Privacy Policy
Privacy Policy LetsExchange
Last updated: October 1, 2024
Introduction
PLEASE READ THIS DOCUMENT CAREFULLY. IT CONTAINS IMPORTANT INFORMATION THAT YOU SHOULD KNOW BEFORE CONTINUING TO USE OUR WEBSITE LOCATED AT: https://letsexchange.io/privacy-policy & beetrootworld.com AND ANY SUBDOMAINS, AS APPLICABLE ("WEBSITE"), WEB APPLICATION ("APPLICATION"), LETSEXCHANGE SERVICES ("PRODUCT"). BY CONTINUING TO USE LETSEXCHANGE WEBSITE, APPLICATION AND/OR PRODUCT YOU WILL BE DEEMED TO HAVE ACCEPTED THIS PRIVACY POLICY.
LetsExchange shall mean CryptoLightHouse Ltd., a company registered and acting in accordance with the laws of the Republic of Seychelles ("LetsExchange" "we" or "us") who are committed to respecting your data privacy and keeping your information secure and confidential.
This Privacy Policy ("Privacy Policy”) explains how LetsExchange collects, uses, shares, and secures the Personal Information you ("customer”, "you” or "your”) provide during your online and offline interactions with us in connection with the Website or Application in order to use the Product.
As used in this Privacy Policy, “Personal Information” means any information that can be used to individually identify a person, and may include, but is not limited to, name, email address, phone number, title, and other personally identifiable information.
LetsExchange will be the controller of your Personal Information that is provided, collected and/or processed pursuant to this Privacy Policy by you directly. If you have any questions about whether any of the foregoing applies to you, please contact us using the information set forth in the “Contact Us” section below.
This Privacy Policy may be updated from time to time for reasons such as operational practices or regulatory changes, so we recommend that you review our Privacy Policy when returning to our Website.
Collected information
This Privacy Policy applies to Personal Information we collect from you through our Website or Application. We obtain Personal Information in the following forms: (i) information provided by you, and (ii) information that we obtain or collect automatically from your use of the Website or Application, and Product.
Personal Information provided by you: When you contact us, sign up for a newsletter, or participate in certain services, we collect any Personal Data you provide to us, such may include: (i) your name; (ii) email address; and (iii) country of residence. LetsExchange may ask you to voluntarily supply us with certain information about yourself by filling out and submitting an online form for marketing purposes as well.
Information that we obtain or collect automatically from your use of the Website or Application: We may automatically collect certain information from your use of the Website or Application, such as usage data, preferences, or any other information concerning how you use the Product.
In particular, our servers automatically record certain information and/or we may use cookies (small text files placed on a device’s hard disk by a web service) or similar tracking technologies to collect the following types of information:
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Your browser type, language, plug-ins, Internet domain, type of device and operating system;
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Your Internet Protocol (IP) address;
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Your timezone;
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Your device screen resolution;
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The website(s) you visited before visiting the Website and the website(s) you visited after visiting the Website;
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Unique identifiers, including mobile device identification numbers, that may help detect the physical location of such devices;
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Data related to your interactions with content on the Website and Applications, such as use patterns and the type of content viewed or favorited in the Website and Applications.
Please note that you may set most browsers to notify you if you receive a cookie or you may choose to block cookies with your browser. Additional information on how we use cookies and other tracking technologies and how to control them can be found in our Cookie Policy https://letsexchange.io/cookie-policy
In addition, by using our Website or Application, network information such as Product usage information, may be transmitted back to us. It helps us to determine how users are interacting with our Product, improve our Product, and correct any problems that may occur.
Geolocation
We collect your location based information such as country, region, city for the purpose of optimizing your connection to our data center. We will only share this information with our data center provider for the sole purpose of providing our service and Product to you.
If you prefer to restrict sharing your information in this manner you may opt-out of location based services at any time by changing the settings in your Internet-connected device or by contacting us using the information in the “Contact Us” section of this Privacy Policy.
Registration options
As described above, we will ask you to create a Personal Account to enable you to use the Product. Once the Personal Account is created, you will be able to access, review and update your personal account information online via the Site or the Application.
When you sign-up, you, therefore, consent to receive system emails, communications from our customer support team and newsletters about Product updates from us. If you would like to discontinue receiving these notifications, you can update your preferences by clicking the "Unsubscribe” link found in such emails or by contacting us using the information in the "Contact Us” section of this Privacy Policy.
