Privacy Policy
1.INTRODUCTION
This Privacy Policy outlines the methods by which ІLERITER sp. z o.o. (referred to as "we", "our", or "us") collects, uses, stores, and shares personal data in connection with your use of the Platform and the Services made available through it. This Policy adheres to the European General Data Protection Regulation("GDPR") and is dedicated to maintaining a transparent, lawful, fair, and secure approach to managing the personal data of our customers and users. This document explains the types of personal data we collect through our Platform and services, the methods and purposes of this collection, how we use the data, and the third parties with whom we share it. It also outlines your rights concerning your personal data and provides instructions on how to exercise these rights. Our main commitment is to ensuring the secure operation of the Platform, protecting personal data, maintaining appropriate security standards, and processing personal data in a lawful, fair, and transparent manner. Although we may occasionally update this Privacy Policy, we assure you that any changes will not compromise the integrity of our mission. Updates to this Policy (along with related policies like the Terms of Service and Cookie Policy) will be communicated to you via email and reflected on this page. It is important to read this Policy to remain informed about how your data is handled, as well as your rights and responsibilities under this Policy. For any questions regarding this Privacy Policy, data collection and usage, data disclosure and sharing, or any other concerns or requests related to your personal data, please contact us at: support@cryptoramper.io
Where regulated crypto-asset services are provided by licensed third-party CASP partners, such partners may process your personal data independently in connection with the regulated services they provide. The processing of such personal data is governed by the applicable privacy policy of the relevant CASP partner.

2. DEFINITIONS
The following terms are defined in this Privacy Policy:
‍“Personal data” means any information that directly or indirectly relates to an identified or identifiable natural person (the subject of personal data).
‍“Processing of personal data” refers to any action or set of actions performed on personal data, whether by automated means or not, including collecting, recording, organizing, structuring, storing, modifying (updating or altering),retrieving, using, disclosing (by transmission, dissemination, or otherwise making available), anonymizing, restricting, erasing, or destroying personal data.
‍“Confidentiality of personal data” signifies the duty of any entity or individual with access to personal data to prevent its unauthorized distribution, unless the data subject has given consent or there are other legal grounds.
‍“Cookies” are small data files sent by a web server and stored on the user's device. These files are sent back to the web server by the web client or browser with each HTTP request when accessing a page on the related site.
‍“User” denotes any individual who accesses and uses the Platform via the Internet.
‍“Site” refers to a Platform available on the Internet at the domain address cryptoramper.io.
"CASP" means a Crypto-Asset Service Provider authorised under Regulation (EU) 2023/1114 on Markets in Crypto-Assets ("MiCA")
"Platform" means the Platform operated by ILERITER sp. z o.o., available at cryptoramper.io, through which Users may access the Services and certain services provided by third-party partners.
"CASP Partner" means an independent licensed CASP that provides regulated crypto-asset services through or in connection with the Platform.

‍3. PERSONAL DATA AND INFORMATION WE COLLECT
This section describes the personal data we collect when you use the Platform and the Services made available through it.
ІLERITER sp. z o.o. will never request information regarding your racial or ethnic origin, sexual orientation, political views, religious or philosophical beliefs, biometric or genetic data, or trade union membership. When you create an account, we may ask for your contact details, including your full name, residence address, email address, and phone number. Additionally, to comply with regulations such as the Act of March 1, 2018, on Counteracting Money Laundering and Financing of Terrorism (the “AML/CFT Act”), we may collect the following personal information:
·     Identification information, including documents issued by government authorities in your country of residence or birth, such as a passport, national ID card, residence permit, driver’s license, birth certificate, visa details, and other documents necessary to verify your identity and comply with AML and anti-financial crime laws.
·     Financial information, including bank account details, payment card information, transaction history relating to the Platform and/or services provided by the relevant CASP Partner, trading data, tax information, and other relevant financial details.
·     Business information, including a certificate of incorporation from relevant authorities, extracts from commercial registries, tax or VAT numbers, Articles or Memorandum of Association, Certificates of Incumbency, personal identification of all ultimate beneficial owners (UBOs), shareholders, and board members, as well as information regarding the origin and source of funds.
·     Employment information, including your job title, employer’s office location, and job description.
·     Transaction information, including details relating to transactions initiated through the Platform or executed by the relevant licensed CASP Partner, such as transaction amounts, recipients, blockchain identifiers (where applicable), timestamps, and transaction status.
·     We may receive personal data from licensed CASP partners, payment service providers, identity verification providers, fraud prevention providers, blockchain analytics providers, or other third-party service providers where necessary to provide the Platform, comply with legal obligations, or prevent fraud and financial crime.
Depending on the Service requested, certain personal data may also be collected, verified, or otherwise processed by the relevant licensed CASP Partner for the purposes of identity verification, compliance with anti-money laundering and counter-terrorist financing requirements, sanctions screening, transaction monitoring, fraud prevention, and compliance with applicable legal and regulatory obligations.

