Политика обработки и защиты персональных данных

1. Contents

• 1. General Provisions
• 2. Users’ Personal Data
• 3. Purposes of Personal Data Processing
• 4. Legal Basis for Data Processing
• 5. Collection of Personal Data
• 6. Storage and Protection of Personal Data
• 7. Transfer of Personal Data to Third Parties
• 8. Use of Data in AML Checks
• 9. Data Processing for In-Office Exchange Operations
• 10. User Rights
• 11. Use of Cookies
• 12. Changes to the Privacy Policy
• 13. Final Provisions

2. General Provisions

This Personal Data Processing and Protection Policy (hereinafter — Privacy Policy) defines the procedures for collecting, storing, processing and using personal data of users interacting with the HASchange digital asset exchange service.

HASchange respects the users’ right to privacy and takes the necessary organizational and technical measures to protect personal data processed within the framework of providing services.

This policy applies to all personal data that may be obtained by the service when a user visits the website, creates a digital asset exchange request, undergoes verification procedures, or otherwise interacts with the service.

By using the website and services of HASchange, the user confirms their agreement with the terms of this policy.

3. Users’ Personal Data

Personal data means any information relating directly or indirectly to an identified or identifiable individual.

While providing services, HASchange may process the following categories of users’ personal data:

• first and last name of the user;
• email address;
• phone number;
• cryptocurrency addresses of the user;
• information about transactions performed;
• IP address;
• browser and device information;
• other information provided by the user while using the service.

In cases предусмотренных AML procedures, the service may additionally request:

• identity document details;
• a photo or scan of the document;
• a selfie of the user with the document;
• proof of residential address;
• documents confirming the source of funds (Source of Funds).

4. Purposes of Personal Data Processing

Personal data of users is processed by HASchange solely for purposes related to the operation of the service and provision of its services.

The main purposes of data processing inсlude:

• ensuring the operation of the digital asset exchange platform;
• processing user requests;
• conducting transactions and settlement operations;
• compliance with AML policy and financial monitoring procedures;
• prevention of fraudulent activities;
• ensuring the security of users and the service;
• providing users with information about the status of operations;
• compliance with applicable legislation and international AML/CTF practices.

5. Legal Basis for Data Processing

Users’ personal data is processed on the following legal grounds:

• user consent to the processing of personal data;
• the necessity of processing data to fulfill a user request;
• compliance with AML procedures and financial monitoring rules;
• protection of legitimate interests of the service and users.

6. Collection of Personal Data

HASchange may obtain users’ personal data in the following ways:

• when filling out a request form on the website;
• when completing verification procedures (KYC);
• when contacting customer support;
• when interacting with the website;
• through automatic collection of technical data.

When visiting the website, the following technical data may be automatically recorded:

• IP address;
• device type;
• browser version;
• information about visited pages;
• time of access to the website.

This information is used exclusively to analyze the operation of the website and improve the quality of services provided.

7. Storage and Protection of Personal Data

HASchange takes reasonable measures to protect users’ personal data from unauthorized access, modification, disclosure or destruction.

To ensure data security, the following measures are applied:

• secure communication channels;
• data access control systems;
• technical data protection tools;
• internal procedures for monitoring data processing.

Personal data is stored only for the period necessary to achieve the purposes of processing or for the period required by applicable financial monitoring regulations.

8. Transfer of Personal Data to Third Parties

HASchange does not sell or transfer users’ personal data to third parties, except in cases where such transfer is necessary for:

• compliance with AML procedures;
• transaction checks using AML tools;
• compliance with legal requirements;
• protection of legitimate interests of the service;
• fulfillment of requests from competent government authorities.

In certain cases, data may be transferred to specialized services used for AML analysis of transactions.

9. Use of Data in AML Checks

Within the framework of financial monitoring policy implementation, HASchange may use users’ personal data to conduct AML/KYC procedures.

• verification of the user’s identity;
• verification of the source of funds;
• analysis of user transactions;
• additional verification of operations.

Personal data obtained as part of AML procedures is used exclusively for financial monitoring purposes and prevention of illegal activities.

10. Data Processing for In-Office Exchange Operations

When performing an exchange transaction during a personal visit to the service office, the user may be required to sign an agreement confirming the exchange operation.

• passport details;
• contact information;
• information about the performed transaction.

This data is used solely to confirm the user’s identity and document the transaction.

11. User Rights

The user has the right to:

• receive information about personal data processed by the service;
• request correction of inaccurate or outdated data;
• request deletion of personal data if its processing is no longer necessary for the purposes of the service;
• withdraw consent to personal data processing.

In case of data deletion, the service may be limited in its ability to provide services.

12. Use of Cookies

The HASchange website may use cookies and similar technologies to improve the website’s operation and analyze user behavior.

Cookies may be used for:

• saving user preferences;
• analyzing website traffic;
• ensuring proper functioning of the website.

The user may restrict the use of cookies in their browser settings.

13. Changes to the Privacy Policy

HASchange reserves the right to make changes to this Privacy Policy.

The current version of the policy is always published on the official website of the service.

Continued use of the website after the publication of an updated version of the policy means the user agrees with the changes made.

14. Final Provisions

By using the website and services of HASchange, the user confirms that they have read this personal data processing policy and accept its terms.

The service strives to ensure a high level of protection of users’ personal data and comply with the principles of confidentiality and information security.