1 Introduction

Thank you for your interest in Avencia Digital Ltd ("Avencia Digital"). We are committed to protecting and respecting your privacy. This document explains how we look after your personal data and make sure that we meet our legal obligations to you under applicable UK data protection rules and the General Data Protection Regulation (Regulation (EU) 2016/679) ("the GDPR").

This Privacy Notice ("Notice") describes how Avencia Digital collects, stores and uses personal information ("Personal Information") including information about its customers, contacts, suppliers and job applicants, as well as about visitors to the Avencia Digital website at www.avencia.digital ("our site").

In this Notice, we use the terms "we", "us", and "our" (and other similar terms) to refer to Avencia Digital, and "you" and "your" (and other similar terms) to refer to our customers, contacts, suppliers, job applicants and site visitors.

We use your personal data to provide and improve our services. This Notice is an important document. We recommend that you read it carefully. When you deal with Avencia Digital and by using our services, you agree to the collection and use of information in accordance with this Privacy Policy, and we will assume you agree to the uses of your Personal Information described in this Notice unless you tell us otherwise in writing.

For data protection purposes, the data controller is Avencia Digital Ltd. of 30A Thornhill Road, London, United Kingdom N1 1HW.

(1) Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our service or parts of our service.
  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Avencia Digital Ltd, 30A Thornhill Road, London, N1 1HW.
  • Cookies are small files that are placed on Your computer, mobile device, or any other device by a website, containing the details of Your browsing history on the website among its many uses.
  • Country refers to the United Kingdom.
  • Device means any device that can access the service such as a computer, a mobile phone, or a digital tablet.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Website refers to Avencia Digital, accessible from www.avencia.digital.
  • You means the individual accessing or using the Services of Avencia Digital, or the company, or other legal entity on behalf of which such individual is accessing or using the service, as applicable.

(2) How to contact us

If you have any questions about how we collect, store, and use Personal Information, then please contact our Data Protection Officer. You can either write at the above address or e-mail to sergiu.sagaidac@avencia.digital.

If you have any questions about this Privacy Notice, you may also contact us by e-mail to support@avencia.digital.

(3) Who we are and what we do?

Avencia Digital Ltd. is a UK company (company number 12090230) which has its registered office at 30A Thornhill Road, London, United Kingdom N1 1HW.

Avencia Digital provides cryptocurrency brokerage services for cryptoassets and works with individual customers, corporate customers and institutional clients pushing the frontier in the digital currency space, with a dedicated focus on cryptocurrency market liquidity.

www.avencia.digital ("the Website") is operated by Avencia Digital Ltd, which manages all the data on the website and owns the website.

Avencia Digital can be contacted by the following means:

  • by phone: 020 3951 7045;
  • by e-mail: support@avencia.digital; or
  • by post: Avencia Digital Ltd, 30A Thornhill Road, London, United Kingdom, N1 1HW

If you have any queries about the way we use your personal data, please contact our Data Protection Officer, using the e-mail address: sergiu.sagaidac@avencia.digital or the telephone or postal details above.

2 Your Data

(1) The Personal Information that we collect

Before we provide our services to you, we undertake checks for the purposes of preventing financial crime such as fraud and money laundering, and terrorist financing by means of verifying your identity and undertaking specific screening. These checks require us to process personal data about you.

Depending on how you engage with us, we will collect and process the following data about you:

(a) Information that you provide voluntarily

  • If you are an employee or other staff member of an Avencia Digital's corporate customer, supplier or partner: We will use the personal and/or professional contact details, professional title and if necessary identity documents that we ask you to provide for the purposes of carrying out customer due diligence and KYC checks, managing invoicing and/or payments and corresponding with our corporate customer, supplier and/or partner in connection with the applicable services. We may also keep your contact preferences, such as requests to subscribe to publications that we may circulate from time to time, to receive news about any events we are organising or participating in, or to receive information about Avencia Digital and the services we provide.
  • If you are a website visitor: We will use any information that you provide by filling in forms on our website. This includes information provided at the time of registering to use our website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with our website.
  • If you write to us: We will keep a record of that correspondence.
  • If you complete any of our surveys: We will use your responses for research purposes.
  • If you are a job applicant: We will use your contact details, copies of your job application, curriculum vitae and covering letter, as well as any references provided, for the purposes of processing your application and for general recruitment and selection purposes.

(b) Information that we collect automatically as part of our crypto exchange service or manually as part of our brokerage service provision

  • If you are an Avencia Digital customer: We will collect information about the transactions that you make using Avencia Digital' services, your card number or bank account details, transaction amount, cryptocurrency amount, transaction date, including identity documents and contact details, such as name, address, DOB, financial information, employment details and any and all other supporting documents that may be required (i.e. including utility bills) for the purposes of carrying out appropriate KYC checks and customer due diligence to enable us to comply with our anti-money laundering obligations. We may also receive information about you via third party screening vendors or fraud prevention and credit reference agencies or other organisations involved in the support or provision of our crypto exchange or associated services.
  • If you are a website visitor: We will collect, store and use certain, limited information relating to your use of the Avencia Digital website for the purposes of better understanding the types of visitors who browse our site and improving our site offering. Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our site, including the pages accessed and links clicked. Collecting this information enables us to better understand the visitors who come to our site, where they come from, and what content on our site is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our site to our visitors. Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading "Cookies and similar tracking technology" below.

