9 April 2019

Ramp Swaps - Privacy Policy

Important information

Prior to obtaining access to the Ramp Swaps application, please read the following information carefully and ensure that you understand each provision. By accessing our site, you confirm that you have read and understood the Privacy Policy and agree to the storing of cookies on your device (see more detailed information below).

If you are unable to comply with terms or policies of Ramp Swaps, please do not use our application. Failure to comply with this directive may result in a violation of the applicable laws or regulations. When in doubt, you can always contact us at: support@ramp.network

  1. Ramp Swaps - overview of information policy

  1. To use Ramp Swaps, you will need to provide the same identifying information that you use to access the relevant payment accounts as when you log into them yourself. This may include performing strong customer authentication (in particular, two-factor authentication), both when you provide either us or TrueLayer with initial credentials and each time we or Truelayer obtain access to your account information.
  2. Ramp Swaps will never ask you to provide your account password, although your account services provider may (and will) ask you to confirm both our (or AISP’s) and your credentials.
  3. Ramp Swaps will strive to ensure the accuracy of the information presented in the Ramp Swaps application, although it will not hold any responsibility for any missing or wrong information. You are using any and all information available there at your own risk. Also, you should check the data privacy rules of your internet provider, TrueLayer and account service provider.
  4. You are solely responsible for the safekeeping of your wallet and private information, including your private key, and you recognise and agree to using Ramp Swaps at your own risk. Ramp Swaps will never ask you to provide your private key.
  5. Blockchain transactions are irreversible, and any information stored on the blockchain will remain there, with no possibility of deleting or withdrawing it. Yout Ethereum blockchain address and certain data will be displayed permanently and publicly. You accept that any right of rectification or erasure of personal data may be impossible to realise in terms of data saved on the blockchain.
  6. Ramp Swaps is at an early stage of development. We do not in any way guarantee an error-free process.
  7. The provisions of the Terms of Services apply accordingly to this Privacy Policy.

  1. Authorisation and cooperation

  1. In order to provide services under Ramp Swaps, Ramp Swaps cooperates with TrueLayer Ltd. See the Terms of Service for more information.
  2. TrueLayer Ltd is based at 40 Islington High Street, London N1 8XB, and its registration number with the Information Commissioner's Office (ICO) – the regulating body in charge of data protection and privacy – is ZA207054.
  3. By using Ramp Swaps, you agree to TrueLayer’s terms and policies. TrueLayer’s Terms of Service are available here.

  1. Data Protection & Cookies

  1. By accessing Ramp Swaps, you confirm that you have read and understood the Privacy Policy and agree to the storing of cookies on your device in order to enhance navigation of Ramp Swaps and analyse site usage and traffic. You can block cookies by activating the setting on your browser that allows you to refuse some or all cookies. If you use your browser settings to block all cookies, however (including cookies essential for the provision of services under Ramp Swaps), you may not be able to access all or parts of our site.
  2. We use the following third-party cookies:
  1. Google Analytics – website traffic tracking and user targeting;
  2. Crisp – built-in online chat for customer support; and
  3. Hotjar – user analytics.
  1. You can specify or change the acceptance or denial of cookies in your browser settings.
  2. Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the 'GDPR') is in effect since 25 May 2018. You can review it here in order to check the rights it grants you with respect to the processing of your personal data:


  1. The controllers of your personal data are:
  1. Ramp Swaps Ltd - a British private limited company, with its registered office in London 3 More London Riverside, London, United Kingdom, SE1 2AQ;
  2. Ramp Network sp. z o.o. - a Polish limited liability company, with its registered office in Warsaw at Aleje Jerozolimskie no. 181B, 02-222 Warsaw, Poland,  email address: support@ramp.network;
  3. TrueLayer Ltd - a British private limited company, with its registered office in London 1 Hardwick Street, London, EC1R 4RB, email address:  privacy@truelayer.com (please see paragraph 2 above and documents incorporated by reference to check to what extent TrueLayer Ltd will process your data, on what basis and for what purpose);

Ramp Swaps Ltd and Ramp Network sp. z o.o., acting as joint administrators pursuant to the cooperation agreement entered into between them, will be jointly referred to as “we”. Queries regarding personal data or customer support with respect to either Ramp Swaps Ltd or Ramp Network sp. z o.o. will be handled by Ramp Network sp. z o.o. You may contact Ramp Network sp. z o.o. in writing at the following address: ul. Koszykowa 61, 00-667 Warszawa, Poland, via e-mail at: support@ramp.network, or by other means of communication, as referred to in the Customer Support and Complaints Handling Policy.

