Privacy Policy

Welcome to Sinaz Exchange Brokers SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ Data Privacy Notice, Please spend a few moments reading it carefully before providing us with any information about you or any other person.

1. Introduction

Sinaz Exchange Brokers Sp z oo, Poland the (“Company”, “we” or “our”) registered on 02-04-2024 is a Digital Currency Exchange Provider with KRS(registration) number 0001097311 and address at BARTYCKA street, house no. 22B Apartment no. 21A Warsaw 00-716 Poland. The The company provides services to its users and processes some of your personal data as a data controller.

This Privacy Notice aims to explain the personal data we process, our purposes and methods for such processing, the legal basis we rely on, transfer of your personal data, and your rights, in accordance with our obligation to inform you under the Law on the Protection of Personal Data (the “Law”).

Please Note, Due to FCAs regulations, this service is not directed towards Customers in the United Kingdom

Please also see our Cookie Policy in order to learn more about the cookies we use in our Platform and your personal data we process through cookies.

2. Personal Data We Process About You

Depending on whether and how you use our Platform, or Services, we will process different kinds of personal data about you as follows:

  • Your identity information, including name, surname, gender, place of birth, ID number, date of birth, citizenship, signature, information contained in your identity document, passport, driver's license and foreign identity document;
  • Your contact information, including email address, phone number, address, city/region, postal code;
  • Your location information;
  • Your customer transaction information, including your transactions, transfers and orders on the Platform, their date and status, your membership level and transaction fee, discount rate, messages, requests, complaints and suggestions;
  • Your security information, including your IP address information, user ID number assigned to your account, time spent and activity information, device and browser information from which you accessed and accessed the Platform;
  • Your risk management information, including information we process in accordance with anti-money laundering and anti-corruption policies, information processed to manage commercial, technical and administrative risks, and your suspicious transaction information;
  • Your financial information, including your tax identification number, source of funds, bank account details, other information required to verify the source of funds;
  • Your professional experience information, including information about your job and profession;
  • Your visual or voice recording including your photograph, biometric information, including a selfie;
  • Your language and time zone preference;
  • Other data required to deliver the service to you.

3. Our Purposes For Which We Use Your Personal Data

Your personal data will only be processed for specific, explicit and legitimate purposes and in accordance with the law and good faith. In addition, our Company will take care to process your personal data in connection with the purpose of processing, in a limited and appropriate manner and to ensure that the data it processes are accurate and up-to-date.

Purpose of processing Personal data Legal basis
To process and execute your instructions and orders while we provide our Services
  • Identity Data
  • Financial Data
  • Transactional Data
 Performance of a contract
To carry out and comply with the anti-money laundering requirements
  • Identity Data
  • Contact Data
  • Social Identity Data
  • Contact Data
  • Financial Data
  • Expressly stated by laws
  • Compliance with our legal obligations
To process, collect and transfer payments, fees and to collect and recover payments owed to us
  • Identity Data
  • Contact Data
  • Financial Data
  • Transactional Data
 Performance of a contract
To conduct risk and crime prevention including performing anti-money laundering, counter terrorism, sanction screening, PEP checks, fraud and other background checks, detect, investigate, report and prevent financial crimes, respond to complaints
  • Identity Data
  • Contact Data
  • Social Identity Data
  • Financial Data
  • Transactional Data
  • Technical Data
  • Expressly stated by laws
  • Compliance with our legal obligations
  • Performance of a contract
  • Legitimate interests
To use the services of financial institutions, crime and fraud prevention companies and technology providers
  • Identity Data
  • Social Identity Data
  • Contact Data
  • Performance of a contract
  • Legitimate interests
To respond to the demands and enquiries of authorities
  • Identity Data
  • Contact Data
  • Social Identity Data
  • Financial Data
  • Transactional Data
  • Technical Data
  • Expressly stated by laws
  • Compliance with our legal obligations
To be able to follow legal processes, to use as evidence in disputes that may arise, and to protect the company in legal claims
  • Identity Data
  • Contact Data
  • Social Identity Data
  • Financial Data
  • Transactional Data
  • Technical Data
  • Usage Data
 Legitimate interests

Cookies

We do not use cookies, or other tracking applications. However, we encourage you to review the Cookie Policy of the P2P Platform that you are using in order to access our services and our trading desk. We do not control P2P Platforms and are not responsible for their privacy practices. We do not act as a data controller or data processor in terms of data processing activities carried out by P2P Platforms through cookies and other tracking technologies.

Sale or transfer of business

In order to meet our legal obligations, or based on our legitimate interests, we may need to process your personal data in connection with or during the negotiations of any acquisition, merger, sale, bankruptcy, or other change of control.

4. Transfer of Your Personal Data

Your personal data may be shared with our service suppliers, business partners, information technology service providers, group companies, authorized public institutions and organizations and legally authorized persons for the purposes described in the Section 5 of this Privacy Notice, in accordance with the conditions regarding the transfer of personal data under Data Privacy Act 1988 and the Law. For instance, your personal data may be transferred to third parties in the following processes:

  • Our service suppliers, including but not limited to compliance service suppliers, legal service suppliers, marketing service suppliers, anti-fraud service suppliers, and liquidity service suppliers, banking & payments service suppliers;
  • Subsidiary or affiliated companies to provide services securely and carry out analysis and audits;
  • Cybersecurity and Information technology service providers to ensure the security of the platform;
  • Business partners to improve, customize and personalize our services;
  • Authorized public institutions and organizations, including the Financial Crimes Investigation Board.

5. How We Collect Your Personal Data

We use different methods to collect information from and about you by automatic or non-automatic means, including through:

  • Our KYC link during the identity verification process;
  • Fraud and crime prevention technology providers;
  • Publicly available information on the Internet;
  • Your interaction with us;
  • Our business partners and blockchain networks.

6. Data Security

We have implemented appropriate security measures to protect your personal data. These include organizational, technical, and security measures to ensure its ongoing availability, integrity, and confidentiality.

7. Your Legal Rights

You have certain rights under the Law regarding your personal data, including the right to request information, rectification, erasure, objection to processing, and compensation for damages arising from unlawful processing. You can send requests to [email protected], and we will verify your identity before processing your request.

Your data subject requests will be answered free of charge. However, if the requested transaction requires an additional cost, the fees in the tariff determined by the Personal Data Protection Board may be required.

Your requests will be answered in writing or electronically as soon as possible and within thirty days at the latest, depending on the nature of the request. If your request is rejected, your application will be answered with justification.