Privacy Policy | Your Information, Our Responsibility

Intro

IOOI Sp. z O.O (“Inqud” or “we”) welcomes you. This Privacy Notice (“Privacy Notice”) applies to our Website inqud.com and web-based platform app.inqud.com, including crypto widgets (collectively, the “Service”).

The Privacy Notice describes which of your personal data Inqud collects, how stores, processes, and uses it, and what happens when you use the Service.

Content

Lawful bases for processing

Visitors’ data

Registration data

General technical data

Account

Usage data

Payment page

Crypto exchange process

Notification and marketing

Report and customer support

Data received from third parties

Data sharing with third parties

Data transfer outside the European Economic Area

Data protection

Data subjects rights

European Economic Area residents

Privacy Notice updates

About us

We are the controller of your personal data processed through the Service. This means that we determine the purposes and means of personal data processing. Pay attention that you can fall into several categories depending on your actions.

Name	IOOI Sp. z O.O
Registration number	525273421
Address	Gęsia 8/205, 31-535 Kraków, Polska
Email	[email protected] – for general and privacy inquiries

About you

When you visit the Service, you become our user (“User”). We divide the Users into categories so you can easily find details about the processing of your personal data.

Type of User	Description
Visitor	User who visits the Website
User	User who registers with the Service
Merchant	User who registers and uses Business account
Other Requester	User who fills out the “Contact us” form on another topic
Please note! We do not knowingly process the personal data of Users under the age of 18. If you are such a User or the legal representative of such a User, please contact us.

Personal data

Sources of data

We receive your data when you visit the Service and interact with it, depending on your actions on the Service.

You can change your personal data by exercising your right to rectification or by the Service functionality. Please note that the same lawful basis and storage terms apply to the changed data.

We may also (although we do not necessarily do so) receive data from third parties. It depends on your settings and the features you use.

Lawful bases for processing

To process your personal data, we rely on the following lawful bases:

performance of the contract — for the processing of personal data necessary for the negotiating on, conclusion, and performance of a contract (mainly, the Terms of Service) with you;
legitimate interest — for the processing necessary at the development of our services, taking into consideration your interests, rights, and expectations;
legal obligation — for the processing as required by applicable laws (for example, to comply with tax or KYC/AML regulations) or if requested by a law enforcement agency, court, supervisory authority, or another state-authorised public body;
consent — for additional specific purposes.

Visitors’ data

When you use the Website as the Visitor, we collect some data automatically. We need technical data to operate, support, and improve the Website’s functionality.

Data	Description	Reasons for processing	Lawful basis
Necessary technical data	Information about your operating system, device type, browser name and version	The smooth operation of the Website	Performance of the contract
Necessary cookies	Information that is necessary for the operation of the Website	Improving your experience of using the Website	Performance of the contract
Marketing cookies	Marketing information used to match relevant advertising to you	Marketing	Consent
Preference cookies	Information necessary for operating some services on the Website	The operation of some services on the Website	Consent
Statistics cookies	Information that helps us to understand how you interact with the Website by collecting and reporting information	Improvement of the Website and analysis of the statistic for other purposes	Consent
Data storage
Necessary technical data		Stored during the use of the Website and for 2 years from the last visit.
Cookies		Stored during the expiry period provided in our Cookie Policy.

Registration data

When you register an account and start to use our service, we collect or assign the data to enable you access and correct work of the Service.

Data	Reasons for processing	Lawful basis
Name, surname	Register and fill the account	Performance of the contract
Email
Phone number
User ID
Company name
Data storage
Data that is processed based on performance of the contract	Stored for 3 years from the last interaction.

General technical data

This section includes information collected for maintaining and optimising the technical aspects of the service, such as device information, browser details, and session logs. This data helps ensure the smooth functioning and security of the service.

