First published: September 9, 2024
Last updated: October 9, 2024
We, SimplePro LLC, aim to respect and protect the privacy of those who explore our Website (“Users”) and users who sign up for and access our Services (“Customers”) (together referred throughout this policy as “you” and “your”).
The primary task this Privacy Policy aims to is to describe in the clearest and most precise way what personal data we collect, how we use it, how we share it and what rights you can exercise as we provide you with access and utility through our digital asset trading platform via software, API (application program interface), technologies, products and/or functionalities ("Services").
We rely on our users. By accessing our Services, you (a) acknowledge that you have the right, capacity and authority to accept this Privacy Policy; (b) acknowledge that you have read and understand this Privacy Policy and (c) consent to the policies and practices outlined in this Privacy Policy. So please read them carefully to understand what we do. If there are any terms you do not agree with please discontinue your use of our website.
Data controller: SimplePro LLC, a company incorporated in Saint Vincent and the Grenadines under the registered number 3462 LLC 2024.
Data Protection officer: our Data protection officer can be contacted via email privacy@simplepro.io and will work to address any questions or issues that you have with respect to the collection and processing of your personal data.
Personal data means any information capable of identifying you as an individual, such as your name, e-mail address, or that can be connected to you indirectly, such as your language, location, MAC address and other identifies. We collect personal data that you directly provide to us when registering at Website, expressing an interest in using our Services or when participating in our activities or otherwise contacting us via customer support and any other means of communication.
The Personal data we collect depends on the context of your interactions with us, the choices you make and the products and features you use. We also collect or generate Personal data when third parties provide information about you, or provided in the course of providing our Services, and we may collect Personal data from other sources, for example, to keep your information up to date using publicly available sources.
If the personal Data we request is not provided by you, we may not be able to provide you with the benefit of our Services or meet your needs appropriately. Accordingly, we do not give you the option of dealing with us anonymously or under a pseudonym.
1) Information provided by you directly
Registration Data
| We collect your identification data including Full name, E-mail address, Phone number, Residential Address |
| Verification Data | Full name, Country of residence, Country of nationality, Government issued identity document, Source of funds, Source of wealth, Phone number, Gender, Tax identification number |
| Biometric Data | We may ask you to provide the sensitive biometric information such as a video recording of you or a selfie to verify your identity by comparing it with the photo in your identity document as requested by our KYC provider. |
| Transaction Data | We may collect Information about the transactions including the names of the sender and the recipient, the transaction ID, transaction amount, payment method, IP address and other data. |
| Wallet Data | If you use your wallet, we may collect your deposit wallet address, recipient wallet address, recipient memo, deposit memo, User agent and information related to it. |
Credentials Data
| We collect your passwords and similar security data used for authentication and account access. |
2) Information provided by third parties
We will use the information we receive only for the purposes that are described in this Policy or that are otherwise made clear to you on the Website. Please note that we are not responsible for the ways in which any service provider processes any of your personal data and invite you to read their privacy notices and policies for further information on how they process your personal data.
All personal data that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal data or change the incorrect data as provided in your account.
| Service Providers Data | We provide you with the option to register using any service provider's account details like your Google account. Where you choose to do this, we will receive certain profile information about you from such service providers. The profile information we receive may vary depending on the service provider concerned, but such information may often include your name, e-mail address, profile picture as well as other information you choose to make public. |
| Blockchain Data | We may analyze public blockchain data, including timestamps of transactions or events, transaction IDs, digital signatures, transaction amounts, and wallet addresses. |
| Marketing, Analytics and Advertising partners’ Data | Identifiers – the IP address, or other online identifiers of a person, e-mail address if used for direct marketing, and name and address
Demographic data - (e.g., income, family status, age bracket, gender, interests, etc)
Browser/web history data and preferences expressed through selection/viewing/purchase of goods, services and content, information about your mobile device including (where available) type of device, device identification number, mobile operating system.