Please note that you may choose not to create the Personal Account. If you choose so, you will still have access to many of the Site’s web pages, however, you may be unable to access certain options and services that we offer only to registered users.
Use of personal information
LetsExchange uses your Personal Information to:
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operate and improve the Website, Application, and Product;
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customize your experience on the Website, Application, and Product;
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deliver communications that may be of interest to you, either electronically or otherwise;
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enforce this Privacy Policy;
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enforce terms of use / user’s agreement;
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conduct market analysis, traffic flow analysis and related reporting to third parties;
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provide reports based on information collected from use of our Website, Application, and Product;
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keep you up to date on the latest Product announcements, software updates, software upgrades, system enhancements, special offers, and other information, provided that you can modify your marketing preferences;
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provide support and assistance with our Website, Application, and Product;
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verify user’s identity;
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provide you with shipping and billing information;
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request customer feedback;
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provide information related to the use of the Website, Application, and Product;
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conduct questionnaires and surveys in order to provide better products and services to our customers and end users. Your completion of any questionnaires is voluntary;
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understand more about you, so we can personalize newsletters and websites according to your preferences (e.g. enable you to request specific information on products and services to be included in these newsletters);
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marketing purposes;
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for any other purposes disclosed to you at the time we collect your Personal Information.
Processing and sharing your personal information
By accessing or using the Website, Application, or Product, or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries and territories, which may have privacy laws different from your country of residence. Please note that some of the recipients of your Personal Information referenced above may be based in countries outside of the European Union whose laws may not provide the same level of data protection. In such cases, we will ensure that there are adequate safeguards in place to protect your Personal Information that comply with our legal obligations. If the recipient is not a member of the LetsExchange, the adequate safeguard might be provided by signing a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission for transfers of personal data to third countries.
We may also share Personal Information with third parties including as follows:
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Partners, Vendors, Consultants and Other Service Providers: We may share your Personal Information with our third-party providers and vendors, consultants and other service providers who are working on our behalf and require access to your Personal Information to carry out their work, such as to process billing, provide customer support, etc. These service providers are authorized to use your Personal Information only as necessary to provide services to LetsExchange or Product.
In some cases, we may share your information with third-party providers and vendors to understand which areas and features of the Product are most popular and/or to improve the overall effectiveness of the Product and its features.
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Compliance with Laws: We may disclose your Personal Information to a third party if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce our agreements, policies and terms and conditions / user’s agreement, (c) to protect the security or integrity of the Product, (d) to protect LetsExchange, our customers or the public from harm or illegal activities, (e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
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Aggregated or Anonymized Data: We may also share aggregated or anonymized information with third parties that does not directly identify you.
Security of information
We have implemented reasonable administrative, technical and physical security measures to protect your personal information against unauthorized access, destruction or alteration. For example:
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SSL encryption (https) everywhere where we deal with Personal Information.
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Databases encryption;
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Hosting data on physically secure servers that are also protected by firewalls.
We use commercially reasonable organizational, technical and administrative security procedures to protect all collected Personal Information. Please understand that no security system is perfect and, as such, we do not guarantee the security of the Website, or that your Personal Information won’t be intercepted while being transmitted to us. If we learn of a security systems breach, then we may either post a notice, or attempt to notify you by email. We will take reasonable steps to remedy the breach.
Data subject rights
You have certain rights with respect to your Personal Information as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests. We may ask you to provide us with additional information in connection with your request. If we need to verify your identity or the nature of your request, we may ask you to provide more details regarding your Personal Information. In such situations, however, we will still respond to let you know of our decision.
To make any of the following requests, contact us using the contact details referred to in the “Contact Us” section of this Privacy Policy.
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Access: You can request to receive a copy of the Personal Information we hold about you.
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Rectification: If you believe that any Personal Information we are holding about you is incorrect or incomplete, you can request that we correct or supplement it. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
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Objection: You can contact us to inform us that you object to the collection or use of your Personal Information for certain purposes.
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Erasure: You can request that we erase some or all of your Personal Information from our systems.
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Restriction of Processing: You can ask us to restrict further processing of your Personal Information.
