Privacy Notice | Ramp Network | Web3 Financial Infrastructure & Crypto Exchange

We care about your privacy

This Privacy Policy aims to give you information on how Ramp Network collects, uses, discloses, transfers, stores and processes the Personal Data you provide us through your use of our Services.

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1. Who We Are

We are Ramp Network and we operate internationally through different entities to allow you to seamlessly exchange Digital Assets for Fiat and Fiat for Digital Assets (the “Services”). Ramp Network entities are listed in Section ‘Where We’re Based’ below and together are referred to as “Ramp Network”, “we”, “us”, or “our”.

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This privacy notice (the “Privacy Policy”) explains how we, Ramp Network and our Affiliates, Process your (“you”, “your”) Personal Data when you use our website, www.ramp.network (the “Site”), and our Services.

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For the purposes of Data Protection Legislation, we are the data controller in relation to any Personal Data that we collect from you through your or any other user’s use of our Services and the set-up of your account (your “Account”). This means that we are responsible for determining the purposes for which and means of how your Personal Data is Processed. Any Personal Data that we collect from you for the below purposes is referred to in this Privacy Policy as your Personal Data.

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We and certain Affiliates are party to an intragroup data-sharing agreement and may Process your Personal Data as either independent data controllers or as joint data controllers, depending on the nature of the Processing activity. We and our Affiliates will fully comply with our respective obligations under Data Protection Legislation with respect to such Processing.

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If you have any concerns about how we Process or protect your Personal Data or would like to contact us about any aspect of this Privacy Policy, please get in touch with our Data Protection Officer, who oversees our handling of Personal Data, and who can be contacted at dpo@ramp.network.

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This Privacy Policy should be read together with our Cookies Policy, and our Terms of Service.

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2. What Does This Privacy Policy Contain?

At Ramp Network, we understand that your privacy is important. We respect and value the privacy of everyone who visits our Site and uses our Services. This Privacy Policy specifies how Ramp Network will Process your Personal Data when you use our Services. We only collect and use your Personal Data as described in this Privacy Policy and as permitted by Data Protection Legislation.

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It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or Processing your Personal Data so that you are fully aware of how and why we are using your Personal Data. This Privacy Policy supplements the other notices and is not intended to override them.

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To navigate through our Privacy Policy just click on the links below. Capitalised terms not already defined but used in this Privacy Policy are set out in the Glossary below.

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3. Who Does This Privacy Policy Apply To?

This Privacy Policy applies to:

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(a) our users who access our Site, anyone who participates in our surveys and focus groups, and other research;

(b) users who access our Services anywhere on the web, whether through our Site or any third-party website, application or other third-party content;

(d) other persons who interact with us, when they call us or email us.

This Privacy Policy applies to you whether you act in your personal capacity or as an employee or agent of an organisation.

Please read the following carefully. By accessing or using our Services, the Site, or otherwise accepting the terms of this Privacy Policy indicates that you have reviewed this Privacy Policy and have agreed to be bound by it. If you do not agree to these terms you must leave our Site or stop using the Services immediately. If you no longer consent to our Processing of your Personal Data, you may request that we cease such Processing by contacting us. See ‘How to Contact Us’ below.

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4. What Data Do We Collect About You?

We fully respect your right to privacy in relation to your interactions with the Site and the use of our Services and endeavour to be transparent in our dealings with you as to what Personal Data we will collect and how we will use your Personal Data. We only collect and use your Personal Data where we are legally entitled to do so. We will collect Personal Data about you from the following sources:

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(a) from you (for example, when you create your Account, place an Order, make a payment, tell us about your preferences or respond to our campaigns, communicate with us, or use our Site or Services);

(b) from when we host social events;

(d) from providers about your interactions on the Site, Services and from cookies and tracking devices on your devices where you have permitted their use, and from third parties, advertisers, and other companies in Ramp Network. We may also receive information from other parties in accordance with our responsibilities as a regulated financial services business; and

(e) by combining information that we have collected through the Site or use of Services with information that we have collected from other sources.

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We will collect the following types of information:

Type of data

Description

Your personal and contact details

Information including your name, home address, email address, username and password. We may collect your telephone number if you contact us by phone.

Financial information

Such as cryptocurrency address information, wallet address, transaction history, and trading dates. Other information that allows us to verify your identity and understand the source of your funds. Your payment method, including bank account or payment card details.

Transactions, and account history

Such as transactions you have made. We will also receive information about you when you register with us.

