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Privacy Policy

September 19, 2024

This Privacy Policy, together with our Terms of Use and its other essential parts, governs EXMO’s collection, processing and use of your Personal Data. As used in this Privacy Policy, “EXMO“, “we“, “us” or “our” refers to EXMO EXCHANGE LTD., a company duly incorporated and validly existing under the laws of England and Wales under registration number 11655602, having its registered office at 2 Kingdom Street, London, England, W2 6JP. EXMO is a data controller under this Privacy Policy, which sets out the manner in which a company, as a data controller, may use your Personal Data.

EXMO has been registered and regulated as a data controller with the Information Commissioner’s Office (ICO) under the registration number ZA549767. For more information, please follow the link at the ICO website.

EXMO and its Affiliates undertake to take maximum efforts in order to protect your privacy. EXMO uses the collected information about you to fulfill its contractual obligations and improve customer service.

Please read this document carefully in order to understand our approach and policy regarding your Personal Data and how we will use your Personal Data.

This Privacy Policy should be read in conjunction with our Cookie Policy.

1. WHAT DATA WE COLLECT ABOUT YOU

We may collect your Personal Data directly or indirectly through various means, including the following:

Information you give to us

You can provide us with information about yourself by filling in the relevant forms on the Website or by providing us such information by phone, email, during a video conference or in any other manner. This information includes Personal Data which was specified when registering on the Website, when subscribing to our Service, opening an Account and verifying the identity of the Account holder or persons authorized to use it, as well as the payment instruments used by a person, when searching for a product, using any of Services provided by our Website, while placing Orders on our Website, by participating in discussions in Chat or using any other communication functions on our Website, during participation in draws, promotions or surveys, and also when you tell us about problems or issues in the work of the Website.

The information that you give us include:

last name and first name;
residential address and citizenship;
nationality;
contact details including your e-mail address and telephone number(s);
date and place of birth;
gender;
education;
work experience and place of work;
passport or another government-issued identity document;
photos and videos that you may send to us for verification purposes;
tax residence;
results of Politically Exposed Person (PEP) checks, including information collected by our suppliers;
documents establishing your sources of funds and amount of income and/or Deposits;
bank details, including account numbers and payment details, and FATCA/CRS information;
login information for accessing EXMO Platform including your nickname and password;
information on the status of your accounts opened with banks and/or payment systems;
inquiries with EXMO support;
location and log data information that is generated by your use of EXMO Platform;
other personal information that may be required by our AML/CTF and KYC Policy compliance obligations.

Information we collect about you

With regard to each of your visits to our Website and use of our Services we can collect, for example, the following information about you (including automatic collection):

technical information, including the internet protocol (IP) address used to connect your computer to the internet, your Account login information, your browser type and its version, time zone setting, browser plug-in types and versions, operating system and platform, device information such as operating system, unique device identifiers, the mobile network system;
information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); products and Services you viewed or searched for; 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 and any phone number used to call our customer service number;
information about geo-location: we may collect information about real-time location based on information from your device at any time while you download or use our services; we may use this information to optimize your experience;
financial data and information on the use of Services and facilities provided by our Website, including information on implemented transactions and parties thereto, including on transactions, information on the status of Accounts and cash flow on them, accrued commissions, information on Account Deposits and Withdrawal of Funds from Accounts opened on our Platform;
information about the digital device through which you access our Services, such as device type, operating system, screen resolution, unique device identifiers, the mobile network system.

EXMO employs a unique, non-personally identifiable user identifier for each user.

This identifier contains no personal information that could be used by third parties to determine a user’s identity. Is used for tracking user activity, improving services, and internal analytics.

Information we receive from other sources

We may receive information about you if you use any of the other Websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, due diligence providers, credit reference agencies) and may receive information about you from them. Such information may include:

information about financial institutions you employ to perform Deposits and/or Withdrawal of Funds;
credit agencies’ confirmation of information that you have provided to us;
information about your financial standing, name and/or address that may be provided to us by third parties we collaborate with.

Your Personal Data, such as your email and nickname, that you provide to us during the registration at the EXMO Platform is stored by us, regardless of whether your registration process is finished or not. The same is applied to your Personal Data during an unfinished AML/CTF and KYC Policy verification process.

EXMO does not collect nor process sensitive personal Users’ data, such as race or ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships, genetic or biometric data, health, sex life or sexual orientation information. However, we caution you that in case you disclose any information in the public Chat on our Website, it can be collected by persons or companies EXMO has no control over.

EXMO does not collect or store any information about persons under 18. Minors and children should not use our Website and Services. By using our Website and Services, you represent that you have the legal capacity to enter into User Agreement with EXMO.

2. USE OF COOKIE FILES

Please, read our Cookie Policy for information about the use of cookies and in order to manage your consent to such use.

