Introduction:
This Privacy Policy applies to all of the products, services and websites offered by Exchanger101 or its subsidiaries or affiliated companies. In addition, where more detailed information is needed to explain our privacy practices, we post supplementary privacy notices to describe how particular services process personal information.
We understand that in the course of delivering our numerous products/ services to you via the net, we will come across certain information pertaining to your good self which, to our mind, are purely personal and may even be classified information but for the existing relationship which dictates that you shall either fill them in and/or divulge same in order to be linked to our site. Exchanger101 will handle the information in this manner:
Use Of Information:
When you sign up for any Exchanger101 Service or promotion that requires registration, we ask you for personal information (such as your name, email address and an account password). For certain services, such as our payment services, we require your debit or credit card information. We typically do not store this information and when we do, we maintain the data in encrypted form on secure servers. We may combine the information you submit under your account with information from other third parties in order to provide you with a better experience and to improve the quality of our services. For certain services, we may give you the opportunity to opt out of combining such information.
When you access Exchanger101, our servers automatically record information that your browser sends whenever you visit a website.
When you send email or other communications to Exchanger101, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.
We offer some of our services in connection with other web sites e.g. Websites of our subsidiaries. Personal information that you provide to those sites may be sent to Exchanger101 in order to deliver the service. We process such information in accordance with this Privacy Policy. The affiliated sites may have different privacy practices and we encourage you to read their privacy policies.
This Privacy Policy applies to Exchanger101 only. We do not exercise control over the sites displayed or linked from within our various services. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you.
Data Policy:
Exchanger101 Data Protection Policy refers to our commitment to treat information of employees, customers, stakeholders and other interested parties with the utmost care and confidentiality. With this policy, we ensure that we gather, store and handle data fairly, transparently and with respect towards individual rights.
Scope:
This policy refers to all parties (employees, customers, suppliers, Merchants etc.) who provide any amount of information to us. Who is covered under the Data Protection Policy? Employees of our company and its subsidiaries must follow this policy. Contractors, consultants, partners and any other external entity are also covered. Generally, our policy refers to anyone we collaborate with or acts on our behalf and may need occasional access to data.
Policy Elements:
As part of our operations, we need to obtain and process information. This information includes any offline or online data that makes a person identifiable such as names, addresses, usernames and passwords, digital footprints, photographs, social security numbers, financial data etc. Our company collects this information in a transparent way and only with the full cooperation and knowledge of interested parties. Once this information is available to us, the following rules apply. Our data will be:
- Accurate and kept up-to-date
- Collected fairly and for lawful purposes only
- Processed by the company within its legal and moral boundaries
- Protected against any unauthorized or illegal access by internal or external parties
Anti-Money Laundering Policy:
Money laundering is the attempt to conceal or disguise the nature, location, source, ownership or control of illegally obtained money. Money laundering is most commonly associated with tax avoidance. However, other individuals may attempt to launder money in order to conceal their identity or finance their operations. ‘Suspicious activity’ is a very difficult concept to define because it can vary from one transaction to another based upon all the circumstances surrounding the transaction or group of transactions. For example, transactions by one customer may be normal based on our knowledge of that customer and their pattern of activity, while similar transactions by another customer may be suspicious.
Many factors are involved in determining whether transactions are suspicious including the amount, the nature of the transaction and frequency of deposits/withdrawals from the system. Exchanger101 Global Services is committed to fighting money laundering and complying fully with anti-money laundering laws in the Nigeria. We understand that we have responsibilities to help fight the global battle against money laundering and our commitment will supersede all other privacy obligations contained in our policies. Accordingly, Exchanger101 Global Services will take all reasonable and appropriate steps to prevent persons engaged in money laundering, fraud, or other financial crimes from utilizing our products and services. Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable BSA regulations and FINRA rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business. Key components of our AML and CTF framework include the following:
Know Your Customer:
Establishing and maintaining a risk-based approach to Customer Due Diligence (CDD), including customer identification, verification and KYC procedures. To ensure we meet these standards, our customers are required to provide certain personal details when opening a Exchanger101 account and also generate tokens, OTP and PIN for any withdrawal request. The nature, and extent, of what is required is guided by the customer’s deposit and withdrawal limits, account to be used and in some cases, the customer’s country of residence. In certain circumstances, Exchanger101 may perform enhanced due diligence procedures for customers presenting a higher risk, such as those transacting large volumes etc. Maintaining appropriate KYC records for the minimum prescribed periods;
Exchanger101 shall ensure timely and accurate rendition of all AML/CFT returns as specified in the SEC AML/CFT Rules and Regulations as well as other relevant Regulations/Act/Guidelines/Circulars that may be issued from time to time by various government agencies. We shall exercise due diligence in identifying and reporting a suspicious transaction.