1. General

Switchere.com (hereinafter also referred to as “we,” “us,” “our,”website,” or “Switchere”) is committed to protecting and respecting website visitor’s (hereinafter also referred to as “you” or “your”) privacy in accordance with this Privacy Policy (hereinafter also referred to as “Policy”). We highly value your interest in our fiat-to-cryptocurrency, cryptocurrency-to-fiat and cryptocurrency-to-cryptocurrency exchange services and your privacy is equally important to us. We would like you to feel at ease with how we use and share your personal information.

Switchere.com is a website operated by company FITEUM OÜ (Harju maakond, Tallinn, Kesklinna linnaosa, Roosikrantsi tn 2-529K, 10119, Estonia), license number FRK000680 for virtual wallet service provider and license number FVR000779 for virtual currency exchange provider. Under the General Data Protection Regulation (GDPR) and related laws, we have a legal duty to protect all personal information we collect from you. If you do not agree with the terms of this Policy, please do not use the website services.

The website may contain translations of the English version of the content available on Switchere.com. These translations are provided only as a convenience. In the event of any conflict between the English language version and the translated version, the English language version shall take precedence.

2. Definitions

Service or “Switchere.com”

All the fiat-to-cryptocurrency, cryptocurrency-to-fiat and cryptocurrency-to-cryptocurrency exchange services the website Switchere.com provides including visiting/registering/etc.

Personal Data

Personal Data means any information about a living individual who can be identified by this information (or from other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically, either generated by the use of the service or from the service infrastructure itself (for example, the duration of a page visit, device identification, operating system, browser type, etc.).

Cookies

Cookies are small pieces of data stored on your device (desktop computer, tablet PC or mobile device).

Data Controller

Data Controller means the natural or legal person who determines the purposes for which and the manner in which any personal information is, or is to be, processed. For the purpose of this Privacy Policy, we are the Data Controller of your Personal Data.

Data Subject (or User/Customer)

Data Subject is any living individual who uses the services provided by Switchere.com and is the subject of Personal Data.

3. Information Collection and Use

Personal information may be collected in a number of ways when you visit our website. Types of data collected may include:

Personal Data

While using the Switchere.com services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. We use personal information to offer you the services you explicitly solicited for, to facilitate safe services, survey customer interest in all our services, update you on offers, services, products, customize your personal experience, safeguard us against any fraud, error and other kinds of criminal activities. We may periodically request personally identifiable information may include, but is not limited to:

  • Email address and/or other contact information;

  • First Name and Last Name;

  • Address, state, province, ZIP/postal code, city;

  • Cookies and usage data;

  • Scans/copies of ID documents, photos sent by you, etc.;

  • Financial and transactional information. It includes the names of your chosen financial institutions, the number of bank accounts, balance information, trading history, point of sale details, wallet addresses, etc.;

  • Identity information. It includes facial image and any other data that can be found in your ID documents and thus used to prove your identity;

  • Authentication information. This is information that can be used to authenticate your identity on Switchere.com such as username, password and/or other account information;

  • Shared information. You may share your personal information such as family details, life goals and events with us in the course of our cooperation;

  • Other information described in Terms of Use or other legal documents.

Usage Data

We may also collect information how Switchere.com is accessed and used ("Usage Data"). When you visit our website, some information is automatically collected through the use of log files, such as your computer’s Internet Protocol (IP) address, your computer’s operating system (OS), the browser type, the address of a referring website and your activity on the website. We use this information for purposes such as analyzing trends, administering the website, improving customer service, diagnosing problems with our servers, etc.

Tracking & Cookies Data

Switchere.com uses cookies and similar tracking technologies to track the activity on the website and hold certain information. Cookies are tiny text files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from the website and stored on your device. To collect and track information and to improve and analyze the Switchere.com services, we also use the following tracking technologies, namely: beacons, tags and scripts. You can set up your browser to decline all cookies or to indicate when cookies are being sent. However, if you do not accept cookies, some of the Switchere.com services may be disabled. Examples of Cookies we use: Session Cookies ꟷ cookies to operate the website within a single session; Preference Cookies ꟷ cookies to remember your preferences and various settings; Security Cookies ꟷ cookies for security purposes. All of the cookies we collect are encoded so that no third-party can intercept or use any of the information collected in them.

