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Privacy Policy

Last updated on the date of 07\12\2021

Topexchange.io is committed to protecting your privacy. This Privacy Policy applies to the website https://topexchange.io/, and its associated subdomains (collectively the “Services”). By accessing or using our Services, you signify that you have read, understood, and agree to the collection, storage, use, and disclosure of your personal information as described herewith. If you do not agree with the terms of this privacy policy, please do not access the website.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification.

You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted.

Definitions and key terms

For the purposes of this Privacy Policy:

Account means a unique account created for you to access our Service or parts of our Service.

Cookies are small pieces of data generated by a website and saved by your web browser. They are used to identify your browser, provide analytics, remember information about you such as your language preference or login information.

Company (“we,” “us,” or “our”) refers to Svelge OÜ, registration number 14911892, registered address Valukoja tn 8/2 Lasnamäe linnaosa, Tallinn Harju Maakond, 11415, Estonia

Customer (“you” or “user”) refers to the individual accessing the website and/or using the Service

Device – any internet connected device such as a phone, tablet, computer or any other device that can be used to visit Topexchange.io and use the services.

IP address – every device connected to the Internet is assigned a number known as an Internet protocol (IP) address. These numbers are usually assigned in geographic blocks. An IP address can often be used to identify the location from which a device is connecting to the Internet.

Personnel refers to those individuals who are employed by the Company or are under contract to perform a service on behalf of the Company.

Personal Data means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Service refers to the service provided by the Company as described in the platform’s Terms and Conditions.

Third-party service refers to advertisers, contest sponsors, promotional and marketing partners, and others who provide our content or whose products or services we think might be interesting for you.

Website – the platform accessible via https://topexchange.io/

You – a person or entity that is registered with Topexchange.io to use the Services.

Collection of customers personal information

While using our service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

  • Full name, residential address and contact details;
  • Date of birth, place of birth, gender, citizenship;
  • Bank account information, credit card details, including details about your source of funds, assets and liabilities, OFAC information and information on whether you hold a prominent public function (PEP);
  • Any additional personal information provided by email, telephone or other correspondence;
  • Payment details and transaction information;
  • IP address, browser and operating system information, geolocation details;
  • Verification and identification information that includes information necessary to verify your identity such as a passport, driver’s license or Government-issued identity card, as well as whatever information we, in our sole discretion, deem necessary to comply with our legal obligations under various anti-money laundering (AML) obligations.

Note: Failure to provide such information and data may cause usage limitations of Topexchange.io services.

Internal use of personal information

We use your personal data to activate your Topexchange.io account, provide you with and maintain relevant services, including to monitor their usage. The data you shared is used also to manage your registration on the website, fulfill your requests and grant access to different functionalities.

The Company may use personal data also for the performance of a contract – in order to provide our services and products, and enable the completion of the client onboarding process. Besides that, we use the data to contact you by e-mail, telephone, SMS or other forms of electronic communication such as a mobile application’s push notifications.

Further to the above, we must ensure our compliance with various legal obligations imposed by relevant legislation – anti-money laundering laws, financial services laws, corporation laws, privacy laws and tax laws. Such obligations and requirements imposed on us necessary personal data processing activities for identity verification, payment processing, compliance with court orders, tax laws or other reporting obligations and anti-money laundering controls.

We also take steps to safeguard the legitimate interests pursued by us or by a third party. A legitimate interest is when we have a business or commercial reason to use your information. In the event of issues or disputes we shall ensure they get investigated and resolved in a timely and efficient manner.

Legal bases for processing (for EEA users):

If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:

  • We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
  • It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
  • You give us consent to do so for a specific purpose; or
  • We need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.

Control over personal information

The Company 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. We will also retain usage data (IP address, browser and operating system information, geolocation details) for internal analysis purposes.

Our operations are powered by a vast network of computers, servers, and other infrastructure and information technology, including, but not limited to, third-party service providers committed to the best security of your personal data.

In case of any changes in your personal information (e.g., name, address or telephone number) you must update it accordingly in your Topexchange.io account yourself or contact our customer service. If you want to close your account, you need to contact with the customer service.

We shall not be liable for any losses arising from your failure to maintain the confidentiality of your personal data.

Messages to your email address

When you register for a new account on Topexchange.io website, we will use your email address to send you the following:
1. Email message to validate your mail. We will use your email to communicate with you through it in any future dealings.
2. Email messages to inform you about your orders.
3. Electronic messages to your email that are sent automatically after some operations such as notification of password change, notification about newsletter subscription, etc.
4. Newsletters to your email to inform you about our new products, services and special offers.
To unsubscribe from the newsletters, press “Unsubscribe” link below the message.

