Privacy Policy
Fiat201 GmbH (hereinafter "Fiat201" or "We") respects the privacy of the users of our payment processing platform (collectively, the “Platform”), as well as users of our website available at: fiat201.com or fiat201.ch (the “Site”), and is committed to protect the personal information that users share with us in connection with the use of our Platform and/or Site (collectively – the “Service”).
This Privacy Policy (the “Privacy Policy”) is intended to describe our practices regarding the information we collect from you when you visit our Site (“Site Visitors“), when you use our Service or any part thereof (“User“) including through a cryptocurrency exchange’s website or trading platform carrying the Service (“Exchange“), or when you register as a customer (“Customer“), as well as the manners in which we use your personal information, and the options and rights available to you.
This Privacy Policy is incorporated by this reference into, and made part of, the Terms & Conditions available at (https://fiat201.com/terms-and-conditions/).
The term “GDPR” shall mean the General Data Protection Regulation (Regulation (EU) 2016/679).
From whom we collect Personal Information?
This Privacy Policy applies to the Company’s’ collection, use, and disclosure of the Personal Information of the following categories of individuals:
Site Visitors: Individuals who visit our Site and who may volunteer certain contact data (such as their email address) to receive communications from the Company or otherwise pre-register to receive our Service. For clarity, Site does not include any sites owned or operated by our Customers.
Users: Individuals whose information we process in order to:
Provide the Service to our Customers pursuant to our agreements with them and Fulfill regulatory objectives, prevent illegal activities and to comply with applicable laws.
Which information we collect?
We collect, or have collected certain information that identifies or may identify an individual with reasonable efforts (“Personal Information”), as explained below.
Personal Information collected about Users consists of the following:
The User’s IP address, as well as other persistent device identifiers, which are automatically recorded from the User’s device.
In the event that following the preliminary examinations the User is determined as qualified to use the Service (as shall be determined in our sole discretion), then after clicking the Service button the User will be requested to fill out the registration form available on the Service, and such User will be required to provide certain information such as his/her personal and contact details, including the following:
Full name
Physical address
E-mail address
Phone number
Copy of a government-issued ID (such as a passport or driver’s license) – this is collected as means for official proof of identity, for screening and identity verification/authentication;
Details regarding the government-issued ID, such as the number, issuing country and issuance/expiration date;
Photo/video selfie – this is collected as means for official proof of identity, for screening and identity verification/authentication;
Country of residence
Date of birth
Gender
Billing address
Wallet ID or Wallet Address(if applicable)
Payment card details – however, please note that such data is transmitted directly to our trusted third party payment processors. We do not retain the full details of the credit card;
Any additional required information in order to render the Service.
Kindly note that without providing the above information the User will not be able to complete the transaction or make use of the Service.
We also automatically collect or generate the following information when the User makes use of the Service: transaction status and transaction history, amounts deposited/withdrawn and login history, payment identifiers (such as a payment ID), risk assessment/scoring, and other information related to the User’s use of the Service. In addition, we also collect the behavior of the User on our Services, which includes keystrokes, captioning and recording of user behavior, mouse movements and other activities in our Services.
Any Personal Information provided voluntarily by the User via its use of the Service, such as the User’s e-mail address in order to be contacted (and any additional information related to such contacts), User responses to customer surveys about how we can improve our product(s) and service(s), transaction details provided through use of the Service, and/or other actions performed by the User in connection with the Service.
We also collect additional data from third-party sources regarding the User. This includes the User’s sanctions data and adverse media checks, as well as certain information enabling us to verify or authenticate the User (such as the User’s location), as well as to assess the risk associated with onboarding the User.
Please note that the Personal Information we collect is required in order for us to contractually provide the Services, as well as for us to meet our regulatory requirements (such as Anti-Money Laundering and Know-Your-Customer regulations), and to safeguard our legitimate interests. In the event that you will not provide such information, we may not be able to provide our Service.
We collect the following information about our Site Visitors:
We collect your contact data (for example your name, email address) and if relevant your Payment ID (the reference you received by email) for the purpose of providing you with customer support (such as when you submit a ticket), or when you submit web forms on our Site.
We also collect your contact data (for example your name, and email address and organization’s name) when you sign up for and agree to receive email communications from us, when you pre-register to receive our Services. We also may ask you to submit such personal information if you choose to use interactive features of the Site.
Log Files. Just as when you visit and interact with most websites and services delivered via the Internet, when you visit our Site, we gather certain information and store it in log files. This information may include but is not limited to Internet Protocol (IP) addresses, system configuration information, URLs of referring pages, and local and language preferences.
Cookies and Other Tracking Technologies. We use cookies and other information gathering technologies for a variety of purposes, such as providing us with information about how you interact with our Site and assisting us in our marketing efforts.
How Do We Collect Personal Information?
Through your use of the Service and/or the transactions carried out in connection with the Service. In other words, when you are using the Service, including when you browse an Exchange, we collect and record the information relating to such usage, either independently or through the help of third-party services as detailed below.
