Privacy policy

Our data protection declaration is based on the terms used by the European and UK legislators for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

a) Personal data

Personal data means any information relating to an identified or identifiable natural person ("data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Data subject

Data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.

c) Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

f) Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g) Controller or controller responsible for the processing

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h) Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i) Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

j) Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

k) Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Controller for the purposes of the UK GDPR, the EU GDPR, other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

CoinSwaps Ltd
71-75 Shelton Street
Covent Garden
London, WC2H 9JQ
United Kingdom

Company number: 16118847 (incorporated in England & Wales on 4 December 2024).
Email: hello@coinswaps.ai
Website: www.coinswaps.ai

The Coinswaps website does not set tracking cookies. We use Vercel Web Analytics, a cookie-free analytics service that does not fingerprint visitors or persistently identify individuals. That is why this site has no cookie banner.

Strictly necessary technical cookies or local storage entries may be set by the underlying hosting platform to keep the site functioning (for example, to balance traffic across servers). These are not used for tracking or profiling. Most browsers allow the data subject to refuse the setting of cookies through browser settings; the data subject may also delete cookies and local storage at any time. If cookies are deactivated entirely, not all functions of our website may be entirely usable.

The Coinswaps website collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files of our hosting processor (Vercel). Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites accessed, (5) the date and time of access to the website, (6) an Internet protocol (IP) address, (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, CoinSwaps Ltd does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimise the content of our website, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

The Coinswaps website provides information that enables quick electronic contact with our enterprise, as well as direct communication with us, which includes a general electronic mail (e-mail) address. If a data subject contacts the controller by e-mail or via the waitlist form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties for marketing.

When you sign up to the Coinswaps early-access waitlist, we collect:

• Your email address.
• Your first name and last name.
• Answers about your transfers: anticipated transaction volume, frequency, and whether you are a business or individual.
• A timestamped record of your submission. By submitting the form you consent to us contacting you about early access; this submission is that record of consent.

All of the fields above are required to submit the form. We do not ask for phone numbers, company names, job titles, or referral source, and we do not track you across other sites. The data is used to (a) contact you when early access begins, plus an immediate confirmation that you are on the list, and (b) help us optimise the user experience and prioritise product features in aggregate.

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European or UK legislators in laws or regulations to which the controller is subject.

If the storage purpose is not applicable, or if a storage period prescribed by the European or UK legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements. Waitlist entries are retained until the launch email goes out, or for up to 12 months, whichever comes first; after that, entries that have not opted in to ongoing product updates are deleted.

a) Right of confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact us at hello@coinswaps.ai.

b) Right of access

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

• the purposes of the processing;
• the categories of personal data concerned;
• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
• where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
• the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
• the existence of the right to lodge a complaint with a supervisory authority;
• where the personal data are not collected from the data subject, any available information as to their source;
• the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

c) Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

d) Right to erasure (right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

• The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
• The data subject withdraws consent on which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
• The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
• The personal data have been unlawfully processed.
• The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
• The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If any of the aforementioned reasons applies and a data subject wishes to request the erasure of personal data stored by CoinSwaps Ltd, he or she may at any time contact hello@coinswaps.ai. We will promptly ensure that the erasure request is complied with.

e) Right of restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

• The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
• The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use.
• The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
• The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

f) Right to data portability

Each data subject shall have the right granted by the European legislator to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

g) Right to object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

CoinSwaps Ltd shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

If CoinSwaps Ltd processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to CoinSwaps Ltd to the processing for direct marketing purposes, CoinSwaps Ltd will no longer process the personal data for these purposes.

h) Automated individual decision-making, including profiling

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.

i) Right to withdraw data protection consent

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time. You can withdraw consent by replying STOP to the confirmation email, or by emailing hello@coinswaps.ai. We will confirm once you have been removed from the list.

Art. 6(1) lit. a GDPR (and the equivalent UK GDPR provision) serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose — this is the basis we rely on for the waitlist, together with PECR Regulation 22 for the launch email. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, the processing is based on Article 6(1) lit. b GDPR. Where our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject.

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favour of the well-being of all our employees and the shareholders, and to maintain the security and integrity of our website and information systems.

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of a contract or the initiation of a contract. Waitlist data is retained until launch or for a maximum of 12 months, as set out in Section 7.

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. For the early-access waitlist, all fields on the form (your name, e-mail address, and answers about your transfers) are required: the e-mail address is necessary so we can contact you when early access begins, and the remaining fields help us shape and prioritise the product. Without them, we cannot accept the submission.

As a responsible company, we do not use automatic decision-making or profiling.

We use a small number of vendors to actually run the waitlist and host the website. These are processors acting on our instructions. We do not sell your data, and we do not share it with anyone else for marketing.

• Resend (Resend, Inc., United States) — delivers the confirmation email and the notification to our internal mailbox. Data is processed under their Data Processing Agreement with EU-US Data Privacy Framework / Standard Contractual Clauses in place for transfers out of the UK.
• Vercel (Vercel Inc., United States) — hosts the website that receives your submission and provides cookie-free analytics. Their DPA and SCCs cover international transfers.
• Microsoft 365 (Microsoft Corporation, United States / Microsoft Ireland Operations Ltd) — hosts the shared inbox we use to read waitlist notifications. Covered by Microsoft's Data Protection Addendum and Standard Contractual Clauses.

The processors above are US-headquartered and may store data in the United States. Transfers from the UK rely on the UK-US Data Bridge (an extension of the EU-US Data Privacy Framework) or on Standard Contractual Clauses, as set out in each processor's DPA.

If you believe we have mishandled your data, you have the right to lodge a complaint with the UK's Information Commissioner's Office (ICO) at ico.org.uk/make-a-complaint, or with the supervisory authority in your EU Member State. We would appreciate the chance to fix it first — email us and we will do our best.

If we change anything material, we will update the "last updated" date at the top of this page. Substantive changes (for example, a new processor handling your email) will be notified by email before they take effect.