Effective date: 9 December 2020

We are committed to protecting your privacy and safeguarding your personal data. The purpose of this TRADN privacy policy (the “Privacy Policy”) is to inform you about our privacy practices, including how we collect, use and disclose your personal data. This Privacy Policy applies to our crypto currency exchange platform available at https://tradn.io (the “Website”) and the related mobile applications and services (collectively, the “TRADN Services”). If any policies or practices of this Privacy Policy are unacceptable to you, please do not visit, access, or use the TRADN Services.

General information

In this section, we provide you with general information about the entity that is responsible for your personal data, this Privacy Policy, and the TRADN Services.

Owner and data controller

The TRADN Services are owned and operated by Verico International Co., Ltd.. having a registered business address at 12F-6, N. 872, Jhong Jheng Road, Jhanghe City, New Taipei City, 23586, Taiwan (ROC)(“Verico”, “ we”, “us”, and “our”). Verico acts as a data controller with regard to all personal data collected through the TRADN Services.

About the TRADN Services

The TRADN Services include operating and managing a peer-to-peer crypto currency exchange platform and the related services.

Children

The TRADN Services are not intended for children under the age of 18 or equivalent minimum age in the relevant jurisdiction. Therefore, we do not knowingly collect personal data of persons under the age of 18. If we learn that we have collected the personal data of a child under 18, we will immediately take steps to securely delete such information from our systems.

Cookies

To ensure the best possible user experience, we use cookies. For detailed information about our cookies, please refer to our cookie policy available at https://intercom.help/tradn/en/articles/4212972-tradn-cookie-policy

Applicability of the Privacy Policy

This Privacy Policy applies to the TRADN Services only; it does not apply to any third-party applications or software that integrate with the TRADN Services or any other third-party products, services or businesses.

Changes to the Privacy Policy

Your privacy matters to us so whether you are new to the TRADN Services or a long-time user, please take the time to get to know and familiarize yourself with our policies and practices. Feel free to print and keep a copy of this Privacy Policy, but please understand that we reserve the right to change any of our policies and practices at any time, by notifying you accordingly. You can always find the latest version of this Privacy Policy with the effective date here on this page.

Before you submit any personal data through the TRADN Services, you are encouraged to read this Privacy Policy. In most cases, we rely on the lawful grounds for the processing of your personal data other than your consent. However, in some cases, we may seek to obtain your consent. For example, we may seek your prior consent in the following instances:

  • If we intend to collect other types of personal data that are not mentioned in this Privacy Policy;

  • If we intend to use your personal data for purposes that are not indicated in this Privacy Policy;

  • If we would like to disclose or transfer your personal data to third parties that are not specified in this Privacy Policy; or

  • If we significantly amend this Privacy Policy.

Important terms

In this Privacy Policy, you will encounter recurrent terms. For your convenience, we would like to explain what such terms mean:

  • “Consent” means a freely given, specific, informed and unambiguous agreement to the processing of personal data;

  • “Data controller” means the entity that determines the purposes and means of the processing of personal data;

  • “Data processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the data controller;

  • “Personal data” means any information relating to a natural person who can be identified, directly or indirectly, by using such information (e.g., name, address, phone number, email, and IP address);

  • “Processing” means the use of personal data in any manner, including, but not limited to, collection, storage, erasure, transfer, and disclosure of personal data; and

  • “You” and “your” means a natural person or a business entity that accesses and uses the TRADN Services.

Types and purposes of personal data collected

We collect only a minimal amount of personal data that is necessary for ensuring your proper use of the TRADN Services. We use your personal data for specified and limited purposes. In this section, we explain what personal data we collect from you, for what purposes we use that data, and on what lawful bases we rely when processing personal data.

Types of personal data

We comply with data minimisation principles. Thus, we collect only a minimal amount of personal data that is necessary for your use of the TRADN Services. Your personal data can be collected directly from you when you provide it to us (e.g., when you sign up to use the TRADN Services or contact us) or by automated means (e.g., when you browse the Website or make a transaction). The list of the types of personal data that we collect from you is provided in the table below.