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Portability: You have the right to ask for a copy of your Personal Information in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
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Withdrawal of Consent: If we are processing your Personal Information based on your consent (as indicated at the time of such data collection), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have then to provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Information, if such use or disclosure is necessary to enable you to utilize some or all of our Products.
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Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Information with the supervisory authority of your country or EU Member State.
Access by minors
LetsExchange does not knowingly collect or store any Personal Information from or about children under the age of 18. If you believe a child under the age of 18 has under any circumstances provided us with their Personal Information and data, ask a parent or legal guardian of that child to contact us using the contact details referred to in the “Contact Us” section of this Privacy Policy and request to delete their children’s information from our records.
Changes to this privacy policy
We will occasionally update this Privacy Policy to reflect customer feedback and changes in our Website, Application, or Product. When we post changes to a statement, we will revise the “last updated” date at the top of the statement. If there are material changes to the statement or any changes in the way LetsExchange will use Personal Information, we will notify you either by posting a notice of such changes before they take effect or by directly sending you a notification.
User consent
By using Website, Application, or Product you consent to the terms of this Privacy Policy and to our processing of Personal Information for the purposes given above as well as those explained where LetsExchange collects Personal Information.
Recourse, enforcement and liability
Since LetsExchange is committed to protect your privacy as set forth in this Privacy Policy, if you think we are not in compliance with our Privacy Policy, or if you have any question or if you wish to take any other action concerning this Privacy Policy or your Personal Information, we encourage you to contact us using the contact details set forth in “Contact Us” section below. We will investigate your complaint, take appropriate action and report back to you within 30 days.
With respect to complaints concerning Personal Information that is transferred from the EU, we have agreed to participate in the dispute resolution procedures of the EU Data Protection Authorities. LetsExchange will cooperate with the appropriate EU Data Protection Authorities during investigation and resolution of complaints concerning Personal Information that is transferred from the EU to the United States.
The resource mechanisms are available at no cost to you. Damages may be awarded in accordance with applicable law.
Under certain conditions, if you are not satisfied with the above recourse mechanism, you may be able to invoke binding arbitration.
SimpleSwap
1. General information
1.1. References in this Privacy Policy to “SimpleSwap”, “Service”, “Application”, “App” relate to the website, available at https://simpleswap.io, operated by SimpleSwap.
1.2. SimpleSwap is the data controller regarding the Personal Data processed within the framework of this Privacy Policy.
1.3. An individual can only become a Client of SimpleSwap and use its features if he/she is aged 18 or over or the age of majority in the country in which he/she resides if that happens to be greater than 18. SimpleSwap does not knowingly collect any information (including Personal Data) or market its services to minors or users under the age of majority.
1.4. SimpleSwap is committed to protecting and respecting the privacy of its Clients and ensures their security when using the Service. This Privacy Policy is intended to help the Client to understand what data and for which purposes Service collects, how collected data is processed and protected.
1.5. SimpleSwap reserves the right to amend this Privacy Policy; therefore it is recommended that the Client of the Service checks Privacy Policy on a regular basis. The service will send a notice or an email regarding such changes to the Client.
1.6. All the changes to this Privacy Policy are effective as of the “Last updated” date. The Client who continues to use the Service after the Last updated date is deemed to accept the changes made to it.
1.7. SimpleSwap expressly states and declares that no personal data of the Client is operated when Additional Services are provided to the Client pursuant to the Terms (Special Terms on Fiat to Crypto Exchange Services). That Client may be required to provide personal data to the third party rendering fiat to crypto exchange services and the operation by that third party of the Client personal data will by all means be regulated by that third party terms and conditions, and privacy policy.
2. Contact us
2.1. SimpleSwap has designated a Data Protection Officer (DPO) who could be reached by emailing to Emily@simpleswap.io or by post at the address provided above.
2.2. By registering with the Service, the Client consents to the processing of his/her Personal Data by the Service in accordance with the provisions set below.
2.3. By registering with the Service, the Client gives consent to SimpleSwap to anonymize his/her Personal Data for the purposes of further use in anonymized form in order to improve the performance of the Service.
3. Collected data
3.1. When using the Services, the Client agrees to the processing of the following Personal Data:
3.1.1. Personal Data that the Client provides to the Service:
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When creating an address, the Client obliges to provide the Service with basic details necessary for the Service to work as it might be requested, such as the Client’s name, gender, date of birth and location.
