Privacy and Data Retention Policy

This Privacy and Data Retention Policy (the Policy) explains the way in which Changelly Pro (hereinafter referred to as “Company”), Fintechvision Ltd. (hereinafter referred to as “Changelly”), and Sum & Substance Ltd. (hereinafter referred to “Sum & Substance”) collects, uses, shares, and protects Personal Data of users ("User", "you") obtained through the website ("Website") associated applications and its Technology Platform. The terms “we,” “us,” and “our” refer to “Company”.

Personal Data” is an information and data that identifies or can be used to identify, contact, or locate the person to whom such information and data pertains.

At Company, we are fully committed to respecting privacy and to protecting any data that our users provide. Your privacy and security are both our highest priorities and we make every effort to ensure that all the data provided by you is protected.

  1. Who we are

The Personal Data on the Website is collected, controlled and processed by the

  • Changelly Pro, a legal entity with registration address 306 Victoria House, Victoria, Mahe, Seychelles, contact e-mail: [email protected]
  • Fintechvision Ltd. 7/F, Woon Lee Commercial Building, 7-9 Austin Ave, Tsim Sha Tsui, Kowloon, Hong Kong, contact e-mail: [email protected]
  • Sum & Substance Ltd. Office 7 Westwood Business Centre, Continental Approach, Westwood, Kent, United Kingdom, contact e-mail: [email protected]
  1. Personal Data which We May Collect
    • While providing our services, we may collect the following Personal Data:
      • Data necessary for registration. In order to access the full functionality of the Website, you need to register. When you go through the registration process, you shall provide an e-mail address and any other information, that can be required according to AML/KYC procedure and create a password.
      • Financial Data. For user accounts, we may collect financial data including data on your balance accounts, your trade history, incoming and outgoing transactions.
      • Information, which we may collect through automated means. Through your use of the Website, we also monitor and collect tracking information related to usage such as access date & time, device identification, operating system, browser type and IP address. This information may be directly obtained by Company or through third party services.
      • We reserve the right to require verification data for the purpose of AML/KYC procedure, including without limitation photographs of national identity documents, like passport, driving license ID card, and identification data from these documents, utility bill details for residence verification, etc.
      • For the purpose of AML/KYC procedure we may require details to and proof of funds: i.e. banking statements or any other details provided by banks or financial institutions, contracts of sales or contracts in general, or any other suitable data to prove or determine the origin of funds. In order to determine User's purpose for using the services of the Company, additional information on recent, past or planned business or personal activities of business or private User or other data to determine the User's intentions, if necessary, can be processed, as requested by Company or provided by the User.
      • The Technology Platform may collect some of your behavior data, such as pages you have visited on our Technology Platform, clicking on ads and similar. Metadata related to such information, such as timestamps and geolocation data, may be attributed to your behavior information and may be collected by us.
      • If for any reason you share with us some other Personal Data, we may collect it as well.
    • We use Google Analytics on Our Technology Platform. If You want to know more about Google Analytics and its “do not track” policy, please visit
  2. Children
    • If you are under 18, have not yet reached legal age of your country, or by any other reason require parental guide, do not enter any personal data on our Website.
    • Technology Platform is not intended to be solicited for anyone under the age of 18 (or higher in accordance with your local rules for legal age).
  3. Our Use of Your Data
    • We collect, retain and use Personal Data solely for the purpose of providing and improving the Website. In particular, we use users' Personal Data for the following purposes:
      • For Website maintenance. We use Personal Data to ensure that our services function properly. Legitimate purpose of processing is performance of contractual obligations;
      • For Website improvement. Personal Data helps our systems ensure that our interface is accessible for users across all platforms. Legitimate purpose of processing is performance of contractual obligations;
      • For compliance with legal obligations. In many countries the laws oblige us to collect certain information about our users (Know Your Client and Anti-Money Laundering regulations). Legitimate purpose of processing is compliance with legal obligations;
      • For assets protection: The Personal Data may be used for your identification and identification the assets belonging to you in order to secure your accounts. Data about your transactions allows us to monitor suspicious activity and protect you from fraud and scam activity. Legitimate purposes of processing are protection of the legitimate interests and performance of contractual obligations;
      • For periodic e-mails: We may use the data we collect from you when you register or use certain other site 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. We may also send periodic emails with news and Website updates, or use data to follow up with you following live chat or email. Legitimate purposes of processing are performance of contractual obligations, protection of legitimate interests;
      • For disputes resolution and enforcement of our agreements to the extent necessary and sufficient for protecting your interests or interests of other Users. Legitimate purpose of processing is protection of legitimate interests.
  1. Data Retention
    • We will retain your data only for as long as is necessary for the purposes set out in this policy. We will retain your data just to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
  2. Sharing of the Data
    • In connection with the Services provided on the Website, to protect our legitimate interests or to fulfill legal requirements, it may be necessary to share your Personal Data with our employees, agent and officers; subsidiaries; with business partners of Company; as well as with applicable public authorities and law enforcement. Specifically, such sharing of data may be necessary to respond to your inquiry, to execute the Services, to provide access to additional data and to inform you on new services or offers.
