1. Data Controller and Processors
2. Users must be over 18 years old
If you are under 18 years old, please do not use our exchange and do not provide us with any personal data
3. Data categories
– Verification data: for personal accounts: data and documents providing information on your identity, such as full name, residential address, nationality, passport or ID card number, date and place of birth; also, data on your status as political exposed person or sanctioned person; or records from the video authentication process; for corporate accounts: data and documents providing information on the legal entity’s name, address and number; its directors and the legal representative;
– Profession, business and financial data, e.g., origin and source of funds, occupation or business, income, source of wealth, transactional data, payment service provider information, payment details, transaction-ID, etc.
– Log data, e.g., IP-address, transaction data, deposit and withdrawal address, device information, frequency, time, operating system, browser type, device type, unique device identification number, cookies, etc.
– Contact details, e.g. email and phone number – Support requests, e.g., information provided to our support team.
– Marketing data, i.e., statistical and marketing data when you visit our website or social media sites, e.g. number of visitors, frequency, clicks, time, places, target groups, data from cookies and similar technologies, consumer’s behaviour, interests and preferences, data about market research and target groups surveys, etc.;
– Hiring data, e.g. contact data, CV, links to your social media platforms and similar data, if you apply for a job on our website or via LinkedIn
– Other personal data that we consider necessary to comply with our legal obligations under the applicable anti-money laundering laws
– No special categories of data are processed by Monetum.
4. Purpose and lawful basis for processing your data
We will process your personal data only for the below purposes and on the below bases:
– To perform our contract with you, and therefore provide you with our services;
– To comply with applicable laws, subpoenas, court orders, other judicial process, or the requirements of any applicable regulatory authorities
– To provide you with our services, or information about our services, and to review your ongoing needs.
– To establish, exercise or defend legal claims
– To help us improve our services, including support services, and develop and market new tariffs plans and services.
– To keep you updated on our latest services
– To safeguard legitimate interests pursued by us or by a third party
– Marketing purposes. Based on your express consent, we may send you marketing communications, promote tariff plans or affiliate systems on our exchange.
5. Recipients of personal data
We will not sell your data and we will not disclose your data to unauthorised third parties. Your data will only be transferred to:
– Employees, officers and directors within our group of companies to perform our contract with you, fulfil legitimate interests or comply with legal obligations;
– Processors that carry out services for us, e.g. video identification services (e.g. ID Now), IT services (Google), Customer Support (Freshdesk), performance of contracts, account management, accounting, transactions monitoring, and sending out newsletters;
– Regulators or Public Authorities, if we are so required by law or in the context of legal proceedings, if we believe that this is necessary to prevent damages or financial loss, or if this is related to an investigation into suspected or actual fraudulent or illegal activities;
– Other third parties, e.g., payment service providers for the provision of our services or fulfilment of a legitimate interest.
6. Where we store your personal data
We and our third-party service providers and business partners store and process your personal data in the European Union, Switzerland and the United States of America.
7. Your rights
You have the following rights:
– Right of access, i.e. to ask for our confirmation as to whether we are processing your personal data, to know what data we have stored and to receive a copy of your data that are processed
– Right to rectification, i.e., to request the rectification of inaccurate personal data
– Right to erasure, i.e. to ask us to erase your data based on any of the following grounds: the personal data is no longer necessary in relation to the purposes for which they were collected; you withdraw your consent on which the processing was based and where there is no other legal basis or overriding legitimate interest for the processing; the personal data have been unlawfully processed; or erasure of the personal data is required for compliance with a legal obligation under European Union or Member State law to which the Controller is subject. Any such request must include the respective ground.
– Right to restriction of processing, i.e. to ask us to restrict processing of your data based on any of the following ground: you contest the accuracy of the personal data (the restriction shall be put in place for a period allowing us to verify the accuracy of the personal data); the processing of your personal data was unlawful, and you oppose the erasure of your personal data and request instead the restriction of their use; we no longer need your data for the purposes of the processing, but you require them for the assertion, exercise or defence of legal claims; or you have objected to processing of your personal data and it has not yet been determined whether the legitimate grounds of Monetum override your own.
– Right to data portability, i.e. to receive the data that you provided us in a structured, commonly used and machine-readable format. You also have the right to ask us to transfer these data directly to another controller, indicated by yourself, where technically feasible and not adversely affecting the rights and freedoms of others.
– Right to object, i.e. to object to the processing of your data at any time if the processing is based on our legitimate interests. If you have objected to processing, we shall no longer process your personal data, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or unless the processing is for the assertion, exercise or defence of legal claims. The objection does not affect the lawfulness of processing your personal data based on legitimate interests before your withdrawal.
If you are not satisfied with any aspect of the processing of your personal data by us, we would like to discuss it with you to understand how we can rectify the issue. You can do this by sending an email to email@example.com. If you are still not satisfied with our response, you have the right to make a complaint to the data protection authority in the jurisdiction where you work or live or where you believe that the issue has arisen.
8. Retention periods
We will only retain your data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements. As a result, we apply criteria to determine the appropriate periods for retaining your personal data depending on its purpose.
9. What should you consider when sending data over the Internet?
The Internet is not always a secure environment, and unauthorised third parties may access information sent via the Internet. We therefore assume no liability for the security of your information whilst in transit over the Internet to Monetum
10. Data transfer outside Switzerland and EU
Your personal data may be processed in a country outside European Union or Switzerland. However, if we process your data outside the European Union or Switzerland, we will only transfer data for the performance of our (pre)contractual obligations, based on your consent, to comply with a legal obligation or fulfil our legitimate interests. In any case, we will make sure that adequate safeguards are employed by such third parties to ensure that your data are appropriately protected.
11. Social Media
We send newsletters only with your express consent, if you have ticked the related box or where there is a legal basis to do so. You can however unsubscribe from our newsletter, e.g. by withdrawing your consent, at any time.
13. Automated decision-making
We do not use personal data for automated decision-making.
14. Processing for other purposes
We process personal data for the purposes for which they were collected. In exceptional cases, however, we might process your data for other purposes. In such a case, however, we will inform you before the intended processing, the period for which your personal data will be stored, the exercise of data subject rights, the option to withdraw consent, the existence of the right to file a complaint with the data protection authority, whether provision of the data was necessary on legal or contractual grounds and what the consequences would be if it were not provided, and whether automated decision-making or profiling is carried out.
15. Your consent
By ticking the respective separate box for the newsletter, you expressly agree to receive such communications.
You can withdraw your consent at any time by sending an email to firstname.lastname@example.org. Please note, however, that we might not be able to provide all our services to you anymore, if you withdraw your consent. The withdrawal of your consent does not affect the lawfulness of processing your personal data based on consent before your withdrawal.
16. Contact us
Monetum acts as a central point of contact for all data protection issues relating to our services through this website. If you have any query about the processing of your personal data and your rights under the data protection laws, please email email@example.com.