Privacy policy

INTRODUCTORY PROVISIONS

Present privacy policy (hereinafter “Policy”) describes how RampWay s r o osoba rizikového kapitálu (hereinafter “Company” “we” “our” or “us”) collects uses shares and stores personal data of users of our website/-es https://protoncrypto.pro https://rampway.cz (hereinafter “Sites”)

This Policy applies to the Sites applications products and services (collectively “Services”) on or in which it is posted linked or referenced

By using the Services you accept the terms of this Policy and our Terms of Use and consent to our collection use disclosure and retention of your information as described in this Policy If you have not done so already please also review our Terms of Use

We may update this policy to reflect changes in our practices or based on the change of the legislation If there are any material changes we will notify you by email to your registered email address or by notification on https://protoncrypto.pro

IF YOU DO NOT AGREE WITH ANY PART OF THIS POLICY OR OUR TERMS OF USE THEN PLEASE DO NOT USE ANY OF THE SERVICES

PURPOSE OF THIS PRIVACY NOTICE

We process personal data in an appropriate and lawful manner in accordance with the laws of Czech Republic which shall be applicable to this Policy unless this conflicts with mandatory consumer protection provisions of any other EU/EEA member state and to the exclusion of collision laws in particular we process personal data in accordance with the Czech Republic The Personal Data Processing Act No 110/2019 Coll the “Act” as amended and the General Data Protection Regulation Regulation EU 2016/679 the “GDPR” as well as subsidiary legislation and regulations promulgated thereunder

The Services are not intended for minors i e persons under age of majority in respective jurisdiction of residence and we do not knowingly collect personal data relating to minors

It is important that this Policy is read together with any other privacy notice or policy which we may provide on specific occasions when we are collecting or processing personal data about in order to become fully aware of how and why we are using personal data This Policy supplements the other notices and is not intended to override them unless otherwise stated

DATA CONTROLLER

The Company as defined above is the controller

Concerning any questions or requests including any requests to exercise legal rights as a data subject please use the details set out below

• Full name of legal entity RampWay s r o osoba rizikového kapitálu
• Email address [email protected]
• Postal address Na příkopě 583/15 Staré Město 110 00 Praha

WHAT AND HOW DO WE COLLECT DATA

We collect information about you in a following way

Information You Give Us

• Identification Data such as your first name last name date and place of birth permanent or other residence address gender citizenship
• Contact Information such as your email address and telephone number
• Transaction Information such as your crypto wallet address and network information regarding transactions bank details details about status and amount of transaction
• AML Related Data i e data required by Act No 253/2008 Sb on certain measures against the legalization of the proceeds of crime and the financing of terrorism as amended AML Act such as copies of identity cards photographs information on the source of income purpose of the transaction status of politically exposed person
• Marketing information such as your preferences for receiving marketing communications and details about how you engage with them
• Feedback and correspondence such as information you provide in your responses to surveys when you participate in market research activities report a problem with Service receive customer support or otherwise correspond with us
• Log Data such as data about the use of Services IP address browser type and version preferred language geographic location of the IP address operating system and computer platform full URL information click-through information including date and time
• Other Data required by the relevant legislation

Information That Collected Automatically

We may automatically record certain information about how you use our Sites we refer to this information as Log Data

We process this information mainly when it is necessary for

• fulfillment of our obligations e g under the AML Act
• provide our Services
• the functionality of the Site

You may also give your consent for the processing of certain log data through the cookie banner on the Site More about cookies can be found here

To the extent of the consent given the information may be used for service management and analysis which may involve third parties to improve and enhance the service by expanding its features and functions and tailoring it to the needs and preferences of our users

We also may use Google Analytics to help us offer you an optimized user experience You can find more information about Google Analytics use of your personal data here Google Analytics Terms

We also may use Apple Store by Apple Inc to help us offer you an optimized user experience You can find more information about Apple Store services in use of your personal data here Apple Store SLA

Sensitive Data

We do not collect any sensitive data as defined in the GDPR also referred to as special categories of personal data

HOW WE WILL USE YOUR DATA

We only use your personal data as permitted by law We are required to inform you of the legal basis of our processing of your personal information which are described in the table below We may process personal data for more than one lawful ground depending on the specific purpose for which we are using data If you have questions about the legal basis under which we process your personal data contact us at [email protected] Most commonly we will use personal data in the following circumstances

• Where we need to perform our contractual obligations and duties we are about to enter into or have entered into with users in respect of customer relationships with us
• Where it is necessary for our legitimate interests or those of a third party and user interests as well as fundamental rights do not override those interests
• Where we need to comply with a legal or regulatory obligation

Processing Purposes

Opting Out

Users can ask us to stop sending such advertising and marketing communications at any time by

• following the opt-out links on any marketing message sent
• contacting us at any time

Where users opt out of receiving such communications this will not apply to personal data processed or provided to us as a result of customers’ entry into a customer relationship with us and our Services for the other respective purposes

Sharing of Personal Data

We do not share the personal data collected with other organizations without your express consent except as described in this Privacy Policy

