Instaswap

Privacy Policy

This Privacy and Data Retention Policy (the Policy) explains the way in which instaswap.io operators collect, use, share, and protect Personal Information of Users (“you”) obtained through the instaswap.io (“Website“), any related applications and its exchange tools integrated into third-party services (“Services”). The terms “we,” “InstaSwap,” “us,” and “our” collectively refers to collectively refers to the company AltEx Fintech Ltd., duly organized under the laws of Seychelles with certificate number 215309.

“Personal Data” is an information that identifies or can be used to identify, contact, or locate the person to whom such information pertains.

At instaswap.io, we are fully committed to respecting privacy and to protecting any information that our clients provide. Your privacy and security are both our highest priorities and we make every effort to ensure that all the information provided by you is protected.

We follow and comply with best practices and regulation in the sphere of privacy including but not limited to General Data Protection Regulation (GDPR).

1.Data Controller

The Personal Information is collected, controlled and processed by the following entities:
AltEx Fintech Ltd, Global Gateway 8, Rue de la Perle, Providence, Mahe, Seychelles, Certificate No. 215309

2. Personal Data Which We May Collect

InstaSwap respects the privacy of its Users by not requesting any information that is unnecessary for the use of the service or to comport with our obligations under applicable law.

  • A data, which we may collect through automated means. Through your use of our Services, including 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 Us or through third party services .
  • Your email which is optional and is given with your consent
    1. Personal Data Collected when purchasing with FIAT

Personal Information collected for purchasing with FIAT are shared with Moon Pay Limited (“data processor”)which is a company, organised and existing under the laws of Malta, and having its principal place of business at Triq l-Uqija, Swieqi SWQ 2332.You can find their privacy policy at https://www.moonpay.io/privacy_policy/ . We may process personal information of Users in a variety of ways, including, but not limited to, when users visit our Site, or use any of our Services; register on the Service; fill out a form; provide information for passing of anti-money laundering procedures. We also may obtain information about you from third party sources as required or permitted by applicable law, such as public databases, credit bureaus, ID verification partners, resellers and channel partners, joint marketing partners, and social media platforms for purposes of verifying your identity. We obtain such information with a purpose and a legal basis to comply with our legal obligations, such as anti-money laundering laws. From time to time, we may process additional data about client to make sure our Service is not used fraudulently or for other illicit activities. In such instances, processing is necessary for us to continue to perform our contract with you and others, as well as on the basis of our legitimate interest to prevent fraud, money laundering and other illicit activities.

Categories of data involved in data processing include:

  • Personal Identification Information: Name, e-mail, date of birth, nationality, gender, utility bills, photographs, phone number, mailing address, ID or other documents number and other details;
  • Payment Information: Bank information, card information, transaction history;

Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Service-related activities. Thus, in some cases, we will be unable to render services to you if you do not provide us personal identification information due to the requirements of anti-money laundering laws and other legal acts.

We may ask you to supply additional documents or information where it is necessary for compliance with our legal obligations e.g. in the prevention of fraud, money laundering and counter-terrorism.

We will ask User’s consent before processing of aforementioned information in other purposes. When collecting such consents, we inform the Data Subject of the respective purposes of processing and such processing is conducted only when appropriate consent is received.

2.1.1 Information collected automatically

We may collect information about Users whenever they interact with our Service, for example, through the use of cookies. Such information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as IP-address, location, date and time of connection, the operating system and the Internet service providers utilised and other similar information.

We may process aforementioned information on the following legal basis and purposes:

where it is necessary to ensure the technical availability of our Service and thus to perform a contract with you for the provision of our Services;

where it is necessary for the purposes of our legitimate interests to prevent fraud, money laundering or unauthorized use of your account, as well as to analyze your account activity in order to be able to distinguish you from other users and provide you with an adequate and reliable service and to offer you the best possible options suitable for your needs.

We will ask User’s consent before processing of aforementioned information in other purposes. When collecting such consents, we inform the Data Subject of the respective purposes of processing and such processing is conducted only when appropriate consent is received.

3.Children Personal Data

We do not intend to solicit or collect Personal Data 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 on our Website. . If you are under the age of 18 do not use our exchange platform or share personal data such as your email.

4.What We Do With Your Personal Data

  • To maintain our Website and Services. We use Personal Data to ensure that our services function properly
  • To improve our Website and Services. Personal Data helps our systems ensure that our interface is accessible for Users across all platforms
  • 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
  • To send periodic e-mails. We may use the information we collect from you. 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 and our Services. We may also send periodic emails with news and Services updates, or use this information to follow up with you following live chat or email
  • To resolve disputes and enforce our agreements to the extent necessary and sufficient for protecting your interests or interests of other users

5.Lawful Basis For Processing Data

The lawful bases for processing are set out in Article 6 of the GDPR

Personal Data

Lawful Basis

Email (Transaction Optional*)

Consent (Art.6 a)

Contact Forms

Consent (Art.6 a)

I.P.

