At Ramp, we understand that your privacy is important. We respect and value the privacy of everyone who visits www.ramp.network (together with our content, or other services the “Site”) or uses any of our applications on their devices. We only collect and use your Data as described in this Privacy Notice (“Notice”) and as permitted by Data Protection Legislation.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing information about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
California Notice of Collection of Personal Information: We collect, and in the past 12 months have collected, the following categories of information from and about you: identifiers, personal information described under Cal. Civ. Code 1798.80; commercial information; biometric information; internet or similar network activity; geolocation information; audio, electronic, visual or similar information; inferences drawn from other Data; and sensitive personal information. We collect these categories of information from you in order to provide our services to you, to run our business, to communicate with you, and as required by law. We may have disclosed each of these categories of personal information for a business purpose as described in Section 5 of the Notice below, but we have not “sold” or “shared” personal information in the past 12 months, as those terms are defined by the CCPA. We will retain each of these categories of personal information based on the factors detailed in Section 6 of the Notice.
To navigate through our Privacy Notice just click on the links below. Capitalized terms used in this Notice are defined in the Glossary below. Please note that our Sites are not intended for use by individuals under 18 years old.
1. Who does this privacy notice apply to?
This notice applies to:
- our service users who access our services such as our website or content anywhere on the web, participate in our surveys and focus groups and other users;
- our clients, suppliers, and business partners; and
- other persons who interact with us, when you call us or email us.
This notice applies to you whether you act in your personal capacity or as an employee or agent of an organization.
2. Who are we?
Our Site is owned and operated by Ramp Swaps Ltd, Ramp Swaps LLC, and its subsidiaries (“Ramp”, “we”, “us”, or “our”). This privacy notice explains how we, Ramp and our affiliated subsidiaries, process your (“you”, “your”) personal data when you use our Site.
For the purposes of the Data Protection Legislation, we are the data controller which means that we are responsible for determining the purposes for which and means of how your Data is Processed.
If you have any concerns about how we Process or protect your Data or would like to contact us about any aspect of this Notice, please get in touch with our Data Protection Officer, who oversees our handling of Data, and who can be contacted at firstname.lastname@example.org
3. What Data do we collect about you?
We will collect Data about you from the following sources:
- From you (for example, when you create an account, make a payment, tell us about your preferences or respond to our campaigns, communicate with us, or use our Site or Apps);
- From when we host social events;
- From public sources of information such as public records or social media postings;
- From providers about your interactions on the Site and from cookies and tracking devices on your devices where you have permitted their use;
- from third parties, advertisers, and other companies in Ramp. We may also receive information from other parties in accordance with our responsibilities as an authorized financial services business.
- By combining information that we have collected through the Site with information that we have collected from other sources.
We will collect the following types of information:
Your personal and contact details
Information including your name, home address, email address, telephone number, username and password.
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.
Such as cryptocurrency address information, wallet address, transaction history, and trading dates. Other information that allows us to understand your creditworthiness or 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
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.
Your communications via our Site
Such as chat conversations via our chatbox or email conversations with our customer support teams.
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’s hardware and software.
Advertising and direct marketing preferences and responses
We may also Process Data about you that is sensitive in order to meet our legal and regulatory obligations and to protect our business. This includes Data as required by the Financial Conduct Authority (FCA), the Anti-Money Laundering Regulations and the Proceeds of Crime Act, and otherwise any other information to fulfill our legal and regulatory obligations as a regulated financial services business. This also includes biometric data (such as through digital photographs) and information about suspected fraud, theft, or offenses. If you come to an event that we host, this also includes information you provide (such as dietary preferences or disability information).
4. How do we use your Data?
We use your Data in the following ways, and for the following reasons:
What we use your Data for
Basis on which we can use your Data
To register you as a new user on the Site.
We need to Process this information to meet our contractual obligations.
To allow you to use our services (including managing your payments).
We need to Process this information to meet our contractual obligations 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 Notice.
We need to Process this Data to meet our contractual obligations; comply with our legal and regulatory obligations; and it is in our legitimate business interests to keep accurate records.
To receive feedback from you on our products and services.
We need to Process this Data to meet our contractual obligations and it is in our legitimate business interests to understand how we can improve our products and services. You do not have to provide us with this information.
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).
We need to Process this Data as it is in our legitimate business interests to provide you with a personalized experience when you use our services. Where necessary, we Process this Data based on your consent.
To provide customer support services.
It is in our legitimate business interests to respond to any communications we receive from you. If you do not wish to provide us with this information, we may not be able to respond fully to your queries.
To train our staff (for example our call staff).
It is in our legitimate business interests to provide you with a helpful service.
To maintain and administer our Site.
It is in our legitimate business interests to maintain our IT services, network security, to maintain our system; and we need to Process this information to comply with our legal and regulatory obligations.
To improve our Site, products and services, and experiences, such as by understanding analytics.
