Privacy policy - WhiteSwap

General information

WhiteSwap ("Exchange") administers https://ws.exchange/ website (the "Website"). This Privacy Policy applies when you use WhiteSwap Website, WhiteSwap application, and other online products and services (collectively, WhiteSwap "Services"), contact WhiteSwap, engage with WhiteSwap on social media, or otherwise interact with WhiteSwap.

This Privacy Policy document advises you of administration regarding to the collection, storage, usage, maintenance, disclosure and elimination (the "Processing") of the Personal Information WhiteSwap receives and collects. WhiteSwap may change and update this Privacy Policy from time to time to reflect changes to Exchange information collection, usage and storage practices.

WhiteSwap encourages you to review this Privacy Policy regularly to stay informed about information practices and the options available to you.

Everything WhiteSwap collects and saves is encrypted as Exchange has implemented the technical and organizational measures designed to secure your information from accidental loss and from unauthorized access, use, alteration or disclosure.

Your privacy is appreciated as WhiteSwap applies all the necessary measures to preserve and secure it and prevent it from unauthorized access, conversion or any disclosure.

Data collection

WhiteSwap may ask you to provide certain Personal Information that can be used to contact or verify your identity, to register and provide Exchange Services to you ("Personal Information").

You may refuse to provide such Personal Information and/or decide to give WhiteSwap any other non-required data. In case you refuse to provide to WhiteSwap your Personal Information, you may not be able to access or use all or any of Services.

WhiteSwap has implemented a variety of security measures to maintain the safety of your Personal Information when you enter, submit, or access your Personal Information.

Purposes of collection

WhiteSwap only collects the Personal Information that is reasonably necessary for WhiteSwap to efficiently conduct its activities (for the proper use of the Website and the Services).

WhiteSwap collects and uses the Personal Information in furtherance of the following aims:

to maintain and improve Website and the Services. WhiteSwap uses Personal Information to ensure that Services function properly;
to establish and verify your identity;
to conduct internal verification check to ensure that you were not coming from the list of blacklisted countries;
to comply with the Anti-Money Laundering and Counter the Terrorism Financing Rules;
to contact you about WhiteSwap products and Services and to provide replies to you;
to protect your assets. WhiteSwap may use information to identify you and the assets belonging - to you in order to secure access to your accounts and to prevent fraud.
to send periodic emails. WhiteSwap may use the information which is collected from you when you register or use certain other Website 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. WhiteSwap 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 WhiteSwap’s agreements to the extent necessary and sufficient for protecting your interests or interests of other users;
to ensure your eligibility for a reward and compliance with other terms and conditions under the WhiteSwap Bug Bounty program.
to provide the possibility for you to register your account at WhiteSwap Governance Forum and to earn WSD tokens, as a representative voting shares at the WhiteSwap Governance.

Regulation

WhiteSwap Privacy Policy includes the provisions of the EU General Data Protection Regulation (GDPR), California Consumers Protection Act 2018 (CCPA), Directive on privacy and electronic communications (ePrivacy Directive), and corresponds to them and also operates within the framework of existing legislation.

You have the following rights under the above-mentioned regulations:

Right to withdraw - you have the right to withdraw consent where you have previously given your consent to the processing of your Personal Information;
Right to object - you have the right to object to the processing of your Personal Information if the processing is carried out on a legal basis other than consent.
Right to be informed - you can ask WhiteSwap what categories of your Personal Information is being collected;
Right to opt out - you can ask WhiteSwap to stop using your Personal Information for business benefits;
Right to erasure (‘right to be forgotten’) - you can ask WhiteSwap to delete your Personal Information;
Right of access - you can ask WhiteSwap to provide the list of actual Personal Information values collected;
Right to non-discrimination - WhiteSwap provides equal Services, meaning they cannot discriminate against your rights;
Right to rectification - you can ask WhiteSwap to correct your Personal Information in a situation when such data available to the Service or disclosed to third parties is inaccurate or incomplete;
Right to restrict - you can ask WhiteSwap to introduce the restriction regime on the processing of your Personal Information, so that in each case the data may be processed only upon separate consent from you.

To exercise any of these rights, please contact WhiteSwap at [email protected]. WhiteSwap will respond to your request to change, correct, or delete your Personal Information within a reasonable timeframe and notify you of the actions taken.

Acceptance

WhiteSwap presumes that you fully understand the scope of rights and obligations. If you do not comply with this Privacy Policy, WhiteSwap expects you to abstain from using Website and/or other Services or registering an Account on WhiteSwap Governance Forum.

This Privacy Policy is an initial part of WhiteSwap Terms of Use. WhiteSwap uses and processes your Personal Information strictly and is limited to the purposes of providing the Website, Services and improving it.

By using Website and/or Services, WhiteSwap assumes that you agree to the collection and use of information in accordance with this Privacy Policy and agree to provide to Exchange an explicit consent to terms and the data practices described in this Privacy Policy and in the Terms of Use including the processing, storage, and usage of your Personal Information.