(2) How we use your Personal Information

Depending on how you engage with us, we will use your information for the following purposes:

  • For communication purposes: We use information and preferences to communicate with our customers, partners and suppliers and to send publications that we may circulate from time to time, news about any events we are organising or participating in, and/or other information about Avencia Digital and the services that we provide. We will only contact you in accordance with the contact preferences that you have specified (which may include e-mail) and will not send you marketing communications where there is no active and explicit consent provided and where you have told us you do not wish to receive these. You can specify your contact preferences when registering online to receive communications from us (for example, through the Avencia Digital website) or by subsequently advising us of your contact preferences using the contact details provided above.
  • To provide our crypto exchange services to our customers: We will use Personal Information to provide our services to our customers, facilitating trade execution and settlement of transactions, carrying out due diligence checks and transaction monitoring and cryptocurrency tracing for compliance with anti-money laundering regulations and obligations derived from the Money Laundering Regulations and our status of FCA regulated entity, and for the purposes of dealing with any customer enquiries.
  • To receive services from our suppliers: We will use our suppliers Personal Information to receive their services from them. Please note that we will assume, unless our suppliers instruct us otherwise in writing, that we may use and disclose their Personal Information in such manner as we believe is reasonably necessary to receive and to review the provision of those services from them.
  • To collect our charges or costs in connection with service provision or other legal enforcement: We will use Personal Information to agree payment arrangements with you and to collect our fees and costs owing to us in connection with the service provision and/or legal enforcement.
  • To manage our supplier relationships: We will use our suppliers Personal Information to agree payment arrangements with our suppliers and to make payments to them.
  • For recruitment and selection purposes: If you apply for a position with Avencia Digital, we will use your Personal Information to process your job application and for general recruitment and selection purposes. If you are successfully recruited, the Personal Information you provide will be stored on your personnel file.
  • For monitoring and quality assurance purposes: We may monitor e-mail communications between our employees and third parties for the purpose of quality assurance and training or as otherwise permitted by law. Also, we may use the data to develop and improve the products and services that we provide.
  • For site analytics purposes: We may collect, store, and use certain, limited information relating to your use of our website for the purposes of better understanding the types of visitors who browse our site and improving our site offering. Other than information you choose to submit voluntarily to receive communications from Avencia Digital, the information we collect about site visitors does not enable any visitor to be individually identified, is processed only in anonymised, aggregated form, and will only be used for site analytics purposes as described below in Cookies and similar tracking technology section.

(3) Your data protection rights

Your personal data is protected by legal rights. You have the following data protection rights, subject to certain exemptions and satisfying certain conditions:

  • You have the right to access the personal data we hold about you. Requests to access your personal data should be made in writing and sent by e-mail. If you wish, to access, correct, update or request deletion of your Personal Information, you can do so at any time by contacting us via e-mail to support@avencia.digital.

    You may ask us to delete your personal data in certain circumstances. It may not be possible for us to delete all of the personal data we hold about you where we have an ongoing relationship, however, please contact our Data Protection Officer who will be able to assist with your request.

  • In addition, you can object to the processing of your Personal Information, ask us to restrict the processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us via e-mail to support@avencia.digital.
  • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided above.
  • Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. Again, you can exercise these rights by contacting us using the contact details provided under the "How to contact us" heading above or via e-mail to support@avencia.digital.
  • You have the right to complain to Information Commissioners' Office about our collection, processing and use of your personal information. Further details on how to raise a compliance are provided below.
  • We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

For more information or to exercise your data protection rights, please contact us using the contact details above.

(4) Automated decisions

We use the personal data you provide to us to create a risk profile of our customer. This risk profile is considered as part of your service provision, and we may take decisions by automated means as part of KYC, screening and due diligence checks with the scope to verify your identity to prevent and detect crime and money-laundering.

As part of the processing of your personal data, where decisions may be made by automated means is being endorsed by manual intervention. This means we may automatically conduct checks and when the result turns that you pose a fraud or money laundering risk or if our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct, or is inconsistent with your previous activity or pattern, or you appear to have deliberately hidden your true identity then we will have a look manually into the flagged activity or result and will manually decide to accept or refuse the business relationship and provide the services you have requested, or we may stop providing existing services to you consistent and in accordance with the legal requirements applicable to us.

(5) Who we share your Personal Information with

We may disclose your Personal Information with the following categories of recipients:

  • Business partners, service providers and other third parties: who provide data processing services to us (for example, to support the delivery of our website or due diligence services), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information.
  • To any competent law enforcement body, regulatory, government agency, court or another third party: where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.
  • To an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice.
  • To any other person with your consent to the disclosure.