Your communications via us

Such as email conversations with our customer support teams, chats, telephone calls or similar.

How you use the Site and the Services

Such as which pages you visit, which content you view, and what links and buttons you click. This information may be collected through cookies or similar technologies. For more information, please see our Cookies Policy.

General Location information

The device or computer you use to access the Site or Services will provide us with your IP address. The IP address tells us which city, county, or country you are accessing the Site or Services from but does not give us detailed information about your location.

How you use the Site

General Location information

The device or computer you use to access the Site will provide us with your IP address. The IP address tells us which city, county, or country you are accessing the Site from but does not give us detailed information about your location.

Device and other technical information

Such as the unique device identifier and other information about the device you are using to access our Site or Services.

Advertising and direct marketing preferences and responses

Such as your interaction with offers and competitions, including any requests to stop receiving marketing communications. This information may be collected through cookies or similar technologies. For more information, please see our Cookies Policy.

Sensitive Information

We may also Process Special Categories of Personal Data about you in order to meet our legal and regulatory obligations, protect our business and provide our Services. This includes certain Personal Data and any other information to fulfil our legal and regulatory obligations as a regulated financial services business. These Special Categories of Personal Data include biometric data (such as through digital photographs) and information about fraud, theft or offences. If you come to an in-person event that we host, this also includes information you provide to us (such as dietary preferences or disability information).

Visual images

Such as videos and photographs of you provided in your interactions with us in social events we host and your profile image on social media if you choose to enable this through your social media account.

Lifestyle and demographic

Such as information available publicly on your social media profile where you connect with or contact us through your social media account.

We endeavour to keep your Personal Data accurate and up-to-date. As such, you must tell us about any changes to such information that you are aware of as soon as possible.

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5. How Do We Use Your Personal Data?

We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

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Note that we may Process your Personal Data for more than one legal basis, depending on the specific purpose(s) for which we are using your Personal Data. Please contact us if you need details about the specific legal basis we are relying on to Process your Personal Data where more than one ground has been set out in the table below. See ‘How to Contact Us’ below.

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We use your Personal Data in the following ways, and for the following reasons:

Purpose

Legal basis for Processing and, where necessary, the basis of legitimate interest

To register you as a new user.

We need to Process this information to perform a contract with you or to take steps at your request before entering into a contract.

To allow you to use our Services (including placing an Order and managing your payments).

We need to Process this information in order to perform a contract with you and to comply with our legal and regulatory obligations.

To communicate with you about updates to the Site, our Services, and any changes to our terms and conditions or Privacy Policy.

We need to Process this information to perform a contract with you and to comply with our legal and regulatory obligations.

To receive feedback from you on our products and Services.

Your consent.

To run our promotional events such as competitions and offers which may be of interest to you. We may send you marketing material about our offers and events via email or text. You may opt out of direct marketing at any time (see below).

Your consent.

To provide customer support services.

We need to Process this information to perform a contract with you and to comply with our legal and regulatory obligations.

To train our staff (for example our call staff).

It is necessary for our legitimate interests to upskill our staff in order to improve our Services.

To maintain and administer our Site.

We need to Process this information to comply with our legal and regulatory obligations.
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It is necessary for our legitimate interests to maintain our IT services, network security, and to maintain our system.

To improve our Site, products and Services, and experiences, such as by understanding analytics.

Your consent.

To comply with our legal and regulatory obligations as a regulated financial services business. This may involve verifying your identity, age and source of funds.

We need to Process this information to comply with our legal and regulatory obligations.
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It is necessary for our legitimate interests to prevent fraud and illegal activities on our Site or by using our Services.

To protect our business from money laundering, terrorist financing, and other illegal activities. We may identify you electronically using technology such as cookies.

We need to Process this information to comply with our legal and regulatory obligations, including AML, KYC, CTF and sanctions enforcement laws and regulations aimed at preventing and detecting money laundering, terrorist financing, fraud, and the evasion of sanctions.
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It is necessary for our legitimate interests to protect our business from any illegal or abusive use of our Services.

To provide you with advertising which is relevant to you, and to understand your advertising preferences.

In relation to legal action, or when acquiring or selling a business.

We need to Process this information to perform a contract with you and to comply with our legal and regulatory obligations.
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It is necessary for our legitimate interests to be able to develop the business through acquiring or selling parts of our business.

In addition to the above data uses, we may also use your Personal Data at your request or direction. We may also use your Personal Data for other purposes that we may describe to you in the future.

