1. Controller and Contact
Simply.Exchange is the controller responsible for personal data processed through the Simply.Exchange Platform. You can reach us at v@simply.exchange.
Privacy Policy
2. Overview
We respect your privacy. This Policy explains what we collect when you use our non-custodial interface and what we do not collect (especially payment card and bank credentials). The Company is a technology provider; fiat payments and identity verification (KYC) are handled by independent, licensed Third-Party Processors under their own privacy policies.
3. Data We Do Not Collect
Payment Data Security: The Platform does not collect, store, or process sensitive financial data, including credit card numbers, CVV codes, or bank routing details. When utilizing the fiat-to-crypto checkout, all financial data is entered directly into a secure, encrypted interface managed by our third-party payment processors. All transmissions are compliant with the Payment Card Industry Data Security Standard (PCI-DSS). The Platform only receives post-transaction confirmation tokens and wallet addresses via API to verify delivery status.
Primary fiat flows for retail buy use onramp and offramp operators we integrate. Each operator's privacy policy applies to payment and KYC data collected on their hosted pages.
4. Information We Collect
| Category | Examples | Purpose |
|---|---|---|
| Wallet & transaction context | Withdrawal address, coin, network, country selection, fiat amount | Generate quotes and checkout links |
| Technical | IP address, browser type, logs, timestamps | Security, fraud prevention, debugging |
| Communications | Support emails you send us | Respond to inquiries |
| Cookies / local storage | Session preferences, country selection cache | UX (see §9) |
| HRPT orders (if applicable) | Order ID, webhook status, treasury settlement metadata | Fulfil token sale flow |
We do not intentionally collect government ID, payment card data, or bank account numbers on the Platform.
5. How We Use Information and Legal Bases
We use information to:
- operate and secure the Platform;
- facilitate API calls to processors (quote, checkout link, webhook status);
- comply with law and enforce our Terms; and
- improve reliability (aggregated analytics where used).
Where GDPR applies, we rely on: contract (providing the interface), legitimate interests (security, product improvement), and legal obligation where required. Processor licensing and product rules may vary by country (including EEA users paying in EUR via hosted buy); availability is processor-determined, not guaranteed by us.
6. Sharing
We may share data with:
- Payment processors (onramp and offramp operators and their partners);
- Infrastructure providers (e.g. Amazon Web Services — hosting, CDN, Lambda
onramp-apiin us-east-1) under confidentiality obligations; and - Professional advisers and authorities when required by law.
We do not sell personal information for money as defined under applicable US state privacy laws.
7. AML, Sanctions, and Legal Disclosure
We and our Third-Party Processors may process and disclose personal data where necessary to comply with anti-money-laundering (AML), counter-terrorist-financing (CFT), and sanctions obligations, or in response to lawful requests by competent authorities, courts, or regulators. Identity verification and sanctions screening for fiat transactions are performed by the licensed processor at the point of payment.
8. International Transfers
Processors and infrastructure may process data outside your country (including the United States). We use appropriate safeguards where required (e.g. Standard Contractual Clauses for EEA transfers to vendors).
9. Cookies
We may use essential cookies and similar technologies for security and preferences. If we add non-essential analytics, we will update this Policy and, where required, obtain consent.
10. Retention
We retain personal data only as long as needed for the purposes below, then delete or anonymise unless law requires longer storage:
| Data type | Retention period |
|---|---|
| API and security logs | 12 months |
| Checkout quotes, order IDs, webhook metadata | 7 years (tax, fraud, dispute) |
| Support email correspondence | 3 years after last message |
| Cookies / local preference cache | Until cleared by user or 13 months (non-essential, if added) |
11. Security
We implement reasonable administrative, technical, and organisational measures. No method is 100% secure.
12. Your Rights
Depending on jurisdiction, you may have rights to access, correct, delete, restrict, object to, or port your personal data, and to complain to a supervisory authority. Contact us at v@simply.exchange. Requests regarding KYC or payment data held by an onramp or offramp operator (or other processor) must be directed to that processor, which controls that data.
13. Children
The Platform is not directed to children under 18 (or age of majority in your jurisdiction). We do not knowingly collect their data.
14. Changes
We may update this Policy. The effective date will change; material updates will be posted on the Platform.
15. Governing Law and Contact
Governing law and dispute venue will be confirmed when the operating entity is finalized, consistent with our Terms of Service.
- Company Simply.Exchange
- Attn Orlando Belova, Managing Member
- Email v@simply.exchange
- Phone USA +1 850-830-9350