Legitimate Interest (Art.6 f)

5.1 Lawful Basis for processing data when purchasing crypto with FIAT:

  • where it is necessary to perform a contract with you for the provision of our Services or to enter into a contract with you for the provision of our Services;
  • where it is necessary for compliance with our legal obligation across jurisdictions in regard to provision of financial services, as stipulated by accounting, taxation and other laws and to prevent criminal activity, fraud and money laundering;
  • where it is necessary for the purposes of our legitimate interests to prevent fraud, money laundering or unauthorized use of your account, as well as to analyze your account activity in order to be able to provide you with an adequate and reliable service and to offer you the best possible options suitable for your needs;
  • where we have received your explicit consent as required by applicable law.

and with the following purposes:

  • to identify you as a client and distinguish you from other users of our Service;
  • to be able to continuously provide you with functional, secure, efficient, and customized service;
  • to operate and develop our Service, to content and advertising, and for loss prevention and anti-fraud purposes;
  • to respond to you about any comment or enquiry you have submitted;
  • to comply with legal and regulatory requirements, including to carry out Know-Your-Customer (KYC) and other checks;
  • to provide you with customer and technical support;

6.Security

If you choose to contact us using the contact form, none of the data you provide will be or processed by any third party data processor as defined in section. Instead, this data will be emailed to us through the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by a TLS security protocol (sometimes known as SSL), meaning that email is encrypted using 256-bit SHA-2 encryption before being sent over the Internet. The content of the email is decrypted by our local computers and devices. In addition, our e-mail platform is hosted by a company that is fully compliant with GDPR.

7.Data Retention

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.

The User may request to remove the personal data. Should that be a case, user requests could be fulfilled by the erasure of personal data to the extent permissible by the applicable law and regulations. In certain cases we are obliged to store your information to be legally compliant.

7.1 Data Retention when purchasing with FIAT
We store collected information for as long as it is necessary to be able to provide products and services to you. If you do not use our services, we keep your information for 5 years after the end of our relationship with the customer due to the requirements of anti-money laundering laws and other legal acts - after 5 years your personal information will be deleted. However, the information may be, wholly or in part, retained for longer or shorter term if required by applicable law or if there is other justified reason to retain or delete them.

In some cases, we can keep your information longer than 5 years: such exceeding can be used only in a case of arising of legal requirements that will oblige us to store your information for more than 5 years. We also store information on your transactions for 5 years due to the requirements of anti-money laundering laws and other legal acts. Information associated with your account will be kept until your account is deleted, unless we no longer need the data to provide products and services.

Please note that retention periods may be changed from time to time based on business or legal and regulatory requirements.

8.Cookies Policy

Cookies are small files stored by your Browser on your computer, tablet, mobile phone, and generally the device you are browsing through instaswap.io. Each cookie contains information such as the name of the website from which it originates, its ‘lifetime’ (ie how long it will stay on your device), and a value, usually a number. In essence, cookies allow sites to store various anonymous information such as visitor preferences or if they have visited the site again. On our website, cookies are used to make it easier for users to navigate the site, to better tailor your interests and needs and improve its use and functionality. In addition, cookies are used to compile anonymous traffic statistics and also know how you discovered our websites. These statistics help us understand how you use our site to improve its structure and content. In any case, we can not verify your personal identity from cookies. Cookies are stored exclusively on your own device (computer, tablet, mobile phone), and instaswap.io does not maintain any files or data files with your personal data.

What Cookies Do:

  • Preventing fraudulent activity;
  • Improving security;
  • Reporting. This allows us to measure and analyze the performance of our services
  • Google Analytics on Our Cryptocurrency Exchange Platform. If You want to know more about Google Analytics and its “do not track” policy, please visit google analytics (https://www.google.com/analytics/terms/us.html)

Disable Cookies

Typically, Browsers are configured to accept all cookies. If you wish, it is possible to set your own Browser not to accept cookies from a specific site, to alert when storing cookies or not accepting any cookies.

However, if you choose to disable cookies for instaswap.io, we may not be able to provide you with all the features offered on our site.

To learn more about cookies settings for different browsers, the following links may help you. Alternatively, click on the “Help” button in your browser or refer to the program information.

Useful Links for Cookies

  • https://www.google.com/ads/preferences/?hl=el
  • http://www.aboutads.info/choices
  • http://www.youronlinechoices.com/uk/your-ad-choices
  • http://www.aboutcookies.org

9.Your Rights

The right of access: This is a right for an individual to obtain confirmation whether a controller processes personal information about them and, if so, to be provided with details of that personal information and access to it.

The right of rectification: This is a right for an individual to obtain rectification without undue delay of inaccurate personal data a controller may process about them

The right to erasure: This is a right for an individual to require a controller to erase personal information about them on certain grounds – for example, where the personal information is no longer necessary to fulfil the purposes for which it was collected

The right to restriction: This is a right for an individual to require a controller to restrict processing of personal information about them on certain grounds;

The right to object: This is a right for an individual to object, on grounds relating to their particular situation, to a controller's processing of personal data about them, if certain grounds apply

The right to data portability: This is a right for an individual to receive personal information concerning them from a controller in a structured, commonly used and machine-readable format and to transmit that information to another controller, if certain grounds apply

If any Request is received in relation to a data subject’s rights (including the right to rectification, erasure, restriction, object or data portability) the Request must be sent at support@instaswap.io

10.Relevant Legislation

This website is designed to comply with the following national and international legislation on data protection and privacy of users:

11. Data Breaches

We will report any unlawful violation of the database of this third party data processing site or database to anyone and to all relevant stakeholders as well as authorities within 72 hours of the violation if it is obvious that the personal data that is stored in recognizable form, have been stolen.

12.Changes to our privacy policy

This privacy policy may change from time to time according to legislation or industry developments. We will not explicitly notify our customers or users of our site about these changes. Instead, we encourage you to occasionally review this page for any policy changes.

Last Updated: January 2020