PRIVACY AND DATA RETENTION POLICY

1.1. The Personal Information on the Website is collected, controlled and processed by the Interchange Technology Limited, a legal entity with registration address in ‘Kyle’ Apartment 4, Room 2, Triq il- Mediterran, St. Julians. Malta, contact e-mail: [email protected].

2.1. While providing our services, we may collect Personal Information, namely:

2.1(a) An information necessary for registration. In order to access the full functionality of the Website, you need to register. When you go through the registration process, you shall provide an e-mail address and create a password. You may also choose to log in via supported third-party service provider (for example, Twitter, Facebook and Google+). You can also choose to add a Google Authenticator account to be used for 2FA verification for improved security.

2.1(b) Financial Information. For all personal user accounts, we collect financial information including transaction history, storing information.

2.1(c) An information, which we may collect through automated means. Through your use of Interchange and its exchange tools, we also monitor and collect tracking information related to usage such as access date & time, device identification, operating system, browser type and IP address. This information may be directly obtained by Interchange or through third party services.

2.1(d) We reserve the right to require verification data for the purpose of AML/KYC procedure, including without limitation photographs of national identity documents, like passport, driving license ID card, and identification data from these documents, utility bill details for residence verification.

2.1(e) For the purpose of AML/KYC procedure we may require details to and proof of funds: i.e. banking statements or any other details provided by banks or financial institutions, contracts of sales or contracts in general, or any other suitable data to prove or determine the origin of funds. In order to determine User's purpose for using the services of the Interchange, additional information on recent, past or planned business or personal activities of business or private User or other data to determine the User's intentions, if necessary, can be processed, as requested by Interchange or provided by the User.

2.2. We do not collect any information that may identify You without your permission. However, We use Google Analytics on Our Technology Platform. If You want to know more about Google Analytics and its “do not track” policy, please visit https://www.google.com/analytics/terms/us.html

3.1. We do not intend to solicit or collect Personal Information from anyone under the age of 16 or under the legal age of your country, if it is higher. If you are under 16 or are not of a legal age of your country, do not enter any personal information on our Website.

4.1. We and our representatives store and use Personal Information only for providing and improving the Website. In particular, we use users' Personal Information for the following purposes:

4.1(a) To maintain our Website. We use Personal Information to ensure that our services function properly;

4.1(b) To improve our Website and services. Personal Information helps our systems ensure that our interface is accessible for users across all platforms;

4.1(c) To comply with our legal obligations. In many jurisdictions we are obliged to collect certain information about our users to be authorized to act (Know Your Client and Anti-Money Laundering regulations). We obliged to obtain Personal Information in order to be able to aid during criminal investigations;

4.1(d) To protect your assets: We may use information to identify you and the assets belonging to you in order to secure access to your accounts and to prevent the fraud. Information about your transaction allows us to monitor suspicious activity and protect you from fraud and scam activity;

4.1(e) To send periodic e-mails: We may use the information we collect from you when you register or use certain other site features. This might be for security reasons, to ask your opinion about the website, or it may be to keep you updated on any changes to the services provided on the Website. We may also send periodic emails with news and Website updates, or use this information to follow up with you following live chat or email;

4.1(f) To resolve disputes and enforce our agreements to the extent necessary and sufficient for protecting your interests or interests of other Users.

5.1. In certain situations, We may be required to disclose Personal Information in response to lawful requests by competent authorities, including to meet national security, public interests or law enforcement requirements.

5.2. We may disclose your Personal Information where required by law (e.g., to comply with a subpoena, warrant, court order, or legal process served on Interchange), and when we believe that disclosure is necessary to protect our rights, avoid litigation, protect your safety or the safety of others, investigate fraud, and/or respond to a government request.

5.3. We share Personal Information with certain companies that perform services on our behalf on a need-to-know basis. We require any company with which we may share Personal Information to protect that data in a manner consistent with this policy and to limit the use of such Personal Information to the performance of services for Interchange.

5.4. You agree that We may share and transfer Your information which no longer identifies You to the third party (pseudonymisation) who is a contracting party with Us, usually Our service providers or advertising partners.

6.1. We will retain your information only for as long as is necessary for the purposes set out in this policy. We will retain your information just to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

7.1. Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from the Website and stored on your computer's hard drive.