Data	Reasons for processing	Lawful basis
IP	IP address from which the request originated.	Legitimate interest
User Id	Unique identifier for the user.	Performance of a contract
Browser Info	Information about the user's browser.	Performance of a contract
Event ID	Unique identifier for the audit event.	Performance of a contract
Creation Time	Timestamp indicating when the audit event occurred.	Performance of a contract
Action type	Indicates if the audit event is an administrative action.	Legitimate interest
Settings	Indicates if the user associated with the audit event is muted.	Performance of a contract
Event type	Type of audit event (e.g., login, logout, data access).	Performance of a contract
User Agent	User agent information associated with the audit event (e.g., browser, device).	Legitimate interest
Data storage
Data based on performance of the contract	Stored for 3 years from the last interaction.
Data based on legitimate interest.	Stored for 3 years from the last interaction, if you do not object.

Account data

Account data consists of information related to user accounts, including registration details, authentication records, and account preferences. This data is essential for user access and customization of the service.

Data	Reasons for processing	Lawful basis
AML status	Indicates if AML (Anti-Money Laundering) is enabled for the user’s transactions.	Legal obligation
Company Name	Name of the company associated with the user.	Performance of a contract
Creation time	Timestamp indicating when the user account was created.	Performance of a contract
Email	Email address of the user.	Performance of a contract
Name and surname	Name of the user.	Legitimate interest
Group Id	Identifier for the group associated with the user.	Performance of a contract
Locale	Locale settings for the user.	Legitimate interest
Timestamp	Timestamp indicating when the user account was last modified.	Legal obligation
OIDC Provider	OpenID Connect (OIDC) provider type associated with the user.	Performance of a contract
Password hash	Password associated with the user.	Performance of a contract
Phone	Phone number associated with the user.	Performance of a contract
Referral data	Referral code associated with the user. Identifier for the user who referred this user.	Legitimate interest
Referral data		Legitimate interest
UserType	Type of user account.	Performance of a contract
Verification Level	Level of verification for the user.	Legal obligation
Data storage
Data based on legal obligation	Stored for 6 years from the collection.
Data based on performance of the contract	Stored for 3 years from the last interaction.

Usage data

Usage data encompasses information about how users interact with the service, including pages visited, actions performed, and duration of sessions. This data aids in understanding user behaviour and improving the service based on usage patterns.

Data	Reasons for processing	Lawful basis
Password_log	Password-related actions: password forgotten, changed, incorrect login attempt, and attempts counter reset.	Performance of the contract
Email_log	Password-related actions: password forgotten, changed, incorrect login attempt, and attempts counter reset.
Account status	Account security actions: temporary freezing, blocking, excessive login attempts, and unblocking.
API status	API token management: creation, deletion, activation, and deactivation.
2FA	Two-factor authentication (2FA) events: activation, deactivation, and incorrect TOTP entry.
Verification status	Account verification and completion: confirmation of signup, phone verification, and completion of KYC process.
History of changes	Account profile updates: changes in user type or role, and updates to associated names.
Data storage
Data based on performance of a contract	Stored for 3 years from the end of service usage.

Payment page

This section pertains to data collected during the payment process, such as transaction details, payment method used, and billing information. It is crucial for facilitating secure and efficient payment transactions.

