PRIVACY POLICY

Last Update: 28.02.2025

Version 1.0

 

These Privacy Policy constitute a legally binding agreement between VERSATA SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ (Versata SP. Z O.O) , register number 001144389, registered address: Ul. Stefana Batorego 18 / 108, 02-591 Warsaw, Poland (hereinafter referred to as “Exchiq” , "we" , or "us" ) and you (hereinafter referred to as "you" or the "User" ).

Exchiq (as defined below under “Our Relationship to You”) is committed to protecting the privacy of visitors to our websites, our customers, and any other individuals whose personal data we process. This Privacy Policy outlines how we collect, use, store, and share your personal information when you access or use our services, including but not limited to our websites, mobile applications, email communications, social media pages, and any other platforms, features, or content owned or operated by us that reference this Privacy Policy (collectively, the “Services”).

If you have any questions regarding this Privacy Policy, you may contact our Data Protection Officer at dpo@Exchiq.com.

1. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data processing practices or to comply with evolving legal and regulatory requirements. In the event of material changes (such as modifications to the purposes of processing, the identity of the data controller, or the way you can exercise your rights), we will notify you and publish the revised version on our website Exchiq.com.

We encourage you to review this Privacy Policy periodically to stay informed about how we handle your personal data. The “Last Updated” date at the top of this notice indicates when this Privacy Policy was last revised.

2. Our Relationship to You

Exchiq operates internationally through various legal entities (collectively referred to as “Exchiq,” “we,” “us,” or “our”) to deliver Services to our customers. The specific entity with which you are contracting depends on your location and the nature of the Services you access.

3. Personal Data We Collect and How We Collect It

The term "personal data" refers to any information that can be used to identify an individual, either directly or indirectly. This includes, but is not limited to, a person’s first and last name, telephone number, postal and email addresses, date of birth, payment details, and banking information.

We collect personal data in various ways, depending on how you interact with us and our Services, including:

3.1. Information You Provide to Us
This includes personal data you share with us when you create an account, subscribe to receive updates from us, or contact us via phone, email, or other communication channels. This information may be required by law (e.g., for identity verification), necessary for service provision (e.g., linking a bank account to Exchiq), or collected for our legitimate interests, as outlined below.

Basic Customer Information
- Full Name
- Address
- Date of Birth
- Nationality
- Country of Residence
- Gender
- Phone Number
- Email Address

Supplemental Identification Information
- Utility bills (for address verification)
- Photographs and/or videos
- Government-issued identification (e.g., passport, driver’s license, national ID card)
- Social Security Number or equivalent tax identification number
- Employment details (e.g., company name)
- Proof of residency, including visa information

Electronic Identification ("EIDV") Information
- Biometric data derived from photos or videos submitted for identity verification
- Institutional Information (if you are an institutional partner)
- Employer Identification Number (or equivalent government-issued number)
- Personal identification information for all material beneficial owners of your business

Financial Information
- Bank account number
- Payment card details (e.g., Primary Account Number, "PAN")
- Trading and investment history
- Tax identification number
- Income, net assets, and wealth verification statements

Wallet Information
- Cryptocurrency or NFT wallet address and related details when you instruct us where to deliver purchased digital assets

Account Information
- Login credentials, passwords, and other account management details

Preferences
- Settings and preferences selected within the Exchiq  platform

Transaction Information
- Transaction details, including:
- Sender and recipient names
- Transaction amount
- Currency preferences
- Payment method
- Transaction date and timestamp

Additional Information You Submit to Us
- Communications: Survey responses, customer support inquiries, recorded calls, or any other communication provided through our support channels, including chatbot interactions.

3.2. Information We Collect Automatically or Generate About You
In addition to the personal data you provide to us, we may automatically collect or generate certain information about you when you interact with our Services. This data is gathered through technologies such as cookies, server logs, and other tracking mechanisms. The automatically collected data includes:

App, Browser, and Device Information
-  Details about your device, operating system, and browser
- Other device characteristics or identifiers (e.g., installed plugins, network connection details)
- IP address

Product Usage Information
-  Activity Information: Data on what you view, click on, or interact with while using our Sites and Apps, as well as your overall usage of our Services
- Diagnostic and Troubleshooting Information: Performance-related data, including timestamps, crash reports, error messages, website performance logs, and other service-related diagnostics

Information from Cookies and Similar Technologies
We use cookies and similar technologies to enhance your user experience and improve our Services. For more details on how we use cookies, please refer to our Cookie Policy .

