1. Introduction
- 1.1. This website-hosted user interface (this “Interface”) is made available by GET-Exchange., a corporation organised and existing under the laws of Panama (the “Company” “us” “we” or “our”).
- 1.2. This Privacy Policy (the “Policy”) governs the manner in which we make the Interface available and how we collect, use, maintain and disclose information collected from our users (each, a “user”, “you”, or “your”) through the Company’s websites, including the Interface, web applications mobile applications and all associated sites linked thereto by the Interface, or by us or our affiliates (the “Site”).This Policy further applies to all information we collect through our Site and otherwise obtain in connection with products and Services, content, features, technologies, functions and all related websites we may provide to you or to which we may provide access (collectively with the Site, the “Services”).
- 1.3. Please read this Policy carefully. We are committed to protecting your privacy through our compliance with the terms of this Policy.
- 1.4. Our Terms of Services (“Terms**”) govern all use of our Services and, together with the Privacy Policy, constitute your agreement with us (the “Agreement”). If you do not agree with the terms of this Policy, please do not access our Site.
- 1.5. By accessing or using our Services, you agree to the terms of this Policy. Specifically, by (i) using, visiting, or accessing the Services, (ii) using, accessing, establishing an account through or purchasing any of the Services, and/or (iii) clicking “**accept”, “**agree”, or “OK” (or a similar term) with respect to any of our Terms or similar policies, you consent and agree to be legally bound by each of the terms and conditions contained in this Policy.
- 1.6. In operating the Site and providing the Services we may collect (and/or receive) certain information about you and your activities. You hereby authorize us to collect and/or receive such information to operate the Site and provide the Services.
2. APPLICABILITY
- 2.1. This Policy applies to all the information collected by us from you in connection with the Site and offering the Services
- 2.2. This Policy does not apply to the information collected by us offline or through any other means, including on any other website made available by us or by any third party.
3. INFORMATION COLLECTED AND HOW WE COLLECT THEM
- 3.1. We collect information
- 3.1.1. directly from you when you provide it to us;
- 3.1.2. automatically as you navigate through the Site which may include usage details, IP Addresses; standard web logs information such as browser type and pages you accessed on our Site, and information collected through Cookies and other tracking technologies; and
- 3.1.3. in certain instances, from third parties, such as our business partners, third-party providers, subsidiaries or other networks where you have connected your account and authorised the Site to access this information. You may optionally provide us with this information through third-party sign-in services such as Facebook and Google. In such cases, we fetch and store whatever information is made available to use by you through these sign-in services.
- 3.2. If you create an account with us, the following information may be collected from you:
- 3.2.1. Personal information:
- 3.2.1.1. means information that can be associated with a specific person and can be used to identify that person including name, postal address, registration at the place of residence, email address, telephone number, date of birth and other demographic information such as age, gender, hometown and interests that you voluntarily provide to us.
- 3.2.1.2. Includes the personal information of third parties that may be contained in information provided by us through your use of the Site.
- 3.2.1.3. There is no obligation for you to provide us with personal information of any kind, but your refusal to do so may prevent you from using the Services.
- 3.2.1.4. Personal information doesn’t include information that has been aggregated and/or anonymized so that it doesn’t identify a specific user.
- 3.2.2. Derivative information: information collected automatically when you access the Site, such as IP Address, browser type, operating system, and access time.
- 3.2.2.1 It may not include other information about your internet connection and the equipment used to access our Site and usage details.
- 3.2.3. Financial Information: You authorize our third-party payment vendors and wallet providers to collect, process, and store your Financial Information in accordance with their respective privacy policies. If applicable, in order for us to process payments of any fees in relation to the Services and the Site, you will be required to provide bank account online login information, credit card information and other data related to your payment method.
- 3.2.4. Other information: information obtained otherwise- mobile device such as mobile type, mobile device identification, time zone, browser type; geolocations information such as your location by using certain longitude and latitude, GPS, Wi-Fi, may be collected for fraud prevention and risk management purpose among other reasons; corresponding and recordkeeping to retain records and copied for your correspondence as applicable by law.
- 3.2.1. Personal information:
- 3.3. We may collect additional information from or about you in other ways not specifically described here.
