PRIVACYBELEID / PRIVACY POLICY

Omdat AMDAX zowel Nederlandse als internationale klanten bedient, hebben we onze juridische documenten in het Engels opgesteld. Binnen AMDAX is Engels het uitgangspunt als het om juridische communicatie gaat – de Engelse contracten zijn dus leidend. Indien u vragen heeft over een van de documenten, staan we altijd voor u klaar om deze te beantwoorden – uiteraard (ook) in het Nederlands.

Table of Contents

Welcome to AMDAX

Welcome! Thanks for visiting AMDAX, a digital asset platform operated by and proprietary to AMDAX B.V., with its principal address at Beursplein 5, 1012 JW Amsterdam, THE NETHERLANDS (Chamber of Commerce number: 74458477). Use of the words “AMDAX,” “we,” “us,” or “our” refers to AMDAX B.V. This Privacy Policy explains what Personal Information (as defined below) we collect, why we collect it, how we use and disclose it.

Your privacy matters to us so whether you are new to AMDAX or a long-time customer, please do take the time to get to know and familiarize yourself with our policies and practices. Feel free to print and keep a copy of this Privacy Policy, but please understand that we reserve the right to change any of our policies and practices at any time. But don’t worry, you can always find the latest version of this Privacy Policy here on this page.

Personal Information We Collect

As used herein, “Personal Information” means information that identifies or is reasonably capable of identifying an individual, directly or indirectly, and information that is being associated with an identified or reasonably identifiable individual.

Personal Information we collect from you

We may collect the following categories of Personal Information directly from you:

  • Identification Information, such as name, email, phone number, postal address, government identification numbers (which may include Social Security Number or equivalent, driver’s license number, passport number);
  • Commercial Information, such as trading activity, order activity, deposits, withdrawals, account balances;
  • Financial Information, such as bank account information, routing number;
  • Correspondence, such as information that you provide to us in correspondence, including account opening and customer support;
  • Sensory Information, such as images collected for identity verification, audio recordings left on answering machines;
  • Employment Information, such as job title, source of wealth; and
  • Institutional Information, such as for institutional customers, we may collect additional information, including: institution’s legal name, Employer Identification Number (“EIN”) or any comparable identification number issued by a government, and proof of legal existence (which may include articles of incorporation, certificate of formation, business license, trust instrument, or other comparable legal document).

Personal Information we collect automatically

We may collect the following categories of Personal Information automatically through your use of our services:

  • Online Identifiers, such as IP address; domain name;
  • Device Information, such as hardware, operating system, browser;
  • Usage Data, such as system activity, internal and external information related to AMDAX pages that you visit, clickstream information; and
  • Geolocation Data.

Our automatic collection of Personal Information may involve the use of Cookies, described in greater detail below.

Personal Information we collect from third parties

We may collect and/or verify the following categories of Personal Information about you from Third Parties:

  • Identification Information, such as name, email, phone number, postal address, government identification numbers (which may include Social Security Number or equivalent, driver’s license number, passport number);
  • Financial Information, such as bank account information, routing number;
  • Transaction Information, such as public blockchain data (bitcoin, ether, and other Digital Assets are not truly anonymous. We, and any others who can match your public Digital Asset address to other Personal Information about you, may be able to identify you from a blockchain transaction because, in some circumstances, Personal Information published on a blockchain (such as your Digital Asset address and IP address) can be correlated with Personal Information that we and others may have. Furthermore, by using data analysis techniques on a given blockchain, it may be possible to identify other Personal Information about you); and
  • Additional Information, at the discretion of our Compliance Team to comply with legal obligations, which may include criminal records or alleged criminal activity.

Personal Information you provide during the registration process may be retained, even if your registration is left incomplete or abandoned.

Accuracy and retention of Personal Information

We take reasonable and practicable steps to ensure that your Personal Information held by us (i) is accurate with regard to the purposes for which it is to be used, and (ii) is not kept longer than is necessary for the fulfillment of the purpose for which it is to be used.