3. WHY WE USE YOUR PERSONAL DATA

We are going to use your Personal Data for the following purposes:

Provision of our Services

to fulfill the obligations under contracts signed with you, as well as to provide you with the information, products and Services that you requested;
to ensure the security of our Website, our Services, and your Account;
for administration of our Website and for internal operations, including troubleshooting, data analysis, testing, statistical data collection and for conducting surveys;
to give you access to the interactive features of the Website in case you wish to use them;
to support, respond and resolve your complaints and issues related to the use of our Services and the capabilities of our Website.

Informing you about our products and Services

to notify you about other existing and/or new products and Services, similar to those products or Services that you already purchased or information that you searched for;
to notify you about changes related to our products and Services.

Helping us improve our products and Services

to improve our Website and to make sure that our content is most convenient for the operating system of your computer;
to evaluate and understand the effectiveness of promotional materials that we provide to you and other Users, as well as to provide you with the necessary advertising information;
to ensure the most effective presentation of the content of our Website to you and the use of it on your computer.

Safeguarding vested interests

for risk management;
for security and control of our IT systems, crime prevention;
for measuring the use of our Services and products for its further development;
for internal business and research purposes, i.e. communication with you regarding our products and Services;
for anonymized data analysis via web beacons and pixel tags to ensure our products and Services are relevant for the market we operate on.

Assuring legal procedures

to respond to law enforcement requests;
to initiate and/or respond to legal claims;
to investigate and/or settle disputes with you.

Complying with legal regulations

to verify and check the identity of Users who open and operate Accounts in order to prevent fraud and associated illegal activities;
to comply with legal requirements of our AML/CTF and KYC Policy as well as other relevant laws and regulations;
to notify our Users about changes to policies and terms of use of EXMO Platform.

4. DISCLOSURE OF YOUR PERSONAL DATA

We may share your personal information within EXMO Group, which includes our subsidiaries, affiliates, our ultimate holding company and its subsidiaries.

We may share your information with selected third parties including:

business partners, suppliers, subcontractors, service providers performing relevant credit and due diligence checks to fulfill contractual obligations we enter into with them or you;
marketing networks that require certain data to select and promote relevant adverts; we do not disclose sensitive information about our clients to marketing companies, but we may provide them with aggregate information about our Users (for example, we may inform them that 500 females aged under 30 have clicked on their advertisement on any given day);
we may also use such aggregated information to help marketing companies reach the kind of audience they want to target (for example, women, living in a particular region); we may make use of the Personal Data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to a specific target audience;
analytics and search engine providers that assist us in the improvement and optimization of our Website.

We may also disclose your Personal Data to third parties in the following cases:

if we sell or buy any business or assets; Personal Data of Users may be disclosed to a potential buyer or seller;
if EXMO or all of its assets are purchased by a third party, Personal Data of Users will be transferred as one of the assets’ form;
if we are required to disclose or transfer Personal Data of the User in accordance with any applicable laws or within the implementation of decisions of the relevant courts, requests of judicial and law enforcement authorities or we are compelled to force Users to comply with the terms and conditions of the agreements signed with us;
in case it is necessary to protect our rights, property or to guarantee the safety of EXMO, our Users or others; this includes the exchange of information with relevant organizations to prevent fraud and reduce the likelihood of default.

5. SECURITY AND STORAGE OF PERSONAL DATA

We have implemented security measures to ensure the confidentiality of your Personal Data and to protect it from loss, misuse, alteration or destruction. Only authorized personnel of EXMO have access to your Personal Data, and this personnel is required to treat the information as confidential. Security measures in place will, from time to time, be reviewed in line with legal and technical developments.

The information we receive from you can be transferred and stored outside the European Economic Area (“EEA“) for the purposes of providing you with our Services. The information about you can be processed by our employees or employees of service providers outside the EEA. When storing or otherwise processing your Personal Data by such third parties outside the EEA, we guarantee that we will notify such third parties of our obligations under this Privacy Policy and will enter with them into relations that will impose obligations for them regarding your Personal Data, provided that they have the relevant level of security as specified in this Privacy Policy. Such employees, among other things, can process your requests, payment details and provide technical support. By giving us your Personal Data, you consent to the transfer, storage and processing of your Personal Data. We, in turn, will take all necessary measures to ensure that your Personal Data is processed in compliance with international security standards and in accordance with the provisions of this Privacy Policy.

Whilst the transmission of information via the internet is not completely secure, we will endeavor to protect your Personal Data. With this in mind, we cannot, however, guarantee the security of the channels you will use to transfer your personal information to our Website. In this regard, you are solely responsible for possible failures in the transfer of your Personal Data to the Website. Once we have received your Personal Data, we will use strict procedures and all necessary technical and security measures to prevent unauthorized access to your Personal Data.

