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Privacy Policy

01.08.2019

1. PRIVACY POLICY STATUS AND ACCEPTANCE

This Privacy Policy (hereinafter referred to as the “Policy”) sets forth the general rules of User’s Personal Information collection, processing, distribution, use and keeping by Remme Capital LTD (hereinafter the “Company” or “We”) during the use of Website and the Services. Description of our Services you may find in Terms of Use.  We assure that Swapy.app, is committed to safeguarding your privacy and protecting your Personal Information.

We define "Personal Information" as any information which, directly or indirectly, identifies you personally, e.g. your name, address, e-mail address, location data etc.

Remme Privacy Notice explains how we collect, use and share your Personal Information in the course of our business activities as well as the legal basis underpinning the collection of your Personal Information. We only collect the personal data that is reasonably necessary for us to efficiently conduct our business activities. 

Each User must carefully read and comply with this Policy. It is understood and presumed per se that by the fact of the Website and the Services use or otherwise by providing Us the Personal Information directly on our request, the respective User fully read, understood and accepted this Policy. If any User does not agree with this Policy in general or any part of it, such User must not access and use the Website and/or the Services of Swapy.app.  

We reserve the right to change, modify, add or remove provisions of this AML/KYC Policy from time to time for any reason. We will provide you with notice of such changes by sending an e-mail, providing notice on the homepage of the Website and/or by posting the amended Policy via our Website and updating the "Last Updated" date at the top of these Terms. In any case we suggest that you review this Policy periodically for changes. Such changes shall be effective immediately upon posting them on the website. You acknowledge that by accessing the services after we have posted changes to the Policy, you are agreeing to the modified provisions.


2. PURPOSE OF PERSONAL INFORMATION USE

We only collect from the Users the Personal Information that is reasonably necessary for us to efficiently conduct our business activities (for the proper use of the Website and the Services).
We collect and use the Personal Information in furtherance of the following aims:
   • to maintain and improve our Website and the Services. We use Personal Information to ensure that our services function properly;
   • to establish and verify your identity;
   • to conduct our internal KYC check to ensure that you were not coming from the list of blacklisted countries;
   • to comply with the Anti-Money Laundering Rules;
   • to contact you about our products and services and to provide replies to you;
   • 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 when you register or use certain other site features. 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.


3. PERSONAL INFORMATION COLLECTION AND PROCESSING

While providing our Services we may collect the following Personal Information from you:
   • first name;
   • last name;
   • e-mail;
   • address of your Ethereum wallet;.

We reserve the right to collect any Other Data, including data which can be not Personal per se but can be treated as such when combined with other Personal information, such as :
   • country of residence;
   • telegram username;
   • date of birth;
   • telephone number;
   • postal address;
   • any other information if we deem necessary in accordance with this Privacy Policy and AML/KYC policy which you may find at page.  

We may also obtain information from other sources and combine that with information we collect through our Services. For example, we may collect information about you from third parties, including but not limited to social media platforms and publicly available sources (such as Google, Facebook, Twitter). If you do not want a social media platform to collect or share information about you, please review the privacy policy and privacy settings of the applicable social media property before using such features on our Service. 
We do not process any sensitive Personal Data, such as religion, race, ethnicity and/or political views.

When You visit the Website or use our Product, We automatically collect the Personal Information sent to Us by Your computer, mobile phone, or other access device. This Personal Information may include:
   • your IP address;
   • device information including, but not limited to, identifier, name, and type, operating system;
   • mobile network information;
   • standard web log information, such as Your browser type, and the pages You accessed on Our Website, access times, web-site navigation paths.
The Company collects some information automatically, namely information about devices (including mobile devices), which you may use to access the Website, IP-address of your devices, used browser and operating system, date, time.
You agree to provide the Personal Information specified herein and agree that Your provided Personal Information may be processed and stored by Us.
The components of Personal Information that mentioned below may be modified from time to time according to the Applicable law and our needs that will be reflected in this Policy. We will not collect any other Personal Information except for the mentioned herein until we amend and post these amendments to the Policy on the homepage of our Website.

4. LEGAL GROUNDS FOR PROCESSING

Our processing of your Personal Information is based on the following legal grounds:
   • consent –   where you have consented to our use of your Personal Information;
   • legal obligation – where we need to use your Personal Information to comply with our legal obligations (identification and verification of your identity to manage the risk of our client base and to ensure you fall within our acceptable risk profile);
   • contract performance – where we need to collect and use your Personal Information to perform the services to you;
   • legitimate interest – it is our legitimate interest to promote our business, develop our communication with the customer. If you are a data subject protected by the GDPR you may have rights to restrict or object to this processing, however, please note that this may adversely affect the product we offer as well as our ability to effectively communicate with our customers.