Data	Reasons for processing	Lawful basis
User Id	Unique identifier for the user.	Legal obligation
Creation Time	Timestamp indicating when the user account was created.
Key request	Key associated with the payment service provider (PSP) used for the transaction request.
Transaction Id	Unique identifier for the transaction.
Currency	Currency used for the transaction.
Amount	Amount of currency involved in the transaction.	Legal obligation
IP	IP address from which the request originated.	Performance of the contract
Fingerprint	Fingerprint data associated with the user (nullable).	Legal obligation
Card holder name	Name of the cardholder for the payment card used in the transaction.	Legal obligation
Card holder name	Name of the cardholder for the payment card used in the transaction.	Legal obligation
Card details	First 8 digits (partial) and last 4 digits (partial) of the payment card's PAN (Primary Account Number). Expiry date of the payment card	Legal obligation
Hash data	Hashed value associated with the payment card.	Legal obligation
Verification status	Data related to anti-fraud measures and integration.	Legal obligation
Fraud score	Risk score assigned by the anti-fraud system (Double).	Legal obligation
Card token	Hashed values of the payment card's PAN and token.	Legal obligation
Time of transaction	Timestamp indicating when the transaction was created (OffsetDateTime).
Error Status	Status of any errors encountered during the transaction (CardPayErrorStatus).
Integration ID	Identifier for the integration.
Client Order Id	Identifier for the client's order associated with the transaction.
Data storage
Data based on legal obligation	Stored for 6 years from the collection.
Data based on performance of a contract	Stored for 3 years from the end of service usage.

Сrypto exchange process

Data related to cryptocurrency exchange processes, including transaction history, exchange rates, and wallet information. This data is necessary for executing and monitoring cryptocurrency transactions securely.

Data	Reasons for processing	Lawful basis
ID	Unique identifier for the transaction.	Performance of the contract
Amount	Amount of the transaction.
Creation time	Timestamp indicating when the transaction was created.
Currency	Currency type of the transaction.
Timestamp data	Timestamp indicating when the transaction expires.
Timestamp data	Timestamp indicating the last update time of the transaction.
Transaction Name	Name associated with the transaction.
Control ID	Reason for any conflicts in the Crypto Acquiring Deposit Request.
Status	Status of the Crypto Acquiring Checkout.
Transaction type	Type of the Crypto Acquiring transaction.
User Id	Identifier for the user associated with the transaction.
Data storage
Data based on performance of a contract	Stored for 3 years from the end of service usage.

Notification and marketing data

Information gathered for managing communication with users, including email preferences, notification settings, and marketing analytics. This data helps in delivering relevant updates and promotions to users.

Data	Reasons for processing	Lawful basis
Location	To inform you about useful information, promos and other activities	Consent
Email		Consent
Email	To send you emails related to the usage of the Service	Legitimate interest
History of interaction	Analyse and improve service	Legitimate interest
Data received from 3rd parties	Analyse and improve service	Legitimate interest, Consent
Data storage
Data based on legitimate interest.	Stored for 3 years from the last interaction, if you do not object.
Data based on consent.	Stored for 2 years from collection, if you do not withdraw consent.

Third-party providers

We use 3rd-party providers for our marketing activities. Here you can see the list and read how we involve them.

Name	Description
Google tag manager	Google service that allows quickly and easily updating measurement codes and related code fragments collectively known as tags on your website or mobile app. Please see details at Privacy Notice.
Apollo	A cloud-based sales automation tool that serves as a tool for lead generation, contact database management, and email outreach. Please see details at Privacy Notice

Report and customer support data

Data collected during customer support interactions, including issue reports, support tickets, and user feedback. This data is vital for resolving user queries and improving the overall service experience.

Data	Reasons for processing	Lawful basis
User ID	To identify the user	Performance of a contract
Request data	Understand and complete your request	Performance of a contract
Data storage
Data based on performance of a contract	Stored for 3 years from the end of service usage.

Data received from third parties

We may receive some personal data from third parties.

The amount of data collected, the purposes, and the lawful basis for processing is determined by the respective privacy documents of these third parties.

Party name	Type of data		Reasons for processing
Google analytics	User behaviour	Contact Information	Analytics and monitoring
Google Search Console	User behaviour on the site	Demographic Information	Improving user experience
ActiveCampaign CRM	History of interaction	Social Profile Information	Optimization of marketing campaigns
Calendly	Interests and preferences	Communication preferences	Personal connection with clients
Hotjar	Session Recordings, Surveys and Polls	Chat history	Evaluating the effectiveness of email marketing
Zoho Live Chat	Purchase and transaction data	Integration with external services	Brand reputation monitoring
GetResponse	Traffic data	Events and interactions	Audience segmentation and targeting
Data storage
Legal basis		Legitimate interest	Сonsent
Term		3 years from the last interaction, if you do not object.	2 years from collection, if you do not withdraw consent.