(6) Legal basis for processing Personal Information

We process your personal data on different bases, according to the reason for which you have provided your data to us. Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only

  • where the processing is in our legitimate interests and not overridden by your rights. We may process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services once you access our service
  • where processing is necessary to fulfil a contract with you (such as the trading agreement, specific terms and conditions if applicable and where applicable)
  • where processing is necessary to fulfil a contract with our partners that we work with, or
  • we have your consent to do so. When you are browsing the website, we process your data on the basis that you have given your consent to such processing by accessing the website. When you write to us, you also provide us with your personal information voluntarily. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person (e.g. our legal obligation to carry out appropriate customer due diligence, KYC and anti-money laundering checks).

If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests, and if appropriate, we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the "How to contact us" heading above or e-mailing us at support@avencia.digital.

(7) Do I have to provide you with my personal data? What happens if I don't?

You will need to provide us with certain information in order for us to consider your application, and if you are accepted as a customer, in order for us to meet our contractual obligations to each other. You have no obligation to agree to us giving your data, but in that instance, we won't be able to initiate a business relationship with you and provide our service, while in the instance when you are an existing customer, we will have to terminate the business relationship. However, to consider your application or in the instance when you are an existing customer, you do not have to provide personal data to us which is over and above that which we need in order to fulfil our obligations to each other and/or meet a legal requirement.

(8) Cookies and similar tracking technology

We use cookies and similar tracking technology (collectively, "Cookies") to collect and use personal information about you. For further information about the types of Cookies we use, why, and how you can control Cookies, please see below our Cookie Statement.

(9) International transfers of Personal Information

Avencia Digital does not transfer your Personal Information to business partners or service providers that are located in territories outside of the UK.

(10) How we look after your Personal Information

We have in place what we believe to be appropriate technical and organisational security measures to protect your Personal Information against unauthorised or unlawful use, and against accidental loss, damage, or destruction. We put in place strict confidentiality agreements (including appropriate data protection obligations) with our third-party service providers. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

If you or others on your behalf give us any Personal Information about another person, you take full responsibility for complying with any relevant data protection laws which apply to the provision of that information to us, and our use of it as explained in this Notice.

(11) Data retention and security

We understand that the privacy and security of your personal data are of great importance, and therefore we have implemented security policies, rules, and controls to protect your information.

We will only retain personal data for as long as is necessary. In accordance with our retention policy and applicable anti-money-laundering legislation, we will retain your personal data for a minimum of five years from the end of our business relationship with you. Our business relationship will be deemed to be at an end on the date upon which your account is closed. This will either be when all outstanding sums under the agreement have been cleared and settled.

We retain Personal Information where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, compliance, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

3 Other Information

(1) Cookies Statement

The website uses cookies which are placed on your computer or other device and may collect some pieces of personal data from you. Some cookies are essential to the operation of the website, while others are used for purposes which include improving your experience of our website, affiliate tracking, and advertising. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse our website and interaction with site visitors. When accessing our website, you accepted or declined the use of different types of cookies; you can edit the cookies the website process in the cookie settings of your browser. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our website.

We use both session, and persistent cookies for the purposes set out below:

  • Necessary / Essential Cookies

    Type: Session Cookies

    Administered by: Us

    Purpose: These cookies are essential to provide You with services available through the website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

  • Cookies Policy / Notice Acceptance Cookies

    Type: Persistent Cookies

    Administered by: Us

    Purpose: These Cookies identify if users have accepted the use of cookies on the website.

  • Functionality Cookies

    Type: Persistent Cookies

    Administered by: Us

    Purpose: These cookies allow us to remember choices You make when You use the website, such as remembering your login details or language preference. The purpose of these cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the website.

(2) What if I have a complaint?

We work to high standards when it comes to processing your personal data. If you are unhappy about how your personal data has been used, please contact our Data Protection Officer (DPO):

Our DPO will acknowledge your complaint straightaway and will independently investigate and respond within 30 days. In the unlikely event that the DPO has not been able to fully address the raised issue and offer a response within the statutory timeframe, you may escalate the complaint to the Information Commissioner's Office (ICO), which regulates the processing of personal data.

Following the response provided if you remain unhappy, you have the right complaint to the ICO about the way we handle your data or respect your rights. However, we would appreciate raising your dissatisfaction with our Data Protection Officer first to give a chance looking into the matter and try to resolve the complaint to your satisfaction. By allowing our independent officer looking into your dissatisfaction might help you obtain both a quicker resolution to your complaint and an answer with the sought explanation, you might be looking for.

You may reach out to ICO by following means:

Additional information on raising a complaint, you may find on ICO's website by following this link https://ico.org.uk/your-data-matters/raising-concerns/

(3) Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical, or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

You are advised to review this Privacy Notice periodically for any changes. Changes to this Privacy Notice are effective when they are posted on the website. You can see when this Privacy Notice was last updated by checking the "last updated" date displayed at the top of this Privacy Notice.

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