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6. Who Do We Share Your Personal Data With?

In some cases, we may share your Personal Data with third parties in order to support your needs, provide you with the Services, or comply with our legal obligations. We may also share your Personal Data with third parties if it is in the public interest or the sharing is in our legitimate interest or the legitimate interest of another organisation.

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The other organisations we may share your Personal Data with are typically:

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Our Affiliates for the purposes set out in this Privacy Policy.
Third-party suppliers and service providers for the purposes set out in this Privacy Policy. In particular, we work with platform services (to provide financial services and account management functions), cloud providers (to host the Site), Affiliate platform services, customer support software services, data storage services, payment service providers, KYC and AML services as well as enhanced due diligence and anti-fraud services, financial services regulators, data matching services (to ensure we receive accurate information if you register with us) and click fraud detection and protection services.
Business partners and other organisations to help us meet our contractual and regulatory obligations, including audit, legal, and compliance services.
Affiliates and third parties which you have not opted out of marketing communications with, have been barred or have self-excluded so that we can ensure that you do not receive unsolicited promotional material.
Identity verification and fraud prevention agencies such as other financial services businesses, banks, credit card companies, and similar agencies which investigate and prevent underage, fraudulent, criminal or suspicious activity, or any other behaviour we are legally required to investigate. We will also pass on your information if we have reason to believe you have undertaken such activity.
Analytics and search engine providers and other selected organisations which provide us with feedback about our Site and aid us in improving their optimisation.
Statutory authorities when we are required to comply with a request for information, a court order to disclose your Personal Data, a regulatory investigation from a relevant governmental or financial or regulatory authority, our legal obligations including our requirement to report suspicious behaviour.
Regulators, law enforcement or fraud prevention agencies as well as legal professionals, courts, and other adjudication services to investigate any actual or suspected criminal activity.

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We may also share your Personal Data with third parties in the following circumstances:

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If our business is acquired or merged with another non-Ramp Network group entity, your Personal Data may be transferred to the new owners/acquirer in connection with that transaction and/or so that we may continue to provide the Services to you. If we become involved in a merger, acquisition, or any form of sale of some or all of our assets, your Personal Data will not be transferred to any third party unless there are adequate safeguards in place with the recipient in respect of the security of your Personal Data.
If we need to enforce our Terms of Service.
To protect our safety, rights or property, or the safety, rights, or property of our customers, staff, and others by sharing information with other companies and organisations such as the local police.
Where we are required by law, we may share your Personal Data with regulators or other financial services organisations.
At your request or direction.

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7. How Long Do We Retain Your Personal Data?

We will not keep your Personal Data for longer than is required for the purposes for which we collected it, including for the purposes of satisfying any legal requirements. The length of time for which we retain your Personal Data will depend on what we are using it for as set out in this Privacy Policy, the nature of the Personal Data, and how sensitive it is. For example, we will keep your email address while dealing with your inquiries but, even when you unsubscribe, we are required to continue to retain your email address to ensure that we do not send you any email communications in the future and for our KYC and AML purposes.

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Please note, however, that we may be subject to legal and regulatory requirements to keep your Personal Data for a longer period. We may also extend the retention times where your Personal Data is needed to investigate a crime, handle a claim or resolve a complaint. As a general rule, we keep your Personal Data based on the criteria below:

In addition to the above data uses, we may also use your Personal Data at your request or direction. We may also use your Personal Data for other purposes that we may describe to you in the future.

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6. Who Do We Share Your Personal Data With?

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The other organisations we may share your Personal Data with are typically:

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Our Affiliates for the purposes set out in this Privacy Policy.
Third-party suppliers and service providers for the purposes set out in this Privacy Policy. In particular, we work with platform services (to provide financial services and account management functions), cloud providers (to host the Site), Affiliate platform services, customer support software services, data storage services, payment service providers, KYC and AML services as well as enhanced due diligence and anti-fraud services, financial services regulators, data matching services (to ensure we receive accurate information if you register with us) and click fraud detection and protection services.
Business partners and other organisations to help us meet our contractual and regulatory obligations, including audit, legal, and compliance services.
Affiliates and third parties which you have not opted out of marketing communications with, have been barred or have self-excluded so that we can ensure that you do not receive unsolicited promotional material.
Identity verification and fraud prevention agencies such as other financial services businesses, banks, credit card companies, and similar agencies which investigate and prevent underage, fraudulent, criminal or suspicious activity, or any other behaviour we are legally required to investigate. We will also pass on your information if we have reason to believe you have undertaken such activity.
Analytics and search engine providers and other selected organisations which provide us with feedback about our Site and aid us in improving their optimisation.
Statutory authorities when we are required to comply with a request for information, a court order to disclose your Personal Data, a regulatory investigation from a relevant governmental or financial or regulatory authority, our legal obligations including our requirement to report suspicious behaviour.
Regulators, law enforcement or fraud prevention agencies as well as legal professionals, courts, and other adjudication services to investigate any actual or suspected criminal activity.