WhiteSwap will ask your agreement to process your Personal Information for specific purposes and you have the right to withdraw your consent at any time by contacting Exchange.

Also, periodically WhiteSwap may contact you regarding operational issues or to adhere to the performance requirements of the Services. These will not be marketing communications and WhiteSwap will operate under legitimate interests in order to contact you for these reasons.

Personal Information collection

While providing Services WhiteSwap may collect the following Personal Information from you:

first name;
last name;
e-mail;
address of your crypto wallet;

WhiteSwap reserves the right to collect any other data, including data which can be not Personal Information but can be treated as such when combined with other Personal information, such as:

country of residence/;
telegram or other messenger username;
date of birth;
telephone number;
postal address, zip code;
GitHub account information;
your location/timezone information;
your website/social network profile information;
any other information if WhiteSwap deems necessary in accordance with this Privacy Policy and Terms of Use which you may find at the Website from time to time.

WhiteSwap may also obtain information from other sources and combine that with information which is collected through Services.

When You visit the Website or use Services, WhiteSwap automatically collects the Personal Information sent to WhiteSwap by Your computer, mobile phone, or other access device. WhiteSwap collects information that your browser sends whenever you visit Website ("Log Data").

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 Website, access times, web-site navigation paths.

WhiteSwap collects some information automatically, such as monitoring and tracking information, related to usage such as access date & time, device identification, operating system, browser type and IP address, etc.

This data may be directly provided to Exchange or through other third-party services.

WhiteSwap may collect information about your location whenever you interact with Website, for analytical purposes only. Your location can be discovered by your IP-address. This service usage data helps WhiteSwap systems to ensure that the Exchange interface is accessible for users across all platforms and can aid in case of disputes or technical issues.

You agree to provide the Personal Information specified herein and agree that Your provided Personal Information may be processed and stored by WhiteSwap.

The components of Personal Information that mentioned below may be modified from time to time according to the Applicable law and WhiteSwap necessities that will be reflected in this Policy.

WhiteSwap will not collect any other Personal Information except for the mentioned herein until WhiteSwap amended and posts these amendments to this Privacy Policy on the homepage of Website.

When you register an Account on WhiteSwap Governance Forum, You provide WhiteSwap with personal information that includes your contact information that is required for authentication (email address, nickname, name and a password).

WhiteSwap additionally collects information about when you were registered as well as the last time you visited the WhiteSwap Governance Forum.

You can also choose to add a phone number for SMS or Google Authenticator account to be used for 2FA verification for better security protection.

Personal Information WhiteSwap does not process

WhiteSwap does not collect or store any information about children under 18.

WhiteSwap does not process any sensitive Personal Information, such as racial or ethnic origin, membership in political parties or political opinions, religious or philosophical beliefs, trade union membership, genetic/biometric data, health, sex life or sexual orientation.

If you believe that WhiteSwap has collected such information, please directly contact WhiteSwap immediately ([email protected]) in order to delete this information.

Cookie Policy

When You access the Website or use Services WhiteSwap 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 WhiteSwap obtains 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.

If you access Services from a mobile or other device, WhiteSwap may collect information for that device such as a unique device identifier ("UDID"), mobile phone number, and details about your mobile carrier.

WhiteSwap uses these technologies to recognize You as Exchange user, customize 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 adjust your browser to reject all cookies or to indicate when a cookie could be sent. WhiteSwap requests you to provide the explicit consent to use cookies. However, if you do not accept cookies, you may not be able to use Services provided by Website in a full manner.

Security

WhiteSwap protects Your Personal Information under internationally acknowledged standards, using physical, technical, and administrative security measures to protect the privacy of the information You provide to WhiteSwap from unauthorized or accidental access, loss, misuse, disclosure, alteration, destruction as well as from other illegal actions of third-parties.

WhiteSwap has implemented a number of security and technical measures to ensure that your information is protected and securely maintained such as encryption, data storage diversification, internal data access restrictions, anonymization technology, data and asset diversification, and strict physical access controls to buildings & files.

Please note that transmission of information (including communications by email) over the Internet or other publicly accessible networks is not one hundred percent secure, no method of transmission over the Internet is totally secure.

Also, please note that WhiteSwap is not liable for the security of any information You are transmitting over the Internet, or third-party content.

You should also understand the responsibility and take safety precautions to protect your own Personal Information.

If you have any suspicions that your Personal Information has been put in jeopardy, or at any risk, particularly your account, password and/or other information, please make sure to contact Exchange as soon as possible ([email protected]).

Personal Information sharing

WhiteSwap is sometimes required to compare the Personal Information You provide to third-party information bases in order to verify its accuracy and verify you This allows WhiteSwap to comply with relevant Anti-Money Laundering (AML) and Counter the Financing of Terrorism (CFT) regulations or secure your personal assets.

WhiteSwap hasn’t got any third-parties with whom your Personal Information is shared.