3.3. Information Collected from Other Sources
In addition to the personal data you provide directly to us, we may obtain information about you from third-party sources. These may include our business partners, service providers, public databases, credit bureaus, ID verification partners, blockchain data, marketing partners, resellers, social media networks, or other publicly available sources. The main types of third parties from which we receive your personal information are:

Exchiq  Group of Companies (“Affiliates”)
We may receive information such as Basic Customer Information, Transaction Information, and Product Usage Information from our Affiliates as part of our business operations.

Public Database Information
We collect information from public databases, including but not limited to:
- The United Nations Sanctions List, US ITA Consolidated Screening List, and SEC EDGAR
- Information such as your name, address, email address, phone number, national ID number, nationality/country of residence, date of birth, job role, public employment profile, and any listings on sanctions lists.

Blockchain Data
We analyze publicly available blockchain data, including:
- Timestamps of transactions or events
- Transaction IDs and digital signatures
- Transaction amounts and wallet addresses

Marketing and Advertising Partners
We receive data such as:
- Your name and contact details
- Information on marketing content you have viewed or your interactions with our Sites

Analytics Providers
We collect information on:
- Your Site usage and interactions
- Demographic data, such as age group
- Survey responses (including before account creation, where applicable)

Retail Merchant Information
If you conduct a transaction with one of our third-party partners using your Exchiq account, the partner may provide us with:
- Your name and contact details
- Transaction details related to that partner

3.4. Special categories of personal data
Under EU data protection laws, certain types of personal data are classified as "special categories" due to their sensitive nature. This includes:
- Racial or ethnic origin
- Political opinions
- Religious beliefs
- Trade union membership
- Genetic and biometric data
- Health-related data
- Sexual orientation and sex life information

We do not intend to process special categories of personal data, except for biometric data used for identity verification (as outlined in this Policy). If such data appears incidentally in transaction details, it is considered to be publicly manifest and not intentionally processed.

3.5. Changes to Your Personal Data
Ensuring that the data we hold about you is accurate and up to date is crucial. If your personal data changes or if you become aware of any inaccuracies, please inform us promptly.

4. How We Use Your Personal Information
At Exchiq, we use your personal data to deliver, customize, operate, enhance, and further develop our Services. Our objective is to provide you with a secure, efficient, and tailored experience, while also ensuring compliance with legal requirements, protecting against losses, and preventing fraud. Below is an overview of how we use your personal information and the legal basis for each purpose:

4.1. Data Use Necessary to Perform Our Contract with You
- To Create and Maintain Your  Exchiq  Account:
We require your personal information to enable you to set up and manage your Exchiqaccount and profile, which is essential for providing you with our Services.
Data Categories: Basic Customer Information, Supplemental Identification Information, Financial Information.

- To Provide You with Consumer Services:
We use your data to offer personalized investment-related services (e.g., buying and selling) that cater to your specific needs.
Data Categories: Basic Customer Information, Supplemental Identification Information, Financial Information, Institutional Information, Transaction Information, Wallet Information, Preferences, Blockchain Data, Product Usage Information, and any additional information you submit (excluding Referral Information, which we do not retain)

- To Provide You with Partner Services:
We facilitate partnerships with institutions by processing your data to deliver integrated services that benefit both you and our institutional partners.
Data Categories: Basic Customer Information, Supplemental Identification Information, Financial Information, Institutional Information, additional information you submit, Wallet Information, Transaction Information, Blockchain Data

- To Provide Customer Support:
We use your personal data to respond to your inquiries and support requests—via the App, our Sites, email, or other communication channels—including telephone-based premium support, chat support (including chatbots), and social support.
Data Categories: Basic Customer Information, Supplemental Identification Information, Transaction Information, Product Usage Information (including Location Information), Communications, Wallet Information, Blockchain Data

