AMM (Bahamas) Ltd. (“IX Swap”, “we” or “us”) is a digital securities platform licenced in The Bahamas using blockchain technology and smart contracts, and we shall protect the privacy of your personal data in accordance with the Data Protection (Privacy of Personal Information Act), 2003 of The Bahamas (“PPIA”) and any other applicable laws.
The term “you” or “User” as used herein refers to any member, user or viewer of our Website, including, but not limited to, any issuer, sponsor or investor.
We may receive and collect your Personal Data when:
We may collect personal, financial, technical, legal and other data relating you, including but not limited to the following:
We do not collect more Personal Data than is necessary for the purposes for which they are collected.
When you visit our Website, we may send one or more cookies to your device. “Cookies” are small text files containing a string of alphanumeric characters that may be placed on your web browser when you visit our Website that may convey to us anonymous information about your preferences and how you browse our Website. However, cookies do not collect your Personal Data.
Please refer to http://www.google.com/policies/privacy/partners to find out more about how Google uses data when you use our Website and how to control the information sent to Google. You may prevent Google’s collection and processing of your Personal Data by using the Google Ads Settings page or downloading and installing Google’s browser plug-in (https://tools.google.com/dlpage/gaoptout).
In addition, we (or our service providers, such as Google Analytics) may also collect technical information related to your use of our services. This may include, but is not limited to:
Such technical data may be used for administrative purposes to assess the usage, value and performance of our online products and services and with a view of improving user experience. As with cookies, the web surfing information collected is aggregated, anonymous "click stream" and transactional data, and is not associated with any Users as individuals.
The Personal Data we collect is required for legal, compliance or security purposes. Where possible, we shall inform you of the specific purpose for which such Personal Data is being collected.
We may use the Personal Data collected on our Website/App for the following purposes:
In order to access/utilize our services, you need to voluntarily provide us with your Personal Data. It may be absolutely impossible for us to provide you with certain products and services in the absence of certain key Personal Data about yourself, including your identity document, email, name and telephone number. You acknowledge that if you withdraw your consent for us to process your Personal Data, then you acknowledge that we may exercise any rights we may have to refrain from or discontinue providing you with any or all of our services.
Our services are not directed at persons under the age of 18. If you are a parent or guardian and you become aware that your child has provided us with Personal Data without your consent, please contact us. We shall only process Personal Data of a child under the age 18 only where consent is given or authorized by the child’s parent or guardian. If we become aware that a child under the age of 18 has provided us with Personal Data without consent, we shall delete such information from our files, including any accounts that may have been created.
We do not sell Users’ Personal Data to third parties. We do, however, work with a number of trusted third parties who perform vital functions as part of our operations.
In addition to AWS and Hubspot, we work with (among others) providers of hosting services for our Website, electronic signature providers, electronic payment service providers and other service providers who provide information technology and system administration services to us. We may engage third parties to help us to carry out certain other internal functions such as account processing, client services or other data collection relevant to our business where examples of such third parties may include those that perform data processing, compliance checks, reporting, tax or legal documentation, digital asset custody or escrow services.
By using our Website or services, you consent for us to disclose your Personal Data to such third parties. Your Personal Data shall be shared with these third parties only to the extent necessary, including but not limited to performing services for you, making our services available to you or acting on your instructions. Such third parties shall be required to comply with any applicable data protection laws.
If you use our blog or other public forums on our Website, please note that any Personal Data you disclose on our blog or other public forums on our Website shall be available to other Users and you shall be deemed to acquiesce to any consequences of such disclosure that we would not be responsible for, which includes but is not limited to any wrongful use of such Personal Data by other Users.
We may also share your Personal Data in the following circumstances:
Please also be aware that the use of the App, based on public blockchains, is intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to deanonymization and the unintentional revelation of Personal Data, in particular when blockchain data is combined with other data. Because blockchains are decentralized or third-party networks which are not controlled or operated by us, we are not able to erase, modify, or alter Personal Data from such networks.
We may send you email notifications from time to time. These shall typically relate to your activities on our App or changes to various legal agreements or User policies. By using our services, you consent to receiving such service-related emails.
From time to time, we may also send surveys, requests for feedback, marketing offers or newsletters. Completing any surveys or requests for feedback or accepting any offer is strictly voluntary. If you do not wish to receive these offers, surveys or feedback requests, please select the opt-out option in any such survey, request, offer or newsletter you may receive from us.
