Privacy Policy

Last Updated: January 2, 2024
This Privacy Notice is designed to help you understand how RWA Operating LLC, doing business as iTransfr (“iTransfr,” “we,” “us,” or “our”), collects, uses, and shares your personal information, and to help you understand and exercise your privacy rights.1. Scope and Updates to This Privacy NoticeThis Privacy Notice applies to personal information processed by us, including on our website www.iTransfr.com (the “Site”), our products and services available on iTransfr.com, and any other online or offline offerings (collectively called the “iTransfr Products”).
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‍Changes to our Privacy Notice
We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use the iTransfr Products after the new Privacy Notice takes effect.2. Personal Information We CollectThe categories of personal information we collect depend on how you interact with us, the iTransfr Products, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use the iTransfr Products, and information from other sources such as third-party services and organizations, as described below.A.
Personal Information You Provide to Us Directly
We may collect personal information that you provide to us.
‍Account Information: We and our service providers may collect personal information in connection with your application for, and creation of, an iTransfr Product account, including Know Your Customer (“KYC”) information, such as your name, business’s name, state of incorporation, type, mailing address, your employer tax identification number (or comparable number issued by a government) or social security number, and personal identification information for all material beneficial owners of your business. We may also collect your bank account number, payment card primary account number (“PAN”), and tax identification number.
‍Transaction Information: We collect information about the transactions made on the iTransfr Products, such as the wallet addresses of the recipients and the senders, their names, your account balance, payment history, currency amounts, currency preferences, payment methods, dates, and/or timestamps.
‍Financial and Blockchain Information: When you sign up to use the iTransfr Products, you may choose to connect the iTransfr Products to your bank account. If you do so, we will collect your bank account number and account balance. The iTransfr Products may also enable you to: (A) store information about the digital assets and currencies on decentralized blockchains (each, a “Blockchain”) that iTransfr, in its sole discretion, elects to support (each, a “Supported Digital Asset”) to facilitate transactions; and (B) monitor deposits, view balances of, and stake your associated Supported Digital Assets. iTransfr will collect information related to such Supported Digital Assets.
‍Your Communications with Us: We may collect personal information, such as your name or company name, when you request information about iTransfr or the iTransfr Products, register for our newsletter, request support, or otherwise communicate with us.
‍Interactive Features: We and others who use the iTransfr Products may collect personal information that you submit or make available through our interactive features (e.g., social media pages). Any information you provide using the public sharing features of the iTransfr Products will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.
‍Conferences, Trade Shows, and Other Events: We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
‍Business Development and Strategic Partnerships: We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
‍Job Applications: We may post job openings and opportunities on the iTransfr Products. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us.
‍B. Personal Information Collected Automatically
We may collect personal information automatically when you use the iTransfr Products.
‍Automatic Collection of Personal Information: We may collect certain information automatically when you use the iTransfr Products, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of the iTransfr Products, such as pages that you visit before, during, and after using the iTransfr Products, items that you search for via the iTransfr Products, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use the iTransfr Products.
‍Cookie Policy (and Other Technologies): We, as well as third parties that provide content or other functionality on the iTransfr Products, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of the iTransfr Products.Cookies: Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
‍Pixel Tags/Web Beacons: A pixel tag (also known as a web beacon) is a piece of code embedded in the iTransfr Products that collects information about engagement on the iTransfr Products. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded. Our uses of these Technologies fall into the following general categories:
‍Operationally Necessary: This includes Technologies that allow you access to the iTransfr Products, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;
‍Performance-Related: We may use Technologies to assess the performance of the iTransfr Products, including as part of our analytic practices to help us understand how individuals use iTransfr Products (see Analytics below);
‍Functionality-Related: We may use Technologies that allow us to offer you enhanced functionality when accessing or using the iTransfr Products. This may include identifying you when you sign into the iTransfr Products or keeping track of your specified preferences, interests, or past items viewed; See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.
‍Analytics: We may use Technologies and other third-party tools to process analytics information on the iTransfr Products. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize the iTransfr Products.
‍Google Analytics: We use Google Analytics to review the performance of the iTransfr Products. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other data), please read “How Google uses information from sites or apps that use our services.” To learn more about how to opt-out of Google Analytics’ use of your information, please click here.3. How We Use Your Personal InformationWe use your personal information for a variety of business purposes, including to provide the iTransfr Products, for administrative purposes, and to market our products and services, as described below.
‍A. Provide the iTransfr Products
We use your personal information to fulfill our contract with you and provide you with the iTransfr Products, such as:Managing your information and accounts;Providing access to certain areas, functionalities, and features of the iTransfr Products;Answering requests for customer or technical support;Communicating with you about your account, activities on the iTransfr Products, and policy changes; andProcessing applications if you apply for a job we post on the iTransfr Products.
‍B. Administrative Purposes
We use your personal information for various administrative purposes, such as:Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;Measuring interest and engagement in the iTransfr Products;Improving, upgrading, or enhancing the iTransfr Products;Developing new products and services;Ensuring internal quality control and safety;To facilitate the connection of third-party services or applications;Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;Debugging to identify and repair errors with the iTransfr Products;Auditing relating to interactions, transactions, and other compliance activities;Sharing personal information with third parties as needed to provide the iTransfr Products;Processing information about your iTransfr account to provide you the iTransfr Products;Enforcing our agreements and policies; andCarrying out activities that are required to comply with our legal obligations. For example, when you use our digital currency services, we are required to collect, use, and store your personal information such as verifying your identity in order to comply with anti-money laundering laws across jurisdictions.
