One of the main priorities of Ashswap AG (‘’Ashswap’’) is the protection of the privacy of all visitors of the Ashswap web app https://app.ashswap.io and https://ashswap.io website and its sub-domains.
As We are committed to protecting and respecting Your privacy, the following information will provide You an overview of what happens to Your Personal Data we collect, use, and share in connection with the Ashswap website as well as the purposes we use it. We are aware of the importance of how Personal Data as confidential information are handled and We assure you that We observe all applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”). Unless otherwise indicated, terms used in this Regulation shall have the same meaning as under GDPR.
Ashswap tries to collect and store as little as possible of your personal data, such as first name, last name, street address, date of birth, email address, or IP address.
Ashswap in particular collects non-identifiable data, such as public on-chain data, and limited off-chain data like device type, browser version, etc. This is to help drive production vision, not track users. - Ashswap endeavours to refine its practices by exploring methods to further protect consumer privacy such as opt-out prompts, migrating to privacy-centric tooling, and deploying proxies to anonymize network traffic. - Users are empowered to explore client-side privacy techniques and tools.
YOUR LEGAL RIGHTS
If you are located in the EEA and if we collect your personal data you have certain rights in relation to your personal data:
Right of access and information
You have the right to request from us free confirmation of the processing of the data or information in question and to be informed of such data and to receive further information and a copy of the data in accordance with the provisions of the law. The subject of the information is the stored personal data themselves, the origin of the data, their recipients, and the purpose of the data processing (cf. Art. 15 GDPR).
Right of rectification
You have the right to correct your data when it is inaccurate or incomplete (for example, change your address).
Right to cancel or blocking
You have the right to demand from us as the responsible party the immediate deletion of the data concerned or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions (cf. Art. 17, 18 GDPR).
Right to data transfer
You have the right to demand from us that we hand over to you or pass on to third parties the data concerning you which you have made available to us in accordance with the statutory provisions (cf. Art. 20 GDPR). Direct transfer to another responsible party is subject to technical feasibility.
Right to object and withdraw your consent
You may withdraw consent at any time where we are relying on consent to process your data. However, we note that this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will of course advise you if this is the case at the time you withdraw your consent. At any time, you may withdraw your consent or object to the receipt of newsletters and advertising emails, the personalization of advertisements, or the sharing of your data with our partners (except for technical service providers) by email request to [email protected].
We will not refuse any requests submitted by you to exercise your rights without a legal reason.
We will consider all requests to exercise your rights and provide our response without undue delay (and in any event within one month of your request unless we tell you we are entitled to a longer period allowed by applicable law).
Certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims. If an exception applies, we will tell you this when responding to your request.
We may request you provide us with information necessary to confirm your identity before responding to any request you make.
DATA WE COLLECT
Privacy is central to everything we do at the Ashswap. And we've enshrined transparency as one of our Company values. Accordingly, we aspire to be transparent about what little data we do collect. When you interact with the Services, we collect only:
Publicly-available blockchain data. When you connect your non-custodial blockchain wallet to the Services, we collect and log your publicly-available blockchain address to learn more about your use of the Services and to screen your wallet for any prior illicit activity. We screen your wallet using intelligence provided by leading blockchain analytics providers. Note that blockchain addresses are publicly-available data that are not created or assigned by us or any central party, and by themselves are not personally identifying.
Information from localStorage and other tracking technologies. We and our third-party services providers may access and collect information from localStorage, mobile deviceID, cookies, web beacons, and other similar technologies to provide and personalise the Services and features of the Services for you across sessions. For example, we may use this information to remember tokens you import, star, or add to your shopping bag. We may also use this information to learn about your preferences, your use of the Services, and our interactions with you. Information we collect from these technologies may include things such as browser type, referring/exit pages, operating system, device or browser language, and other device information. We group and analyse these user journeys collectively, in the aggregate, to improve our product user experience.
Information from other sources. We may receive information about your wallet address or transactions made through the Services from our service providers in order to comply with our legal obligations and prevent the use of our Services in connection with fraudulent or other illicit activities.
Some features of the Services may require you to directly enter certain personal information about yourself. You may elect not to provide this personal information but doing so may prevent you from using or accessing these features. Personal information that you directly submit through our Services may include:
- Survey or usability information. If you participate in a survey or usability study with us, we will record any biographical information you directly provide to us (for example, your name, email, and job title), the responses you provide to us, and your interactions with the Services.