Should this change, WhiteSwap will notify you accordingly.

WhiteSwap will not sell or rent your Personal Information and/or customer lists to third-parties without your explicit consent.

WhiteSwap may combine Your Information with information WhiteSwap collects from other companies and use it to improve and personalize the Website and Services, as well as Exchange content and advertising.

WhiteSwap may use Your name and email address to provide You with information about any products or services that may be of interest to You.

In addition to the disclosures for the purposes identified elsewhere in this Privacy Policy, WhiteSwap may disclose information about you:

to the extent required by law;
in connection with any legal proceedings or prospective legal proceedings;
to establish, exercise or defend WhiteSwap legal rights (including providing information to others for the purposes of fraud prevention and reducing any other risks).

Also, in order to provide you with the high quality Services, WhiteSwap uses services from third-party companies.

As part of providing these services, WhiteSwap will share part of your Personal Information with such companies, for example: Cloud services/server services, etc.

In some circumstances WhiteSwap will anonymise your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case WhiteSwap may use this information indefinitely without further notice to you.

If you are located in the EU, make a notice that your Personal Information may be transferred to countries that are not part of the EU.

WhiteSwap will take additional measures in order to establish that your Personal Information is treated just as safely and securely as it would be within the European Union and under the Data Protection Legislation as follows:

choosing only partners and services that are compliant with the EU standards;
limiting access to your Personal Information to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, your personal data) including notifying you and the governing authority where WhiteSwap is legally required to do so.

Personal information protection rights

Regarding your Personal Information, you have the right to request WhiteSwap:

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, WhiteSwap shall delete your respective Personal Information from any sources within 24 hours from the moment WhiteSwap receives 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;
to send your Personal Information to any third party in structured and machine-readable format.

You can complete these requests by contacting WhiteSwap ([email protected]).

Also you may request to access and control the Personal Information WhiteSwap have collected.

Within a reasonable timeframe WhiteSwap will handle any of your requests and notify you of the actions that have been taken.

You can withdraw your consent for your Personal Information processing at any time and ask Exchange to stop access, storage, usage and other processing of your Personal Information if you believe that WhiteSwap don't have the proper rights to do so.

Withdrawing your consent will not affect the lawfulness of any processing WhiteSwap conduct prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

Please keep in mind that WhiteSwap might not be able to provide all Services to You anymore, if you withdraw your consent.

WhiteSwap always works to fully protect your rights and comply with Exchange obligations under Privacy and Data protection frameworks including the GDPR and European Commission standards, and you will always have the opportunity to opt-out.

Personal information retention

WhiteSwap will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes for its collection, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

WhiteSwap may retain your personal data for a longer period in the event of a complaint or if it is reasonably believed that there is a prospect of litigation in respect to WhiteSwap relationship with you.

To determine the appropriate retention period for personal data, WhiteSwap considers the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which WhiteSwap processes your Personal Information and whether WhiteSwap can achieve those purposes through other means, and the applicable legal, regulatory, accounting or other requirements (for example, as needed to provide Services, comply with WhiteSwap legal obligations, resolve disputes, etc.).

By law, WhiteSwap have to keep basic information about its users (including Contact, Identity, Financial and Transactional Data) for at least 5 years after you've requested account deletion.

WhiteSwap will not keep your Personal Information for any longer than is necessary in scope of the reason(s) for which it was collected.

Your Personal Information will be stored according to the following factors which determines the period of how long it will be kept:

WhiteSwap objectives and requirements for performance of the Services;
the types of Personal Information in question;
the purposes for which Personal Information in question is collected, held and processed;
WhiteSwap legal basis for collecting, holding and processing that Personal Information;
any legal obligation to store such Information.

WhiteSwap ensures that Personal Information kept is regularly reviewed against such criteria to access whether it should be kept any longer.

For the purpose of defending WhiteSwap legitimate interests against possible legal claims, please note that correspondence (e.g. email addresses and content, chats with the customer service team, call recordings etc.) will be kept up to 10 years, depending on the limitation period (a limitation period is a time period during which a claim can be made) applicable in your country, after the end of the relationship.

Privacy Policy changes

This Privacy Policy is effective as of the date of publishing on this Website and will remain in effect except with respect to any changes in its provisions in the future, that come into force and will be applied immediately after they are published on the Website.

WhiteSwap may update and/or change the terms of this Privacy Policy, and WhiteSwap will notify you by revising the date at the top of this policy and, in some cases, WhiteSwap may provide you with additional notice such as adding a statement to Website by emailing you directly prior to these changes taking effect, so that you aware of the type of Personal Information WhiteSwap collects, proceeds and storages, and how it will be used, and under what circumstances, if any, WhiteSwap may disclose such information.

This Privacy Policy was last updated on the 6st of June 2021.

Contact details

Should you have any questions about this Privacy Policy, Services, the practices of Website, or your dealings with Website or Services please contact WhiteSwap.

You may send an email at [email protected].