Privacy Policy

Luca Investment Strategic Sp. z O.O., reg. number LLC23233, authorised to provide virtual currency service, with registered and operational address at 86 Hoża Street, Unit 210, Warsaw, Postcode 00-682, Poland (“Clearcrest” or “we”) is dedicated to protecting the privacy rights of our online users and customers (“users” or “you”). This Privacy and Cookie Policy (the “Policy”) sets out how we collect, use, and protect any Personal Information that you provide to us in connection with sereneswap.com (the “Site”) or any of our services (collectively, the “Service”).

Capitalised terms not defined herein shall have the meaning ascribed to them in our Terms of Use available here, to which this Privacy Policy is incorporated by reference. Clearcrest may provide additional product- or Service-specific privacy notices to be read in conjunction with this Privacy Policy.

We will process your personal information per applicable law, including ensuring a valid legal basis for such processing if required. Where applicable law requires consent to process your personal information, you hereby agree to such processing in the manner provided in this Policy and our Terms of Use. You are free not to use the Service.

Which Personal Information Do We Collect About You?

We collect these types of information: Personal Information and Non-Personally Identifiable Data:

Personally ID Information is sometimes also referred to as Personal Information, personally identifiable information, or other terms to mean any information that directly or indirectly identifies you or is reasonably capable of being associated with you or your household.

The other type of data we collect is individually identifiable data. This data identifies an individual or is of a private and/or sensitive nature, such as your contact information and financial data, including:

Your contact details include your email address, phone number, full name, date of birth, gender, and residence.
Your financial data, including the identity of cryptocurrency, accounts you transferred sums to or from, and your bank details and transaction list.
Your documents and data are uploaded in our Know-Your-Customer process, including a photocopy of your ID, a video containing your image, proof of address and utility bills, source of wealth and source of funds, and other data you entered in our forms.

Non-Personally Identifiable Data. The first type is non-personally identifiable data and statistical information. Non-personally identifiable data being gathered consists of technical information and behavioural information that does not pertain to a specific individual (“Non-Personal Information”). This includes your device type, browser type, version, screen size, resolution, language, and other technical data. While it is not specifically personally identifiable, it may be reverse-engineered to be identifiable and, therefore, is considered Personal Information.

How Do We Collect Personal Information?

Personal Information is collected from your use of services and from trusted service providers who provide us with financial services, know-your-customer services, and financial intelligence services. We may combine the information we collect about you from these various sources.‍

Information We Collect Directly from You

We collect Personal Information you voluntarily provide us when you use the Services. The types of Personal Information that we may collect directly from you include the following:

Your contact details include your email address, phone number, full name, date of birth, gender, and residence.
Your financial data, including the identity of cryptocurrency, accounts you transferred sums to or from, and your bank details and transaction list.
Your documents and data uploaded in our Know-Your-Customer process, including a photocopy of your ID, a video containing your image, your proof of address and utility bills, source of wealth and source of funds, and other data you entered in our forms.‍

Information That We Collect About Your Use of the Services

When you use our Service, we may automatically collect information about your device and your activities on our Service. This information helps us to understand how you use our Service and to improve your experience.

The types of information we may collect automatically include:

Log data includes your IP address, browser type, version, and the pages you visit on our Service.
Device information includes information such as your device type and operating system.
Usage data includes information about your interactions with our Service, such as the features you use and the content you view.

Information from trusted Third Parties

In some cases, we may receive Personal Information about you from a third party, such as a data provider, credit reference agency, or other trusted source. This Personal Information may be used to verify your identity, address, or creditworthiness and improve our services’ quality.

The third parties we receive Personal Information from are carefully selected and are bound by strict confidentiality agreements to protect your Personal Information. They are also subject to applicable data protection laws and regulations, such as the GDPR.

What Are the Purposes of the Collection and Processing of Data?