- Correspondence. We will receive any communications and information you provide directly to us via email, customer support, social media, or another support channel (such as Twitter or Discord), or when you participate in any surveys or questionnaires.
- Biographical information. If you apply for a job with us, we collect all information provided through our Jobs form, including name, email phone, work and immigration status, and any other resume, cover letter, or free form text you include.
Cookies are small files that are automatically created by Your browser and stored on Your end device (computer, tablet, smartphone, etc.) when You visit our website and do not cause any damage. They are either stored temporarily for the duration of a session (“session cookies”) or they are permanently archived on your device (“permanent cookies”). Session cookies are automatically deleted once You terminate your visit. Permanent cookies remain archived on Your device until you actively delete them, or they are automatically eradicated by Your web browser. In some cases, it is possible that third-party cookies are stored on Your device once You enter our site (“third-party cookies”). These cookies enable You or us to take advantage of certain services offered by the third party.
Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of the cookies (e.g., the display of videos). The purpose of other cookies may be the analysis of user patterns or the display of promotional messages. Cookies allow Us to analyze Your interaction with our services, make improvements and recognize Your browser the next time You visit and use the information to personalize Your experience.
Any visitors and users that deny the use and saving of cookies from this website are advised to take the necessary steps within their web browsers security settings to block all cookies from this website. Please note that deactivating cookies means that You may not be able to use all functions of our website. Accepting cookies is not a prerequisite for visiting our website.
In the event that third-party cookies are used or if cookies are used for analytical purposes, We will separately notify You in conjunction with this Data Protection Policy and, if applicable, ask for Your consent.
Tracking pixels work in a similar way to cookies and may allow us to gather information about Your behavior on Our website or emails received from Us. Tracking pixels are electronic images that may be used to help deliver cookies, count website visits, understand usage and allow us to analyze how users find Our service, make the service more useful to You, and tailor Your experience with Us to meet Your particular interests and needs.
HOW WE USE DATA
We use the data we collect in accordance with your instructions, including any applicable terms in our Terms of Service, and as required by law. We may also use data for the following purposes:
- Part of the data is collected to ensure flawless provision and security of the Website and the Services.
- Providing the Services. We use the data we collect to provide, maintain, customise and improve our Services and features of our Services.
- Customer support. We may use the information to provide customer support for and answer inquiries about the Services.
- Safety and security. We may use data to protect against, investigate, and stop fraudulent, unauthorised, or illegal activity. We may also use it to address security risks, solve potential security issues such as bugs, enforce our agreements, and protect our users and Company.
- Legal compliance. We may use the information we collect as needed or requested by regulators, government entities, and law enforcement to comply with applicable laws and regulations.
- act in any other way we may describe when you provide us with any information.
LEGAL BASIS FOR PROCESSING DATA
We may process information and any other data collected by us under the following conditions:
- Performance of a contract: If necessary for the performance of an agreement with you or for any pre-contractual obligations thereof.
- Legal obligations: If necessary for compliance with a legal obligation to which the Company is subject.
- Vital interests: If necessary, in order to protect your vital interests or those of another natural person.
- Legitimate interests: If necessary for legitimate interests pursued by the Company.
- Consent: If you have given your consent for us to process information and any other data collected by us for one or more specific purposes.
In any case, Ashswap will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of data is a statutory requirement or a contractual or pre-contractual.
If you feel that your rights have not been respected after having contacted us, you have the right to make a complaint to the competent supervisory authority. For Liechtenstein, the competent authority is:
Datenschutzstelle Liechtenstein: Städtle 38, Postfach 684, FL-9490 Vaduz, T +423 236 60 90, [email protected]
HOW WE SHARE DATA
We may share or disclose the data we collect:
- With service providers. We may share your information with our service providers and vendors to assist us in providing, delivering, and improving the Services. For example, we may share your wallet address with service providers like Infura and Cloudflare to provide technical infrastructure services, your wallet address with blockchain analytics providers to detect, prevent, and mitigate financial crime and other illicit or harmful activities, and your activity on our social media pages with our analytics provider to learn more about you interact with us and the Services.
- To comply with our legal obligations. We may share your data in the course of litigation, regulatory proceedings, compliance measures, and when compelled by subpoena, court order, or other legal procedure. We may also share data when we believe it is necessary to prevent harm to our users, our Company, or others, and to enforce our agreements and policies, including our Terms of Service.
- Safety and Security. We may share data to protect against, investigate, and stop fraudulent, unauthorized, or illegal activity. We may also use it to address security risks, solve potential security issues such as bugs, enforce our agreements, and protect our users, Company, and ecosystem.