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We may also share your Personal Data with third parties in the following circumstances:

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If our business is acquired or merged with another non-Ramp Network group entity, your Personal Data may be transferred to the new owners/acquirer in connection with that transaction and/or so that we may continue to provide the Services to you. If we become involved in a merger, acquisition, or any form of sale of some or all of our assets, your Personal Data will not be transferred to any third party unless there are adequate safeguards in place with the recipient in respect of the security of your Personal Data.
If we need to enforce our Terms of Service.
To protect our safety, rights or property, or the safety, rights, or property of our customers, staff, and others by sharing information with other companies and organisations such as the local police.
Where we are required by law, we may share your Personal Data with regulators or other financial services organisations.
At your request or direction.

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7. How Long Do We Retain Your Personal Data?

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Type of Data

Retention time

Information

Marketing consents

Until you no longer consent

If you withdraw consent, we will keep this information on a ‘suppression list’ so we don’t contact you.

Customer Personal Data

Six years from the date your Account is closed

We will only continue to retain this Personal Data where this is legally required under financial services regulations or tax legislation or other regulations; or required to exercise or defend our legal rights.

Where it is no longer necessary to Process your Personal Data, we will delete it or anonymise or aggregate it by removing all details that identify you in accordance with Data Protection Legislation.

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8. Where Do We Transfer Your Personal Data?

We primarily store and Process your Personal Data within the UK and European Economic Area (the “EEA”). However, if we transfer your Personal Data outside of the UK or EEA, we ensure a similar degree of protection is afforded to it to safeguard your Personal Data in accordance with Data Protection Legislation, which can include: (i) ensuring that your Personal Data is only Processed in countries which have adequate data protection laws (in accordance with Data Protection Legislation); (ii) requiring recipients to sign up to strong contractual commitments that ensure the protection of your Personal Data (such as the EU Model Standard Contractual Clauses); (iii) taking any other measures that comply with Data Protection Legislation.

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9. Keeping Your Personal Data Safe

While the nature of the internet means that the transmission of information may not be totally secure, we have implemented security measures designed to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Where you use a password to access certain Services or features of our Site, please keep this confidential and do not share it with anyone. We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks that are presented by the Processing of your Personal Data. In particular, we consider the risks presented by accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your Personal Data transmitted, stored or otherwise Processed.

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We restrict access to your Personal Data to employees, contractors and agents who need to know your Personal Data in order to operate, develop or improve the Services. We ensure that we have appropriate physical and technological security measures to protect your information and we ensure that when we outsource any Processes the service provider has appropriate security measures in place. However, our Site may contain hyperlinks to websites owned and operated by third parties, or you may access our Services through such websites. These third party websites have their own privacy policies, including cookies. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

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Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of any data transmitted to us and any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. To the extent permitted by law, we are not responsible for any delays, delivery failures, or any other loss or damage resulting from (i) the transfer of data over communications networks and facilities, including the internet; or (ii) any delay or delivery failure on the part of any other service provider not contracted by us, and you acknowledge that our Services may be subject to limitations, delays and other problems inherent in the use of such communications facilities. You will appreciate that we cannot guarantee the absolute prevention of cyber-attacks such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorized disclosure, loss or destruction of your Personal Data arising from such risks.

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10. Cookies

We use Cookies for the purposes above. For more information, please see our Cookies Policy.

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11. Marketing

You can tell us whether or not you wish to be contacted for marketing purposes and, if so, how we can contact you. To that end, we will obtain consent from you and we may ask you what kind of communication you would like to receive from us.

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You can opt-out from receiving marketing communications from us at any time by following the instructions below:

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Email marketing: to opt out from emails, use the unsubscribe link provided within any email you receive or manage your preferences by emailing support@ramp.network. Note that you may continue to receive transactional messages from us after you have opted out of receiving marketing emails.

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Please be aware it may take up to ten (10) working days for your request to take effect. Please note you will still receive other important information about our product and Services.