Analytics and profiles of the individuals based on the data collected on them. For more information about this please see our Cookie Policy.
Interests or inferred interests and marketing preferences. |
3) Data automatically collected
We automatically collect certain information through cookies and similar technologies when you visit, use or navigate the Website.
To the extent permitted under the applicable law, we may collect certain types of information automatically, for example whenever you interact with us or use the Services. This information does not reveal your specific identity (like your name or contact information) and does not allow to identify you. However, it may include device and usage information, such as your IP address, browser and device characteristics, its type and version, operating system, MAC address, time zone, language preferences, referring URLs, device name, country, location, information about how and when you use our Website, information about your interaction in our emails, and other technical and statistical information.
This information helps us address customer support issues, improve the performance of our sites and Services, maintain and or improve your user experience, and protect your account from fraud by detecting unauthorized access.
| Category of Data | Description |
| Browsing Data | Information about the device, operating system, and browser you’re using Other device characteristics or identifiers (e.g. plugins, the network you connect to) IP address MAC address Device name Country Location Time Zone |
| Usage Data | Activity information: Information about what you view or click on while visiting our Sites and Apps and how you use our Services
Diagnostic and Troubleshooting Information: Information about how our Services are performing when you use them, i.e. service-related diagnostic and performance information, including timestamps, crash data, website performance logs, and error messages or reports. |
| Information from cookies and similar technologies | See our Cookie Policy for more information |
We may use your personal data for a variety of reasons like maintenance of your account and provide you with our services. Below, you can find the specific ways in which we use your personal data.
Notice for the residents of the European Economic Area (“EEA”) and Switzerland: the GDPR requires us to indicate the specific legal basis for personal data processing which is set forth below as well.
1) We use the following information in order to perform our contract with you:
| Purpose | Category of Data |
To create and maintain your account:
In order to use our Services, we allow you to set up and maintain your customer account and profile. | Registration Data Credentials Data Service Providers Data |
To provide Services to you
In order to provide you with Services to invest (such as buy or sell), exchange within your account, including hosting and maintaining your digital wallets.
| Registration Data Verification Data Service Providers Data Biometric Data Transaction Data Wallet Data Credentials Data Blockchain Data Usage Data |
To send Service communications
To send you administrative or account-related communications about our Services, which can include security updates or transaction-related information, through email or in-product/push notifications. You may not opt-out of receiving critical service communications, such as emails or mobile notifications sent for legal or security purposes. | Registration Data Transaction Data Usage Data |
To provide customer support service
To address your request for support via available means and to respond to customer care and other inquiries, including providing email-based customer support to users, chat message support (including chatbots), and social support. | Registration Data Verification Data Transaction Data Wallet Data Blockchain Data |
To maintain safety, security and integrity of the Services
To verify accounts and related activity, find and address violations of our agreement with you or our policies, investigate suspicious activity, detect, prevent and combat harmful or unlawful behaviour, detect fraudulent behaviour and to maintain the integrity of our Services. | Registration Data Verification Data Biometric Data Transaction Data Wallet Data Browsing Data Usage Data Blockchain Data |
2) We use the following information in order to comply with our legal obligations:
| Purpose | Category of Data |
To provide legal and regulatory compliance
We may access, read, preserve, and disclose information when we believe it is reasonably necessary to comply with law, legal obligations, regulations, law enforcement, governmental, and other legal requests, court orders, or for disclosure to tax authorities. Examples of laws that may require us to collect, use or disclose your information:
| Registration Data Verification Data Biometric Data Transaction Data Wallet Data Usage Data Blockchain Data Marketing, Analytics and Advertising partners’ Data |
To verify your identity
We are generally required to collect various pieces of personal information to properly identify or verify your identity and comply with other specific anti-money laundering (“AML”) or sanctions laws/regulations (e.g. funds transfer rules). Our verification processes also involve electronic identification through the comparison of your ‘selfie’ against your provided verification information. All such information is securely maintained by us and our KYC providers, and is only disclosed where permitted by law.