Data sharing with third parties

We can share your personal data with third parties without any harm to you and in full compliance with applicable law. In addition, we have implemented organisational and technical measures to ensure the security of personal data during data transfer to third-party.

Third parties	Description
Analytics tools	We use analytics tools to understand and promote our business.
Messengers	We use messengers to communicate with you in ways that are convenient for you.
Contractors, services providers on Service	We cooperate with service providers and contractors to provide you with their services, operate, develop and improve the features and functionality of the Service, fulfil your support requests, complete payment transactions, etс.
Providers of the services our team use	We use CRM systems, messengers, and other services in our organisation to provide you with our services.
State authorities, courts, law enforcement agencies, etc	We may be obliged to transfer some of your data to tax authorities, courts, law enforcement agencies, and other governmental bodies: to comply with a government request, court order, or applicable law; to prevent unlawful use of the Service; to protect against claims of third parties; to help prevent or investigate fraud.
To get a detailed list of the third-party recipients of your personal data, contact us.

To share your data, we rely on the following lawful bases, depending on the case: consent, compliance with the law, and performance of a contract.

Data transfer outside the European Economic Area

The data is stored in Germany by default, but we may need to process your personal data in another country.

If there is no adequate decision by the European Commission regarding the country we transfer data to, we use the adopted Standard Contractual Clauses based on legislation assessments for data protection during transfer and storage.

If there is an adequate decision by the European Commission regarding the country we transfer data to, we can transfer personal data to that third country without any further safeguard being necessary.

You can read more detailed measures to protect your personal data here.

Data protection

We are regularly certified by ISO 27001 Standard.

We apply a variety of security measures appropriate to the possible risks.

Organisational measures
Staff training	Internal policies and instructions
Non-disclosure agreements (NDA)	Transfer protection

Physical measures
Video monitoring	Signalling
Limited access to premises	Round the clock security

Technical measures
Two-factor authentication	Backups
Firewalls	Encryption technologies

Data subjects rights

You, as a data subject (individual), have the right to interact with your data directly or through a request to us. This section describes these rights and how you can exercise them depending on your residency.

European Economic Area residents

You, as a data subject, have the right to interact with its data directly or through a request to us. This section describes these rights and how you can exercise them:

Right	Description
Right to access	You can request an explanation of the processing of your personal data.
Right to rectification	You can change the data if it is inaccurate or incomplete.
Right to erasure	You can send us a request to delete your personal data from our systems. We will remove them unless otherwise provided by law.
Right to restrict the processing	You may partially or completely prohibit us from processing your personal data.
Right to data portability	You can request all the data you provided to us and request to transfer data to another controller.
Right to object	You may object to the processing of your personal data.
Right to withdraw consent	You can withdraw your consent at any time.
Right to file a complaint	If your request was not satisfied, you could file a complaint to the regulatory body.
To exercise your rights, contact us. If your request was not satisfied, you can submit a complaint to your local Data Protection Authority. You may find it here.

Cookies

We use cookies that are needed for the Website’s operation. By using cookies, we receive automatically collected data. You can read more in the Cookie Policy.

If you want to turn off cookies, you can find instructions for managing your browser settings at these links:

Internet Explorer	Firefox	Chrome	Opera
Microsoft Edge	Vivaldi	Safari	Brave

Privacy Notice updates

This Privacy Notice is developed according to the General Data Protection Regulation, other applicable privacy laws, and best privacy practices.

Existing laws and requirements for the processing of personal data are subject to change. In this case, we will publish a new version of the Privacy Notice.

If there are material changes to the Privacy Notice or the Service that affect your data privacy rights, we will notify you by displaying information via the Service and, if necessary, ask for your consent.