4. HOW WE USE YOUR INFORMATION
- 4.1. We use and process the information we collect for purposes described in this Privacy Policy or as otherwise described to you on our Services or in connection with our Services. For example, we use your information to:
- 4.1.1. Create and process your account and deliver the Services to you, including allowing you to register for the Services and participate in trading activities and for GET-Exchange to authenticate your identity, handle billing and account management, fulfil our legal and regulatory obligations, and complete other administrative matters;
- 4.1.2. Send you transactional information, including confirmations, invoices, technical notices, product and services information and announcements, software updates, security alerts, support and administrative messages, and information about your transactions with us;
- 4.1.3. Communicate with you such as responding to your comments and questions, deliver newsletters or other content we believe you will be interested in, provide customer service or feedback, contact you about amounts owed, conduct surveys, respond to employment opportunities for which you’ve applied, notify you about upcoming events, or for any other purposes in connection with the Services;
- 4.1.4. Contact you regarding your account with us, use of the Site and Services, and questions regarding the Service
- 4.1.5. Conduct research and analytics to understand our visitors and customers and tailor our product offerings and verify it with third parties;
- 4.1.6. Provide you with updates about products and services offered by us and selected partners, as well as facilitate new contests, sweepstakes, promotions, and rewards;
- 4.1.7. Monitor, administer, and enhance our Services, including troubleshooting, data analysis, testing, research, statistical, and survey purposes;
- 4.1.8. Prevent potentially fraudulent, prohibited or illegal activities, and enforce our Terms of Services through the use of our risk and fraud tools;
- 4.1.9. Enhance the safety and security of our Services, Platform, and Members, and investigate or provide notice of fraud or unlawful or criminal activity;
- 4.1.10. Perform audits and protect or exercise our legal rights or defend against legal claims, including to enforce and carry out contracts and agreements; and
- 4.1.11. comply with applicable laws and legal obligations.
- 4.1.11.1. in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements,
- 4.1.11.2. when required by law, court order, or other government or law enforcement authority or regulatory agency; or
- 4.1.11.3. whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of us or others.
5. DISCLOSURES OF INFORMATION
- 5.1.1.Without limiting the foregoing, you also authorised us to use, disclose and/or share information as described below:
- 5.1.1.1. share your information with other companies, who may provide your information about the products and services they or their partners offer. You may prevent us from sharing and/or licensing your personal data to third parties by sending an email to legal@getexchange.app;
- 5.1.1.2. we may employ other companies and individuals to perform functions on our behalf;
- 5.1.1.3. we may also disclose anonymous user statistics in order to describe our Services and business to current and prospective business partners and other third parties for other lawful purposes. This anonymous information does not identify you personally. We may use this anonymous information and share it with our affiliates, agents, business and promotional partners, and other third parties;
- 5.1.1.4. we may share some or all of your information with any of our parent companies, affiliates, subsidiaries, joint ventures, or other companies under common control with us;
- 5.1.1.5. we disclose personal data to respond to subpoenas, court orders, legal processes, law enforcement requests, legal claims, or government inquiries and to protect and defend the rights, interests, safety, financial loss, and security of GET-Exchange, our affiliates, users, or the public.
- 5.1.1.6. as noted above, we may use the information we collect about you to fulfill any other purpose for which you may provide us with your information such as: to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
- 5.1.2. If you authorise an account connection with a third party account or platform, then we may:
- 5.1.2.1. exchange your personal information and other information directly with such third-party such as: connecting your account to a third-party data aggregation or financial services company; using your account to make payments to a merchant or allowing a merchant to charge your account etc.;
- 5.1.2.2. we may have access to your account balance and account and transactional information, such as purchases and funds transfers. If you choose to create an account connection, we may receive information from the third party about you and your use of the third party’s Services.
- 5.1.3. We may collect, process and store your User ID or any Information associated with any third-party account (including Google and Facebook) that you use to sign into the Services or connect with or use the Services. When you sign in to your account with your third-party account information or otherwise, you consent to our collection, storage, and use, in accordance with this Privacy Policy. This could include, without limitation, any information that has been made public through your social media account or information that is disclosed during the sign-in process or otherwise. Before using this Service/Site, you can review Google’s privacy policy and terms of use and Facebook’s privacy policy and terms of use.
- 5.1.4. We do not disclose your credit card number or bank account number to anyone except with your express, written permission unless we are compelled with a subpoena or other legal process.
- 5.1.5. We do not send your personal information to third-party social networks unless you have specifically requested or authorized us to do so. When you broadcast information to such third party social networks, such information is no longer under our control and is subject to the terms of use and privacy policies maintained by such third parties.
6. CONTROL OVER YOUR INFORMATION
- 6.1. Account profile.
- 6.1.1. You may update certain of your account profile information by logging into your account.
- 6.2. Access to your device data.
- 6.2.1. You may control the mobile app’s access to your device information in your device’s settings.
- 6.3. How to control your communications preferences.