4. Use of Data

Switchere.com uses the collected data for various purposes:

  • to allow you to open and operate an activated account on Switchere.com;

  • to identify you as a customer and distinguish you from other users of our service;

  • to be able to regularly provide you with functional, secure and customized services;

  • to notify you about changes and upgrades introduced to Switchere.com;

  • to allow you to participate in promotional campaigns run by Switchere.com when you choose to do so;

  • to send you information for marketing purposes and keep you posted on our latest product announcements, and upcoming promotional events;

  • to provide timely and professional Customer Care services and establish a better understanding of you as a valued customer or visitor;

  • to monitor the usage of the Switchere.com services;

  • to detect, prevent and eliminate any technical issues;

  • to prevent losses and/or frauds;

  • to fulfil all mandatory legal obligations.

5. Legal basis for processing personal data under General Data Protection Regulation (GDPR)

If you are or your IP address is from the European Economic Area (EEA), Switchere.com's legal basis for collecting and using the personal information described in this Privacy Policy depends on the personal data we collect and the specific context in which we collect it. In accordance with General Data Protection Regulation (GDPR), we adopt appropriate technical and organizational measures to help prevent unauthorized access to your information and ensure data is held securely.

Switchere.com may process your personal data due to the following reasons:

  • We need to perform a contract with you;

  • You have given us permission to do so;

  • The processing is in our legitimate interests and it is not overridden by your rights;

  • To comply with all applicable laws and regulations.

6. Retention of Data

Switchere.com will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Switchere.com will also retain usage data for internal analysis purposes. Usage data is generally retained for a short period, except when this data is used to strengthen the security or to improve the functionality of our services and functionality, or we are legally obliged to retain this data for longer time periods. By registering on Switchere.com, you give your consent for us to retain your personal data.

7. Transfer of Data

Your information, including personal data, may be transferred to ꟷ and maintained on ꟷ computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. Please take into consideration that we may transfer the data, including personal data, outside your jurisdiction (including outside the EU if it is your jurisdiction) and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. Switchere.com will take all reasonable measures to ensure that your data is treated securely and in accordance herewith and no transfer of your personal data will take place to any entity or country unless there are adequate controls in place including the security of your data and other personal information.

8. Disclosure of Data

In certain situations, we rely on our legitimate business interests in order to collect and use your personal data. In these situations, we have conducted a balancing test to carefully consider the impact of the processing on your interests, rights and freedoms. We will only undertake the processing if we are satisfied there is no negative impact on you. Switchere.com may disclose your personal data in the good faith belief that such action is necessary:

  • to comply with a legal obligation;

  • to protect and defend the rights or property of Switchere.com or its customers;

  • to prevent or investigate any possible wrongdoing in connection with Switchere.com services;

  • to protect the personal safety of users of Switchere.com or the public;

  • to protect against legal liability.

Except as described in this Privacy Policy, Switchere.com will not share personal information with a third party, unless it is your request, you consent to such disclosure, or disclosure is required or authorized by law.

9. Security of Data

In accordance with GDPR, we adopt appropriate technical and organizational measures to help prevent unauthorized access to your information and ensure data is held securely. The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security. The security measures include firewalls, data encryption, and information access authorization controls. While we are dedicated to securing our website and services, you are responsible for securing and maintaining the privacy of your passwords and account registration information and verifying that the personal data we maintain about you is accurate and current.

10. "Do Not Track" signals under California Online Privacy Protection Act (CalOPPA)

We do not support Do Not Track ("DNT"). DNT is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the Preferences or Settings page of your web browser.

11. Data protection rights under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Switchere.com aims to take reasonable measures to allow you to correct, amend, delete, or limit the use of your personal data. However, we imply the same rights to all our users from any jurisdiction.

If you wish to be informed what your personal data we hold and if you want it to be removed from our systems, please contact us. We will do our best to do so as soon as possible unless it is currently not possible due to services provided to you at Switchere.com. In this case, we will fulfil your request after all the obligations under such services are fulfilled.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or to delete the information we have on you;

  • The right of rectification;

  • The right to object;

  • The right of restriction;

  • The right to data portability;

  • The right to withdraw consent. You also have the right to withdraw your consent at any time where Switchere.com relied on your consent to process your personal information (with the exceptions mentioned in Terms of Use).