It is in our legitimate business interests to better understand your preferences, update our Site and develop our business strategy.
To comply with our legal and regulatory obligations as a financial services business. This may involve verifying your identity and age.
We need to Process this information to comply with our legal and regulatory obligations and it is in our legitimate business interests to prevent fraud and illegal activities on our Site.
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 under financial services, anti-money laundering, anti-fraud, and anti-terrorism laws. We also Process this information in the public interest and it is in our legitimate business interests to protect our business from any illegal or abusive use of our Site.
To provide you with advertising which is relevant to you, and to understand your advertising preferences.
It is in our legitimate business interests to understand how you use our Site and how we should develop our marketing strategy.
In relation to legal action, or when acquiring or selling a business.
It is in our legitimate business interest to be able to protect ourselves through legal action and to develop the business through acquiring or selling parts of our business.
In addition to the above data uses, we may also use your Data at your request or direction. We may also use your Data for other purposes that we may describe to you in the future.
5. Who do we share your Data with?
In some cases, we may share your Data with third parties in order to support your needs, provide you with services, or comply with our legal obligations. We may also share 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 organization.
The other organizations we may share your Data with are typically:
- Members of the Ramp Group for the purposes in section 4 above.
- Third-party suppliers and service providers for the purposes identified above – 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, know-your-customer and anti-money laundering services as well as enhanced due diligence and anti-fraud services, financial services regulators (such as the FCA), 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 organizations 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 behavior 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 organizations which provide us with feedback about our Site and aid us in improving their optimization.
- Statutory authorities when we are required to comply with a request for information, a court order to disclose your Data, a regulatory investigation from a relevant governmental or financial or regulatory authority, our legal obligations including our requirement to report suspicious behavior.
- 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.
We may also share your Data with third parties:
- If we consider selling or acquiring businesses or assets, in which case we will share your Data with the counterparty.
- If Ramp, or any of its group companies, becomes insolvent (i.e., becomes subject to administration or liquidation processes).
- If we, or substantially all of our assets, are acquired by a non-Ramp Group entity.
- When we check your identity when you first become a customer, we share information with a Credit Reference Agency and this will leave a “soft” footprint on your credit file.
- If we need to enforce our terms and conditions.
- 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 organizations such as the local police.
- Where we are required by law, we may share your Data with regulators or other financial services organizations.
- At your request or direction.
6. How long do we retain your Data?
We will not keep your 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 Data will depend on what we are using it for as set out in this Notice, the nature of the 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 know-your-customer (“KYC”) purposes.
Please note, however, that we may be subject to legal and regulatory requirements to keep your Data for a longer period. We may also extend the retention times where the Data is needed to investigate a crime, handle a claim or resolve a complaint. As a general rule, we keep your Data based on the criteria below:
Until you no longer consent
If you withdraw consent, we will keep this information on a ‘suppression list’ so we don’t contact you
Six years from the date your account is closed
We will only continue to retain this 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 Data, we will delete it or anonymise or aggregate it by removing all details that identify you in accordance with Data Protection Legislation.
7. Where do we transfer your Data?
We primarily store and Process our Account data within the UK and European Economic Area (“EEA”). However, if we transfer your Data outside of the UK or EEA, we ensure a similar degree of protection is afforded to it to safeguard your Data in accordance with Data Protection Legislation, which can include by: (i) ensuring that your Data is only processed in countries which provide adequate data protection laws (in accordance with the 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 Clauses); (iii) taking any other measures that comply with Data Protection Legislation.
8. Keeping your 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 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 with anyone. Unfortunately, we cannot guarantee the complete security of the information transmitted via the internet. While we have implemented security measures, any transmission is at your own risk.
You can tell us whether or not you wish to be contacted for marketing purposes and, if so, how we can contact you. We will obtain this information from you when we first collect your Data and we may ask you what kind of communication you would like to receive from us.
You can opt-out from receiving marketing communications from us at any time by following the instructions below:
- Email marketing: to opt-out from emails, use the unsubscribe link provided within any email you receive or manage your preferences by emailing email@example.com or by chat by pressing the green icon in the right corner of our website page. Note that you may continue to receive transactional messages from us after you have opted out of receiving marketing emails.
Please be aware it may take up to 10 working days for your request to take effect. Please note you will still receive other important information about our product and services.
11. Your rights
Under Data Protection Legislation, you may have a number of rights in relation to your Data. We have listed these below, but please note that some only apply in certain specific circumstances (detailed in the 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.
Agents that you have authorized 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. If we are unable to verify the authenticity of a request, we may ask you for more information or may deny the request.
How to exercise your rights
Right to access and receive a copy of the Data we hold about you.
It is generally free for you to request access to your Data by contacting our data protection representative by emailing firstname.lastname@example.org
or by chat by pressing the green icon in the right corner of our website page. If your request is repetitive or excessive, we may refuse to comply or we may charge you a fee.