Purposes of personal data

We process your personal data only for specified and legitimate purposes explicitly mentioned in this Privacy Policy. In short, we will use personal data only for the purposes of enabling you to use the TRADN Services, providing you with the requested services, complying with our legal obligations (e.g., anti money-laundering laws and regulations), maintaining and improving the TRADN Services, conducting research about our business activities, and replying to your enquiries. We will not use your personal data for any purposes that are different from the purposes for which your personal data was provided.

Overview of types and purposes of your personal data

The values below provides a detailed description of the types of personal data that we collect, the purposes for which we use it, and the legal bases on which we rely when processing your personal data.

When you sign up to receive notifications about the TRADN Services, we collect your:

  • Email address

In order to:

  • To inform you about the TRADN Services

Legally based on:

  • Your consent

When you sign up to use the TRADN Services, we collect your:

  • Email address; and

  • Password.

In order to:

  • To enable your access to the TRADN Services;

  • To register and maintain your user account;

  • To deliver the requested services;

  • To contact you, if necessary; and

  • To analyse and improve our business.

Legally based on:

  • Performing a contract with you; and

  • Pursuing our legitimate business interests (to administer and improve our business).

When you upgrade your user account for transaction, we collect your:

  • Full name;

  • Date of birth;

  • Residential address;

  • Nationality;

  • Identification number;

  • A copy of your identity document and any information included therein;

  • Employment status;

  • Bank account information (bank name, bank account number, bank address, contact details, name of beneficiary, wire instructions);

  • Annual income;

  • Asset net worth;

  • Occupation and industry;

  • Source of funds; and

  • Tax Identification Number.

In order to:

  • To deliver the requested services;

  • To verify your identity;

  • To comply with our legal obligations (e.g., anti-money laundering laws and regulations);

  • To contact you, if necessary; and

  • To analyse and improve our business.

Legally based on:

  • Performing a contract with you; and

  • Pursuing our legitimate business interests (to comply with legal obligations, ensure security, administer and improve our business).

When you make a transaction, we collect your:

  • Trading records;

  • Trading logs;

  • Addresses of digital assets; and

  • Wallet address.

In order to:

  • To facilitate your transactions;

  • To comply with our legal obligations (e.g., anti-money laundering laws and regulations); and

  • To administer, analyse and improve our business.

Legally based on:

  • Performing a contract with you; and

  • Pursuing our legitimate business interests (to comply with legal obligations, ensure security, administer and improve our business).

When you contact us by email or via live chat, we collect your:

  • Email address; and

  • Any personal data that you decide to provide us in your message.

In order to:

  • To respond to your enquiries; and

  • To provide you with the requested information.

Legally based on:

  • Pursuing our legitimate business interests (to grow and promote our business); and

  • Your consent (for optional personal data).

When you make a deposit or withdrawal, we collect your:

  • Name;

  • Bank account information (i.e;, bank account number, bank name, and billing address);

  • Purpose of transaction;

  • Contact information;

  • Relationship of recipient;

  • Recipient information.

In order to:

  • To process your deposits or withdrawals;

  • To maintain our accountancy records; and

  • To comply with our legal obligations (e.g., anti-money laundering laws and regulations).

Legally based on:

  • Performing a contract with you; and

  • Pursuing our legitimate business interests (to administer our business and comply with our legal obligations).

When you use the TRADN Services, we collect your:

  • IP address;

  • Device ID, OS, model name;

  • TRADN App version;

  • Errors encountered;

  • Cookie-related data*; and

  • Your approximate location.

*Please refer to our cookie policy available here for more information.

In order to:

  • To analyse, improve, and evaluate our business activities;

  • To customise the TRADN Services for your location; and

  • To ensure security of the TRADN Services.