| Registration Data Verification Data Biometric Data |
3) We use the following information for our legitimate interest:
| Purpose | Legitimate Interest we rely on | Category of Data |
To improve our Services
We analyze data and core metrics to provide a better user experience. | It is our interest to make use of our Services more user-friendly. | Registration Data Transaction Data Browsing Data Usage Data |
To customize your experience
In order to perform core metrics, customize your experience with our Services and to generally improve our Services, we collect information about your online activity while you are using the Services (for example, when and how often pages on our Sites are visited, and our Services are used).
| It is in our interest to understand how you interact with the Services in order to customize and/or improve our products and Services and enable accurate and reliable reporting.
| Registration Data Transaction Data Browsing Data Usage Data Marketing, Analytics and Advertising partners’ Data Information from cookies and similar technologies |
To provide you with promotion and the benefits of the loyalty program
We use your information to provide promotions, including sweepstakes offers or other incentives and rewards for using our Services.
| It is in our interest and your interest to reward customer loyalty.
| Registration Data Transaction Data Wallet Data |
4) We use the following information based on your consent:
| Purpose | Category of Data |
To provide marketing communication and promotions to you
To send you targeted marketing communications through email, in-app, and push notifications or by SMS. You may also see ads for our Services when you visit other apps and websites. | Registration Data Usage Data Browsing Data Transaction Data Marketing, Analytics and Advertising partners’ Data |
To enable device-based settings (Cookies)
Collecting information that you allow us to receive through the device-based settings you enable which we use to provide the features or services described when you enable the setting.
| Information from cookies and similar technologies |
We may use cookies and similar tracking technologies to access or store personal data.
You may refuse the use of cookies by selecting the appropriate settings on your browser. Note however that this may affect your experience of our Website.
Please read our Cookie Policy to understand how we collect data via cookies technology.
We do not sell your personal data as the term “sell” is traditionally understood. However, your personal data will be transmitted to third parties that we use to provide our Services; these parties have been rigorously assessed and offer a guarantee of compliance with the legislation on the processing of personal data. These parties have been designated as data processors and carry out their activities according to the instructions given by us and under our control.
We may share your personal data with the following categories of third parties:
As we are operating our business globally, your personal data may be stored and processed in any country where we have operations or where we engage our service providers. We may disclose or transfer information to our service providers that can be located outside your country of residence or the country in which your personal data was originally collected.
Those other countries may have data protection or privacy rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your personal data remains protected to the standards described in this Privacy Policy.
Notice for the residents of the European Economic Area (“EEA”) and Switzerland. Transfers outside of the EEA are sometimes referred to as “third country transfers”. We may transfer your personal information to our Affiliates, third-party partners, and service providers based throughout the world. In cases where we intend to transfer personal information to third countries or international organisations outside of the EEA, we rely on decisions from the European Commission where they recognise that certain countries and territories outside of the European Economic Area ensure an adequate level of protection for personal information. We ensure our partners established in the countries with an inadequate level of protection of personal data have adopted SCC and suitable technical, organizational and contractual safeguards , as appropriate, to ensure confidentiality, security, and legality of the processing of your personal data.
We store your personal data as necessary for providing you the Services, compliance with our legal obligations, fulfillment of our legitimate interests, or during the validity of your consent as stated in this Privacy Policy. We store your personal Data as long as it may be required by law such as for tax and accounting purposes, compliance with Anti-Money Laundering laws, or to resolve disputes and/or legal claims or as otherwise communicated to you.
As soon as information stops serving these purposes, we delete it.
While retention requirements vary by jurisdiction, we will keep some personal data that we are allowed or required to maintain, in such cases as:
After you close your account and/or upon your request we will delete and/or anonymize your personal data without undue delay, but no later than in 30 days.
We have implemented appropriate technical, physical and administrative security safeguards designed to protect the security of any personal data we process and to protect your personal data from unauthorized access, use, disclosure, alteration or destruction. We provide updates and test the security technology we are using on an ongoing basis.