We collect and process your Personal Information for the following purposes:

To provide and improve our services: We use your Personal Information to provide and improve the services we offer, including processing transactions and providing customer support.
To communicate with you: We use your Personal Information to communicate with you, such as sending you updates about your account or our services, responding to your inquiries, and sending you promotional materials. For more information about opting out of certain communications, please see the “Your rights and choices in relation to your personal information” section below.
To comply with legal obligations: We may use your Personal Information to comply with legal obligations, such as to comply with tax laws or to respond to subpoenas and other legal requests.
To protect our rights and interests: We may use your Personal Information to protect our rights and interests, such as to enforce our terms of service, to prevent fraud and abuse, and to protect the security of our services.
To personalise your experience: We may use your Personal Information to personalise your experience, such as to provide recommendations and advertisements that are more relevant to you.
To personalise your experience. We may use your Personal Information to analyse how you interact with the Service, to monitor and analyse usage and activity trends, and for other analytical and statistical research purposes.
Carry out any other purpose described to you at the time the information was collected.

Lawful Basis to Processing

If you are in the EEA, when we process your Personal Information, we will only do so in the following situations:

Consent: We have your consent to do so. When consent is the legal basis for our processing, you may withdraw such consent at any time.
Performance of a Contract: We may process your Personal Information to perform our obligations under your contract, such as delivering the requested services.
Legal Obligation: We may process your Personal Information to comply with legal obligations, such as to comply with tax laws or to respond to subpoenas and other legal requests.
Legitimate Interests: We may process your Personal Information for our legitimate interests, such as to improve our services, to communicate with you, and to protect our rights and interests, enforce our Terms of Use and legal notices, and for the establishment, exercise, and defence of legal claims, conclude corporate transactions (e.g., corporate restructuring, sale or assignment of assets, merger), share your information with third-party marketplaces and service providers for advertising purposes, enforce our Terms of Use and prevent fraud, illegal activity and/or any violation of our intellectual property rights.

How Can We Contact You?

If you register for our service, we may contact you with periodic updates and promotional emails relating to the service and our products or services.

You may opt out of these anytime, but not from transactional emails, such as payment updates, withdrawals, or cryptocurrency purchase orders.

Sharing Personal Information with Third Parties

We respect your privacy and will not disclose, share, rent, or sell your Personal Information to any third party unless the sharing of your Personal Information is made upon your specific and explicit request or due to compliance with regulatory requirements and performance of legal obligations, as set out below.

Third parties that assist us in providing the Service. They are given access to customers’ accounts and Service Data only as reasonably necessary to provide the Service and will be subject to confidentiality obligations in their service agreements. If you do not wish to have this information shared, please do not use our Service. If you wish to no longer have your personal information used by such partners, you may contact us, and we will facilitate your request to the partner.
Third-party service providers. We share data with third-party service providers, providing us with services such as research and analytics, anti-spamming and anti-phishing services, marketing, and data enrichment.

We share data with third-party payment processors who process your credit card and other payment information.

We share data with third-party partners to assist us in KYC and provide any further support

needed to use our Service.

Third parties for legal, fraud prevention, and security purposes. We may share data with auditors, lawyers, accountants, and other professional advisers who advise and assist us concerning the lawful and effective management of the Service and any disputes we may become involved in.

We may share data with Law enforcement, other government and regulatory agencies and bodies, or other third parties as required by and in accordance with applicable laws and regulations or otherwise deemed necessary to detect, prevent, or otherwise address fraud, security, technical issues, or other threats to sereneswap.com or others.

Third parties in the context of a merger, acquisition, corporate transaction, or other legal process. We may disclose your information to another entity in connection with, including during negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer.

This list is non-exhaustive, and there may be circumstances where we need to share Personal Information with other third parties unless prohibited under law from doing so.

Where necessary (such as when we transfer data to service providers), we put in place appropriate contractual arrangements and security mechanisms to protect the Personal Information shared and to comply with our data protection, confidentiality, and security standards and obligations.

Note that we may also disclose data to comply with authorised data requests from governmental agencies or judicial warrants. Unless prohibited under law from doing so, we shall notify you about such requests.

Your Personal Information Rights

Right of Access, Rectification and Correction

You have the right to know what Personal Information we collect about you and to ensure that such data is accurate and relevant for the purposes for which we collected it. You can receive a copy of your Personal Information and rectify such Personal Information if it is not accurate, complete, or updated. However, we may first ask you to provide us with certain credentials to permit us to identify you before performing any change to your data.

Right to Delete Personal Information or Restrict Processing

Right to Withdraw Consent

You have the right to withdraw your consent to processing your Personal Information. Exercising this right will not affect the lawfulness of processing your Personal Information based on your consent before its withdrawal. Please note that in most cases, withdrawal of your consent would most likely cause us to delete your Personal Information rather than cease data processing.