- 6.3.1. You can stop receiving promotional emails from us by clicking on the provided “unsubscribe” link. You may not opt out of service-related or other non promotional communications (e.g., account verification, transactional communications, changes/updates to features of the Services, and technical and security notices).
- 6.4. To the extent you have registered for the Services, you may access, review, make changes to, and delete your personal information by following the instructions found on the Site or by sending an email to us at legal@getexchange.app. We reserve the right to ask for information verifying your identity before we begin complying with a request to review, make changes to, and delete your personal information.
- 6.5. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “Unsubscribe” link located on the bottom of any marketing email, or by sending us an email at hello@getexchange.app with the subject line, “Unsubscribe from Marketing”.
- 6.6. Registered users cannot opt out of receiving transactional or administrative emails related to their accounts. We will use commercially reasonable efforts to process such requests in a timely manner in compliance with applicable laws. You should be aware, however, that it is not always possible to completely remove or modify information in our databases.
7. CHILDREN’S PRIVACY
- 7.1. We do not knowingly collect or solicit any information from anyone under the age of 18 on these Services. In the event that we learn that we have inadvertently collected personal information from a child under age 18, we will take reasonable steps to delete that information unless we are legally obligated to retain such information. If you believe that we might have any information from a child under 18, please contact us at legal@getexchange.app
8. USE OF COOKIES, THIRD-PARTY LINKS AND TRACKING
- 8.1. We use Cookies to recognise you as a customer, to customise the Services, other content and advertising, to measure the effectiveness of our promotions, to perform a wide range of analytics, to mitigate risk and prevent potential fraud, and to promote trust and safety across our Services. When you visit our Site and use our Services, we and certain business partners and vendors may use cookies and other tracking technologies (collectively, “Cookies”).
- 8.2. Most browsers are set to accept cookies by default, however, you can remove or reject cookies. It is important to note that certain Services are only available through the use of cookies. Therefore, if you choose to disable or decline Cookies, your use of the Services and other Services may be limited or not possible.
- 8.3. Some of the Services may contain links to content maintained by third parties that we don’t control. We’re not responsible for the privacy practices or the content on the third-party services, the information practices of these third parties are not coerced by this Privacy Policy. Please note that the third-party services have their privacy policies, and we strongly recommend that you read their privacy policies as well as terms and conditions of use to understand how they collect, use and share your information.
9. TRANSFER OF INFORMATION
- 9.1. Our Services are currently designed for use in certain selected markets. Hence, your personal information may be transferred to and maintained on a computer located outside your state or government jurisdiction with varying protection laws. By using the Services, you consent to the transfer of your information outside of your country of residence or any other country in which Get Exchange or its parent, subsidiaries, affiliates, or service providers or business activities exist, which may have different data protection rules from that of your country.
10. YOUR DATA PROTECTION RIGHTS
- 10.1. Your rights to personal information are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied As per the applicable law where you reside, you may be able to assert certain rights related to you upon such requests:
- 10.1.1. The right to access. You have the right to access, update or delete the information we have on you, and you may email us at legal@getexchange.app to request a copy of the personal information the Site’s databases currently contain.
- 10.1.2. The right of correction or rectification. You have the right to have your information rectified if that information is inaccurate or incomplete by emailing us at legal@getexchange.app. Using the same email address associated with your use of the Site or your Site account, simply type the words “Correction or Rectification” in the subject line of your email to us.
- 10.1.3. The right to object. You have the right to object to our processing of your personal information by emailing us at legal@getexchange.app. When such objections are not possible, we will advise you accordingly.
- 10.1.4. The right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information by emailing us at legal@getexchange.app.
- 10.1.5. The right to restrict and/ erasure. If you should wish to cease or restrict the use of our Site and have your personal information deleted from our Site, then you may submit a request by emailing us at legal@getexchange.app.
11. CHANGES TO THIS POLICY
- 11.1. This Privacy Policy will evolve with time, and when we update it, we will revise the “Effective Date” herein and post the new Privacy Policy. To stay informed of our privacy practices, we encourage and recommend you review the Privacy Policy on a regular basis as you continue to use our Services.
- 11.2. You acknowledge and agree to review this Privacy Policy periodically and become aware of modifications. Your continued use of the Site following the posting of changes to this Privacy Policy will be deemed your acceptance of those changes.
12. JURISDICTION
- 12.1. The Services, including the Site, are made available by us from Panama and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of Panama.
13. HOW TO CONTACT US
We understand that you may have questions regarding this Policy, including your personal information, how it may be collected, and how it may be used. You may email us at legal@getexchange.app with any concerns or privacy-related questions that you may have.