Privacy Policy

This Privacy Policy (“Policy”) describes how Personal data of Data subjects are processed by Block Back LLC (“Block Back LLC” or “We”) when they use the Website (“Website”), and/or interact with our online advertisements or marketing emails.

Please, read this Policy carefully. By accepting this Policy, you agree to be legally bound by it and all terms incorporated by reference. If you don’t agree with this Policy or any of its clauses, you shall immediately cease to use our Website.

• Block Back LLC treats collection and use of its Data subjects data responsibly. The Policy was developed in such a manner as to comply with the requirements of Georgian law in particular Law of Georgia on Personal Data Protection № 5669-რს. We confirm that our internal processes are aligned with the Policy.
• Please, note, that according to Terms of Use Block Back LLC acts as an aggregator, informational service provider and intermediary between the Users and various virtual currency exchanges across the globe that act as external third parties with respect to Block Back LLC.
• The Website's Services are limited to technical provision of user interface to facilitate the transaction; Block Back LLC is neither a party to virtual currency exchange transactions, nor has any rate or commission decision making powers.Block Back is neither a party to exchange transactions, nor has any rate or commission decision making powers.

Definitions:

“Website” - website with the URL: https://swapzone.io/.

“Block Back LLC”, “Ourselves”, “We” and “Us” refers to the company Block Back LLC, a legal entity, incorporated under the laws of Georgia, registry code: 402184710, Georgia, Tbilisi, Saburtalo district, Bakhtrioni street, N 22, flat N 75.

“Data subject” or “User” - a natural person who visits the Website.

“Personal data” - information that relates to Data subject and identifies Data subject (Section 3).

“Party” refers to either you or us. For the avoidance of any doubt, the contracting Parties under these Terms are you and Block Back LLC.

Purposes of data processing

Block Back LLC has the right to process Personal data for the following purposes: KYB procedure, analyzing the interaction of Data subjects with the Website, statistical and analytical purposes, User support, improving the work of the Website; providing the User with all the functionality of the Website.

Legal basic of data processing and list of data processed

There are legal grounds necessary for the processing of Personal data and we count on them to process your Personal data.

We do not collect any Personal data other than the Personal data set out in this Policy. Other data may be collected by third parties; we are not responsible for the actions of third parties.

We use the main four grounds to process your Personal data: consent, legal obligation, legitimate interests (to perform terms and conditions):

KYB procedure

According to terms and conditions of AML Policy Block Back is authorized to procсess UBO’s Personal data in order to check the compliance with applicable anti-money laundering and KYB rules. The list of data processed during KYB procedure is specified in the text of AML Policy.

Cookies

Cookies are small fragments of data sent by our web server and stored on the user's device. Cookies are stored when you visit the Website, and this allows us to make it work effectively: Cookies allow us to save your selected settings (e.g., language) and analyze Website traffic.

Block Back uses the following cookies:

• Necessary cookies: help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
• Statistics cookies: help website owners to understand how visitors interact with websites by collecting and reporting information anonymously. These cookies may register data on visitors' website-behavior, collect statistics on the user’s interaction with the real time price- and stock bar on the website.
• Marketing: are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.

These cookies may:

• determine if the visitor has any ad blocker software in their browser – this information can be used to make website content inaccessible to visitors if the website is financed with third-party advertisement,
• save information of actions that have been carried out by the user during the current visit to the website, including searches with keywords included,
• set a unique ID for the visitor, that allows third party advertisers to target the visitor with relevant advertisements.

Third parties and limitation of liability

Please pay attention to the fact that Block Back does not process end-user payment data. As is stated in our Terms of Use, Website is an aggregator, informational service provider and intermediary between the end user and various virtual currency exchanges that act as external third parties with respect to Block Back.

Virtual currency transactions are arranged solely between end users and these third parties. For this reason, Block back does not handle any personal data processing that arises from these transactions. That means that collection and processing of all information on exchanges, transactions, data necessary for KYC procedure is processed by third parties and is subject to their privacy policies provisions.

In no way can Block Back be recognized as a data controller in this respect. Block Back does not have access to information about these transactions, nor does it store it.

Website may contain links to third-party sites. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their sites, features or policies. Please read their privacy policies before you submit any data to them. Please familiarize yourself with these providers and their privacy and liability policies.

Data subject’ rights

Each Data has the right to:

• access the information about Personal data that is processed by Block Back LLC.
• lodge a complaint with a supervisory authority against Block Back LLC.
• rectification of inaccurate data about the Data subject.
• erasure the Personal data about the Data subject.
• receive Personal data about the Data subject and transmit such data to another controller.
• object to Personal data processing on the grounds relating to a particular situation.
• withdraw Data subject’s consent to Personal data processing.

If the Data subject is intending to use one of the rights provided, the Data subject shall send a mail or an email to Block Back LLC by using contact details of Block Back LLC provided for in this Policy.

Once we receive any of your requests we will consider and decide on it within 1 month unless there is a justified requirement to provide such information faster. This term may be extended according to the applicable law. We may request specific information from you to confirm your identity when necessary and reasonable.

How we protect your data?

Block Back LLC takes all the reasonable measures to protect Data subject’s Personal data from unauthorized access by third parties, as well as against loss, misuse, alteration, or destruction of Personal data but we cannot guarantee that these measures will stop any users trying to get around the privacy or security settings on the Website through unforeseen and/or illegal activity.

We observe generally accepted standards to protect your information. In particular, we have taken at least the following measures:

• Appointment of a person responsible for the organization of personal data processing
• Determination of the list of employees having access to Personal data;
• Encryption of data during storage and transfer;
• Arrangement of the procedure for destruction of personal data upon expiration of the term of their processing;
• Conducting internal audits of compliance with the requirements to ensure security of personal data;
• Determining the rules of access to personal data processed in personal data information systems;
• Determining the procedure for responding to information security incidents.

Storage of personal data

We strive to limit the period of Personal data processing to the necessary minimum and not to store them for longer than is reasonably necessary. Usually this period is limited to 1 year, but if applicable data protection legislation prescribes storage of personal data for a longer or shorter period of time, we will store personal data for a period in accordance with these legal requirements.

Amendments

The Policy available is presented in the most up-to-date version. Over time, we may unilaterally amend the Policy, including to comply with the latest changes in the applicable law and jurisprudence. All changes come into force from the moment they are published on this page unless a different period is indicated in the text of the amendments. Block Back LLC will make every effort to organize additional ways to notify users of amendments to the Policy, but we ask you to regularly check for the latest version yourself.

Contact

If you have any questions relating to this Privacy Policy, your rights and obligations and/or your use of the Website, or any other matter, please contact us at [email protected]

Legal entity's name: Block Back LLC

Registration number: 402184710

Legal address: Georgia, Tbilisi, Saburtalo district, Bakhtrioni street, N 22, flat N 75