Through publicly available sources. For example, we collect certain information about you through your publicly available Social Network Account(s) information, publicly available credit card blacklists and official limited bank account lists, and other online public information.
From third-party services. For example, we use third-party services to provide our Service and prevent fraud.
Information which you provide us. For example, we collect Personal Information required to use the Service by completing the registration form, the onboarding process (if you register as a Customer) and/or contacting us directly.
We store the Personal Information either independently or through the help of our authorized third-party service providers as detailed below.
What are the Purposes of the Collection of Information?
Provide and operate the Service, including for risk analysis, billing, and other aspects relating to carrying out the transactions performed by the Users (such as identity authentication, payment processing, and charge-backs);
Analytics, statistical and research purposes;
Detect, prevent, or otherwise address fraud, security or technical issues (such as identity theft or financial fraud);
Meet our regulatory requirements, such as Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”) regulatory requirements;
To perform due diligence and other screening activities in accordance with our legal or regulatory obligations and risk management procedures which are carried out in our own legitimate interest or the public interest; this includes conducting identity verification and fraud prevention, including checks related to the source of funds or income, PEP, sanctions and adverse media checks;
Enable us to further develop, customize and improve the Service based on Users’ common preferences and uses, including simplifying the onboarding process to the Service, and for debugging purposes;
Create and provide our business partners and affiliates with aggregated statistical data;
Direct marketing purposes – we may use the contact details you provided us to send you promotional offers or communications; you may withdraw your consent via sending a written notice to Fiat201 by email to the following address: support@fiat201.com or on the same manner as the advertising was transmitted to you (such as via phone text message), or by following the un-subscription instructions on the promotional offer or communication.
Respond to User’s support requests;
Satisfy any applicable law, regulation, legal process, subpoena or governmental requests;
Enable us to provide our Users with a better user experience, with more relevant Content, features, and functionalities, and with technical assistance and support; and
Protect the rights, property, or personal safety of Fiat201, any of its Users, or the general public;
Enforce this Privacy Policy and/or the Terms and Conditions, including investigation of potential violations thereof;
We may also process your information as part of our customer authentication process, that employs the 3D Secure 2.0, which is a secured authentication protocol allowing issuing banks to verify credit card owners during the transaction process, and enabling us to ensure compliance with regulatory requirements and combat online fraud. This information includes your contact information, your payment information (including your credit card number and billing address), your IP address, the amount and currency of purchase, your browser information and additional information.
Abide by any applicable law.
What are the Conditions for Processing of Personal Information?
Fulfillment of a contract, compliance with a legal obligation – it is necessary for us to process your Personal Information where it is necessary for the performance of a contract (such as for the Terms and Conditions) or in order for us to comply with our various legal and/or regulatory responsibilities, including, but not limited to, complying with any AML and KYC legislation).
Legitimate interests – we also process your Personal Information where we deem such processing to be in our (or a third party’s) legitimate interests and provided always that such processing will not prejudice your interests, rights and freedoms. Examples of us processing in accordance with legitimate interests would include: (i) where we disclose your Personal Information to any one or more of our associate/subsidiary companies following a restructure or for internal administrative purposes; (ii) processing for the purposes of ensuring network and information security, including preventing unauthorized access to our electronic communications network; (iii) safeguarding the integrity of our Service by combating, reporting and sharing information related to fraudulent activities; (iv) adhering to regulatory and statutory requirements; (v) improving and optimizing our Service and debugging errors; (vi) sharing personal information with our advisers and professional services providers (such as auditors) for ensuring our compliance with regulatory requirements and industry best practices.
Consent – our processing of your Personal Information will primarily be necessary for us to provide you with the Service. However, on certain occasions we may ask for your consent to processing Personal Information. In these instances your Personal Information will be processed in accordance with such consent and you will be able to withdraw this consent in writing at any time.
Special Categories of Personal Data – our processing of your Personal Information may also involve special categories of personal data, such as biometric data and your racial or ethnic origin (as defined under Article 9 of the GDPR). We will process such information, as well as disclose it to competent authorities (such as law enforcement bodies), where it is necessary for the following purposes (to the extent permissible by applicable law): (i) prevention or detection of an unlawful acts, (ii) safeguarding your (or others’) economic well-being.
Sharing Information with Third Parties
With our commercial partners (as applicable), including the merchants and operators of Exchanges;
With acquiring and card issuing banks;
With third-party authentication vendors (such as identity verification, customer authentication and due diligence vendors), partner risk screening providers and other data sources (such as geo-location services), in accordance with our legal or regulatory obligations and risk management procedures which are carried out in our legitimate interest or the public interest;
With our service providers (such as cloud computing companies, including payment processors, banking platforms and currency clouds, and marketing platforms);
In order to fulfill the purposes stated above, including to satisfy any applicable law, regulation, legal process, subpoena or governmental request;
In order to respond to claims that any content available on the Service violates the rights of third-parties;
When Fiat201 or any of its affiliates is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets.