  1. We process your data only for:
  1. specific purposes, pursuant to the consent you gave us, if applicable (Article 6 (1) letter a GDPR – specific purposes), including providing feedback, newsletter and commercial information;
  2. the purposes of providing services under Ramp Swaps, according to rules set out in this Privacy Policy and the Terms of Service (Article 6 (1) letter b GDPR – performing services and ancillary activities);
  3. compliance with applicable rules and/or regulations (Article 6 (1) letter c GDPR – compliance with our legal obligations);
  4. building statistical models, in order to manage and improve our site (Article 6 (1) letter f GDPR – our legally legitimate interest, – adapting the content to recipients);
  5. the protection of our and your rights (including support provided in accordance with the relevant agreements or policies, including the Customer Support Policy), as well as the rights of other customers and third parties, in particular Ramps Swaps Ltd (Article 6 (1) letter f GDPR – our legally legitimate interest) – the establishment, exercise or defence of legal claims and providing customer support); and
  6. erasure of unnecessary personal data (Article 6 (1) letter f GDPR – your legally legitimate interest) – the protection of your rights).
  1. In particular, we process your data in the following manner:
  1. by collecting data from TrueLayer Ltd;
  2. by storing data;
  3. by transferring certain data about the sender to the receiver and vice versa;
  4. by using certain account information in order to confirm the swap;
  5. by erasing data;
  6. by providing customer support;
  7. by informing you by e-mail about the progress of transactions and other technical matters; and
  8. by sending you feedback, newsletter and commercial information, provided that you have agreed for such action in the Ramp Swaps application interface.
  1. We obtain your personal data:
  1. automatically (i.e. with cookies);
  2. directly from you; and
  3. from TrueLayer Ltd (on the basis of your explicit consent given to TrueLayer as an AISP  to obtain account information).
  1. The disclosure of your data is voluntary but necessary in order to provide service under Ramp Swaps. Failure to provide data may result in an inability to properly access and/or use Ramp Swaps.
  2. Ramp Swaps acquires data from TrueLayer Ltd (acting as a data provider) over an encrypted connection (TLS/SSL), which is also used for any and all data transfers. Any and all data is stored in an encrypted database.
  3. Unless stored or processed for other lawful purposes, account information comprising personal data, which is not necessary to provide service under Ramp Swaps or operate it, will be erased as soon as we receive it from TrueLayer Ltd.
  4. We may use cloud databases provided by third parties in order to store your data (including personal data). In particular, we use Google Cloud. Our service providers cover the following certificates in particular: ISO 27001 (managing information risks), ISO 27017 (controlling cloud-based information security), ISO 27018 (protecting personal data), SOC 1 (controls over financial reporting), SOC 2 (controls over security, availability and confidentiality), SOC 3 (public report of controls over security, availability and confidentiality), EU Model Contract Clauses (GDPR compliance), FIPS 140-2, Privacy Shield, Cloud Computing Compliance Controls Catalog (C5) (information security for cloud services). For more information on standards, regulations and certifications, please see this site.
  5. You possess the rights set out by the GDPR, including the right to access your personal data, the right to the rectification and erasure of personal data (with the reservation of processing personal data on blockchain), the right to the limitation of processing, the right to object against processing, the right to the portability of personal data, and the right to lodge a complaint with the supervisory authority.
  6. Each time your personal data is processed based on your consent, such consent is voluntary and can be withdrawn at any time.
  7. If you want to exercise your rights regarding cookies, you should provide us with additional information that will allow us to identify you.
  8. By accessing Ramp Swaps, you enter into agreement with Ramp Swaps Ltd, based on which your account data (including data such as your name and surname, as well as information submitted by you or your payment service provider that maintains an online payment account on your behalf) and certain other data (such as your IP address and email), can be obtained, stored and processed (including, to the extent necessary, transfer of data) by Ramp Swaps Ltd and other recipients.
  9. Data processed by us may include in particular:
  1. identification data (name, surname, date of birth, place of birth, gender);
  2. information submitted to us or obtained via a transaction related to your bank account (i.e. account information, account balance, transactions, information on loans, insurance data, and investments data); and
  3. information related to your transaction(s) (swap(s)) made via Ramp Swaps (i.e. ETH addresses used in the transaction, your wallet address).

  1. Transfer of your personal data outside of the European Economic Area

The data that we collect from you will not be transferred to or stored outside of the European Economic Area. We will take reasonable steps to ensure that your Account Information (including any personal data) is handled securely and in accordance with this Privacy Policy.

  1. Deletion of Personal Data

We will store your personal data as long as it is needed, but for no longer than 6 years, beginning on 1 January of the year following the year of the swap, unless the law requires the extension of the data processing period beyond that period. The data may be processed thereafter for a period of limitation of any claims.

  1. Disclosure

  1. We may share your personal data with select recipients: the entities who are involved in your transaction (TrueLayer Limited and Ramp Network sp. z o.o.), including any and all business partners, suppliers and subcontractors that assist us in the provision of Ramp Swaps.
  2. By accessing Ramp Swaps, you enter into agreement with Ramp Swaps Ltd, based on which you agree to the transfer of your data to the other side of the swap, to the extent necessary to provide service under Ramp Swaps. In particular, acting as a sender of crypto assets, you agree to providing your account information (including your account number and full name) to the potential receiver. If you act as the receiver, you agree to providing information on the transaction made in the payment system (i.e. making an order to transfer) to the sender.
  3. We may also disclose your personal data to other third parties in the event that:
  1. we reasonably consider that we are under duty to disclose and/or share your personal data in order to comply with any legal obligation;
  2. in order to enforce or apply our Terms of Service and other agreements; and/or
  3. to protect the rights, property, or safety of Ramps Swaps Ltd, Ramp Network sp. z o.o., TrueLayer Ltd, our customers, and/or others.

  1. Security

We use industry-standard encryption methods to ensure the security of your personal data in accordance with applicable laws and regulations, but we cannot guarantee the security of any data transmitted to TrueLayer Ltd or us. We take reasonable precautions to ensure that your data is not lost, misused, accessed, disclosed, altered or destroyed. If you have reason to believe that your personal data is no longer secure, please contact us immediately at: support@ramp.network

  1. Amendments

We may, without prior notice and liability, for any reason:

  1. change this Privacy Policy or any other document relating to Ramp Swaps or any features or elements of Ramp Swaps (including technical);
  2. stop providing Ramps Swaps or any of its features to you or to users in general;
  3. create usage limits for Ramp Swaps; and/or
  4. permanently or temporarily terminate or suspend your access to Ramp Swaps.