Introduction

This Privacy Policy (“Policy”) clarifies how XproTech Ltd (hereinafter, “Xprocoinpay”, “we”, “us”, “our”) collects, uses, shares, and protects Personal Information you provide us during the usage of xprocoinpay.com website (the “Website”) or our products. It governs the rules of personal data processing of our clients, their partners representatives and all other Website visitors.

Xprocoinpay commits to protect your privacy. We have implemented all necessary legal, technical and organisational measures to ensure confidentiality, integrity and availability of your Personal Information.

Under “Personal Information” or “Personal Data” we mean any data you can be identified with or which may help to identify you.

The Data Protection Laws – means all laws relating to the processing of Personal Data, privacy and security, including, without limitation, the EU Data Protection Directive 95/46/EC, the Data Protection Acts, 1988 to 2018 (as may be amended from time to time), the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (S.I. No 336 of 2011) and the General Data Protection Regulations (EU) 2016/679 (“GDPR“) together with equivalent legislation of any other applicable jurisdiction, delegated legislation of other national data protection legislation, and all other applicable law, regulations and approved codes of conduct, certifications, seals or marks in any relevant jurisdiction relating to the processing of personal data including the opinions, guidance, advice, directions, orders and codes of practice issued or approved by a supervisory authority or the European Data Protection Board applies to processing of Personal Information by Xprocoinpay.

 

Our Contact Details

All references to “Xprocoinpay”, “us”, “we” or “our” apply to XproTech Ltd, a company incorporated under the laws of the Republic of Cyprus with the registration number ΗΕ 432278.

Our registered office is at: Agias Zonis, 22Α, Floor 1, Office 10, 3027, Limassol, Cyprus.

For all the issues related to data protection please contact us at: compliance@xprocoinpay.com

 

What Type of Personal Information We Collect

The types of Personal Information we may collect include:

  • Contact details (email, telephone number or messenger ID)
  • Details of your identity document
  • Residence address
  • Financial information
  • Employment details
  • Geolocation details
  • History of your logs and activity on the Website
  • IP address, browser and operating system information, device fingerprint.

Most information we collect is provided by you directly. We could also receive some information from publicly available sources (for example, on sanctions) or from our contractors. We make use of screening lists provided by data vendors, ID verification, anti-fraud and transaction monitoring services.

Please note that we will not be able to provide our services to you if you refuse to provide us information according to our KYC/AML requirements communicated to you once you decide to apply for any of our services that require verification of identity and ongoing monitoring of activity. Please keep in mind that in some cases we may require additional details and documents for KYC and AML/CTF purposes.

Please note that processing of your Personal Data may include automated decision-making including profiling. We may apply automated decision-making including profiling for onboarding, maintaining the account with us and fraud prevention purposes.

 

How We Get the Information and Why We Have It

We process our clients’ data for the following purposes:

  • to provide our services to you, as individual, or a corporate client you represent;
  • to contact you or reply to your requests;
  • to comply with our legal obligations (e.g. KYC/AML requirements);
  • to provide assistance in case of criminal investigation and regulatory action;
  • to protect your assets from unauthorized access;
  • to prevent any fraud and scam activity;
  • to provide you information on our products, news and updates;
  • to resolve disputes and protect your interests or interests of other users.

Under the GDPR, the lawful bases we rely on for processing this information are:

  • Your consent. You are able to withdraw your consent at any time by contacting us at compliance@xprocoinpay.com;
  • We have a contractual obligation;
  • We have a legal obligation to comply with AML/CTF requirements under the applicable laws and regulations, keep records for tax purposes;
  • We have a legitimate interest in providing the necessary updates regarding our services, prevent any fraudulent activity proactively and retrospectively, and contacting employees of our clients and business partners.
 
 
Who we share your Personal Information with
 
We may share this information with:
  • our affiliates, agents and representatives;
  • our contractors providing software for identity verification and anti-fraud purposes;
  • our contractors providing us information from publicly accessible sources (for instance on sanctions);
  • our financial service providers through which we facilitate fiat currency transactions to/from our services;
  • law enforcement or regulatory agencies if required or permitted by law.