You have the right to delete your Personal Information or restrict its processing by us or any third party. We may postpone or deny your request if your Personal Information is currently used for the purposes for which it was collected or due to compliance with legal obligations.

Right of Data Portability

Where technically feasible, you have the right to ask to transfer your Personal Information in accordance with your right to data portability.

The Right to Lodge a Complaint

If you have any questions or concerns regarding privacy at sereneswap.com, please get in touch with us at:

Email: info@sereneswap.com

While we prefer that you contact us in case you have any issues or feel we do not respond adequately to your questions or concerns, please note You have the right to lodge a complaint with a data protection supervisory authority regarding processing your personal data.

In certain territories (including the EU and Brazil), you also have a legal right to ask for a restriction of processing or to object to processing.

“Do Not Track” Signals From Your Browser

If you do not wish your browser to allow us to use trackers, please use your browser’s “Do Not Track” option. Our system is set to respond to such signals.

Exercising Your Rights

We acknowledge your right to access and change the Personal Information we collect and process. If you wish to access or correct, amend, or delete Personal Information, please email us at info@sereneswap.com.

You may also designate an authorised agent to make a request on your behalf by verifying your identity and providing the agent with written permission to make the request on your behalf.

Subject to applicable law, you can freely exercise these rights and choices. We will not charge you different prices or provide various quality services unless those differences are related to your information or otherwise permitted by law. Once we receive your request from you, we may need to request additional information from you to verify your identity or process your request.

Please note that in order to ensure you have control over your Personal Information, you may modify certain parts of your information by contacting us (see right of access and rectification” above.

Links to Other Websites

The Services may contain links to other websites. Please note that we are not responsible for the privacy of information security practices of other websites. These other websites and applications maintain their policies regarding cookies and the collection and use of personal information. We encourage you to review those policies yourself.

Location of Your Data

We may transfer your personal data to recipients located outside the European Economic Area (EEA) or outside your country of residence. The countries where we may transfer your personal data may not have the same data protection as your country of residence.

We ensure that appropriate safeguards are in place to protect your personal data, including using Standard Contractual Clauses approved by the European Commission and Binding Corporate Rules for our group companies, where required by law.

If you would like to receive more information about the safeguards we have in place for international transfers or any concerns about transferring your personal data, please contact us.

Cookies

When you access or use this Site, we may use industry-standard technologies such as “cookies” or similar technologies, which store certain information on your computer and will allow us to enable automatic activation of certain features, thereby improving the overall user experience. You may restrict the use of certain cookies by modifying your preferences through the Site’s cookie settings link. Most web browsers provide the option to erase cookies from your device, block their acceptance, or receive a warning before storage. However, blocking or erasing cookies may limit your online experience.”

Minors / Children

The service is intended for users over the age of eighteen (18). Therefore, we do not intend or knowingly collect Personal Information from children under the age of sixteen (16) and do not wish to do so.

We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the service.

If we learn that we collected Personal Information from minors under the age of sixteen (16), we will delete that data as quickly as possible.

If you have reasons to suspect that we collected Personal Information from minors under the age of sixteen (16), please notify us at info@sereneswap.com, and we will delete that Personal Information as quickly as possible.

Security

We take appropriate measures to maintain the security and integrity of our service and prevent unauthorised access to it or use thereof through generally accepted industry standard technologies and internal procedures.

Please note, however, that there are inherent risks in the transmission of information over the Internet or other methods of electronic storage, and we cannot guarantee that unauthorised access or use will never occur.

We will comply with applicable law in the event of any breach of the security, confidentiality, or integrity of your Personal Information. We will inform you of such a breach if required by applicable law.

To the extent that we implement the required security measures under applicable law, we shall not be responsible or liable for unauthorised access, hacking, or other security intrusions or failure to store or the theft, deletion, corruption, destruction, damage, or loss of any data or information included in the Personal Information.

Data Retention

We will retain the Personal Information for as long as we believe it is accurate and can be relied upon. When Personal Information is no longer required for the purpose for which it was initially collected, it will be deleted unless we have a valid justification to retain it, as permitted by applicable law, to resolve disputes or comply with legal obligations.

Updates to the Privacy Policy

We reserve the right to amend this Privacy Policy at any time; we will provide you with updates on any change, and such updates shall not have a retroactive effect.