User notifications

When you register for a new account on Topexchange.io website, we will use your email address to send you the following:

  1. A message to validate your e-mail address – shall be used for further communication. 2. E-mails to inform you about your orders.
  2. Notifications automatically delivered to your email after certain operations are completed – e.g., password change, newsletter subscription, etc.
  3. Newsletter about our new products, services and special offers. To opt out, press “Unsubscribe” link below the message.

Cookie policy

We are using cookies to improve the quality of the client’s experience on Topexchange.io website. The cookie, a small text file that is stored on the customer’s computer for record-keeping purposes, can be used as an identification card: a cookie is unique to your computer and only the server that gave it to you can read them. By using traffic log cookies, we can identify and monitor what pages are mostly being used. This will help us to analyze data about website traffic and later improve our website. Most existing web browsers can automatically receive cookies, but you can change your browser settings and decide to accept cookies or not. There is one important characteristic – cookies do not provide websites with personal information (such as email addresses or other information) without your permission. Once you choose to provide a website with personal information, your information can be linked to the data stored in the cookie. You should remember that we will not share your personal information with third parties if we do not have permission from you or we are not required to do it by law. Our main goal is to make our website as efficient for you as we can. We can personalize your web experience on our website with cookies: we will remember you as an individual, what content was interesting for you, and as a result, we can remove web pages that are not important and offer you the most popular products and services based on your web preferences (for example we may send you promotional emails with information about our new products, new special offers, special deals, etc.)

Data Protection

We have implemented technical and organizational security measures to ensure the confidentiality, integrity and accountability of your personal information and to protect it against losses, misuse, alteration or destruction. Aforementioned measures include encryption of user personal data, the ability to ensure the ongoing confidentiality of processing systems, the ability to restore the Service due to some technical incident.

In case user data under our control is lost or corrupted, the Company shall restore the data using its backup. In the event of a breach, the Company shall inform you no later than 48 hours after having become aware of the breach.

Your personal data is stored up-to-date under the relevant provision of the Data Protection Regulations with appropriate physical, technological and organizational safeguards and security measures. Only authorized personnel have access to your personal information, and these personnel are required to treat the information as confidential. We audit our procedures and security measures regularly to ensure they are being properly administered and remain effective and appropriate.

Where you have consented to, or we are obliged to disclose personal information to third parties for provision of service ор fulfillment of a legal obligation, we request, when possible, through contractual arrangements, the same level of technical and organizational security measures to be applied.

Disclosure of personal information

We may share your information to the following recipients under particular circumstances:

  • Our correspondent banking partners, disbursement and payment provider partners for the purposes of processing your requested transaction;
  • ID verification services providers used to confirm your identity and meet the applicable AML/CTF & KYC regulatory requirements;
  • Law enforcement agencies and/or other public authorities (e.g., a court or a government agency) when required to do so by law.

Personal data may be also disclosed by the Company in the good faith belief that such action is necessary to protect and defend the rights or property of the Company, or our legitimate business interests require to do so, prevent or investigate possible wrongdoing in connection with the Service, protect the personal safety of Users of the Service or the public, protect against legal liability.

Strict confidentiality agreements shall be observed and adhered to by the respective receiving third parties. We are committed to maximum protection of your personal information, therefore, we only deal with ethical suppliers and business partners who demonstrate similar values and are bound by privacy laws of the same standard.

Funding and transaction information related to your use of certain Services may be recorded on a public block chain. Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to deanonymization and the unintentional revelation of private financial information, especially when blockchain data is combined with other data. Because blockchains are decentralized or third-party networks that are not controlled or operated by the Company, we are not able to erase, modify, or alter personal data from such networks.

GDPR Compliance

Pursuant to GDPR the rights that are available to you in relation to the personal data we hold about you are outlined below:

  1. The right to be informed
  2. The right of access
  3. The right to rectification
  4. The right to erasure
  5. The right to restrict processing
  6. The right to data portability
  7. The right to object
  8. Rights related to automated decision making and profiling

By using our Services, you agree to the collection and use of information in accordance with this Privacy Policy.

Your questions, comments, requests or complaints regarding this Privacy Policy shall be addressed to [email protected]

If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to our lead supervisory authority:

Estonian Data Protection Inspectorate

39 Tatari St., 10134 Tallinn

Telephone: (from abroad add +372) 627 4135

e-mail: info[a]aki.ee

If you are a resident of the United Kingdom and believe we maintain your Personal Data within the scope of the applicable laws relating to personal data in the United Kingdom, you may direct questions or complaints to the UK supervisory authority, the Information Commissioner’s Office.