Legally based on:

  • Pursuing our legitimate business interests (to analyse and improve our business activities and ensure security)

Failure to provide personal data

Unless specified otherwise, all personal data requested by TRADN is mandatory and failure to provide this data may make it impossible for us to provide the TRADN Services. In cases where we specifically state that your personal data is not mandatory, you are free to not communicate this data without consequence to the availability or the functioning of the TRADN Services. Please note that your provision of non-mandatory personal data constitutes your consent for the processing of such personal data by us.

Additional data

From time to time, we may receive certain additional data if you request support, interact with our social media accounts, submit your feedback or otherwise communicate with us. Please note that the provision of such data is optional and you may choose what personal data you would like to share with us. We kindly request you to exercise your due diligence when making your personal data publicly available. We will use such personal data to reply to you, provide you with the requested services, or for pursuing our legitimate business interests (i.e., to analyse and improve our business).

Sensitive data

We do not collect, under any circumstances, special categories of personal data (sensitive data) from you, such as your health information, opinion about your religious and political beliefs, racial origins, membership of a professional or trade association, or information about your sexual orientation, unless you decide to provide such sensitive data, at your own sole discretion.

Personal data made public

If you decide to publish information about yourself through the TRADN Services (e.g., via your public user profile), you may decide to reveal certain information about yourself. Please keep in mind that such data will become available to other users of the TRADN Services. Therefore, we request you to exercise your due diligence and not to disclose your personal data that is not necessary, extensive, or sensitive as such data can be used by third parties for unlawful purposes. Also, please note that you are not allowed to publish personal data pertaining to other persons if they have not provided you with their prior consent to disclose such data. We will take immediate steps to remove any information or user accounts from the TRADN Services if we become aware that they contain personal data disclosed unlawfully.

Privacy of transactions

The TRADN Services allow you to conduct transactions with other users of the TRADN Services. We put reasonable efforts to ensure that any transaction-related data remains confidential and properly protected. Moreover, we do not intentionally and directly access, manage, correct, delete, share, or disclose transaction data, unless it is strictly necessary for the provision of the TRADN Services, enforcement of our legal terms, or we are requested by law to do so.

Location of processing

The personal data is processed at the operating offices of TRADN located in Taiwan and in any other places where the data processors appointed by TRADN are located (please refer to the section “Disclosure and transfer or personal data” below for more information about the location of our data processors). The processing of personal data is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.

Disclosure and transfer of personal data

We may need to cooperate with external service providers and share some personal data with them. Also, to ensure the provision of the TRADN Services, your personal data may be transferred outside the country where you reside. In this section, you can find information about the third parties that have access to your personal data, the purposes of disclosure, instances when we make international data transfers, and what safeguards we implement to ensure that your personal is properly protected.

Disclosure of personal data

In addition to TRADN, in some cases, your personal data may be accessible to certain types of third parties involved with the operation of the TRADN Services (e.g. administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, and communications agencies). Such third parties are appointed by TRADN as its data processors. We do not sell your personal data to third parties. The disclosure of your personal data is limited to the situations when such data is required for the following purposes:

  • Ensuring the proper operation of the TRADN Services;

  • Ensuring the delivery of the services requested by you;

  • Providing you with the requested information;

  • Pursuing our legitimate business interests;

  • Enforcing our rights, preventing fraud, and security purposes;

  • Carrying out our contractual obligations;

  • Law enforcement purposes; or

  • If you provide your prior consent to such a disclosure.

List of data processors

We will share your personal data only with the data processors that agree to ensure an adequate level of protection of personal data that is consistent with this Privacy Policy and the applicable data protection laws. The data processors that will have access to your personal data are listed in the table below.

Service: Hosting service provider

Name: Amazon Web Services

Location: The United States & Japan (location of our servers)

More information: https://aws.amazon.com

Service: Identity verification service provider

Name: Sum and Substance Inc.