‍C. With Your Consent
We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
‍D. Other Purposes
We also use your personal information for other purposes as requested by you or as permitted by applicable law.De-identified and Aggregated Information:
We may use personal information to create de-identified and/or aggregated information, such as demographic information, information about how you use the iTransfr Products, information about the device from which you access the iTransfr Products, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use, disclose, and retain such information as permitted by applicable laws including, but not limited to, for research, analysis, analytics, and any other legally permissible purposes.
‍Information Made Available on the Blockchain Network: Notwithstanding anything to the contrary in this Privacy Notice, information you make available on the blockchain network via the iTransfr Products, such as your user information and related electronic wallet address may be shared with third parties, made publicly visible and/or appear as part of or any other applicable Blockchain network, including when you conduct any sales, purchases, or other related activities through the Services. In these situations, the personal information you share may not be able to be modified or deleted due to the immutable nature of the Blockchain. The foregoing disclosure may be made for purposes related to facilitating those activities or transactions on the Blockchain, including without limitation making payments to iTransfr.4. How We Disclose Your Personal InformationWe disclose your personal information to third parties for a variety of business purposes, including to provide the iTransfr Products, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
‍A. Disclosures to Provide the iTransfr Products
The categories of third parties with whom we may share your personal information are described below.
‍Service Providers: We may share your personal information with our third-party service providers and vendors that assist us with the provision of the iTransfr Products. This includes service providers and vendors that provide us with IT support, hosting, payment processing, customer service, and related services.
‍Business Partners: We may share your personal information with business partners to provide you with the iTransfr Products you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
‍Affiliates: We may share your personal information with our corporate affiliates.APIs/SDKs: We may use third-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of the iTransfr Products. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.
‍B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
‍C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.5. Your Privacy Choices and Rights
‍Your Privacy Choices
The privacy choices you may have about your personal information are determined by applicable law and are described below.
‍Email Communications: If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding the iTransfr Products you have requested. We may also send you certain non-promotional communications regarding us and the iTransfr Products, and you will not be able to opt out of those communications (e.g., communications regarding the iTransfr Products or updates to our Terms or this Privacy Notice).
‍“Do Not Track”: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
‍Cookie Choices: You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the iTransfr Products may not work properly. Please note you must separately opt out in each browser and on each device.
‍Your Privacy Rights
In accordance with applicable law, you may have the right to:
‍Access to and Portability of Your Personal Information, including:(i) confirming whether we are processing your personal information;(ii) obtaining access to or a copy of your personal information; and(iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (also known as the “right of data portability”);
‍Request Correction of your personal information where it is inaccurate or incomplete;
‍Request Deletion of your personal information;
‍Request Restriction of or Object to our processing of your personal information; and
‍Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal.If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.6. International Transfers of Personal InformationAll personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your personal information consistent with the requirements of applicable laws.If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.7. Children’s InformationThe iTransfr Products are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children.If you are a parent or guardian and believe your child has uploaded personal information to the iTransfr Products without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.8. RetentionWe take measures to delete your personal information or keep it in a form that does not permit identifying you when this personal information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this personal information for a longer period. When determining the specific retention period, we take into account various criteria, such as the type of iTransfr Products provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the statute of limitations.9. Supplemental Notice for California ResidentsThe California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.10. Supplemental Notice for Nevada ResidentsIf you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in “Contact Us” below.11. Supplemental Notice for European UsersThis section applies to users located in the European Economic Area (“EEA”), Switzerland or the United Kingdom (“U.K.”).
‍Our Legal Bases for Processing Personal Information
We only process your personal information when we have a valid “legal basis.” The legal bases we may rely on to process your information include:
‍Consent: You have consented to the use of your personal information, for example to use cookies.
‍Contractual Necessity: We need your information to provide you with the iTransfr Products, for example to respond to your inquiries.
‍Compliance with a Legal Obligation: We have a legal obligation to use your personal information, for example to comply with tax and accounting obligations.
‍Legitimate Interests: We or a third party have a legitimate interest in using your personal information. In particular, we have a legitimate interest in using your personal information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of the iTransfr Products. We only rely on our or a third party’s legitimate interests to process your personal information when these interests are not overridden by your rights and interests.
‍Supervisory Authority
If your personal information is subject to the applicable data protection laws of the EEA, Switzerland, or the U.K., you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your personal information violates applicable law.
‍EEA Data Protection Authorities (DPAs)Swiss Federal Data Protection and Information Commissioner (FDPIC)UK Information Commissioner’s Office (ICO)12. Other ProvisionsThird-Party Websites/Applications
The iTransfr Products may contain links to other websites/applications and other websites/applications may reference or link to the iTransfr Products. These third-party services, including the services provided by financial institutions and cryptocurrency exchanges, are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.13.
Contact Us
If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at support@itransfr.com.