SwitchBIT Privacy Policy


Company Reg. No.14632927

Virtual Currency Exchange Service: No: FVT000029 

Document last updated 18th January 2021

This Privacy Policy governs the manner in which SWITCHBIT LIMITED collects, uses, maintains, discloses, and protects information collected from users (each, a "User" or “you”) of the www.SWITCHBIT.ee website ("Site") and mobile applications. This Privacy Policy is an agreement between you and SWITCHBIT, its subsidiaries and affiliated entities (collectively, “us”, “we”, “our” or “SWITCHBIT”) regarding the treatment of Personal Data you provide to us through the Site. This Privacy Policy applies to all products and services offered by SWITCHBIT OÜ. through the Site, mobile applications, and/or online services, that link to or reference this Privacy Statement. In this Privacy Policy, “Personal Data” shall have the meaning ascribed to it in the EU General Data Protection Regulation 2016/679/EU (“GDPR”). By continuing to use our website, you signify that you have read and understood this Privacy Policy. If you do not wish to be bound by the terms of this Privacy Policy, please do not access or register on the Site and on its mobile applications.

Changes to our Privacy Policy

Types of Personal Data we collect

• Individual Customer – We attempt to collect, verify, and authenticate the following


Personal Data:

We may collect personal identification information from Users in a variety of ways, including, but not limited to, the following:

(a) when Users visit our Site;

(b) register on the Site; and

(c) fill out a form and in connection with other activities, services, features, or resources we make available on our Site, you may be prompted to provide the following:

(a) your name;

(b) your residence address and mailing address (if different);

(c) your telephone and/or fax numbers;

(d) a valid email address;

(e) your date and place of birth;

(f) a copy of a valid photo ID (such as a driver's license, passport, or alien identification card);

(g) proof of residence; and

(h) your government-issued identification number (e.g., passport number, social security number, employee identification number, or taxpayer identification number), and any other personal information necessary to verify your identity and your Bitcoin addresses and other related information (personal information) which may lead to your identification. In doing so, you expressly consent to SWITCHBIT collecting such Personal Data. Users may, however, browse our Site anonymously. Institutional Customer – We attempt to collect, verify, and authenticate the following Personal Data:

We may collect Institutional identification information from Institutional Users in a variety of ways, including, but not limited to, the following:

(a) when Institutional Users visit our site;

(b) register on the site; and

(c) fill out a form and in connection with other activities, services, features, or resources we make available on our Site, Institutional Users may be prompted to provide the following:

(a) the legal name of the Institutional User;

(b) full legal name (of all account signatories and beneficial owners);

(c) email address (of all account signatories);

(d) mobile phone number (of all account signatories);

(e) address (principal place of business and/or other physical location);

(f) unique entity number, employer identification number, or any comparable identification number issued by a government;

(g) proof of legal existence (e.g., state certified articles of incorporation or certificate of formation, unexpired government-issued business license, trust instrument, or other comparable legal documents as applicable; contract information of owners; principals, and
executive management (as applicable); and

(h) proof of identity (e.g., driver’s license, passport, or government-issued ID) for each individual beneficial owner that owns 15% or more of the institutional customer entity, as well as all account signatories.


In doing so, you expressly consent to SWITCHBIT collecting such Personal Data.

Personal Information for each entity beneficial owner that owns 15% or more of the institutional customer entity (see the “Individual Customer” section above for details on what Personal Information we collect for individuals). Please note that we do not collect more Personal Data than is necessary for the purposes for which they are collected.

Non-Personal Identification Information we collect

We may collect non-personal identification information about Users whenever they interact with our Site. Nonpersonal identification information may include the following

(a) browser name;

(b) the type of computer and technical information about the Users’ means of connection to our Site, such as the operating system and the Internet service providers utilized by such Users;

(c) location information (information that is automatically collected via analytics systems providers to determine your location, including your IP address and/or domain name and any external page that referred you to us);

(d) log information generated by your use of SWITCHBIT that is automatically collected and stored in our server logs;

(e) account information that is generated by your account activity including, but not limited to, trading activity, order activity, deposits, withdrawals, and account balances; and

(f) correspondence information that you provided to use in correspondence, including opening an account, and with respect to ongoing customer support and other similar information.

Web Browser Cookies

Our Site may use "cookies" to enhance the User’s experience. When you visit the Site, the User's web browser will place a cookie on their hard drive for record-keeping purposes and sometimes to track information about them. “Cookies” are small text files that may be placed on your web browser when you visit our Site that may convey anonymous information about your preferences and how you browse the Site to us. All of such information is stored in an encrypted form, and no personal information about you is stored. User may choose to set their web browser to refuse cookies or to alert you when cookies are being sent. However, if the User chooses to do so, some parts of the Site may not function properly.

How we use and share personal information we collect

We may collect and use a User’s Personal Data for the following purposes:

(a) To improve customer service: Information you provide helps us respond to your customer service requests and support needs more efficiently.

(b) To personalize user experience: We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site.

(c) To improve our Site: We may use the feedback you provide to improve our products and services.

(d) To conduct customer identification and anti-money laundering reviews and compliance and to comply with applicable law.

(e) To send periodic e-mails on updates and promotions.

(f) Non-personal and aggregate information, such as that collected passively, is used in order to customize Our marketing efforts or to customize the efficient use of Our Site for an aggregate group of customers.

(g) For any other purposes permitted by applicable law.