- To Send Service Communications:
We send you essential administrative or account-related messages, such as security updates or transaction notifications, through email, telephone, or in-product/push notifications. These communications are necessary for legal or security purposes, and you cannot opt out of receiving them.
Data Categories: Basic Customer Information, Product Usage Information, Communications, Transaction Information

- To Promote the Safety, Security, and Integrity of Our Services:
We use your personal data to verify account activity, detect and address violations of our Terms of Use, investigate suspicious or fraudulent behavior, and prevent account takeovers (ATO), thereby maintaining the integrity of our Services.
Data Categories: Basic Customer Information, Transaction Information, Product Usage Information, Supplemental Identification Information, Institutional Information, Financial Information, Communications, and any additional information you submit

4.2. Data Use to Comply with Our Legal Obligations
Our Services are subject to laws and regulations that require us to collect, use, and store your personal information in specific ways. If you do not provide the personal information required by law, we may be obligated to close your account.

To Verify Your Identity
We are generally required to collect various pieces of personal information to properly identify or verify your identity and to comply with other specific anti-money laundering (“AML”) and sanctions laws and regulations (e.g., funds transfer rules). Our verification processes include electronic identification through the comparison of your 'selfie' against the verification information you have provided. All such information is securely stored by Exchiq and its service providers, and will only be disclosed where permitted by law.
- Basic Customer Information, Supplemental Identification Information, EIDV Information

To Determine Your Legal Eligibility for Certain Regulated Products
When you use certain locally regulated products, we may be required to carry out additional checks to assess your eligibility.
- Basic Customer Information, Financial Information, Supplemental Identification Information

To Comply with Other Legal and Regulatory Obligations
We may access, review, preserve, and disclose information when we believe it is reasonably necessary to comply with legal obligations, regulations, law enforcement requests, governmental authorities, court orders, or for disclosure to tax authorities.

Examples of laws that may require us to collect, use, or disclose your information:
- Civil, Commercial, Criminal, or Consumer Protection Matters : Where we are served with a court order to disclose information for the purposes of court proceedings or regulatory inquiries (e.g., mandatory requests under applicable laws, subpoenas from any court with jurisdiction).
- Corporate and Taxation Matters : Including obligations to retain personal data for administrative and corporate purposes.
- Regulatory Matters : To fulfill our regulatory obligations, conduct transaction monitoring, and comply with other applicable requirements. This also includes engagement with regulators, such as the Dutch Authority for the Financial Markets (Autoriteit Financiële Markten), U.S. regulators, and the UK Financial Conduct Authority.
- Basic Customer Information, Supplemental Identification Information, Institutional Information, Wallet Information, Transaction Information, Product Usage Information, Communications Information, Blockchain Data

4.3. Data Use for Our Legitimate Interests
We rely on our legitimate interests or those of third parties (such as our other customers and, in some cases, the general public) where these interests are not outweighed by your rights and freedoms. In the European Economic Area (EEA), you have the right to object to, and seek the restriction of, this processing.

To Customize Your Experience with Our Services and Otherwise Improve Our Services
To perform core metrics, customize your experience with our Services, and generally improve our Services, we collect information about your online activity while using the Services (e.g., when and how often pages on our Sites are visited and how our Services are used). It is in our interest to understand how you interact with the Services in order to customize and/or improve our products and Services and enable accurate and reliable reporting.
- Basic Customer Information, Product Usage Information, Transaction Information

To Provide Marketing Communications to You for Exchiq's Own, Similar Products or Services
We use your information to send you targeted marketing communications via email, mobile, in-app and push notifications, or by SMS. Communications for which we use legitimate interest as a legal basis only include information related to Exchiq's own, similar products or services. You may object to the use of your personal data for such communications at the time your personal data is collected and every time you receive such communications.

You may also see ads for our Services when you visit other apps and websites.

It is in our interest to promote Exchiq products and Services that may interest you.

- Basic Customer Information, Institutional Information, Product Usage Information, Transaction Information, Information from Our Marketing Partners

To Provide You with Promotions for Exchiq's Own, Similar Products or Services
We use your information to provide promotions, including sweepstakes offers or other incentives and rewards for using our Services. Communications for which we use legitimate interest as a legal basis only include information related to Exchiq's own, similar products or services. You may object to the use of your personal data for such communications at the time your personal data is collected and every time you receive such communications.