 

International Transfer of Personal Information

We may transfer your Personal Information outside of the European Economic Area only in the following cases:

  • if the country where we transfer your Personal Information to provides adequate level of personal data protection (based on the relevant decision of European Commission);
  • if we take appropriate safeguards to ensure that your rights as a data subject are protected (e.g., conclude standard contractual clausesor ask for your consent for such transfer);
  • if any derogations for specific situations apply (for instance, if is such transfer is necessary for the establishment, exercise or defence of legal claims or for important reason of public interest).

 

Personal Data Retention

We will ensure that any information we need for any purpose shall not be kept for longer than it is necessary. We retain your personal data just to comply with our legal obligations, resolve disputes, and protect your and our legitimate interests.

We will keep your Personal Information for a maximum period of seven (7) years upon termination of legal relationships with us.

You can always request to remove the personal data. But keep in mind that in certain cases we are obliged to store your information to be legally compliant.

 

Your Rights

Under data protection law, you have rights including:

  • Your right of access – You have the right to ask us for copies of your personal information.
  • Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
  • Your right to erasure – You have the right to ask us to erase your personal information.
  • Your right to restriction of processing – You have the right to ask us to restrict the processing of your information.
  • Your right to object to processing – You have the right to object to the processing of your personal data.
  • Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact us at compliance@xprocoinpay.com if you wish to make a request.

Please note that in some cases we will not be able to fulfil your request due to our legal obligations or overriding legitimate interest. In such cases we will explain you the reasons why your request cannot be fulfilled and how you can complain.

 

Security

Xprocoinpay has implemented security measures to comply with acknowledged international security standards. Our platform also uses SSL or TLS encryption for security reasons and for the protection of confidential content transmission when you send us requests.

 

Our Data Protection Officer

Our Data Protection Officer (DPO) is a person in charge of data protection compliance. You may contact DPO if you have any concerns with respect to our data protection practices at: compliance@xprocoinpay.com.

 

Policy Changes

Xprocoinpay may introduce amendments to the current Policy at any time. We shall notify you on our Website or via E-mail Newsletters.

 

Cookie Policy

We can place cookies and other similar technology on your device, including mobile devices, in accordance with your preferences set on our cookie setting center. Depending on your settings in our cookie consent manager on your mobile device, the following information may be collected through cookies or similar technology: your unique device identifier, mobile device IP address, information about your device’s operating system, mobile carrier and your location information (to the extent permissible under applicable law).

Every time you visit our website, you will be prompted to accept or reject cookies, you can also tailor your selection.

Cookies are small text files that are placed on a user’s device when you visit a website, downloaded to your computer or mobile device when you visit a site and allow a site to recognize your device. Cookies store information about the user’s visit, which may include content viewed, language preference, time and duration of each visit and advertisement accessed.

Cookies are a useful mechanism that do a lot of different jobs, such as letting you navigate between pages efficiently, remembering your preferences and generally improving the user experience. They can help to ensure that the advertisements you see online are more relevant to you and your interests and enable us to identify your preferences. There are a different sets of cookies, and we will explain that later in this document.

We may use information collected from our cookies to identify user behaviour and to serve content and offers based on your profile, and for the other purposes described below, to the extent legally permissible in certain jurisdictions.

In other cases, we can associate cookie information (including information from cookies placed via our advertisements on third-party sites) with an identifiable individual.

Some cookies, web beacons and other tracking and storage technologies that we use are from third party companies (third party cookies) to provide us with web analytics and intelligence about our sites which may also be used to provide measurement services and target ads.

You can adjust your preferences about cookies through our cookie setting center. If you want to remove existing cookies from your device, you can do this using your browser options.

If you want to block future cookies being placed on your device, you can do so by modifying the settings at our cookie setting center. Nevertheless, please consider that deleting and blocking cookies may have an impact on your user experience.

When you visit any website, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience. Because we respect your right to privacy, you can choose not to allow some types of cookies. Click on the different category headings to find out more and change our default settings. However, blocking some types of cookies may impact your experience of the site and the services we are able to offer.