Location: The United Kingdom & Germany (location of our servers)

More information: https://sumsub.com

Service: Identity verification service provider

Name: HyperVerge Technologies Pvt Ltd.

Location: India (location of our servers)

More information: https://HyperVerge.co

Service: Customer support service provider

Name: Intercom

Location: The United States

More information: https://intercom.io

Service: Error monitoring service provider

Name: Sentry

Location: The United States

More information: https://sentry.io

International transfers of personal data

Depending on your location, we may need to transfer your personal data to a country other than your own for ensuring the proper provision of the TRADN Services and other purposes of your personal data. For example, if you reside in the European Economic Area (EEA), we may need to transfer your personal data to jurisdictions outside the EEA. In case it is necessary to make such a transfer, we will make sure that the jurisdiction in which the recipient third party is located guarantees an adequate level of protection for your personal data (e.g., the recipient is a Privacy-Shield certified entity) or we conclude an agreement with the respective third party that ensures such protection (e.g., a data processing agreement based pre-approved standard contractual clauses).

Disclosure of non-personal data

Your non-personal data may be disclosed to third parties for any purpose. For example, we may share it with prospects or partners for business or research purposes, for improving the TRADN Services, responding to lawful requests from public authorities or developing new products and services.

If requested by a public authority, we will disclose information about you to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.

Successors

In case our business is sold partly or fully, we will provide your personal data to a purchaser or successor entity and request the successor to handle your personal data in line with this Privacy Policy.

Security of personal data

We put our best efforts to keep your personal data safe and secure. In this section, we inform you about our technical measures that help us to protect your personal data.

Our security measures

TRADN takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of your personal data. The security measures taken by us include secured networks, SSL protocol, strong passwords, limited access to your personal data by our staff, and anonymisation of personal data (when possible). In order to ensure the security of your personal data, we kindly ask you to use the TRADN Services through a secure network only.

Handling security breaches

Although we put our best efforts to protect your personal data, given the nature of communications and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law.

Non-personal data

When you use the TRADN Services, we automatically collect some technical data about your device and visits. In this section, we inform you what non-personal data we collect from you and for what purposes we use that data.

Types of non-personal data

When you use the TRADN Services, we automatically collect technical non-personal data for analytics purposes. Please note that de-identified personal data is also considered to be non-personal data. Although such non-personal data allows us to analyse your use of the TRADN Services, it does not allow us to identify you. The non-personal data collected by us includes the following information:

  • Transaction data. When you make a transaction, we collect expected transaction volume, expected transaction frequency, details of transactions you make, such as trades, deposits, withdrawals, parties to send or receive transactions, relationships, and purpose of the transactions.

  • Usage data. When you access and use the TRADN Services, we collect information about the time of your request, the method utilised by you to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilised by you, the various time details per visit (e.g., the time spent on each page) and the details about the path followed within the TRADN Services with special reference to the sequence of pages visited, and other parameters about the device operating system and/or your IT environment.

  • When you contact us, we keep records of any questions, complaints, recommendations, or compliments made by you and the response, if any. Where possible, we will de-identify your personal data.

Purposes of non-personal data

We will use non-personal data for the following purposes:

  • To analyse what kind of users visit and use the TRADN Services;

  • To examine the relevance, popularity, and engagement rate of the TRADN Services;

  • To investigate and help prevent security issues and abuse;

  • To develop and provide additional features to the TRADN Services; and

  • To personalise the TRADN Services for your specific needs.

Aggregated and de-identified data

In case your non-personal data is combined with certain elements of your personal data in a way that allows us to identify you, we will handle such aggregated data as personal data. If your personal data is aggregated or de-identified in a way that it can no longer be associated with an identified or identifiable natural person, it will not be considered personal data and we may use it for any business purpose.

Direct marketing

From time to time, you may receive promotional messages from us. In this section, we explain when you may receive notices from us and what you can do to decline our commercial communication.