7.2. We use cookies to recognise your browser or device, learn more about your interests, and provide you with essential features and services and for additional purposes, including:

7.2(a) Recognising you when you sign-in to use our services.

7.2(b) Keeping track of your specified wallet addresses for improving user experience.

7.2(c) Keeping track of transaction initiating process

7.2(d) Preventing fraudulent activity.

7.2(e) Improving security.

7.2(f) Reporting. This allows us to measure and analyze the performance of our services.

7.3. You can manage browser cookies through your browser settings. The "Help" feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable cookies, and when cookies will expire. If you disable all cookies on your browser, neither we nor third parties will transfer cookies to your browser. If you do this, however, you may have to manually adjust some preferences every time you visit a Website and some features and services may not work.

8.1. Interchange aims to protect your information as much as we aim to protect our own information and network. We will not permit any third parties to contact you directly on an unsolicited basis in relation to their own products or services. We do not sell, trade, or rent your personal identification information to others. You should never disclose your account password to unauthorized parties.

8.2. We use certain security measures to help keep your personal information safe, but we cannot guarantee that these measures will stop any users try to get around the privacy or security settings on the Website through unforeseen and/or illegal activity. That is why we make no warranty, express, implied or otherwise, that we will prevent such access.

9.1. In accordance with effective regulations You have a significant number of rights related to your Personal Information, such as e.g.:

9.1(a) The right to access and amend the personal information we hold about you. You have a right to request a copy of the personal information we hold about you. Also you have the right to correct or update your Personal Information at any time.

9.1(b) The right to delete your Personal Information. In accordance with the "Right to be forgotten", we leave the opportunity to erase User’s account in any time. If you do not want to use Interchange or want your data to be erased, you can request us to remove your account permanently. In this case, Interchange will cancel your account and delete your personal data subject to erasure.

9.1(c) The right to restrict processing. You have the right to ask us to restrict the processing of your personal information. When processing is restricted, we can still store your information, but will not use it further.

9.1(d) The right to object to the processing of your data. You have a right to object to our use of your personal information for our own purpose at any time. In other words you can withdraw your consent to processing your personal information by us. In case you want to exercise this right, you may contact us. This right also includes the right to object to processing your personal information for marketing and advertising purposes. You can do it by clicking on the special button (an unsubscribe button) or by contact us and opting out from receiving all e-mails.

9.1(e) The right to data portability. You have the right to receive personal information you provide to us, in a "commonly used machine-readable format". This allows you to obtain and reuse your information for your own purposes across different services.

9.1(f) The right to lodge a complaint with a Supervisory Authority. We take privacy concerns seriously. If you believe that we have not complied with this Privacy Policy with respect to your Personal Information, you may contact our respective Data Protection Office. We will investigate your complaint promptly and will reply you within 30 (thirty) calendar days. If you do not receive acknowledgment of your complaint or your complaint is not satisfactorily addressed, you have the right to lodge a complaint with the respective supervisory authority.

9.2. In case you want to exercise your rights, please contact us.

9.3. There are exceptions to these rights, however. For example, access to personal information may be denied in some circumstances if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information. In addition, where some of the data is necessary to maintain Interchange or where that is a legal requirement, we may retain such data for the period it is needed or required even if you withdraw your consent or cancel your account. Such information will not be considered as subject to erasure.

10.1. Notwithstanding anything to the contrary in this Policy, we may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our or our users’ rights or property. However, nothing in this Policy is intended to limit any legal defences or objections that you may have to a government’s request for disclosure of your information.

11.1. By checking the respective box as a part of the registration process, the User confirms to have read the Privacy Policy and agrees to the data processing as described herein.

11.2. The User has the right to withdraw his consents at any time via mail to Interchange Technology Limited at ‘Kyle’ Apartment 4, Room 2, Triq il- Mediterran, St. Julians. Malta, or via E-Mail to [email protected]. The withdrawal of his consent does not affect the lawfulness of processing based on consent before its withdrawal.

12.1. This Policy may be amended at our full discretion without prior notice. We encourage you to review it periodically in order to be aware of the changes we may have made. Reading it carefully and checking for any modifications is your responsibility. By using the Website, you accept and agree to the Policy and the Terms of Use.