- Business changes. We may transfer or share data to another entity in the event of a merger, acquisition, bankruptcy, dissolution, reorganization, asset or stock sale, or other business transaction.
- With professional advisors, such as auditors, law firms, or accounting firms in our legitimate interests or as required by law.
- With your consent. We may share your information any other time you provide us with your consent to do so.
- When you request us to share certain information with third parties, such as through your use of social media widgets or login integrations.
- We do not share your information with any third parties for any marketing purposes whatsoever.
TRANSFER OF DATA TO NON-EU COUNTRIES
Among other things, We use tools and services of companies domiciled outside the EU. If such tools are active and your personal data is being transferred outside the EAA, We make sure that the transfer is made only to countries that have been declared as offering an adequate level of protection through a European Commission decision (‘Adequacy Decision’). In absence of an Adequacy Decision, appropriate safeguards are in place and asserted by each contractual party.
Cookies from Google Analytics are stored for 1 year. Other cookies are stored in the user’s localStorage on their personal device. Ashswap does not delete these localStorage cookies, therefore You are responsible to manually delete them within your web browser.
If You submit inquiries to Us via Our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by Us in order to handle Your inquiry and in the event that We have further questions.
The processing of these data is based on Art. 6(1)(b) GDPR, if Your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases, the processing is based on Our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or on Your agreement (Art. 6(1)(a) GDPR) if this has been requested.
The information You have entered into the contact form shall remain with Us until you ask Us to eradicate the data, revoke Your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g., after we have concluded Our response to Your inquiry). This shall be without prejudice to any mandatory legal provisions, in particular retention periods.
ANALYSIS TOOLS AND ADVERTISING
This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and/or its affiliates.
Google Analytics uses so-called cookies. Cookies are text files, which are stored on Your computer and that enable an analysis of the use of the website by users. The information generated by cookies on your use of this website is usually transferred to a Google server in the United States, where it is stored. Google will possibly also transmit this information to third parties, insofar as this is prescribed by law or insofar as third parties process these data on behalf of Google.
The storage of Google Analytics cookies and the utilisation of this analysis tool are based on Art. 6 Sect. 1 lit. f GDPR. The operator of this website has a legitimate interest in the analysis of user patterns to optimize both the services offered online and the operator’s advertising activities.
Google Tag Manager
We use Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland and/or its affiliates.
The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via it. However, the Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States.
The Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the quick and uncomplicated integration and administration of various tools on his website. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the GDPR. This consent can be revoked at any time.
We also use Meta Pixel. This tool is operated by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. It allows Us to understand and deliver ads and make them more relevant to You. The collected data remains anonymous, and We cannot see the Personal Data of any individual user. However, the collected data is saved and processed by Meta. Meta may be able to connect the data with your Facebook or Instagram account and use the data for their own advertising purposes. Meta has ultimate control of the information gathered through Meta Pixel.
On our website We use the visitor action pixel of Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA ("Twitter") for statistical purposes. The pixel enables us to track the behaviour of users after they have been referred to our website by clicking on a Twitter ad. This process is used to evaluate the effectiveness of Twitter ads for statistical and market research purposes and may help to optimize future advertising efforts. The data collected in this way does not allow us to draw any conclusions about the identity of users. However, the data is stored and processed by Twitter so that a connection to the profile of the respective user is possible and Twitter can use the data for its own advertising purposes. This data may enable Twitter and its partners to place advertisements on and outside Twitter. A cookie may also be stored and read on users' computers for these purposes.
SOCIAL PLUG-INS (Facebook, Twitter; Linked-in etc.)
Our internet pages do not use social plugins from Facebook and Twitter, this means, when visiting our website, no information is passed on to the Facebook and Twitter providers. However, you can share content on your own Facebook and Twitter profiles through our website by visiting links from Facebook and Twitter. You then leave our website and will be redirected directly to the websites and features of the respective providers. The information that they collect about You can be found in the privacy statements of the respective providers.
LINKS TO OTHER THIRD-PARTY WEBSITES
LINKS TO OTHER THIRD-PARTY WALLETS
We do not intentionally gather Personal Data from visitors who are under the age of 13. Our Terms and Conditions require all users to be at least 18 years old. If a child under 13 submits Personal Data to Us and we learn that the Personal Data is the information of a child under 13, We will attempt to delete the information as soon as possible. If You believe that We might have any Personal Data from a child under 13, please contact Us via the form contact or our indicated e-mail indicated in section 3.