Marketing messages

To keep you updated about the latest developments related to the TRADN Services, we will send you direct marketing messages. You will receive such communication only if:

  • We receive your express (“opt-in”) consent to receive direct marketing messages (please note that your voluntary subscription to our updates or newsletters substitutes such consent); or

  • We decide to send you marketing messages about our new services that are closely related to the TRADN Services already used by you.

Opting-out

You can opt-out from receiving marketing messages at any time free of charge by clicking on the “unsubscribe” link contained in any of the messages sent to you, adjusting your account settings, or by contacting us directly.

Informational notices and service updates

If necessary, we will send you important informational notices, such as service-related, technical or administrative emails, information about the TRADN Services, your transactions, user account, privacy and security, and other administrative matters. Please note that we will send such notices on an “if-needed” basis and they do not fall within the scope of direct marketing communication that requires your prior consent.

Retention time

We store your personal data only if it is necessary for its specific and limited purposes. In this section, we specify the time period for which we keep your personal and non-personal data in our systems.

Your personal data shall be processed and stored for as long as required by the purpose for which it has been collected. Therefore:

  • Your personal data collected for purposes related to the performance of a contract between you and TRADN shall be retained until such contract has been fully performed.

  • Your personal data collected for the purposes of the TRADN’s legitimate interests shall be retained as long as needed to fulfil such purposes.

  • If you provide your consent to the processing of your personal data, we will retain your personal data (i) for as long as such personal data is necessary for the purposes for which you have provided your consent or (ii) until you withdraw your consent, whichever comes first.

Once the retention period specified above expires, your personal data shall be immediately securely deleted from our systems. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

Retention as required by law

TRADN may be obliged to retain your personal data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. For example, we may retain your personal data for as long as it is necessary to keep our accountancy records or for the time period stipulated by anti money-laundering laws and regulations.

Retention of non-personal data

We may retain non-personal data pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping non-personal data after you have deactivated your user account for the period of time needed for us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

Your rights regarding your personal data

You have the right to control how we process your personal data. Below, we list the rights that you can exercise with regard to your personal data and explain how you can exercise those rights.

Subject to any exemptions provided by law, you can exercise the right to do the following:

  • Withdraw your consent. You have the right to withdraw your consent at any time where you have previously given your consent to the processing of your personal data;

  • Object to processing. You have the right to object to the processing of your personal data if the processing is carried out on a legal basis other than the performance of a contract with you or pursuing our legitimate business interests;

  • Access your personal data. You have the right to learn what personal data is being processed by us and receive a copy of your personal data;

  • Verify and seek rectification. You have the right to verify the accuracy of your personal data and ask for it to be updated or corrected;

  • Restrict processing. You have the right, under certain circumstances, to restrict the processing of your personal data.

  • Have your personal data deleted or otherwise removed. You have the right, under certain circumstances, to erase your personal data from our systems;

  • Receive your personal data and transfer it to another controller. You have the right to receive your personal data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller; and

  • Lodge a complaint. You have the right to bring a claim before their competent data protection authority.

How to exercise your rights?

Any requests to exercise your rights can be directed to TRADN by using the contact details specified at the end of this Privacy Policy. The requests can be exercised free of charge to you once per year and they will be addressed by TRADN as early as possible and always within one month.

Launching a complaint

If you would like to launch a complaint about the way in which we handle your personal data, we kindly ask you to contact us first and express your concerns. After you contact us, we will investigate your complaint and provide you with our response as soon as possible. If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.

Contact information

For any questions, comments, or requests about this Privacy Policy or your personal data, please contact our Data Protection Officer by using the contact details below.

Company name: Verico International Co., Ltd.

Address: 2F, No. 290, Sec. 4, Zhongxiao E. Rd., Daan Dist., Taipei City, 106, Taiwan

Email address: dpo@tradn.io

Phone number: (+886) 2 2721-1811

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