unless there are demonstrably compelling legitimate grounds for processing, which override the interests, rights and freedoms of the person concerned, or the processing serves the purpose of asserting, exercising or defending legal claims.
You have the right to lodge a complaint with a supervisory authority.
6. Changes to the way we use your information
From time to time we may change the way we use your information. Where we believe you may not reasonably expect such a change we will notify you and will allow a period of at least 30 days for you to raise any objections before the change is made. However, please note that in some cases, if you do not agree to such changes it may not be possible for us to continue to operate your account and/or provide certain products and services to you through the aexchanger.com.
7. Amendments to this Privacy Policy
Vesvis OÜ has the discretion to update this privacy policy at any time. When we do, we will post a notification on the main page of our Site, revise the updated date at the top of this page. We encourage users to check this page with a regular frequency for any changes to stay informed on how we help to protect the personal information we collect. Each user must acknowledge and agree that it is his personal responsibility to review this Privacy Policy periodically and become aware of modifications.
By using this Site, the user automatically signifies his acceptance of this policy. If the user does not agree to this policy, we would require him not to use our Site. In case the user continues the use of the Site following the posting of amendments to this policy, it will be deemed his acceptance of those amendments.