Our legitimate interest is to reward and increase customer loyalty (the processing takes place in your legitimate interest as well, to obtain rewards or discounts).

- Basic Customer Information, Wallet Information, Supplemental Identification Information, Transaction Information
We Preserve and Share Information with Others, Including Law Enforcement, Civil Litigants, and Others Who May Issue Legal Requests

Where not otherwise required by law, and depending on the circumstances, we may preserve and share your information:
- In response to requests from third parties, such as civil litigants, law enforcement, and other government authorities, for example, to assist authorities in the investigation of fraud, money laundering, or other criminal activity.
- To promote the safety, security, and integrity of the Exchiq Services, network, customers, Users, employees, property, and the public.
- When we seek to protect ourselves in litigation or other disputes, such as violations of our Terms of Use and policies; and/or to respond to customer/claimant requests or communications, reviewing customer accounts and transactions for litigation disputes, and recording account details for litigation and settlement purposes.

It is in our interest and the interest of the general public to prevent and address fraud, unauthorized use of the Services, violations of our terms or policies, or other harmful or illegal activity; to protect ourselves (including our rights, Exchiq personnel and property, or the Services), our customers, or others, including as part of investigations or regulatory inquiries; to defend our legal rights and resolve disputes; to secure our platform and network, verify accounts and activity, combat harmful conduct, and detect, prevent, and address fraud, abuse, spam, and other bad experiences or to prevent death or imminent bodily harm.

- Basic Customer Information, Supplemental Identification Information, Institutional Information, Wallet Information, Transaction Information, Product Usage Information, Communications Information, Blockchain Data

4.4. Data Use Based on Your Consent
When we use your information based on your consent, you have the right to withdraw your consent at any time going forward (which will not affect our prior use of your data, based on your previously given consent). You may change your device-based or in-app settings at any time.

To Enable Device-Based Settings
We collect information that you allow us to receive through the device-based settings you enable (such as access to your GPS location, camera, or photos), which we use to provide the features or services described when you enable the setting.
- App, Browser, and Device Information

To Provide Marketing Communications to You for Other Than Exchiq's Own, Similar Products or Services
We use your information to send you targeted marketing communications through email, mobile, in-app, and push notifications or by SMS.

You may also see ads for our Services when you visit other apps and websites.

- Basic Customer Information, Institutional Information, Product Usage Information, Transaction Information, Information from Our Marketing Partners, Additional Information You Provide to Us

4.5. Data Use to Protect Your or Others’ Vital Interests

Preserving, Reviewing, and Sharing Information with Law Enforcement and Others
We may preserve, review, and share information with law enforcement and others in circumstances where someone's vital interests require protection, such as in emergencies. For example, where there is a risk to the well-being or life of an Exchiq customer.

- Basic Customer Information, Supplemental Identification Information, Institutional Information, Wallet Information, Transaction Information, Product Usage Information, Communications Information, Blockchain Data

5. How We Protect and Store Personal Information

Exchiq implements and maintains reasonable measures to protect your information. However, no method of transmission over the internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

You also play a vital role in protecting your own personal information. When registering with our Services, choose a password of sufficient length and complexity, don’t reveal it to any third parties, and immediately notify us if you become aware of any unauthorized access to or use of your account.

6. Cookies

Our websites, applications, and portals use cookies as detailed in the Cookie Policy .

7. Third-Party Applications/Websites

For your convenience, we may provide links to websites and other third-party content or services that we do not own or operate. The websites and third-party content to which we link may have separate privacy notices or policies. Please note, we have no control over the privacy practices of such websites or services that we do not own. We encourage you to review the privacy policies of any third-party website or application for details about such third party’s privacy practices.

8. How to Contact Us

If you have questions or concerns regarding this Privacy Policy, if you have a complaint, or if you need to access this Privacy Policy in an alternative format due to having a disability, please contact us at privacy@Exchiq.com or contact our data protection officer at dpo@Exchiq.com.