Learn more about how Excerce collects and uses data and your rights as a Excerce user.
We at Excerce (defined below) respect and protect the privacy of visitors to our websites and our customers. This Privacy Policy describes our information handling practices when you access our services, which include our content on the websites located at https://www.excerce.finance, https://www.excerce.finance/exchange,https://www.excerce.finance/prime, custody.https://www.excerce.finance, or any other websites, pages, features, or content we own or operate (collectively, the Site(s)) or when you use the Excercemobile app, the Excerce Card App (as defined below), anyExcerce, Excerce Exchange, Excerce Prime, or ExcerceCustody API or third party applications relying on such an API, and related services (referred to collectively hereinafter as Services). Please take a moment to read this Privacy Policy carefully. If you have any questions about this Policy, please submit your request via our Support Portal at https://www.excerce.finance. We may modify this Privacy Policy from time to time which will be indicated by the date at the top of this page. If we make any material changes, we will notify you by email (sent to the email address specified in your account), by means of a notice on our Services prior to the change becoming effective, or as otherwise required by law.
For the avoidance of doubt, Excerce does not provide investment, tax, or legal advice, and you are solely responsible for determining whether any investment, investment strategy or related transaction is appropriate for you based on your personal investment objectives, financial circumstances and risk tolerance. Excerce may provide educational information about Supported Digital Assets, as well as Digital Assets not supported by Excerce, in order to assist users in learning more about such Digital Assets. Information may include, but is not limited to, blog posts, articles, links to third-party content, news feeds, tutorials, and videos. The information provided on the Excerce Site or any such third-party sites does not constitute investment advice, financial advice, trading advice, or any other sort of advice, and you should not treat any of the website's content such. Excerce does not recommend that any Digital Asset should be bought, earned, sold, or held by you. Excerce will not be held responsible for the decisions you make to buy, sell, or hold Digital Assets based on the information provided by Excerce. Excerce does not broker trades on your behalf unless otherwise specified on a specific product. All Excerce trades are executed automatically, based on the parameters of your order instructions and in accordance with posted trade execution procedures.
By accessing and using our Services, you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. We may provide additional just-in-time disclosures or information about the data processing practices of specific Services. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.
The Excerce operating entity you contract with determines the means and purposes of processing your personal information in relation to the Services provided to you (typically referred to as a data controller). You may be asked to provide personal information anytime you are in contact with any Excerce companies. The CB companies may share your personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, and content (additional details below). For example, even if you do not reside in the United States (the US), your information may be shared with Excerce, Inc. which provides global support for all Services including technical infrastructure, product development, security, compliance, fraud prevention, and customer support. If you have any questions about your CB Account, your personal information, or this Privacy Policy, please submit your request via our Support Portal.
Personal information is typically data that identifies an individual or relates to an identifiable individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties. The definition of personal information depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Privacy Policy.
Information you provide to us. To establish an account and access our Services, we'll ask you to provide us with some important information about yourself. This information is either required by law (e.g. to verify your identity), necessary to provide the requested services (e.g. you will need to provide your bank account number if you'd like to link that account to CB), or is relevant for certain specified purposes, described in in greater detail below. As we add new features and Services, may be asked to provide additional information.
If you choose not to share certain information with us, we may not be able to serve you as effectively or offer you our Services. Any information you provide to us that is not required is voluntary. We may collect the following types of information from you:
Identification Information: Full name, date of birth, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email.
Formal Identification Information: Government issued identity document such as Passport, Driver's License, National Identity Card, State ID Card, Tax ID number, passport number, driver's license details, national identity card details, visa information, and/or any other information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws.
Institutional Information: Employer Identification number (or comparable number issued by a government), proof of legal formation (e.g. Articles of Incorporation), personal identification information for all material beneficial owners.
Financial Information: Bank account information, payment card primary account number (PAN), transaction history, trading data, and/or tax identification.
Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.
Employment Information: Office location, job title, and/or description of role.
Correspondence: Survey responses, information provided to our support team or user research team.
Audio, electronic, visual and similar information, such as call and video recordings.
Information we collect from you automatically. To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information helps us address customer support issues, improve the performance of our Sites and Services, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:
Online Identifiers: Geo location/tracking details, browser fingerprint, operating system, browser name and version, and/or personal IP addresses.
Usage Data: Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies. Please read our Cookie Policy for more information.
For example, we may automatically receive and record the following information on our server logs:
How you came to and use the Services;
Device type and unique device identification numbers; Device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL);
How your device interacts with our Sites and Services, including pages accessed and links clicked;
Broad geographic location (e.g. country or city-level location);
and Other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser.
We may also use identifiers to recognize you when you access our Sites via an external link, such as a link appearing on a third party site.
Information we collect from our affiliates and third parties. From time to time, we may obtain information about you from our affiliates or third party sources as required or permitted by applicable law. These sources may include:
Our Excerce Family of Companies: Our family of companies is the group of companies related to us by common control or ownership (Affiliates). In accordance with applicable law, we may obtain information about you from our Affiliates as a normal part of conducting business, if you link your various Excerce accounts (e.g., Excerce Wallet account or Excerce Commerce account in order to convert cryptocurrency into fiat and make withdrawals into your bank account), so that we may offer our Affiliates’ Services to you.
Public Databases, Credit Bureaus & ID Verification Partners: We obtain information about you from public databases and ID verification partners for purposes of verifying your identity in accordance with applicable law. ID verification partners like World-Check use a combination of government records and publicly available information about you to verify your identity. Such information may include your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data. We obtain such information to comply with our legal obligations, such as anti-money laundering laws. In some cases, we may process additional data about you to assess risk and ensure our Services are not used fraudulently or for other illicit activities. In such instances, processing is necessary for us to continue to perform our contractual obligations with you and others. World-Check's Privacy Policy, available at https://www.refinitiv.com/en/products/world-check-kyc-screening/privacy-statement/, describes its collection and use of personal data.