How We Protect Your Information

We adopt appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal information, username, password, transaction information, and data stored on our Site. We limit access to your Personal Data to those employees or third parties who have a legitimate business need to access such information.


Sensitive and private data exchange between the Site and its Users happens over an SSL secured communication channel and is encrypted and protected with digital signatures. Our Site is also in compliance with PCI vulnerability standards in order to create as secure of an environment as possible for Users. We are unable to guarantee that our security is one hundred percent (100%) breach-proof. You assume the risk of such breaches to the extent that they occur despite our reasonable security measures. Our security procedures shall nevertheless continuously be revised based on new technological developments.


If your Personal Data is compromised as a result of a breach of our security measures, we will promptly notify you of such a breach.


SWITCHBIT 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, go to the Site directly.

Sharing Your Personal Information

We do not sell, trade, or rent our users’ personal identification information to third parties. We do not, without your permission, share your personal information with third parties for their marketing purpose. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates, and advertisers for the purposes outlined above.

We may share your personal data with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your personally identifiable information when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order or legal process. We further reserve the right to disclose any of your personal information that we believe, in good faith, appropriate or necessary to take precautions against liability, to investigate and defend against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Site, or to protect the rights, property or personal safety of SWITCHBIT, its Users, or any other person.

Links to Third-Party Websites

Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors, and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites that have a link to our Site, is subject to that website's own terms and policies. We encourage you to review each website’s privacy policy before disclosing any Personal Data.


Our services are not directed at persons under the age of 16. 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 will only process the Personal Data of a child under the age of 16 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 16 has provided us with personal data without consent, we will delete such information from our files, including any accounts that may have been created.

Your Rights

Access to information:
The GDPR gives you the right to find out whether we are processing your Personal Data and, where that is the case, to receive a copy of the Personal Data we process and information on:

(a) why we are processing it;

(b) the categories of personal data we process about you;

(c) the recipients or categories of recipient to whom the personal data has been or will be disclosed;

(d) where possible, how long we plan to keep your personal data or the criteria we use to determine that period;

(e) information on your rights under the GDPR;

(f) information on where we received your personal data from if we did not receive it directly from you, and

(g) details of the appropriate safeguards we have used to protect your personal data and uphold your personal data protection rights.

We will not charge you for complying with your request and providing you with a first copy. Any further copies may be subject to a reasonable administrative fee. Where your personal data is inseparable from the Personal Data of others, we reserve the right to withhold your Personal Data if permitted by applicable law.

Right to request rectification or erasure of personal data:

You have the right to request the amendment of your Personal Data at any time if it is inaccurate. If it is incomplete, you have the right to have such Personal Data rectified. You also have the right to require us to delete your Personal Data as soon as possible where one
of the following applies:

(a) the Personal Data is no longer necessary for which they were collected or otherwise processed;

(b) the Personal Data has been unlawfully processed;

(c) the Personal Data must be erased for compliance with the UK or EU legal obligation on us;

(d) the Personal Data relates to a child under the age of 16; or

(e) you withdraw your consent to us processing your Personal Data and we have no other legal grounds for processing it.

Right to restrict personal data:

You have the right to request the restriction of processing of Personal Data if you think that is inaccurate, that we are processing it illegally, or that we no longer need it for the purposes for which it was collected. While we consider your request, we will stop processing
your Personal Data within a reasonable time from the date we receive your request. We will notify you of our decision and any justifications for continuing to process your Personal Data as soon as we can.

Right to withdraw:

If we process your Personal Data with your consent, you have the right to withdraw your consent at any time. This will not affect the legality of our processing of your Personal Data up until the point at which you withdraw your consent. Please also note that we may still
need to process your Personal Data on other grounds, for example, to fulfill a contract with you or as required by law.

Right to object

You have the right to object, at any time, on grounds relating to your situation, to the processing of Personal Data. If we cannot demonstrate compelling legitimate grounds to continue processing the Personal Data, processing of such data will cease.

Changes to This Privacy Policy

We will amend this Privacy Policy from time to time and the updated versions will be posted on our Site and date stamped so that you are aware of when the Privacy Policy was last updated. We encourage Users to check back frequently to see any updates or changes to
this Privacy Policy. If we make any material changes to this Privacy Policy as decided in our sole discretion, we will provide notice by a banner on our Site.

Your Acceptance of These Terms

Before visiting, accessing, or using SWITCHBIT website or mobile applications, please explicitly indicated that you are at least eighteen (18) years old, have the legal capacity to consent to this Privacy Policy and to agree to be bound by the policies and practices of this
Privacy Policy in their entirety. If you do not agree to this policy, please do not use our Site or mobile applications.

Data Protection Officer and Accessing Your Rights

If you wish to withdraw your consent to any or all use of your Personal Data, or request amendment, restriction or erasure of such Personal Data or exercise any other of your rights, please contact our Data Protection Officer – [DPO], at [info@switchbit.org].

Do note that if you withdraw your consent to any or all use of your Personal Data or request for the erasure of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide our services to you, or administer any contractual relationship already in place. Any withdrawal of consent or request to erase your Personal Data may also result in the termination of any agreements you have with us. Our legal rights and remedies in such event are expressly reserved.

By giving or making available your Personal Data, you expressly agree and consent to the collection, use, processing and disclosure of your Personal Data in accordance with the terms of this Privacy Policy, including but not limited to, consenting and receiving communications and materials from us, from time to time.