How We Use Your Personal Information

The Personal Information we collect and the practices described above are done in an effort to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve AMDAX. We may use your Personal Information to:

  1. Provide you with our services. We use your Personal Information to provide you with our Services pursuant to the terms of our User Agreement. For example, in order to facilitate fiat transfers into and out of your account, we need to know your financial information.
  2. Comply with legal and regulatory requirements. We process your Personal Information as required by applicable laws and regulations. For example, we have identity verification requirements to fulfill our obligations under the anti-money laundering laws of numerous jurisdictions.
  3. Detect and prevent fraud. We process your Personal Information to detect and prevent fraud on your account, which is especially important given the irreversible nature of cryptocurrency transactions.
  4. Protect the security and integrity of our services. We use your Personal Information to further our security-first mentality. Maintaining the security of your account and the Exchange requires us to process your Personal Information, including information about your device and your activity on the Exchange, and other relevant information.
  5. Provide you with customer support. We process your Personal Information anytime that you reach out to our Customer Support team with issues arising from your account.
  6. Optimize and enhance our services. We use your Personal Information to understand how our products and Services are being used to help us improve our Services and develop new products.
  7. Market our products to you. We may contact you with information about our Products and Services. We will only do so with your permission, which can be revoked at any time.
  8. Other business purposes. We may use your information for additional purposes if that purpose is disclosed to you before we collect the information or if we obtain your consent.

How We Share Your Personal Information

We will not share your Personal Information with third parties, except as described below:

  1. Service Providers. We may share your Personal Information with third-party service providers for business or commercial purposes. Your Personal Information may be shared so that they can provide us with services, including identity verification, fraud detection and prevention, security threat detection, payment processing, customer support, data analytics, Information Technology, advertising, marketing, data processing, network infrastructure, storage, transaction monitoring, and tax reporting. We share your Personal Information with these service providers only so that they can provide us with services, and we prohibit our service providers from using or disclosing your Personal Information for any other purpose. Our third-party service providers are subject to strict confidentiality obligations.
  2. Law Enforcement. We may be compelled to share your Personal Information with law enforcement, government officials, and regulators.
  3. Corporate Transactions. We may disclose Personal Information in the event of a proposed or consummated merger, acquisition, reorganization, asset sale, or similar corporate transaction, or in the event of a bankruptcy or dissolution.
  4. Professional Advisors. We may share your Personal Information with our professional advisors, including legal, accounting, or other consulting services for purposes of audits or to comply with our legal obligations.
  5. Consent. We may share or disclose your information with your consent.

If we decide to modify the purpose for which your Personal Information is collected and used, we will amend this Privacy Policy.

Cookies

When you access AMDAX, we may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, “Cookies”) on your computer or other devices used to visit AMDAX. We use Cookies to help us recognize you as a customer, collect information about your use of AMDAX to better customize our services and content for you, and collect information about your computer or other access devices to: (i) ensure compliance with our Client Acceptance Procedure (“CAP”) and Anti-Money Laundering (“AML”) Compliance Program (“CAP/AML Program”), (ii) ensure that your account security has not been compromised by detecting irregular, suspicious, or potentially fraudulent account activities; (iii) assess and improve our services and advertising campaigns.

You also can learn more about cookies by visiting http://www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies on different types of browsers and mobile devices. Please note that if you reject cookies, you will not be able to use some or all of AMDAX. If you do not consent to the placing of Cookies on your device, please do not visit, access, or use AMDAX.

Direct Marketing

Subject to applicable laws and regulations, we may from time to time send direct marketing materials promoting services, products, facilities, or activities to you using information collected from or about you. You may opt-out of such communications at any time by visiting the Exchange tab of your Account Settings page. You may also opt-out of such communications by following the directions provided in any marketing communication. It is our policy to not provide your Personal Information for those third parties’ direct marketing purposes without your consent.

Information Security

No security is foolproof, and the Internet is an insecure medium. We cannot guarantee absolute security, but we work hard to protect AMDAX and you from unauthorized access to or unauthorized alteration, disclosure, or destruction of Personal Information we collect and store. Measures we take include encryption of the AMDAX website communications with SSL; required two-factor authentication for all sessions; periodic review of our Personal Information collection, storage, and processing practices; and restricted access to your Personal Information on a need-to-know basis for our employees, contractors and agents who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

EU Data Protection Law / GDPR

While we could service clients that are located outside of the European Union (“EU”), European Economic Area (“EEA”) or the Channel Islands, or other locations subject to EU data protection law (collectively, “Europe”), they are customers of our Dutch entity. We adhere to relevant EU data protection laws as stated in the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

We have formulated an elaborate GDPR policy outlining how we implement data protection. Please review that document which can be found on https://www.amdax.com

Contact Us

If you have questions or concerns regarding this policy or our processing of your Personal Information, please feel free to email us at: privacy@amdax.com; or write to us at: AMDAX B.V., Beursplein 5, 1012 JW Amsterdam, THE NEHTERLANDS.

If you are a European resident and you believe that we have not adequately resolved any such issues, you have the right contact your local supervisory authority.