Cross-Border Data Transfer

If we transfer your personal data outside the EU to third countries or international organisations it will be protected in accordance with the standard contractual clauses adopted in accordance with the GDPR or where applicable on the basis of a Commission decision on an adequate level of data protection

PROCESSING AND DISCLOSURE OF PERSONAL DATA

We, as the controller of your personal data, primarily process your personal data. We may have to share personal data with the parties set out below for the purposes set out in the table above:

• Business partners providing transaction services, (e.g., authorised representatives, card processing companies, payment processing companies, companies carrying out processes under the AML Act, etc.);
• Business partners providing IT services (e.g. cloud storage providers, etc.);
• Business partners providing services to protect our rights (e.g., debt collection companies or legal services);
• Public Authorities (e.g., Czech National Bank, Financial Analytical Office, Czech Republic Tax Administration, the Office for Data Protection, other law enforcement agencies and authorities who require reporting of processing activities, or may request information from us, in terms of applicable law and in certain circumstances;

We require all third parties to respect the security of personal data and to treat it in accordance with the law (including applicable data protection and privacy law). However, please note that processing carried out by a third party is subject to the terms and conditions set by that third party and is not covered by this Privacy Policy.

We may also disclose customers data:

1. if we are under a duty to disclose or share personal data to comply with any legal obligation, judgment or under an order from a court, tribunal or authority, or
2. if we believe customers’ actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of us or others, or
3. in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company; or
4. if we have consent or at a customer’s direction.

We may also share aggregated or anonymized information, which cannot reasonably be used to identify you.

HOW WE WILL STORE AND SECURE YOUR DATA?

We will only retain personal data for as long as necessary to fulfil the purposes we collected it for (i.e., the ongoing service provision) and, thereafter, for the purpose of satisfying any legal, accounting, tax, and other requirements or obligations to which we may be subject and/or to the extent that we may also need to retain personal data to be able to assert, exercise or defend possible future legal claims against or otherwise involving customers.

We employ industry standard security measures designed to protect the security of all information submitted through the Services. However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data.

WHAT ARE YOUR DATA PROTECTION RIGHTS?

Under the GDPR, you have certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

• The Right to Opt-out. Stop sending you direct marketing communications which you have previously consented to receive. We may continue to send you Service-related and other non-marketing communications.
• The Right to Access. Provide you with information about our processing of your personal data and give you access to your personal information.
• The right to Rectification. Update or correct inaccuracies in your personal data.
• The Right to Erasure. Erase your personal data under certain conditions.
• The Right to Restrict Processing. Restrict the processing of your personal data under certain conditions.
• The Right to Object to Processing. Object to our reliance on our legitimate interests as the basis of our processing of your personal data that impacts your rights.
• Right to Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Right to withdraw consent.

You can submit these requests by email [email protected].

Under the law, you can:

• Request an explanation;
• Demand the removal of an unlawful state;
• File a complaint with the supervisory authority, which is the Office for Personal Data Protection;
• Make a notification through the internal reporting system (LINK).

Kindly note that none of these data subject rights are absolute and must generally be weighed against our own legal obligations and legitimate interests. If a decision is taken to override a data subject request, the user will be informed of this by us along with the reasons for our decision.

We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

Users normally don’t have to pay a fee to exercise their rights as a data subject. However, we may charge a reasonable fee if a request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with requests in the above circumstances.

We will need to request specific information from a user to help us confirm the user’s identity and ensure the user’s right to access the personal data (or to exercise any of the other rights as a data subject). This includes name, address, date of birth, and (in case of a passport/identity card being requested) its validity period.

We try to respond to all legitimate requests within the period of one month from receipt of the request. Occasionally it may take us longer than a month if a request is particularly complex or a number of requests have been made. In this case, we will give notification within four weeks and keep customers updated on the handling of their request

PRIVACY POLICIES OF OTHER WEBSITES

Our Sites may have links to other websites which you can follow, due to that, our Policy applies only to our Sites and other websites has their own privacy policy which you should read.

CHANGES TO OUR PRIVACY POLICY

We keep our Policy under regular review, that is why, we may amend Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make any changes, we will change the “Last Updated” date above.

Any modifications/amendments to Policy will be effective upon our posting of the new terms and/or upon implementation of the changes to the Sites (or as otherwise indicated at the time of posting). In all cases, your continued use of the Sites or Services after the posting of any modified Policy indicates your acceptance of the terms of the modified Policy.

HOW TO CONTACT US

If you have any questions about Policy, the data we hold on you or you would like to exercise one of your data protection rights, please do not hesitate to contact us at: [email protected].

HOW TO CONTACT THE APPROPRIATE AUTHORITY

If you would like to submit a complaint about our use of your personal data or response to your requests regarding your personal data, you may contact us at [email protected] or submit a complaint with the supervisory authority, which is the Office for Personal Data Protection, located at Pplk. Sochora 27, 170 00 Prague 7, website: www.uoou.gov.cz.