6. BASIS FOR PERSONAL DATA PROCESSING

We collect and process your Personal Data only when we have a legitimate reason for such processing. Legal grounds may include:

your consent;
an agreement, where processing is necessary to fulfill the terms and conditions of the agreement between you and EXMO;
compliance with legal obligations, where EXMO is required to request/receive and process, as well as store your Personal Data in order to comply with the requirements of applicable laws, for example, the laws related to anti-money laundering and counter-terrorist financing;
to use legitimate interest, for example, when processing is necessary to protect you or us from certain threats, such as fraud, security threats, etc.;
to comply with the provisions of applicable laws, in order to conduct our business (the quality of the services provided, identification of needs, preparation of reports) in line with regulatory requirements;
execution of corporate transactions (sale of participant interests/shares, mergers, acquisitions), etc.

In cases where the basis for Personal Data processing is your consent, you have the right to withdraw it at any time.

7. YOUR RIGHTS

You have certain rights with respect to your Personal Data, including those set forth below:

right to be informed – you have the right to be informed about the collection and use of your Personal Data;
right to access – you have the right to obtain from us confirmation as to whether or not Personal Data concerning you are being processed, and, where that is the case, access to the Personal Data which you have provided to EXMO in a machine-readable format;
right to rectification – you have the right to obtain from us the rectification of inaccurate Personal Data concerning you, as well as the right to have incomplete Personal Data completed;
right to erasure – you have the right to ask for the deletion of your Personal Data if the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed or if there is no other legal ground for the processing (all or part thereof, considering, however, our regulatory requirements to retain your Personal Data as set forth in Clause 9 of this Privacy Policy);
right to restriction of processing – you have the right to obtain from us the restriction of further processing of your Personal Data, circumstances where you have a legal basis to do so. Where processing has been restricted such Personal Data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person;
right to data portability – you have the right to receive your Personal Data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller where technically feasible;
right to object – you have the right to object, on grounds relating to your particular situation, at any time to processing of your Personal Data if there are no legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims;
right not to be subject to automated decision-making, including profiling – you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you, where such decision is not necessary for entering into, or performance of, the agreement between you and EXMO; or where such decision is not authorized by law to which the EXMO is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or where such decision is not based on your explicit consent.

In addition, you have the right to prohibit the use of your Data for marketing purposes. Before requesting your Data, we usually request your consent to disclose it to third parties for marketing purposes. You can use the right to prohibit the processing of your Data for marketing purposes by putting a tick in the relevant field in the questionnaire. You can also exercise this right by contacting us at any time.

Please note that the implementation of some of your rights, depending on the situation, may limit, complicate or completely exclude the possibility of further cooperation with us.

Our Website may contain active links from/to the websites of our partners, advertisers and Affiliated companies. If you are following an active link, please note that other websites have their own privacy policies, and we are not responsible for the provisions of these policies. Please review the privacy policies of these websites before sharing your Personal Data with them.

8. ACCESS TO PERSONAL DATA

The Data Protection Act 2018 gives you the right to access the information we hold on you. Your right of access can be exercised in accordance with the Data Protection Act 2018, and subject to your written request, sent to the email [email protected], we will provide you with the data we hold about you. In case your request will be manifestly unfounded or excessive or you will request further copies of your Personal Data following your initial request, we may charge you a fee of £10 (ten pounds).

9. RETENTION OF PERSONAL DATA

Making sure your Personal Data is safe and secured is of the highest priority to us. We use secure storage facilities ensuring the safeguard of your Personal Data you share with us at all stages of interaction with our Platform using our products and Services. All appropriate measures to secure your Personal Data from potential hacking attacks, loss or misuse are implemented by our security team.

We will hold your Personal Data only for the duration of you using our products and Services via your Account, having regard to the purposes described in this Privacy Policy as well as legal and regulatory obligations that we comply with. In accordance with our record keeping obligations, we will retain your Account information and your Personal Data for at least a period of 5 (five) years from the moment you cease to carry on the use of our Services or the moment your customer relationship with us ends. unless otherwise required for legal or regulatory reasons.

We may access your Personal Data or retain it for a longer period if it will be subject to an official request or legal obligation, an investigation by governmental bodies or investigation into possible violations of our User Agreement and its essential parts, or in other cases to prevent possible harm based on our reasonable considerations.

If you will cancel your subscription to our email newsletter, we will hold your email on an inactive email list.

10. CHANGES TO THIS PRIVACY POLICY

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, a notification will be sent to you by email. We encourage you to check this page frequently to be aware of any updates or changes to the Privacy Policy.

11. CONTACT

In accordance with the Data Protection Act 2018 and ePrivacy Directive 2009/136/EC, in case you will have any questions, complaints or concerns regarding our Privacy Policy, Cookie Policy or the way or purpose for which we handle your Personal Data — you can contact us. For that purpose, please contact our Data Protection Officer via email [email protected] or phone +44 7440 961453, who will try to assist you promptly.

You can also reach us by postal mail at 2 Kingdom Street, London, England, W2 6JP.

If you are a resident of the EEA you can reach out to the lead supervisory authority for EXMO, which is Information Commissioner’s Office (UK). Alternatively, you reach out to your National Data Protection Authority if you are resident of the EEA. Residents of other jurisdictions may contact their national data protection authority.