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Updated as of 19 July 2024
Astari Ltd (the "Company") is a company incorporated in the British Virgin Islands (the "BVI") whose registered office is at Trinity Chambers, PO Box 4301, Road Town, Tortola, British Virgin Islands. Its principal business is to provide an interface that gives users access to a decentralised Ethereum Virtual Machine. It is a data controller of your personal data in that context. This document (the "Data Protection Notice") explains how the Company collects, uses, and shares your personal data, and how it intends to do so. It also helps you understand your privacy rights under BVI law. In this document, the Company is referred to "we" and "us" as well as "the Company". We use the term "personal data" to mean data that may enable us or any third party (whether fiscal, commercial or governmental) to identify a natural person, such as you (whether from the data itself on its own, or in connection with other data). It includes but is not limited to a person's name, IP address, wallet ID, browsing habits, geolocation, tax ID, credit card number, passport number and driving licence number. When you use the interface, the principal information that we collect from you is your email address, telegram ID, and blockchain wallet address/ID. We may also collect information such as completed transaction hashes, and the token names, symbols, or other blockchain identifiers of the tokens that you swap. We (or third parties acting on our behalf) may collect personal information from you (e.g., your name or other identifiers that can be linked to you) for example to satisfy anti-money laundering, law enforcement and know your customer compliance requirements. By using the interface, you will be providing personal data to us or one or more of our agents for processing, and your personal data will be processed in accordance with this Data Protection Notice. Processing is used to mean any action in relation to that personal data including (but not limited to) storing, transferring, mining, disclosing, modifying, deleting and aggregating with other data.
The Company is the data controller in respect of your personal data as it makes decisions about how, why and where the personal data you provide to us is processed. As we are a BVI company, we are required to process personal data in accordance with BVI law and any other applicable law in respect of the processing of personal data (the "Data Protection Legislation"). This Data Protection Notice applies to the processing of personal data processed both by us and on our behalf by any processors we have appointed. Our Data Protection Notice only applies to personal data collected and processed by or on our behalf. It does not apply to any personal data that may be collected and processed by or for third parties. This includes third parties such as Google Analytics and Hotjar who might collect personal data through cookies and other software. The data protection notices of those third parties govern their collection and use of any such personal data and you should familiarise yourself with their data protection policies and the privacy settings of the websites of those third parties.
The categories of personal data we may collect, share, disclose, delete and otherwise process will depend on how you interact with us, and the requirements of applicable law. We may collect, process and transfer personal data that you provide to us (or an agent acting on our behalf), as well as personal data that is obtained automatically when you browse or interact with the our website or the interface, as well as personal data from other sources such as third-party services and organisations, as described below. We may collect the following personal data that you provide to us. • We may collect data when you create an account such as your name, address, email address, wallet ID, and username. • We may collect personal data and details associated with your transactions, including payment data. We may contract with a third-party payment processor. We may collect or store any payment card data you have provided to this processor and we and the processor may receive data associated with your payment card data (e.g., your billing details). • We may collect personal data such as email address, phone number, and/or address if you contact us or otherwise communicate with us. • We may collect personal data that you submit or make available through messaging and chat features, or when you comment in forums, blogs, and social media pages. Any personal data you provide using public sharing features (referred to herein as “User Content”) will be considered “public,” unless otherwise required by applicable law. Please consider whether you want to reveal personal data that may identify you to other users particularly if you do not know those persons.
We may collect personal data automatically when you browse our website or interact with us, as follows: We may collect certain personal data automatically when you browse our website. This may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), date and time stamps, mobile device ID, and Internet service provider. We may also automatically collect personal data such as pages that you visit before, during and after any actual or abandoned transaction on the interface, information about the links you click, the types of content you interact with, the frequency and duration of your activities. • We, as well as third parties that provide content or other functionality on the website, may use cookies, pixel tags, local storage, and other such software to automatically collect personal data, including your personal data.
We do so for necessary operational reasons, such to enhance your experience of using the website, as well as to better understand how our purchasers and prospective purchasers might interact with our website. We also want to ensure that we prevent fraud and other unlawful use of the website. Where third parties collect personal data through cookies, pixel tags/web beacons and other software, your personal data will be processed by them and in accordance with their privacy policies and data protection notices. These third parties include:
Google Analytics. For more information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your personal data, please click here. Hotjar. For more information, please visit: https://www.hotjar.com/legal/policies/privacy. You can opt out of Hotjar’s processing of your personal data on our website by visiting: https://www.hotjar.com/legal/compliance/opt-out. • Our website may contain buttons for social media and other platforms such as GitHub, Twitter, Telegram, Discord and LinkedIn (that might include widgets such as the “share this” button or other interactive mini programs). These features may collect your IP address, which pages you are visiting, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it. We may obtain personal data about you from other sources. For example, if you access our website through a third-party application, such as an app store, a third-party login service, a third party wallet provider, or a social networking site, we may collect personal data about you from that third-party application, depending on the choices you made via your privacy settings with those third party websites and applications.
