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1. General provisions

This Policy defines the procedure for collecting, processing, using, storing and protecting personal data of users of the Change service (hereinafter referred to as the “Service”).

The Service processes personal data in accordance with the requirements of legislation in the field of personal data protection, anti-money laundering rules (AML/CFT) and “Know Your Customer” (KYC) procedures.

By using the Service, the User confirms that he has read this Policy and consents to the processing of his personal data.

2. What personal data is collected?

2.1 Identification data

  • first name, last name, patronymic
  • date of birth
  • citizenship
  • identification document data
  • photo of the document
  • selfie or video with the document

2.2 Contact data

  • email
  • phone number
  • instant messengers
  • residential address

2.3 Financial and transactional data

  • crypto wallet addresses
  • transaction hashes
  • transaction history
  • payment details
  • source of funds (SoF)

2.4 Technical data

  • IP address
  • device and browser type
  • operating systеm
  • cookies
  • access logs

3. Purpose of processing personal data

  1. providing exchange services
  2. KYC verification
  3. AML checks
  4. fraud prevention
  5. financial monitoring
  6. processing requests
  7. ensuring security
  8. fulfilling legal obligations

4. Legal basis for processing

  • user consent
  • performance of the contract
  • legitimate interests of the service
  • AML/CFT requirements

5. Transfer of personal data to third parties

The service may transfer data to AML providers, banks, payment systems, regulators and law enforcement agencies solely for the purpose of verifying transactions, enforcing the law and preventing financial crimes.

The service does not sell personal data to third parties.

6. Retention of personal data

Data is stored for at least 5 years after the end of the relationship with the user or longer in cases of investigation, litigation or regulatory requirements.

7. Personal data protection

  • encryption
  • HTTPS
  • employee access restriction
  • access logging
  • multi-level authorization
  • secure server storage

8. User rights

  • obtain information about processing
  • correct data
  • restrict processing
  • withdraw consent
  • file a complaint with the regulator

9. Cookies

Cookies are used for site operation, security, analytics, and fraud prevention.

10. International data transfer

Data may be processed on servers outside the user’s country with an appropriate level of protection.

11. Changes to the Policy

The current version of the Policy is always published on the website.

12. Contact information

For questions regarding the processing of personal data, the user can contact the support service via the contacts on the website.