    • To the extent we are requested by public competent authorities or courts and legally required to do so, we may share your Personal Data with them or other third parties.
    • The data sharing may include transfers to companies or organizations in third countries. In these cases, we transfer Personal Data in accordance with applicable provisions on the international transfer of Personal Data, such as, where applicable, the respective provisions of the EU General Data Protection Regulation (GDPR).
  3. Cookie Policy
    • Cookies are small pieces of data sent by Website and stored in user's device. Cookies may include an anonymous unique identifier.
    • The cookies allow us to recognize your browser or device, learn more about your interests, and provide you with essential features and services and for additional purposes, including:
      • Authentication;
      • Remembering stateful information;
      • Remembering arbitrary pieces of information.
    • The browser cookies may be managed through your browser settings. On most browsers it is possible to enable prevention from accepting new cookies; notification on a new cookie receipt; to disable cookies. If you disable all cookies on your browser, neither we nor third parties will be able to transfer cookies to your browser. If you do this, however, you may have to manually adjust some preferences every time you visit a Website and some features and services may not work. Please refer to "Help" feature on your browser to learn more.
  4. Security Measures
    • The Company, Changelly and Sum & Substance aims to protect your data as much as we aim to protect our own information and network. We will not authorize any third parties with whim we share Personal Data to contact you directly on an unsolicited basis in relation to their own products or services. We do not sell, trade, or rent your personal identification data to others.
    • We use certain security measures to help keep your personal data safe, but we cannot guarantee that these measures will stop any users try to get around the privacy or security settings on the Website through unforeseen and/or illegal activity. That is why we make no warranty, express, implied or otherwise, that we will prevent such access. You accept and agree that you should never disclose your account password to unauthorized parties.
  5. Your Rights to Your Data
    • In accordance with effective regulations You are entitled with certain rights related to your Personal Data, such as e.g.:
      • The right to access and amend the personal data we hold about you. You have a right to request a copy of the personal data we hold about you. Also you have the right to correct or update your Personal Data at any time.
      • The right to delete your Personal Data. In accordance with the "Right to be forgotten", we leave the opportunity to erase User’s account in any time. If you do not want to use Website or want your data to be erased, you can request us to remove your account permanently. In this case, Company will cancel your account and delete your personal data subject to erasure.
      • The right to restrict processing. You have the right to ask us to restrict the processing of your personal data. When processing is restricted, we can still store your data, but will not use it further.
      • In certain cases you have the right to object to the processing of your data. You have a right to object to our use of your personal data. This right also includes the right to object to processing your personal data for marketing and advertising purposes. You can do it by clicking on the special button (an unsubscribe button) or by contact us and opting out from receiving all e-mails. In case you want to exercise your right under this clause please contact us via e-mail, indicated in cl. 2 and 13.1 of this Privacy Policy.
      • You can withdraw your consent to processing your personal data by us. In case you want to exercise this right, you may contact us via e-mail, indicated in cl. 2 and 13.1 of this Privacy Policy.
      • The right to data portability. You have the right to receive personal data you provide to us, in a "commonly used machine-readable format". This allows you to obtain and reuse your data for your own purposes across different services.
      • The right to lodge a complaint with a Supervisory Authority. We take privacy concerns seriously. If you believe that we have not complied with this Privacy Policy with respect to your Personal Data, you may contact our respective Data Protection Office. We will investigate your complaint promptly and will reply you within 30 (thirty) calendar days. If you do not receive acknowledgment of your complaint or your complaint is not satisfactorily addressed, you have the right to lodge a complaint with the respective supervisory authority.
      • In case you want to exercise your rights, please contact us via e-mail, indicated in cl. 2 and 13.1 of this Privacy Policy.
    • There are exceptions to these rights, however. For example, access to personal data may be denied in some circumstances if making the data available would reveal personal data about another person or if we are legally prevented from disclosing such data. In addition, where some of the data is necessary to maintain Company or where that is a legal requirement, we may retain such data for the period it is needed or required even if you withdraw your consent or cancel your account. Such data will not be considered as subject to erasure.
  6. Law and Harm
    • Notwithstanding anything to the contrary in this Policy, we may preserve or disclose your data if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our or our users’ rights or property. However, nothing in this Policy is intended to limit any legal defences or objections that you may have to a government’s request for disclosure of your data.
  7. Declarations of consent
    • By checking the respective box as a part of the registration process, the User confirms to have read the Privacy Policy and agrees to the data processing as described herein.
    • The User has the right to withdraw his consents at any time via mail to Changelly Pro, 306 Victoria House, Victoria, Mahe, Seychelles, or via E-Mail to [email protected]. The withdrawal of the consent does not affect the lawfulness of processing based on consent before its withdrawal.
  8. Changes to Policy
    • This Policy may be amended at our full discretion without prior notice. We encourage you to review it periodically in order to be aware of the changes we may have made. Reading it carefully and checking for any modifications is your responsibility. By using the Website, you accept and agree to the Policy and the Terms of Use.
  9. Contact Us

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