‍4.  USE OF YOUR PERSONAL INFORMATON BY US
We use your personal data for the following purposes. Where applicable, certain personal data may also be processed by the relevant CASP Partner for the purposes described in its own privacy policy and in accordance with applicable law:
a. To provide, manage, maintain, and improve the Platform and the Services made available through it.
b. To facilitate payments, support the processing of transactions initiated through the Platform, and enable the provision of regulated crypto-asset services by the relevant CASP Partner.
c. To identify and prevent fund losses, including those arising from fraudulent activities and misuse of our Services.
d. To ensure compliance with applicable laws and regulations to prevent money laundering, terrorism financing, fraud, and other financial crimes including where such compliance activities are carried out together with or by the relevant CASP Partner.
e. To adhere to anti-financial crime regulations and obligations stipulated by Polish authorities, such as the Polish Financial Supervisory Authority (Komisja Nadzoru Finansowego, hereinafter, the "KNF").
f. To communicate with you, whether directly or through our partners, for purposes such as providing customer support, notifying you of changes and updates related to the Services, disseminating important Service-related information, and conducting marketing and promotional activities, including coordinating communications relating to services provided by the relevant CASP Partner, where applicable.
g. To send emails, including notifications, reminders, and confirmations.
h. To improve the quality of our Services. To conduct research and development to introduce innovative features and functionalities and launch new products and services.
j. To perform measurement and analytics to understand user interaction with our Services and gain insights into user behaviors and preferences.
k. To ensure the safety, security, and integrity of the Platform, personal data, and the Services made available through it.
l. To share personal data with the relevant CASP Partner, payment service providers, identity verification providers, fraud prevention providers, blockchain analytics providers, and other trusted service providers where necessary to provide the Platform, comply with legal obligations, prevent financial crime, or facilitate the requested Services.


5. WE SECURE YOUR PERSONAL DATA AND INFORMATION.
We recognize the critical importance of maintaining the security and integrity of your personal data, as any breach could have serious consequences for you and your privacy. Therefore, we have implemented a comprehensive set of physical, technical, and administrative measures to ensure the protection of your personal information. To secure your personal data, we use the Transport Layer Security (TLS) protocol, a robust encryption method designed to prevent unauthorized access and ensure privacy. TLS encryption is applied to all data exchanges between our Platform and servers, including emails and messages. Additionally, your personal and transactional data is stored in an encrypted format, with the support of trusted service providers, including where applicable, CASP Partners, cloud infrastructure providers, identity verification providers, and other technology Partners. Some of these service providers may operate outside the EU/EEA zone. Where personal data is transferred outside the European Economic Area, appropriate safeguards will be implemented in accordance with applicable data protection laws. While we have implemented extensive measures to protect your data, it is important to acknowledge that no system is completely immune to breaches or unauthorized access. Therefore, we encourage you to actively protect your personal information by using strong, unique passwords and ensuring the security of your connection. If you suspect any misuse of your personal information or have concerns about its security, please contact us immediately. Your privacy and security are our top priorities, and we are committed to addressing any issues promptly and effectively. Where regulated crypto-asset services are provided by a CASP Partner, that CASP Partner is independently responsible for implementing and maintaining appropriate technical and organisational measures to protect the personal data processed within the scope of the services it provides.

‍6. DATA RETENTION
Unless specified otherwise, we retain the personal data we collect for as long as necessary to operate the Platform, provide the Services made available through it, comply with applicable legal and regulatory obligations, resolve disputes, and enforce our agreements. These records are kept for a minimum of five(5) years after the end of a business relationship. Where permitted or required by applicable law, we reserve the right to correct, update, or delete inaccurate or incomplete personal data.
Where personal data is processed by a CASP Partner in connection with regulated crypto-asset services, that CASP Partner may retain such personal data in accordance with its own legal and regulatory obligations and applicable privacy policy.

7. UPDATES TO PRIVACY POLICY
This Privacy Policy may be updated at any time at the discretion of ILERІTER sp. z o.o. The revision date at the top of the page will be adjusted accordingly. Additionally, users may also be informed by email, through the Platform, or by other appropriate means where required by applicable law or where we consider the changes to be material. To stay informed about how personal information is protected, we recommend that users regularly review the policy for any changes. Where updates relate to personal data processing carried out by a CASP Partner, Users may also be required to review the applicable privacy policy of the relevant CASP Partner.
By continuing to use the Platform and the Services following the publication of any updated Privacy Policy, you acknowledge that you have read and understood the updated version.

‍8. COOKIE USAGE GUIDELINES
Cookies are essential for us to understand how you interact with our Platform and other services. Where required by applicable law, cookies that are not strictly necessary will only be placed on your device after you have provided your consent through the cookie banner or preference centre. These cookies help us improve our Platform and differentiate your browsing activity from that of other visitors, allowing for a more tailored online experience. To indicate your acceptance of our use of cookies on your device, please click the appropriate button on our Platform. You may withdraw or modify your cookie preferences at any time through the cookie settings available on the Platform, where applicable. While most web browsers are typically configured to accept cookies by default, you have the option to adjust your browser settings to reject all cookies or to prompt you when a cookie is being sent, giving you the choice to accept or decline it. However, changing these settings may affect the functionality of the services provided by us based on your account preferences.
Certain cookies may be placed by trusted third-party providers to support website functionality, analytics, security, fraud prevention, or services made available through the Platform. Such third parties may process information in accordance with their own privacy and cookie policies.

‍Last revised: June 25, 2026