Privacy Policy
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.
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”.
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.
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.
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.
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.
This Privacy Policy should be read together with our Cookies Policy, and our Terms of Service.
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.
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.
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.
3. Who Does This Privacy Policy Apply To?
This Privacy Policy applies to:
(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;
(c) our clients, suppliers, and business partners; and
(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.
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:
(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;
(c) from public sources of information such as public records or social media postings;
(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.
We will collect the following types of information:
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.
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.
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.
We use your Personal Data in the following ways, and for the following reasons:
It is necessary for our legitimate interests to maintain our IT services, network security, and to maintain our system.
It is necessary for our legitimate interests to prevent fraud and illegal activities on our Site or by using our Services.
It is necessary for our legitimate interests to protect our business from any illegal or abusive use of our Services.
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.
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.
The other organisations we may share your Personal Data with are typically:
- 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.
We may also share your Personal Data with third parties in the following circumstances:
- 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.
7. How long do we retain your 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.
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:
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.
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.
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.
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.
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.
10. Cookies
We use Cookies for the purposes above. For more information, please see our Cookies Policy.
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.
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 support@ramp.network. 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 ten (10) working days for your request to take effect. Please note you will still receive other important information about our product and Services.
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.
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.
If we are unable to verify the authenticity of a request, we may ask you for more information or may deny the request.
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.
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).
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.
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.
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.
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.
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.
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.
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.
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.
16. Privacy Policies of other WebsitesQuestions?
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.
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.
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.
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
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).
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).
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.
20. Complaints
If you have a complaint about how we Process your Personal Data, please contact us at support@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).
21. 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.
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.
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.
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 dpo@ramp.network.
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.