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12. Your Rights

Under Data Protection Legislation, you may have a number of rights in relation to your Personal Data. We have listed these below, but please note that some only apply in certain specific circumstances (as detailed in Data Protection Legislation). Note that we may take steps to verify your identity, as permitted or required under Data Protection Legislation before we process your request. Verification may include asking you to provide information about yourself that we can match against information already in our possession.

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Agents that you have authorised to act on your behalf may also submit Data Protection Legislation requests as instructed above. The agent must also provide evidence that they have your written permission to submit a request on your behalf.

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If we are unable to verify the authenticity of a request, we may ask you for more information or may deny the request.

Your rights

How to exercise your rights

Right to access and receive a copy of the Personal Data we hold about you

You have the right to request a copy of your Personal Data. Requests for Your Personal Data can be made by contacting our data protection representative by emailing support@ramp.network. You must specify what Personal Data you need access to, and a copy of such request may be kept by us for our legitimate purpose of providing you with the Services. To help us find the information easily, please give us as much information as possible about the type of information you would like to see. If, to comply with your request, we would have to disclose information relating to or identifying another person, we may need to obtain the consent of that person, if possible. If we cannot obtain consent, we may need to withhold that information or edit the data to remove the identity of that person, if possible.

We are also entitled to refuse a data access request from you where (i) such request is manifestly unfounded or excessive, in particular because of its repetitive character (in this case, if we decide to provide you with the Personal Data requested, we may charge you a reasonable fee to account for administrative costs of doing so); or (ii) we are entitled to do so pursuant to Data Protection Legislation.

Right to correct any inaccurate Personal Data we hold about you

You have the right to request that we amend, correct, delete or edit your Personal Data that we have about you. If you wish to do so, please contact our customer support team by emailing support@ramp.network. Please provide enough information to identify you (e.g. name or account details), and let us know the information that is incorrect and what it should be replaced with.

If we are required to update your Personal Data, we will inform recipients to whom that Personal Data has been disclosed (if any), unless this proves impossible or has a disproportionate effort.

It is your responsibility that all of the Personal Data provided to us is accurate and complete. If any information you have given to us changes, please let us know as soon as possible (see ‘How to Contact Us’ below).

Right to require us to erase your Personal Data

You can request the erasure of your Personal Data by contacting our customer support team by emailing support@ramp.network where: (i) we do not need your Personal Data in order to Process it for the purposes set out in this Policy; (ii) if you had given us consent to Process your Personal Data, you withdraw that consent and we cannot otherwise legally Process your Personal Data; (iii) you object to our Processing and we do not have any legal basis for continuing to Process Your Personal Data; (iv) your Personal Data has been Processed unlawfully or have not been erased when it should have been; or (v) the Personal Data have to be erased to comply with the law.

We may continue to Process your Personal Data in certain circumstances in accordance with Data Protection Legislation. Where you have requested the erasure of Your Personal Data, we will inform recipients to whom that Personal Data has been disclosed, unless this proves impossible or involves disproportionate effort. We will also inform you about those recipients if you request it.

Right to request that we restrict the Processing of your Personal Data

You can request the restriction of Processing of your Personal Data by contacting our customer support team by emailing support@ramp.network. You may request that we stop Processing your Personal Data temporarily if (i) you do not think that your Personal Data is accurate (but we may start Processing again once we have checked and confirmed that it is accurate); (ii) the Processing is unlawful but you do not want us to erase your Personal Data; (iii) we no longer need the Personal Data for our Processing; or (iv) you have objected to Processing because you believe that your interests should override the basis upon which we Process Your Personal Data.

If you exercise your right to restrict us from Processing your Personal Data, we will continue to Process the Personal Data if: (i) you consent to such Processing; (ii) the Processing is necessary for the exercise or defence of legal claims; (iii) the Processing is necessary for the protection of the rights of other individuals or legal persons, or (iv) the Processing is necessary for public interest reasons. Once you have requested this you can change your mind at any time by contacting us again. Your Account will not be accessible while the restriction is in place.

Right to request a copy of the Personal Data we hold on you in a structured, commonly used and machine readable format

You may ask for an electronic copy of Your Personal Data that you have provided to us and which we hold electronically, or for us to provide this directly to a third party by emailing support@ramp.network. The request must include which Personal Data you would like to be transferred, to whom it should be transferred and by which method. You may request that we transfer this to a third party on your request. Please note that this right may not apply to all of your Personal Data This right only applies to Personal Data that you have provided to us – it does not extend to data generated by us. In addition, the right to data portability also only applies where (i) the Processing is based on your consent or for the performance of a contract; and (ii) the Processing is carried out by automated means.