Blockchain Data: We may analyze public blockchain data to ensure parties utilizing our Services are not engaged in illegal or prohibited activity under our Terms, and to analyze transaction trends for research and development purposes.
Joint Marketing Partners & Resellers: For example, unless prohibited by applicable law, joint marketing partners or resellers may share information about you with us so that we can better understand which of our Services may be of interest to you.
Advertising Networks & Analytics Providers: We work with these providers to provide us with de-identified information about how you found our Sites and how you interact with the Sites and Services. This information may be collected prior to account creation. For more information on how you can manage collection of this data, please see our Cookie Policy.
Anonymization is a data processing technique that modifies personal information so that it cannot be associated with a specific individual. Except for this section, none of the other provisions of this Privacy Policy applies to anonymized or aggregated customer data (i.e. information about our customers that we combine together so that it no longer identifies or references an individual customer).
Excerce may use anonymized or aggregate customer data for any business purpose, including to better understand customer needs and behaviors, improve our Services, conduct business intelligence and marketing, and detect security threats. We may perform our own analytics on anonymized data or enable analytics provided by third parties.
Types of data we may anonymize include, transaction data, click-stream data, performance metrics, and fraud indicators.
Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We generally use personal information to create, develop, operate, deliver, and improve our Services, content and advertising; and for loss prevention and anti-fraud purposes. We may use this information in the following ways:
1) To maintain legal and regulatory compliance Most of our core Services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. For example, Excerce must identify and verify customers using our Services in order to comply with anti-money laundering laws across jurisdictions. This includes collection and storage of your photo identification. In addition, we use third parties to verify your identity by comparing the personal information you provide against third-party databases and public records. When you seek to link a bank account to your Excerce Account, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk as required under applicable law. If you do not provide personal information required by law, we will have to close your account.
2) To enforce our terms in our user agreement and other agreements Excerce handles sensitive information, such as your identification and financial data, so it is very important for us and our customers that we actively monitor, investigate, prevent, and mitigate any potentially prohibited or illegal activities, enforce our agreements with third parties, and/or prevent and detect violations of our posted user agreement or agreements for other Services. In addition, we may need to collect fees based on your use of our Services. We collect information about your account usage and closely monitor your interactions with our Services. We may use any of your personal information collected for these purposes. The consequences of not processing your personal information for such purposes is the termination of your account.
3) To detect and prevent fraud and/or funds loss We process your personal information in order to help detect, prevent, and mitigate fraud and abuse of our services and to protect you against account compromise or funds loss.
4) To provide Excerce's Services We process your personal information to provide the Services to you. For example, when you want to store funds on our platform, we require certain information such as your identification, contact information, and payment information. We cannot provide you with Services without such information. Third parties such as identity verification services may also access and/or collect your personal information when providing identity verification and/or fraud prevention services.
5) To provide Service communications We send administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our Services. You may not opt-out of receiving critical service communications, such as emails or mobile notifications sent for legal or security purposes.
6) To provide customer service We process your personal information when you contact us to resolve any questions, disputes, collect fees, or to troubleshoot problems. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.
7) To ensure quality control We process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the Services such as inaccurate transaction records or other interruptions.
8) To ensure network and information security We process your personal information in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations. The threat landscape on the internet is constantly evolving, which makes it more important than ever that we have accurate and up-to-date information about your use of our Services. Without processing your personal information, we may not be able to ensure the security of our Services.
9) For research and development purposes We process your personal information to better understand the way you use and interact with Excerce's Services. In addition, we use such information to customize, measure, and improve Excerce's Services and the content and layout of our website and applications, and to develop new services. Without such processing, we cannot ensure your continued enjoyment of our Services.
10) To enhance your experience We process your personal information to provide a personalized experience, and implement the preferences you request. For example, you may choose to provide us with access to certain personal information stored by third parties. Without such processing, we may not be able to ensure your continued enjoyment of part or all of our Services.
11) To facilitate corporate acquisitions, mergers, or transactions We may process any information regarding your account and use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions.
12) To engage in marketing activities Based on your communication preferences, we may send you marketing communications (e.g. emails or mobile notifications) to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers. Our marketing will be conducted in accordance with your advertising marketing preferences and as permitted by applicable law.
13) To protect the health and safety of our employees and visitors, our facilities and our property and other rights. If you visit one of our locations, to maintain security at such locations you may be photographed or videotaped.
14) For any purpose that you provide your consent. We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time, and as required under the applicable law, we may request your permission to allow us to share your personal information with third parties. In such instances, you may opt out of having your personal information shared with third parties, or allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to limit the use of your personal information, certain features or Excerce Services may not be available to you.
For individuals who are located in the European Economic Area, the United Kingdom or Switzerland (collectively EEA Residents) at the time their personal information is collected, our legal bases for processing your information under the EU General Data Protection Regulation (GDPR) will depend on the personal information at issue, the specific context in the which the personal information is collected and the purposes for which it is used. We generally only process your data where we are legally required to, where processing is necessary to perform any contracts we entered with you (or to take steps at your request prior to entering into a contract with you), where processing is in our legitimate interests to operate our business and not overridden by your data protection interests or fundamental rights and freedoms, or where we have obtained your consent to do so. In some rare instances, we may need to process your personal information to protect your vital interests or those of another person. Below is a list of how Excerce uses your personal information, as described above in Section 5, with the corresponding legal bases for processing. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the How to contact us heading below.