For instance, we follow industry leading practices for securing data using secure socket encryption (HTTPS) on transmission and utilizing encryption services provided by Google Cloud.
However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal data, transfer of personal data to and from our Website is at your own risk. You should only access the Services within a secure environment.
We also restrict access to your personal data to those employees who need to know that information to provide Services to you. Moreover, on a regular basis, we provide training to our employees about the importance of confidentiality and maintaining the privacy and security of your personal data. We commit to taking appropriate measures to enforce our employees’ privacy responsibilities.
We may provide you with company news, promotions, and information relating to our products and services provided by SimplePro. We may share personal Data with third parties to help us with our marketing and promotional projects or sending marketing communications.
We may only use your personal data for direct marketing if you have consented to it via our opt-in mechanism. Besides, if you consented, we will provide a simple means by which you can easily request not to receive direct marketing communications from us. We will draw your attention to the fact you may make such a request in our direct marketing communications. You can opt out from these marketing communications at any time by following the unsubscribe link within any marketing communications sent to you or by contacting our.
For our Service communication such as security updates or transaction-related information, through email or in-product/push notifications, you may not opt-out of receiving critical service communications, such as emails or mobile notifications sent for legal or security purposes. We aim to provide integrity of our Services and the best experience to our users, and we hope for your understanding.
Subject to applicable law, as outlined below, you have a number of rights in relation to your privacy and the protection of your personal data. You have the right to request access to, correct, and delete your personal data, and to ask for data portability.
Notice for the residents of the European Economic Area (“EEA”) and Switzerland. The GDPR provides following rights for data subjects:
If you believe we are unlawfully processing your personal data, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
To protect your privacy and security, we may take steps to verify your identity before complying with your request and we may decline your request if we are unable to verify your identity.
Please contact us by email at privacy@simplepro.io to exercise your rights.
Notice for the residents of the State of California
California Consumer Privacy Act (CCPA) provides our users who are California residents, with the following rights listed below in relation to personal information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
We do not sell the data of users under 16 years of age, unless affirmatively authorized, as specified, to be referred to as the right to opt in. The act will prescribe requirements for receiving, processing, and satisfying these requests from consumers. The act will prescribe various definitions for its purposes and would define “personal information” with reference to a broad list of characteristics and behaviors, personal and commercial, as well as inferences drawn from this.
Please contact us by email at privacy@simplepro.io to exercise your rights.
A personal data breach may, if not addressed in an appropriate and timely manner, result in a physical, material, or non-material risk to your rights and freedoms. Therefore, as soon as we become aware that a personal data breach has occurred,
Notice for the residents of the European Economic Area (“EEA”) and Switzerland. If any personal data breach occurs, we will notify the personal data Breach to the supervisory authority without undue delay and, where feasible, not later than 72 hours after having become aware of it, unless we are able to demonstrate, following the accountability principle, that the personal data breach is unlikely to result in a risk to your rights and freedoms. Where such notification cannot be achieved within 72 hours, the reasons for the delay should accompany the notification without undue further delay.
We do not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with your personal data, please contact us. If we become aware that we have collected personal data from anyone under the age of 18 without verification of parental consent, we take steps to remove that information from our servers.
If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent's consent before we collect and use that information.
Please contact us at privacy@simplepro.io if you become aware of any data we have collected from minors.
We may update this Privacy Policy from time to time. The updated version will be indicated by an updated ‘LAST UPDATED’ date and the updated version will be effective as soon as it is accessible for our users. If we make any updates that affect our user’s privacy significantly, we may notify you directly by sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your data.
SimplePro LLC, a company incorporated in Saint Vincent and the Grenadines under the registered number 3462 LLC 2024.
Our Data protection officer can be contacted via email privacy@simplepro.io and will work to address any questions or issues that you have with respect to the collection and processing of your personal data.