Right to object to our Processing of your Personal Data

You can object to Processing of your Personal Data by contacting our customer support team by emailing support@ramp.network.

Once you have objected you can change your mind at any time by contacting us again. Your Account will not be accessible while the restriction is in place. We will comply with your request unless there is a legal basis for us to continue using it, which we will explain to you.

Right to not be subject to a decision based solely on an automated process

You may ask us to ensure that, if we are evaluating you, we don’t base any decisions solely on an automated process and have any decision reviewed by a member of staff. Profiling may occur in relation to your Personal Data for the purposes of KYC, AML and other compliance checks, targeted advertising and de-targeting you from specified advertising. These rights will not apply in all circumstances, for example where the decision is: (i) authorised or required by law, (ii) necessary for the performance of a contract between you and us, or (iii) is based on your explicit consent. In all cases, we will endeavour that steps have been taken to safeguard your interests. You can exercise this right by contacting our customer support team by emailing support@ramp.network.

Right to withdraw your consent

Where Processing is based on your consent, you have the right to withdraw your consent at any time with future effect by contacting our customer support team by emailing support@ramp.network. However, if you do withdraw your consent we may not be able to continue to provide the Services we offer to you.

13. Privacy When Using Digital Assets and Blockchains

Your use of Digital Assets may be recorded on a public Blockchain (such as your Blockchain Wallet Address). Many Blockchains are open to forensic analysis which can lead to re-identification of transacting individuals and the revelation of Personal Data, especially when Blockchain data is combined with other data. Any information stored in a public Blockchain will remain for an indefinite period of time. Blockchains are decentralised or third-party networks which are not controlled or operated by Ramp Network, we are not able to erase, modify, or alter Personal Data on such networks.

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Ramp Network is not responsible for any inaccuracy in the Personal Data provided by you. You are obligated to check all the information before submitting it to Ramp Network. Blockchain transactions are irreversible and Ramp Network will not be able to reverse any transactions already executed in case you made a mistake in the provided Personal Data or instruction. Ramp Network is under no obligation to provide you with a refund or compensation of any sort for erroneous transactions caused by your input of inaccurate Personal Data.

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14. Children’s Data

Our Site and Services are intended for individuals over the age of 18. We do not knowingly collect Personal Data from persons under the age of 18. If you are a parent or legal guardian and think your child has provided us with information, please contact us at dpo@ramp.network. You can also write to us at the address listed at the end of this Privacy Policy. If we become aware that we have received Personal Data from or about a person under the age of 18, we will delete such information from our records.

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15. Personal Data Breach

We will notify a serious Personal Data Breach in respect of your Personal Data to the appropriate data protection authorities without undue delay, and where feasible, not later than seventy-two (72) hours after having become aware of the same. If notification is not made after seventy-two (72) hours, we will record a reasoned justification for the delay. However, it may not be necessary to notify the data protection authorities where the Personal Data Breach is unlikely to result in a risk to the rights and freedoms of natural persons.

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We will keep a record of any Personal Data Breach, including their effects and the remedial action taken, and will notify you of any Personal Data Breach affecting your Personal Data (which poses a high risk to you) when we are required to do so under Data Protection Legislation. We are not required to notify you of a Personal Data Breach where: (i) we have implemented appropriate technical and organisational measures that render your Personal Data unintelligible to anyone not authorised to access it, such as encryption; (ii) we have taken subsequent measures which ensure that the high risk to data subjects is not likely to materialise; or (iii) it would involve disproportionate effort, in which case we may make a public communication instead.

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16. Privacy Policies of other Websites

Other websites and social platforms have their own cookies and privacy practices, which are controlled by them. These other websites and applications may place their own cookies or other files on your computer, collect data or solicit personal information from you. You acknowledge that the Services may enable or assist you to access the website content of, correspond with, and purchase goods and Services from, third parties via third-party websites and that you do so solely at your own risk.

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We make no representation or commitment and shall have no liability or obligation whatsoever in relation to the content or use of, or correspondence with, any such third-party website, or any transactions completed, and any contract entered into by you, with any such third party and the use by any such third-party of your Personal Data. We do not endorse or approve any third-party website nor the content of any of the third-party websites made available via the Services. We encourage you to carefully familiarise yourself with the terms of use and privacy policies applicable to any websites and/or services operated by third parties. Please be aware that we are not responsible for the privacy practices of any third parties.