Right to correct any inaccurate Data we hold about you.
You can amend, correct, delete or edit your Data if you wish to, please contact our customer support team by emailing email@example.com
or by chat by pressing the green icon in the right corner of our website page.
Right to require us to erase your Data if (for example): (i) we no longer need the Data for the purpose we originally collected it for; (ii) we only collected it with your consent, and you now withdraw your consent; or (iii) you object to how we are Processing your Data.
You can request erasure of your Data by contacting our customer support team by emailing firstname.lastname@example.org
or by chat by pressing the green icon in the right corner of our website page. This process is not reversible.
Right to request that we restrict the Processing of your Data if (for example): (i) you believe that the Data we hold on you is inaccurate; (ii) you have the right to request that we erase your Data but would prefer us to restrict our Processing instead; or (iii) we no longer need the Data for the purpose we originally collected it for but you require the Data for legal actions.
You can request the restriction of Processing of your Data by contacting our customer support team by emailing email@example.com
or by chat by pressing the green icon in the right corner of our website page. 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 Data we hold on you in a structured, commonly used and machine readable format. You can also request that we transfer this to a third party on your request. Please note that this right may not apply to all of your Data.
In some circumstances, you can request the transfer of your Data to a third party by emailing firstname.lastname@example.org
. The request must include which Data you would like to be transferred, to whom it should be transferred and by which method.
Right to object to our Processing of your Data, including for marketing purposes. Please note that in some cases, we may demonstrate that we have legitimate grounds to Process your information which overrides this right.
You can object to Processing of your Data by contacting our customer support team by emailing email@example.com
or by chat by pressing the green icon in the right corner of our website page. 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.
Right to not be subject to a decision based solely on an automated process, such as profiling, which results in you being significantly affected or produces legal effects concerning you.
You can exercise this right by contacting our customer support team by emailing firstname.lastname@example.org
or by chat by pressing the green icon in the right corner of our website page.
Right to withdraw your consent where we only Process your Data based on your consent. You can withdraw your consent to receive marketing communications from us at any time and for free.
To exercise your right to withdraw your consent to receive marketing communications please see section 10 above.
Right to opt out of the “sale” or “sharing” of your Data.
As of the date of this Notice, we do not knowingly “sell” or “share” any personal information without your prior explicit consent. Our site is for users who are aged 18 or over and we do not knowingly process any personal information relating to consumers under the age of 16, as we understand those terms to be defined under the Data Protection Legislation.
Right to limit the use or disclosure of sensitive personal information.
As of the date of this Notice, we do not process any sensitive personal information except as necessary to provide you with our services which forms part of our verification procedures or as required under applicable laws.
Additional Information about your California Rights. If you reside in California, you have the right to ask us one time each year if we have shared Data with third parties for their direct marketing purposes. To make a request, please send us an email at DPO@ramp.network. Indicate in your email or letter that you are a California resident making a “California Shine the Light” inquiry.
12. Children Under 18
The Site is meant for adults. We do not knowingly collect personally identifiable data from persons under the age of 18, and strive to comply with the provisions of COPPA (The Children’s Online Privacy Protection Act). 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 website Policy. Please mark your inquiries “COPPA Information Request.”
13. Privacy Notices of other websites
Our Site may contain links to other websites. This Notice only applies to our Site. If you click on a link to another website, you should read their privacy and cookie policies to understand how they Process your information.
14. Changes to this Privacy Notice
We may, from time to time, change or update this Privacy Notice in line with legal requirements or if our business changes. All changes to this Privacy Notice 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 Notice regularly to ensure that you are up-to-date with the current terms.
If you have any questions or comments about this Notice, want to know more about how we use your Data, or want more information on your rights, please contact our Data Protection representative by emailing: DPO@ramp.network
If you have a complaint about how we Process your Data, please contact us at email@example.com and will try to resolve this. However, if you feel that we haven’t addressed your concern in a satisfactory manner, you have the right to complain to the Information Commission (“ICO”) (www.ico.org.uk) or additionally for any residents in the EU our designated representation office is in Poland so you may raise your concern to the Polish Data Protection Authority: https://uodo.gov.pl/en
Information relating to an identifiable person, who can be directly or indirectly identified in particular by reference to an identifier, or which is otherwise defined as ‘Personal Data’ under Data Protection Legislation.
Data Protection Legislation
Data Protection Act 2018 (UK GDPR), EU General Data Protection Regulation 2018 (GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003, California Consumer Protection Act, as modified by the California Privacy Rights Act (CCPA), Brazil Data Protection Laws (Lei Geral de Proteção de Dados) (LGPD) and any other applicable laws relating to the protection of Data.
Process, Processing or Processed
Accessing, collecting, obtaining, recording, holding, disclosing, using, altering, deleting, erasing or destroying Data, or carrying out any operation(s) on the Data or as otherwise defined under applicable Data Protection Legislation.