The entity responsible for the management and use of our Website/App and your personal is AMM (Bahamas) Ltd., a company incorporated in The Bahamas. However, your Personal Data collected through our Website/App may be transferred, stored and processed outside of The Bahamas where we will safeguard your Personal Data according to the applicable laws in such circumstances . By providing your Personal Data and using our Website/App, you consent to any such transfer of information outside of The Bahamas.
We shall limit access to your Personal Data to only our employees or third parties, as necessary, according to our legitimate business needs. We shall conform to industry standards and practices and maintain appropriate physical, electronic and procedural safeguards and controls to protect your Personal Data.
We shall treat the protection of your Personal Data with due regard and we shall take the appropriate security measures to prevent any unauthorised access to, or alteration, disclosure or destruction, or any accidental loss or destruction of your Personal Data. Unfortunately however, the transmission of information via the internet may not be completely secure due to factors beyond our control. Although we shall endeavour to do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through our Website. In this regard, kindly beware that any Personal Data you choose to provide us with is at your own risk.
If your Personal Data is compromised as a result of a breach of our security measures, we shall promptly notify you of such a breach.
We will never send you an email asking you for your login information. In general, you can protect yourself against phishing by never providing personal or login information via a link contained in an email. Instead, please access our Website directly.
We shall retain your Personal Data in an accurate form and for as long as you continue to use our services and our Website, and/or in compliance with the applicable laws.
For the residents of the European Economic Area (“EEA”) or United Kingdom (“UK”) (collectively, the “EEA/UK Users”), we shall process your Personal Data in compliance with the EU General Data Protection Regulation 2016/679/EU (“GDPR”). IX Swap will be the Data Controller (as defined under GDPR) and in certain circumstances, EEA/UK Users will have certain rights, including the following:
The GDPR gives EEA/UK Users the right to find out whether we are processing their Personal Data and, where that is the case, to receive a copy of the Personal Data we process. We will endeavor to provide EEA/UK Users with an account of their Personal Data in our possession or control within a reasonable time. Such account shall be in respect of how their Personal Data has been or may have been generally used or disclosed.
We reserve the right to charge EEA/UK Users a reasonable administrative fee for carrying out such a request. Where EEA/UK Users’ Personal Data is inseparable from the Personal Data of other Users, we reserve the right to withhold EEA/UK Users’ Personal Data if permitted by applicable law.
EEA/UK Users have the right to request to amend any of their Personal Data at any time if inaccurate. If any of their Personal Data is incomplete, EEA/UK Users have the right to have such Personal Data rectified. EEA/UK Users also have the right to require us to delete their Personal Data as soon as possible, by emailing us at email@example.com, in one of the following circumstances:
Please note that it may take up to thirty (30) working days for any such request to be reflected in our systems.
EEA/UK Users have the right to request to restrict the processing of Personal Data if EEA/UK Users object to us processing their Personal Data and we have no overriding legitimate grounds for the processing or EEA/UK Users think that such Personal Data is inaccurate, that we are processing such Personal Data unlawfully, or that we no longer need such Personal Data for the purposes for which such Personal Data was collected. While we consider such a request, we will stop processing such Personal Data within a reasonable time from the date we receive the request. We will notify EEA/UK Users of our decision and any justifications for continuing to process such Personal Data as soon as we can.
If we process EEA/UK Users’ Personal Data with such EEA/UK Users’ consent, such EEA/UK Users have the right to withdraw their consent at any time. This will not affect the legality of our processing of such Personal Data up until the point at which consent was withdrawn. Please also note that we may still need to process such Personal Data on other grounds, for example to fulfill a contract with such EEA/UK Users or as required by law.
EEA/UK Users have the right to object, at any time, on grounds relating to their particular situation, to the processing of their Personal Data. If we cannot demonstrate compelling legitimate grounds to continue processing such Personal Data, such processing will cease.
EEA/UK Users have the right to request that we transfer their Personal Data that we have collected to another organization, or directly to them, under certain conditions.
We have appointed a data protection officer and if you wish to withdraw your consent to any or all use of your Personal Data, or request any amendment to, or restriction or erasure of, such Personal Data, or exercise any other of your rights, please contact firstname.lastname@example.org.
Do note that if you withdraw your consent to any or all use of your Personal Data or request for erasure of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide services to you, or administer any contractual relationship already in place between you and us. Any withdrawal of consent or request to erase your Personal Data may also result in the termination of any agreement you may have with us. Our legal rights and remedies in such an event are expressly reserved.
You may make a request to access and be supplied with a copy of your Personal Data kept by us. However, we may refuse any such request if there are reasons to do so, in accordance with the applicable laws.
Questions? Please email us at email@example.com.
Last updated: 17 February 2023