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17. Changes to This Privacy Policy

We may, from time to time, change or update this Privacy Policy to make updates to our Services, for legal or regulatory changes, or at Ramp Network’s discretion. All changes to this Privacy Policy will be published on this page of the Site. Each change will become effective on publication. We recommend that you revisit and read this Privacy Policy regularly to ensure that you are up-to-date with the current terms. If you do not agree to these changes, please do not continue to use the Services or our Site.

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18. How to Contact Us

If you have any questions or comments about this Privacy Policy, want to know more about how we use your Personal Data, or want more information on your rights, please contact our Data Protection representative by emailing: dpo@ramp.network

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19. Where We’re Based

Ramp Swaps Limited is incorporated in England and Wales, with its registered office located on the Fourth Floor, Verse Building, 18 Brunswick Place, London, United Kingdom, N1 6DZ. We are registered with the Financial Conduct Authority (FCA) as a cryptoasset business. Please note that for cryptoasset purchases, you are unlikely to have access to the Financial Service Compensation Scheme (FSCS) or the Financial Ombudsman Service (FOS).

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Ramp Swaps LLC is a limited liability company registered in the State of Delaware, United States. Our registered office is at 8 The Green, STE B, Dover, County of Kent, DE 19901. We operate as a money services business registered by the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN).

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Ramp Swaps (Ireland) Limited is incorporated in Ireland, with its registered office located on the 6th Floor, 2 Grand Canal Square Dublin 2 D02 A342, Ireland. Ramp Swaps Ireland Ltd. is registered and supervised as a VASP by the Central Bank of Ireland for Anti-Money Laundering and Countering the Financing of Terrorism purposes only. Its Central Bank reference number is C515693. Please note that the Central Bank does not supervise Ramp Swaps (Ireland) Ltd. for consumer protection purposes and that the Consumer Protection Code does not apply to our Services. This means, for example, that you cannot refer a complaint about us to the Financial Services and Pensions Ombudsman and your investment is not covered by a deposit guarantee scheme or by an investor compensation scheme.

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20. Complaints

If you have a complaint about how we Process your Personal Data, please contact us at support@ramp.network or dpo@ramp.network and will try to resolve this. If you reside in the EEA, you can file a complaint through your relevant data protection authority. In Ireland, the relevant authority is the Data Protection Commission (DPC. In the United Kingdom, the relevant authority is the Information Commissioner’s Office (ICO).

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21. Glossary

Terms

What this means

Affiliate

means an entity that owns or controls, is owned or controlled by, or is or under common control or ownership with a party, where control is defined as the direct or indirect power to direct or cause the direction of the management and policies of such party, whether through ownership of voting securities, by contract, or otherwise;

AML

stands for Anti-Money Laundering, which means a set of procedures, laws, and regulations that are intended to stop the practice of obfuscating income generated through illegal activities;

Blockchain

means a system in which records of transactions made in Digital Assets are maintained across several computers that are linked in a peer-to-peer network;

Blockchain Wallet Address

means an on-Blockchain virtual address in which Digital Assets can be held and transferred;

CTF

stands for Counter-Terrorist Financing, which refers to the provisioning of funds for terrorist activity;

Data Protection Legislation

means the GDPR, the Data Protection Acts 1988 to 2018, the UK GDPR, the CCPA, and any other applicable law or regulatory requirements relating to the Processing of Personal Data and to privacy including, as such legislation shall be supplemented, amended, revised or replaced from time to time and all guidance and codes of practice issued by a relevant data protection authority, from time to time and which are applicable to a party;

Digital Asset

means a digital representation of value in which encryption techniques are used to regulate the generation of digital units and verify the transfer of assets, operating independently from a central bank;

Fiat

when used in reference to money or currency, means the coin and paper money of a country that is designated as legal tender, circulates, and is customarily used and accepted as a medium of exchange in the country of issuance;

KYC

stands for Know Your Customer, which means the process of a business verifying the identity of its customers or clients and assessing potential risks of illegal intentions for the business relationship;

GDPR

means the General Data Protection Regulation (EU) 2016/679;

Off-Ramp Services

facilitates the sale of crypto assets to Ramp Network in exchange for certain fiat currencies;

On-Ramp Services

facilitates the purchase of crypto assets from Ramp Network in exchange for certain fiat currencies;

Order

means a requested Digital Asset transaction by you for the purchase or sale of a supported Digital Asset through our On-Ramp and Off-Ramp Service;

Personal Data

has the meaning given to such term in Article 4(1) of the GDPR;

Personal Data Breach

means any Personal Data Breach as defined in the GDPR in respect of Personal Data and Personal Data Breaches shall be interpreted accordingly;

Processing

has the meaning given to such term in Article 4(2) of the GDPR, and “Processed”, “Process”, “Processes” and cognate terms shall be interpreted accordingly; and

Special Categories of Personal Data

means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data; biometric data for the purpose of uniquely identifying a natural person; or data concerning health, a person’s sex life or sexual orientation.

