“Ecurrencyx“, “we“, “us“, and “our“ refer to Galaxy Digital Holdings Co., Ltd. together with its employees, directors, successors, affiliates, and assignees use variety of tools and third party services to provide services to you (“you”, “customer”, “user”, “your” refer to users of the Service, whether in their capacity as Senders, Recipients, or visitors to our websites or apps).
Ecurrencyx will be the data controller of all personal information you submit to us.
Data collection in public page:
When you browse our web page without logging in, we don't hold any personal data about you, but we use a number of tools to help us maintain the website and provide the best possible experience for you.
We collect 2 types of data about you when you're not logged in:
1) Technical performance, behavioral and affiliate data: This data includes technical logs about page performance and anonymous customer behaviour data to improve the website. This data is anonymous and cannot be tracked back to you, but is essential for us to keep our page and business up and running. Affiliate data does include customer identification number, but it cannot be traced back to you by a third party, only by Ecurrencyx. Here's a list of providers we are currently using:
- Google Analytics - a tool used to track aggregated customer behaviour and provide insights about the system. We're always masking your IP address, so it’s not possible to identify you. – New Relic – a tool which lets developers, ops, and tech teams measure and monitor the performance of their applications and infrastructure.
2) Marketing oriented data: This data is used for marketing purposes, including retargeting you across the web or social networks, measuring conversions, personalising ads based on your profile (e.g. country you're visiting from to provide ads in your native language). Here's a list of providers that we are currently using: - Google DoubleClick/Adwords - a tracking “pixel” to match you on Google network for retargeting purposes and/or conversion tracking.
All this data is stored in your cookies and does not contain personal identifiable information on our side. If you wish to reset this setting, please clear the browser cookies.
Data collection in product:
Once you're logged in, you become an identifiable person to us, thus we track and keep more information about you, including your personal data. We may share your personal information with third parties if we are requested or required to do so by the police or any regulatory or government authority investigating suspected illegal activities, or upon the receipt of a court order, and such disclosure is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect Ecurrencyx rights or property. We may also provide third parties with aggregate statistical information and analytics about users of our Service, but we will make sure that no one can be identified from this information before we disclose it.
Security of your data:
We take protecting your data very seriously - we encrypt the information you provide during the transmission of the information, our internal systems are logging access to your data when/if accessed by our employees, our offices have perimeter control from unauthorized entry, we have internal IT security procedures and use best security practices to minimise risks from outside attacks, all critical systems require 2 factor authentication and/or are accessible only through internal network/VPN.
Why we need your personal data:
1) As a financial institution, we are required to reliably identify the customer before providing any financial service and do everything in our power to prevent any anti-money laundering and fraudulent activities, for which we may need additional information and/or documentation from the customer, depending on specific cases.
2) For regular business operations and fulfilment of our Terms of Agreement with you to use Ecurrencyx services. When sending money, we need to specify who's sending it. We may sometimes request a sender to provide more information or additional documents on a recipient. 3) To protect customers and/or our interests, we keep all communications with our clients to ensure that in case of disputes we have all available communication logs. 4) To provide better offers for you - knowing personal details about means you we can offer you a better, more personalised service and provide valuable offers. We collect 3 types of data in the product:
1) Personal and financial data required to comply with KYC (Know Your Customer), AML and CTF (Anti-Money Laundering and Combating the Financing of Terrorism) regulations and perform financial and business operations:
This data includes your e-mail, phone number, name, surname, address, nationality, date of birth, bank (electronic money payment institution) account information (including debit/credit card details), transaction history and other personal data which may help us comply with the regulation and prevent fraudulent behaviour. When transferring money, we also provide some personal details to our partners (financial intermediates) to complete the transaction (including, but not limited to payment cards processor, sanctions list providers, fraud detection systems, partner banks, electronic money payment institutions).
2) Technical performance, behavioural analysis and communication data:
This data is intended to be anonymous but may include parts of personal data or user related data. We use number of tools to track technical page performance, monitor errors, page usage statistics which help us to improve our services and provide better customer experience and communicate effectively with our customers. Here's a list of providers we are using:
3) Marketing, personalization, profiling data:
We use a wide range of marketing tools to reach to our existing and potential customers. Such tools include retargeting platforms, user-matching “pixels” and other tools to show relevant ads to you and/or improve your experience. Here's a list of providers we are currently using:
Partner selection policy:
We reserve the right to include or exclude new partners to process the data in any of the categories mentioned in this policy. We take data protection seriously and always partner with companies which provide solid Data Processing Agreement (DPA) or other data protection agreements with these companies.
Profiling, segmentation and automated decision making:
We have a very wide range of customers across the world and we try to personalise the experience for them. Profiling ranges from sending marketing communication in preferred language, to new product announcements which might be useful for particular customers or providing special offers. None of our profiling activities cause legal effects for the customer, except for fraud prevention measures which we have a legal responsibility to as per Anti-Money Laundering legislation.
Marketing communication preferences:
Executing your rights to data:
European General Data Protection Regulation (GDPR) gives you more rights to control which data about you can be accessed by companies like us. Here’s a list of rights specified in regulation:
The data subject’s right of access. The data subject’s right to rectification. The data subject right to restriction of processing. The right to be informed. The right to data portability. The right to object data processing.
Cookies are a small piece of information saved in your browser storage. They are used to improve the customer experience in pages and helps third party services to work properly.
Additional information about this policy and future changes:
In the event that we sell any business or assets, personal information may be disclosed or transferred to buyers or prospective buyers of our business or any of our assets as part of any such sale.
This policy is available in different languages. If there’s any mismatch between different languages, English version has higher power.
If you have any questions about this policy, please contact us for more information via email firstname.lastname@example.org. We reserve the right to change this policy and inform the customers either via product or other communication means (e.g. email) 7 days before the actual change.