5. COOKIE POLICY

When You access the Website or use Our Product or services We (or Google Analytics or similar service provider on our behalf) may place cookies on Your computer or other device.
A cookie is a small text file that is sent to and stored on your computer or other internet connected device to identify your browser or store information. They are widely used in order to make websites work, or work in a better, more efficient way.
The information we obtain through the use of Cookies may include information about your computer, device, and browser, such as your IP address, browser, operating system and device characteristics, language preferences, mobile device or advertising ID, referring URLs, and actions taken by you on REMME Services such as what content you visited, whether you have used REMME Services before, dates and times you access REMME Services, email and advertising views and click-throughs, frequent article searches on REMME Services, and other software or hardware information. If you access REMME Services from a mobile or other device, we may collect information for that device such as a unique device identifier ("UDID"), mobile phone number, and details about your mobile carrier.
We use these technologies to recognize You as our User, customize Our Website, understand usage and determine the effectiveness of email marketing campaigns, measure promotional effectiveness and collect information about Your computer or other access device to mitigate risk, help prevent fraud, and promote trust and safety. You may control the use of cookies within Your internet browsers’ settings. If you reject or delete certain cookies, be aware that the performance of the related features and functions of our Websites and services may be impaired. Web beacons (or pixel tags) are electronic images that may be used in our web Services or emails to help deliver cookies, count website visits, understand usage and determine the effectiveness of email marketing campaigns.
You can stop Cookies from being downloaded to your device from REMME Services at any time by selecting the appropriate settings in your browser. Most browsers will tell you how to change your browser settings to notify you when a Cookie is being set or updated, or to restrict or block certain types or all Cookies. Please consult the "Help" section of your browser for more information or by visiting www.allaboutcookies.org. If you reject or delete certain cookies, be aware that the performance of the related features and functions of our Websites and services may be impaired.
Your device settings may also allow you to prohibit mobile app platforms (such as Apple or Google) from sharing certain information obtained by automated means with us.


6. PERSONALINFORMATION PROTECTION AND SHARING

No data transmission over the Internet or website can be guaranteed to be secure from intrusion, and is subject to possible loss, interception, or alteration while in transit. Accordingly, REMME does not assume any liability for possible loss, interception or alteration of your information while in transit. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your Personal Information in accordance with data protection legislative requirements We will do any and all efforts and actions prescribed by Applicable Law to store any of Your Personal Information in secrecy, to protect Your Personal Information from accidental loss, disclosure or erasure, from illegal processing or illegal access.  
Your Personal Information is being stored as a database of customers on the Google Drive Personal Account (https://www.google.com/drive/) – cloud storage service with the only right to access belonging to directors of the Company. The directors may authorize access to Personal Data only for those employees or contractors who require it to fulfil their job or service responsibilities. We will ensure that the Personal Data will be stored and processed with the reasonable level of care and security.
We provide all organizational and technical measures for the data protection, which are required under the GDPR, including encryption and pseudonymization of your Personal Information. We take necessary and sufficient organizational and technical measures to protect your information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties. We protect Your Personal Information under internationally acknowledged standards, using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Some of the safeguards We use are firewalls and information encryption, physical access controls to our information centers, and information access authorization controls.
We are sometimes required to compare the Personal Information You provide to third party information bases in order to verify its accuracy and confirm Your identity. This allows Us to comply with relevant Anti-Money Laundering (AML) regulations and “Know-Your-Customer” (KYC) regulations.
We have no Third-Parties with whom we share your Personal Information. Should this change, we will notify you accordingly.
We will not sell or rent Your Personal Information and/or customer lists to third parties without your explicit consent.
We may combine Your Personal Information with information we collect from other companies and use it to improve and personalize the Website and our Product, as well as our content and advertising.
We may use Your name and email address to provide You with information about products or services that may be of interest to You, but we will not use Your Personal Information without complying with applicable laws and, where appropriate, obtaining your consent.
Our services may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates (including, but not limited to, websites on which the Website is advertised). If You follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any Personal Information that may be collected through these websites or services, such as contact and location information. Please check these policies before You submit any personal information to these websites or use these services.
In addition to the disclosures for the purposes identified elsewhere in this Policy, we may disclose information about you:
   • to the extent that we are required to do so by law;
   • in connection with any legal proceedings or prospective legal proceedings;
   • to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); and
   • to the purchaser or seller (or prospective purchaser or seller) of any business or asset which we are (or are contemplating) selling or purchasing.


7. INFORMATIONSTORAGE AND RETENTION

We will store your Personal Information till it is necessary to carry out our obligations regarding the Services we provide to you. This period lasts from 12 to 36 months and can be extended in specific cases but not more than 5 years. Once your Personal Information is not used anymore for the purposes listed in this Policy and if we are no longer legally obliged to hold your Personal Information for regulatory or legal purpose, we will anonymize or dispose of your Personal Information in line with acceptable industry and security standards so that this information cannot be subsequently retrieved and associated with you.


8. SECURITY

We use relevant electronic and procedural safeguards to protect the privacy of the information You rovide to Us from loss, misuse, disclosure, alteration and destruction. Please note that transmission of information or information (including communications by e-mail) over the Internet or other publicly accessible networks is not one hundred percent secure. Please note that We are not liable for the security of any information You are transmitting over the Internet, or third-party content.

9. YOUR RIGHTSREGARDING YOUR PERSONAL INFORMATION

Regarding your Personal Information, you have the right to request us:
   • an access to the information that was collected;
   • to withdraw your consent (if applicable);
   • to rectify/erase your Personal Information;
   • to update and keep information accurate;
   • to delete any undesirable collected information, we shall delete Your respective Personal Information from any sources within 24 hours from the moment We receive such request from You.;
   • to restrict the processing of the information;
   • to stop the processing of the information in case that the information is used for direct marketing purposes; and
   • to send your Personal Information to any third party in structured and machine-readable format.

You can complete requests by contacting us at team@swapy.app. If you believe that our use of your Personal Information violates your rights, you can lodge a complaint with your national data protection authority.

10. CONTACT DETAILS

Should you have any questions about this Privacy Policy, please contact us.
You may email us at team@swapy.app
Our registered office is at: QUIJANO & ASSOCIATES (BVI) LIMITED, Quijano Chambers, P.O. Box 3159, Road Town, Tortola, British Virgin Islands.