22. US Consumer Privacy Notice

_{Please see below our Ramp Swaps LLC (hereinafter “}_{Ramp Network US}_{”) Gramm-Leach-Bliley Act (}_GLBA_{) Privacy Notice for disclosures under the GLBA. This disclosure applies to you if you are an individual who resides in the United States or US Territories and uses the services or websites of Ramp Network US. For residents of the United States, the terms in this notice take precedence over the terms in the Ramp Network Global Privacy Policy.}

Facts

What does Ramp Network US do with your personal information?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Ramp Network US chooses to share; and whether you can limit this sharing.

What?

The types of personal information we collect, and share depends on the product or service you have with us. This information can include: - Social security number, date of birth, government identification number, and other identity verification information- Financial and transaction data- Technical data and usage dataWhen you are no longer our customer, we continue to share your information as described in this notice.

Reasons we can share your personal information

Does Ramp Network share?

Can you limit the sharing?

For our everyday business purposes:

‍Such as to process your transactions, maintain your account, respond to court orders and legal investigations, or report to credit bureaus

Yes

For our marketing purposes:

‍To offer our products and services to you

Yes

Yes, you can opt-out of receiving marketing messages.

For joint marketing with other financial companies

N/A

For our affiliates’ everyday business purposes:

‍Information about your transactions and experiences

Yes

For our affiliates’ everyday business purposes:

‍Information about your creditworthiness

N/A

For our affiliates to market to you

Yes

For nonaffiliates to market to you

N/A

Questions?

Email us at support@ramp.network or dpo@ramp.network or contact us at +1 888 702 5875

Who we are

Who is providing this notice?

Ramp Swaps LLC

What we do?

How does Ramp Network US protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include technical, physical, and administrative safeguards designed to protect the confidentiality, integrity, and availability of your personal information.

How does Ramp Network US collect my personal information?

We collect your personal information, for example, when you
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■ create an account with us or take advantage of our services through one of our partnerships
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■ conduct transactions on our platform including partner applications that we provide services for
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■ provide us your information directly We also collect your personal information from others such as our affiliates, our partners, and our service providers such as those we use for identity verification.

Why can’t I limit all sharing?

Federal law gives you the right to limit only:
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■ sharing for affiliates’ everyday business purpose - information about your creditworthiness
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■ affiliates from using your information to market to you
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■ sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

What happens when I limit sharing for an account I hold jointly with someone else?

Currently we do not provide a feature which allows for holding an account jointly with someone else.

GLBA Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include companies with a Ramp Swaps or Ramp Network name, such as Ramp Network, Inc., which is the ultimate parent company of Ramp Swaps LLC.

Non-affiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies. Our nonaffiliates include service providers that perform services or functions on our behalf.

Joint marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

How to Opt-Out?

Marketing

To opt-out from marketing emails, use the unsubscribe link provided within any email you receive or manage your preferences by emailing support@ramp.network or dpo@ramp.network

22. Notice to California residents

This notice is pursuant to the California Consumer Privacy Act (“CCPA”). Under the CCPA you have a right to ask Ramp Network about our data collection practices and your privacy-related rights under California law. We will comply with all requests required under the law.

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A. Deletion Rights

Subject to certain exceptions, you have the right to request that we delete any of your personal information that we collected from you and retained.

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B. Non-Discrimination

We recognize and respect that you have the right to not receive discriminatory treatment by the business for exercising any of your CCPA rights.

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C. Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above as a California resident, please submit a verifiable consumer request to us by contacting us at support@ramp.network or dpo@ramp.network.

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D. Use of an Authorized Agent to Submit a Request

Only you or a person you formally authorize to act on your behalf, may make a verifiable consumer request related to your personal information as a California consumer. If you use an authorized agent to submit such a request, we will require written proof that the authorized agent has been authorized to act on your behalf or a copy of the power-of-attorney document granting that right.