Privacy Notice

Last Updated: 21 July 2023

This Privacy Notice outlines the procedures for collecting and handling your personal information through the IO Ready website [and application], as referenced herein. It is meant to complement any agreement and Terms of Use and to comply with all applicable regulations under the General Data Protection Regulation ("GDPR") or any other relevant data protection regulation in your jurisdiction. The terms "Service" and "Site" hold the same meaning as defined in the Terms of Use.

This Privacy Notice is applicable to all processing of Personal Data on the Site. If you do not consent to this Privacy Policy, in its entirety or in part, kindly refrain from using the Sites or Services. We conduct periodic reviews of this Privacy Policy to ensure that it aligns with new obligations and changes in our business model. Any modifications to this Privacy Policy will be published on our website. The term “Personal Data”, “Data Subject”, “Personal Information”, “Controller”, and “Processor” should have the same meaning as defined in GDPR.

1. Who we are?

UAB IO Ready (trading as “Inqud”) (“IO Ready”, “we”, or “us”) is an international company duly incorporated and registered under the laws of the Republic of Lithuania. We are committed to protecting the privacy of our customers, and we take our data protection responsibilities with the utmost seriousness.

You may send questions, comments and requests regarding this Privacy Notice and the personal data we use to:

[email protected]

2. What data do we collect about you?

There is a different type of Personal Data you may provide to us, we may collect on an automated basis or we may collect by using external sources. 

Information you may provide to us directly:

a) Account Data. We may gather personal information from you as part of managing your account. This may include but is not limited to, your name, date of birth, age, nationality, country of residence, gender, occupation, signature, utility bills, professional details, photographs, phone number, home address, email address, government-issued identification (e.g., passport, driver's license, national ID card with a photograph), tax identification number, national insurance number, social security number, visa information, and any other data deemed necessary to meet our legal obligations. 

b) Financial and Transactional Information: We may collect financial details, such as your wallet address, bank account numbers, bank statements, transaction history, trading data, and credit/debit card numbers. Additionally, we may collect personal information associated with your transactions, including but not limited to information about the purpose of the transactions, sources of funds, sender and receiver details, and ultimate beneficiary information.

c) Communication Means Information: When you request information about our Services, register for our newsletter, seek customer or technical support, or communicate with us in any other way, we may collect personal information such as your email address, phone number, or mailing address.

d) Surveys: We may invite you to participate in surveys, and if you choose to take part, we may collect personal information related to the survey.

Information Collected Automatically: 

a) Automatic Collection of Personal Information: We may automatically collect certain information when you use our Services, including your IP address, user settings, cookie identifiers, mobile carrier, mobile advertising identifiers, browser or device information, location information (including precise or approximate location derived from the IP address), and Internet service provider. Additionally, we may automatically gather information about your interactions with our Services, such as the pages you visit before, during, and after using our Services, the links you click, the types of content you interact with, and the frequency and duration of your activities.

b) Device Information: We collect information about the device you use to access your account, such as the hardware model, operating system and version, and unique device identifiers. This information is anonymized and not linked to any specific individual.

c) Transaction Information: In connection with our Services, we may collect and retain information regarding transactions you perform using IO Ready Services, such as converting one virtual currency to another or purchasing virtual currencies.

d) Information Acquired from External Sources: We also receive information from other sources and combine it with the data collected through our Services, including Sum and Substance Limited under the registered address at Suite 1, 5 Percy Street, Fitzrovia, London, England, W1T 1DG(hereinafter referred to as the “SS”).

e) We use "cookies" occasionally to enhance your online experience on our Sites. Cookies are small text files stored on your computer to improve the Sites' user-friendliness. You can find more details about the cookies we use in our Cookie Policy. Cookies provide us with information about your site usage, helping us enhance the Sites and your overall experience. Any Personal Data collected through cookies will be processed in line with this Privacy Policy. If you have set your browser to alert you before accepting cookies, you will receive an alert message with each cookie. You may disable cookies in your browser, but please note that our Sites, like many other popular sites, may not function optimally with cookies disabled.