For a description of the categories of third parties to whom personal information was disclosed, please see section 2.
Please note that for the purposes of identity verification and required regulatory screenings, Fiat201 utilizes certain third party identity verification and authentication services, provided by Sum and Substance Ltd. Sum and Substance’s collection and use of the information, which includes a copy of a government-issued ID and a photo selfie for biometric comparison, is described in Sum and Substance’s privacy policy. We may access the verification results generated by Sum and Substance including relevant identification data disclosed by you.
Since we operate globally, it may be necessary for the provision of Services and to the extent required for the specific purpose, as stipulated in this Privacy Policy to transfer your Personal Information to countries outside the European Economic Area or Switzerland.
We use best efforts to ensure that your Personal Information is protected in accordance with our Privacy Policy and applicable data protection laws, through contractual means or other means.
For more information about the transfer of your personal data outside of the EEA or Switzerland, please contact us at privacy@fiat201.com.
Retention of Personal Information
If you have registered with an account through our Service, Fiat201 will retain your Personal Information during the period your account is active. In addition, Fiat201 will retain your Personal Information for additional periods, as necessary to enable Fiat201 to meet its legal obligations under applicable laws or regulations, such as the applicable financial regulations, KYC and AML regulations, as well as to meet Fiat201’ contractual obligations.
In addition, Fiat201 may retain Personal Information provided that retaining such information is strictly necessary for Fiat201’ legitimate interests, such as fraud prevention and record keeping, enforcing its policies, resolving or exercising claims regarding potential disputes, and where Fiat201 is guided to do so by the applicable regulatory authority.
Minors
To use the Service, you must be over the age of eighteen (18). Fiat201 does not knowingly collect Personal Information from children under the age of eighteen (18) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of eighteen (18) are not using the Service. In the event that it comes to our knowledge that a person under the age of eighteen (18) is using the Service, we will prohibit and block such User from accessing the Service and will take appropriate measures to prevent that User from making use of our Service.
Tracking Technologies
When you access or use the Service, we may use (and authorize third parties to use) industry-wide technologies such as cookies or similar technologies, including web beacons, pixel tags, scripts, tags and other technologies that store certain information on your computer (“Local Storage”) and which will allow us to enable automatic activation of certain features, and make your Service experience much more convenient and effortless (collectively “Tracking Technologies”). These Tracking Technologies allow us and third parties to automatically collect information about you (such as your IP address, device unique identifiers and your online behavior), in order to enhance your navigation on our Site, improve our Site’s performance and customize your experience on our Site, as well as for advertising and fraud prevention purposes. We also use this information to collect statistics about the usage of our Site, perform analytics, deliver content which is tailored to your interests
Your Rights
You may contact us at any time at privacy@fiat201.com, and request:
To access (including asking for supplementary information), delete, change or update any Personal Information relating to you (for example, if you believe that your personal information is incorrect, you may ask to have it corrected or deleted);
That we will restrict or cease any further use of your Personal Information;
That we will provide the Personal Information you volunteered to us in a machine-readable format.
To withdraw your consent to our processing activities (provided that such processing activities rely on your consent, and not on a different legal basis);
To not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where such processing is necessary for the performance of the contract between you and us, or it is based on your explicit consent, as provided hereunder.
Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations (such as KYC and AML regulations).
If you have any general questions about the Personal Information that we collect about you, how we use it, please contact us at privacy@fiat201.com.
Security
We take great care in implementing and maintaining the security of the Service and safeguarding any Personal Information we process. Fiat201 employs industry standard procedures and policies to ensure the safety of its Users’ Personal Information, and prevent unauthorized use of any such information. Please note that while we take reasonable measures to safeguard your personal data, we cannot fully guarantee its security.
Third Party Websites
While using the Service you may encounter links to third party websites and/or services. Please be advised that such third party websites and/or services are independent of Fiat201, and may use cookies and other web-tracking technologies to collect non-personal and/or Personal Information about you. We assume no responsibility or liability whatsoever with regard to privacy matters or any other legal matter with respect to such third party websites and/or services. We encourage you to carefully read the privacy policies and the terms of use of such third party websites and/or services, as their terms, not ours, will apply to any of your interactions with such third parties.
Changes to the Privacy Policy
Fiat201 reserves the right to change this Privacy Policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes to this Privacy Policy on the Service and/or we will send you an email regarding such changes to the e-mail address that you volunteered. Such substantial changes will take effect seven (7) days after such notice was provided on any of the above-mentioned methods.
Have any questions?
If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send them to our Data Protection Officer at:
privacy@fiat201.com
Fiat201 GmbH
Boesch 106
6331 Huenenberg
Switzerland
We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. We will also provide the information translated into your language, if possible, for a standard market fee to be agreed upon by both parties in advance.