Last updated: May , 2019
I. How is your information being collected:
SPEZA exchange does not target its websites, mobile app, API, or any of the Services at children. SPEZA exchange does not intentionally collect information from children. If we become aware that we have inadvertently received personal data from a user under the age of 21 (or any lower age pursuant to applicable law), we will delete such information from our records.
If you create an account or use the Services, we, or our affiliates or Vendors (as defined hereunder) acting on our behalf may collect the following types of information for the purpose as set forth hereunder:
Account Information – your email address and password;
Contact Information – your name, date of birth, address, phone number;
Identity Verification Information – our ID number, image of your government issued ID, passport, national ID card, driving license, your selfie along with the above mentioned ID documents, and FATCA (Foreign Account Tax Compliance Act) related information;
Financial Information – withdrawal address, source of fund, the number of bank account linked with your SPEZA exchange account, and image of bank statement or similar information;
Nationality/Residence Verification Information – your address, nationality, country of residence, and utility bill or similar information; and/or
Survey Information – certain personally identifiable information you provide in response to our survey. This may include details about your education history, income and your employment;
Technical information – IP, login information, browser information, time zone setting , operating system and platform;
Information about geo-location – real-time location based information from your device at any time while you download or use our services. We may use this information to optimise your experience;
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, search information providers, credit reference agencies) and may receive information about you from them.
Internet infrastructure - cloud storage and cloud computing;
Communication tools and platforms - SMS services, email services, and push notification, and customer support tool;
Error collection tools - web page error message collection, APP crash tracking, web and APP experiment (A/B testing), and APP statistics;
User behaviour analysis - user behaviour tracking tool and bot prevention tool; and
Anti-money laundering tool - such as AML database.
When you use the Services, we collect information about your transactions and/or your other activities on our website and we may continuously collect name and type of your computer, mobile device, or other access device, such as the name and device of your operating system, for fraud prevention purposes, to monitor for possible breach of your SPEZA exchange account, and to identify any malicious software or other activity that may harm SPEZA exchange or its users.
Finally, we collect additional information that you provide voluntarily to our customer success team.
II. How we protects and stores your personal data:
We store and process your personal and transactional data, including certain payment information, where SPEZA exchange facilities or our service providers are located, including in EU and in the United States.
III. How personal data is used:
Our primary purpose in collecting personal data is to provide you with a secure, smooth, efficient, and customised experience. We use your personal data to:
Provide the Services and requested customer support;
Process transactions and send notices about your transactions;
Resolve disputes, collect fees, and troubleshoot problems;
Prevent and investigate potentially prohibited or illegal activities, and/or violations of our posted user terms;
Customise, measure, and improve SPEZA exchange Services and the content and layout of our website and applications;
Deliver targeted marketing, service update notices, and promotional offers based on your communication preferences; and/or
Verify your identity by comparing your personal data against third-party databases.
We process your personal data on one or more of the following legal bases in accordance with applicable rules and regulations, including the General Data Protection Regulation (GDPR) in EU:
With the consent from you, we may provide you with SPEZA exchange and our Services. On the same basis, we may also optimise and enhance SPEZA exchange for all customers, or for you specifically;
For our legitimate business purposes, we may monitor the usage of SPEZA exchange, conduct automated and manual security checks of our Service, to protect our rights and perform our lawful obligations; and/or
In order to comply with legal obligations under applicable rules and regulations, we may conduct AML procedure, anti-fraud procedure, identity verification and authentication checks.
We will not use your personal data for purposes other than those purposes we have disclosed to you, without your consent. From time to time we may request your consent to allow us to share your personal data with third parties for the purpose of provide the Services. You may refuse to provide or may withdraw your consent at any time without adverse consequence. Your refusal and withdrawal of consent will have no effect on the services we provide hereunder, provided that such consent is not necessary for our performance of the Services hereunder.
We do not engage in individual automated decision-making.
We will never sell or rent your personal data to any third parties.
Any communications we send to you will either be related to your account or will be related to SPEZA exchange services or products. In the event SPEZA exchange sends any communication to you which is not related specifically to your account, SPEZA exchange will provide you with an “unsubscribe” mechanism through which you may opt out of receiving other similar messages in the future.
IV. How we share your personal data:
We may share your personal data with the following parties for the following reasons.
Authorised Third Party Applications. If you authorise one or more third-party applications to access your SPEZA exchange account, then information you have provided to SPEZA exchange may be shared with those third parties. Unless you provide further authorisation, these third parties are not allowed to use this information for any purpose other than to facilitate your transactions made during you use of the Services.
Law enforcement, government officials, or other third parties. We may be required to disclose personal data if and when compelled to do so by a subpoena, court order, or similar legal procedure.
Miscellaneous. We may also make disclosures of personal data if we believe in good faith that the disclosure of personal data is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our terms and conditions of use.
Before SPEZA exchange shares your personal data with any third party, SPEZA exchange will, to the extent permitted by applicable laws, rules, or regulations, enter into a written agreement or seek other safeguards requiring that the third party provide at least the same level of privacy and data protection as set out hereunder.
If you establish a SPEZA exchange account indirectly on a third-party website or via a third-party application, any information that you enter on that website or application (and not directly on a SPEZA exchange website) will be shared with the owner of the third-party website or application and your information may be subject to their privacy policies.
V. How you can contact us to exercise your rights:
If you have questions or concerns regarding this policy, or if you have a complaint, you should first contact us on our support page by emailing helpdesk@SPEZA.zendesk.com .
VI. If you are located in, or a resident of, EEA, you have the following rights under EU data protection law:
Right of access: you can request information about your Personal Data and request a copy of that data.
Right of rectification: you can request that we correct or update your Personal Data if they are incomplete or incorrect by SPEZA exchange at any time by submitting a request to: support@SPEZA.zendesk.com with the subject line “Revise Personal Information”.
Right to erasure: you can request erasure of your Personal Data, if the data are inaccurate or processed in a way which is incompatible with the purpose(s) pursued by us.
Right to data portability: if we process your Personal Data on the basis of a contract with you or based on your consent, you can request to receive your Personal Data in a structured, commonly used and machine-readable format, and ask us to transfer such data to a third party, where technically feasible.
Right to objection: you can object to the processing of your Personal Data for direct marketing purpose at any time.
Right to lodge a complaint: you can lodge a complaint with a competent supervisory authority in the EU situated at your habitual residence, place of work, or place of alleged infringement of the GDPR.
Right to refuse or withdraw your consent: you can refuse to give and withdraw your consent to data processing at any time. You can also oppose processing of your Personal Data, based on our legitimate interests, including profiling based on this provision, on compelling grounds relating to your particular situation at any time.
Right not to be subject to automated individual decision-making: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Right to deactivate/delete your account: if you no longer wish to use our Services, you have the right to deactivate/delete your SPEZA exchange account by submitting a request to helpdesk@SPEZA.io with the subject line “Deactivate/Delete Account”. Please note, however, that we may need to retain certain information for record keeping or regulation compliance purposes on a necessary basis.
If you want to exercise these rights, you can contact us at helpdesk@SPEZA.org.