f) We may analyse public blockchain data to ensure that users of our Services are not involved in illegal or prohibited activities, in accordance with our Terms of Use, and to study transaction trends for research and development purposes.

g) We utilize third-party services, that may partner with us, with clear notice to users. Mainly, we utilize the services of SS in order to undertake the process of identity verification and all related AML/KYC checks. SS may collect and process your Personal Data on behalf of Inqud in accordance with SS’s own privacy policies. We do not control how SS collect, store, or use your data, and it is your responsibility to review and understand their applicable terms, conditions, and privacy policies. 

h) Banks or payment processors used for fiat currency transfers may provide us with basic Personal Data, such as your name and address, as well as your bank account information.

i) Advertising or analytics providers may offer us anonymized information about you, including but not limited to how you discovered our website.

3. For what purpose we do collect your Personal Data?

We collect your personal data:

a) To provide and improve our Services;

b) For the communication with you as a customer;

c) For internal use in our system;

d) For AML/KYC procedures/requirements, and protection of your account from fraudulent actions of third persons; 

e) For fulfilment of our contractual obligations and statistics, AML/KYC procedures/requirements;

f) For fulfilment of our contractual obligations, e.g. deal with your requests, provide information in case of difference of opinions, settlement of disputes;

g) For the performance of risk management;

h) For data analysis;

4. International Transfer

We may transfer your Personal Data to locations outside of the European Economic Area ("EEA"), UK, and Switzerland. 

During such transfer to third-party partners, and service providers situated worldwide, we will strive to implement appropriate technical, organizational, and contractual safeguards to ensure compliance with applicable data protection regulations.

5. What are my rights? 

According to GDPR and applicable to you data protection legislation, you have statutory rights that relate to your Personal Data.

Such rights include:

a) Right to object to the processing of your Personal Data; 

b) Right to withdraw consent. You can withdraw your consent to process your personal data at any time. 

c) Right to access your Personal Data;

d) Right to rectification of your Personal Data. You can request the rectification of inaccurate personal data concerning them without any undue delay, considering that the accuracy of newly supplied data will be verified by IO Ready;

e) Right to erasure; You have the right to request the erasure of your Personal Data. This means you can ask us to delete or remove your Personal Data in specific circumstances. 

f) Right to restriction: You have the right to request the restriction of processing your Personal Data.

g) Right to data portability: In certain cases, you have the right to request the transfer of your Personal Data to yourself or a third party of your choosing. 

6. How long do you store my data?

We retain personal data for the duration required to provide Services or until you withdraw your consent for further data processing. In order to fully comply with legal obligations, Personal Data will be retained for a period of five to eight years, depending on the type of data (subject to any regulatory extensions), after the cessation of Service provision, as mandated by the Republic Of Lithuania Law On The Prevention Of Money Laundering And Terrorist Financing (cl.19). 

7. Who do we disclose your Personal Data?

We may lawfully disclose the information to the next third parties:

a) Regulatory and law enforcement authorities, governmental bodies, whether inside or outside of the EEA, where the law allows or requires to do so; 

b) Fraud or crime prevention agencies, which prevent fraud, money laundering and terrorist financing;

c) Identity verification agencies to undertake required verification checks;

d) Providers and contractors/subcontractors, employees that may need information for the provision of services such as IT website and platform maintenance, technical communication services, data processing, legal support services, and others. 

We are obliged to disclose your personal information in the following cases:

a) In response to lawful requests by public authorities, including to meet legitimate national security or law enforcement requirements;

b) To protect, establish, or exercise our legal rights or defend against legal claims, including to collect a debt; to comply with a subpoena, court order, legal process, or other legal requirement;

c) Disclosure is necessary to comply with the law, prevent imminent physical harm or financial loss, or investigate, prevent, or take action regarding illegal activities, suspected fraud, threats to our property, or violations of IO Ready Terms of Use and AML/KYC Policy;

d) To the third parties in case of: merger, acquisition, restructuring, joint venture, assignment, sale part of the business or the whole business.

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Company name UAB I0 Ready

Address Eisiskiy Sody 18-oji g. 11, Vilnius, Lithuania

License No.: 306194878

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