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your personal data. For more information, please contact your local Data Protection Authority in the European Economic Area (EEA).

12. Service Providers

We may employ third-party companies and individuals to facilitate Switchere.com (hereinafter referred to as the "Service Providers"), to provide Switchere.com on our behalf, to perform Switchere.com -related services or to assist us in analyzing how the website is used. These third-parties have access to your personal data to the extent of performance of these tasks on our behalf and are obliged not to disclose or use it for any other purpose.

13. Links to Other Websites

Switchere.com website may include links to third-party websites, plug-ins and applications. Clicking on third-party links or enabling those connections may allow third parties to collect or share data about you. We do not control such third-party websites and, when you leave our website, we encourage you to read Privacy Policy of every website you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

14. Protecting Children’s Privacy

Switchere.com’s products and services are for a general audience and not aimed at children under the age of 18 and we do not knowingly collect PII from such individuals. If we obtain actual knowledge that we have collected personal data from a child under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data. Contact us directly via the contact form if you believe that we have mistakenly or unintentionally collected information from a child under the age of 18.

15. Establishing Contact with Us and with Other Users

Switchere.com enables you to establish contact with us. It is possible, for example, by sending an email to us, or any message via the permitted message service (in accordance with Terms of Use). The information you provide when contacting us is stored to process the request and, where appropriate, for the subsequent correspondence.

We do not disclose your personal information to any other Switchere.com users unless it is necessary. You agree that, in the course of operating Switchere.com account, it may be required to send to other users, as the case may be, certain transactional information (for example, a unique identifier, your ask/bid info, asset details etc.); but not your First Name and Last Name, ZIP/Postal address, or payment details. We will not be liable for any use or misuse of the transactional data by others, but you must inform us of any misuse of Switchere.com that you have become aware of. You are solely responsible for your interactions with other Switchere.com users. We reserve the right, but have no obligation, to monitor disputes between you and other users.

16. Governing Law and Jurisdiction

Any disputes concerning this Privacy Policy will be governed by the laws of Estonia without regard to any principles of conflicts of law. The state courts of Estonia will have exclusive jurisdiction over any claims arising out of or related to this Privacy Policy.

17. Registration Function

You can register as a user of our Switchere.com service on the relevant website page. The received data will be used in operation of our Switchere.com service, as well as to inform you about changes in the scope of our Switchere.com services, or any technical changes or for other messages (via email). Registration at Switchere.com includes the entry of the following data:

  • Email address;

  • Password;

  • AML/KYC Policy information and documents which may be requested during and after registration, such as gender, First Name, Last Name, phone number, address, ID document, photos, etc. See AML/KYC Policy for more information.

Besides, the IP address used for registration, as well as the date of registration, are securely stored in order to prevent the abuse of registration. By adding information from social networking profiles for Switchere.com registration, we receive information from the social network (profile ID, First Name, Last Name, other data according to terms and conditions of social networks). You agree with processing of your social networking information during registration.

18. Access Data/Server Log Files

Details of your visit to our Switchere.com website are stored in a log file (the so-called "Server Log File"). We collect (or our internet provider servers) the following data on each access to Switchere.com:

  • IP address of the accessing computer;

  • Name of the file requested;

  • Date and time of the request;

  • Amount of data transmitted;

  • Notification of successful request;

  • Browser type and version along with the operating system used;

  • Referrer URL;

  • Requesting provider;

  • Screen resolution.

The log data is used by us only for statistical analysis in the context of operation of Switchere.com. In case of illegal use of our services, the log data also may serve as a resolution in the eventuality of any violation of the law.

19. Monitoring and Recording

We may monitor, record, store and use any telephone, email or other means of communication with you to check any instructions given to us, for instructional purposes, crime prevention, and in order to improve the quality of our Customer Care Team service.

20. Consent

By registering as a user of Switchere.com, you consent to the terms of Privacy Policy without any exclusions or reservations.