We use your personal data for a variety of purposes, as described below. We use your personal data to fulfil any contract we have with you including where we set up an account for you so that we transact on the interface. These purposes include: • Managing your personal data and account; • Answering requests for customer or technical support; • Communicating with you about your account; • Processing your financial information and other payment methods; and • Allowing you to learn more about and to register for and attend events and receive other benefits associated with using our interface. We use your personal data for various administrative and compliance purposes, such as (but not limited to): • Network and information security, and fraud prevention; • Surveillance and detecting security incidents, protecting against actual or attempted unlawful, deceptive, fraudulent or illegal activity, and pursuing those responsible for that activity (and assisting law enforcement wherever law enforcement is based with such pursuit); • Improving, upgrading or enhancing the website; • Developing new products and associated services; • Ensuring internal quality control and safety; • Complying with legal, tax or regulatory enquiries or investigations including assisting law enforcement and other governmental departments or agencies by filing suspicious activity and transaction reports and sharing personal data to support any lawful tax, fiscal, regulatory, legal, administrative law or criminal investigation; • Authenticating and verifying individual identities, including requests to exercise rights under this Data Protection Notice and applicable law; • Debugging to identify and repair errors; • Audit of interactions, transactions and other compliance activities; • Managing our risk and operations; • Enforcing our agreements and policies; and • Complying with our legal obligations. We may also use personal data to provide you with tailored content, such as through email campaigns for marketing purposes. We shall provide you with these materials only as permitted by applicable law. We also use your personal data for other purposes as requested by you or as permitted by applicable law. For example: • We may use personal data for other lawful purposes that are clearly disclosed to you at the time you provide personal data or with your consent. • We may use personal data and other data about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our website, or other analyses we create. • We may use personal data that you have provided that is from your friends and family. Please only share with us contact data of people with whom you have a relationship (e.g., relative, friend, neighbour, or colleague) and who have consented to you sharing such content. • We may create anonymised data records from your personal data. We may use this data to analyse requests and usage patterns so that we improve the services we offer to our users. We reserve the right to use this data for any purpose and to disclose this to third parties without any restriction or prior notice to you.
We disclose your personal data to third parties for a variety of purposes, including to protect us or others from attempted fraud, to support law enforcement or government authorities (wherever situated), or in the event of a merger, sale, or asset transfer. The privacy policy of those third parties will apply to the processing of your personal data in these cases. Where a tax authority, regulator, government, or law enforcement agency requests that we voluntarily provide your personal data to them, whether or not they are incorporated, formed or registered in the BVI, we shall reserve the right to do so without first seeking your express permission to do so provided we consider in our absolute discretion that that request is not frivolous. If you are not comfortable with this potential disclosure of your personal data, you must not provide it to us.
The rights you may have about your personal data are determined by applicable law and under BVI law, include the following rights: • If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive emails as are necessary to enable us to provide products and any related services associated with the interface. We may also send you certain non-promotional communications. You will not be able to opt out of those communications unless you no longer wish to use our services or the functionality we provide. • You may stop or restrict the placement of cookies and other comparable software on your device or remove them by adjusting your preferences as your browser or device permits. Please note that cookie-based opt-outs may not be effective on mobile applications, and you must separately opt out in each browser and on each device. You may access your personal data held by us: if we hold such personal data, you are entitled to know (i) whether we are processing your personal data; and (ii) to receive an electronic copy of the personal data that we are processing (subject to limited exceptions); • You are entitled to require that we correct or that we enable you to correct any of your personal data where it is inaccurate or incomplete; • You are entitled to require that we delete your personal data (subject to limited exceptions); • You are entitled to object to certain kinds of processing of your personal data (such as for marketing purposes); and • You are entitled to withdraw your consent to our processing of your personal data where you have previously consented to our processing (subject to limited exceptions). If you would like to exercise any of these rights, please contact us using the email address provided in the “Contact Us” section below. We will process such requests in accordance with applicable laws. We may require satisfactory proof of identity in order to proceed.
Our duty to keep your personal data secure We take steps to ensure that your personal data are kept secure. We have taken appropriate safeguards to require that your personal data will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. By providing personal data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues.
All personal data processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, other countries, legal areas, or territories which may have data protection laws that may be different from the laws of the BVI and not offer comparable protections. If we transfer personal data to countries outside the BVI (unless such transfer is to the UK or the European Economic Area), we will put in place appropriate safeguards to ensure that this transfer complies with applicable laws and regulations (unless an exception or exemption applies). For more information about these safeguards, please contact us.
We will retain and process the personal data we collect as described in this Data Protection Notice for as long as necessary to fulfil the purpose(s) for which it was collected, including to set up and maintain an account for you, provide the interface, resolve disputes, establish legal defences, conduct audits, comply with applicable anti-money laundering law and regulations, enforce our agreements, and comply with applicable laws. We are required to, and will, delete any personal data once it is no longer necessary to hold, store or otherwise process it. We reserve the right to delete your account and any personal data it holds if you have not accessed your account within a period of 24 months of its creation. Notwithstanding the above, and any other information in this Data Protection Notice, we cannot edit or delete any information that is stored on a blockchain as we do not have custody or control over any blockchain. This may include purchases, sales, and transfers related to your blockchain address. When you use the interface, you are interacting with a public blockchain which provides transparency of your transactions. We are not responsible for protecting your privacy in respect of any personal data and any information that is made public on a blockchain.
This website may link to the websites/applications of third parties and third party websites/applications may reference or link to us. These third-party websites and their services are not controlled by us. We encourage you to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal data to third-party websites or applications is at your own risk. Certain territories may give you different or additional rights under Data Protection Legislation (for example, if you are a California resident or a user in the European Economic Area or the United Kingdom); this may include a right to file a complaint with your local data protection supervisory authority for example if you believe your personal data has been unfairly processed. This right may be in addition to any rights you may have under BVI law. If you are unsure of your data protection rights, you should seek appropriate advice from a suitably qualified person. We may revise our data processing practices and this Data Protection Notice from time to time in our sole discretion. If there are any material changes we will notify you as required by applicable law. You will be deemed to have accepted the updated Data Protection Notice if you continue to use this website.
If you have any questions about this Data Protection Notice, or you wish to exercise your rights as detailed herein, please contact the Company at: support@astari.one.