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SimpleSwap reserves the right to monitor or record interactions between the Client and the Support Service for training purposes and to ensure high quality of service.
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When participating in Client verification procedures: Client’s Personal Data, as requested by the Service for the Client identification purposes.
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When participating in surveys or focus groups: insights and evaluation of SimpleSwap’s services, responses to the questions from the Service.
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When proceeding with transactions: information required under AML/KYC applicable standards in order to ensure the security of transactions.
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While ordering merchant Product through SimpleSwap’s website: Client’s Personal Data, as required for the Product’s delivery, such as Client’s full name, postal address, phone number.
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3.1.2. Personal Data collected through the use of the Service:
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When the Client is using SimpleSwap’s App, the Service may collect data regarding the device(s) the Client uses to access the Service (such as his/her IP address, device identifier (including unique advertising device identifiers, for example Google Advertiser ID and IDFA), technical and statistical data (including data about the Internet connection, cellular service provider and application usage data) and location data (upon a separate consent from the Client).
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3.2. By providing Personal Data to SimpleSwap, the Client warrants that such data is true, accurate and up to date.
3.3. In case the Client is entitled to create a Client’s account instead of Client’s address, the present Privacy Policies shall be applicable accordingly.
4. Use of User’s/Client’s personal data
4.1. SimpleSwap collects, process and uses Personal Data of Clients of the Service based on the following grounds:
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when such processing is performed in order to fulfil the contract between the Service and the Client;
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based on legitimate interest of the Service;
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upon explicit prior consent from the Client.
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4.2. SimpleSwap collects and processes Personal Data of the Service’s Clients in order to maintain the functionality of the Service, Product delivery and to ensure compliance with legal and business-related requirements. The User’s/Client’s Personal Data is processed for the following purposes:
4.2.1. When processing of personal data is related to fulfilment of the contract between the Service and the Client:
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to set up, operate and manage the Client’s address and, if necessary, to contact the respective Client through the means provided by the Client upon registration, in connection with the operation and management of the Client’s address;
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to analyze the Client’s profile, activity on the Service, preferences and current location in order to improve the Services;
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to proceed and respond to the requests and enquiries received from the Client;
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for administrative purposes, such as password reminders, service messages (including but not limited to the Website’s maintenance messages, updates to the Service’s Privacy Policy and Terms of Service).
4.2.2. Under legitimate interests of the Service:
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for Client verification purposes, conducted in relation to an ongoing or alleged misbehavior, performed by the Client of the Service, in order to block addresses as part of the Services anti-spam procedures, to investigate possible fraud;
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to evaluate the effectiveness of marketing and to perform market research and training.
4.2.3. Under an explicit consent from the Client:
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to facilitate networking opportunities of the Client with the Service by way of allowing him/her to add additional information to the Client’s address;
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to serve the Client with targeted Website advertisements;
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for remarketing purposes, allowing the Service to identify the Client who has previously visited the Website and optimize advertising information according to the Client’s preferences. This feature is used by the Service through third-party services such as Google Advertising and myTarget;
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to prepare statistics regarding the use of the Services by the Client;
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to identify possible technical malfunctions in the work of the Service, to assist internal research and development and to make improvements to the Website.
4.2.4. When processing delivery of the Products ordered by the Client:
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to facilitate the delivery of the Products ordered by the Client.
5. Duration of the Сlient’s data retention
5.1. SimpleSwap retains the Client’s Personal Data for the period of time necessary to carry out relevant activities, specified in section 4 of this Privacy Policy and as permitted by applicable law. Personal Data, that the Client has communicated to the Service upon registration and subsequently through the use of the Service, will be retained by the Service as long as the Client remains the Client of the Service.
5.2. To protect the safety and security of the Clients of the Service, SimpleSwap implements a safety retention window of 30 days following a Client’s address deletion.
5.3. SimpleSwap reserves the right to store the Client’s Personal Data for a longer period of time than provided in paragraph 5.1., when it is performed in order to fulfill the legal obligations of the Service (including law enforcement requests, dispute resolution), ensure compliance with applicable law or when the relevant Personal Data is stored on the basis of the Service’s legitimate interests (including security reasons, prevention of fraud).
6. Disclosure of Personal Data
6.1. SimpleSwap may share the Client’s Personal Data with third parties in the following cases:
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Other Clients of SimpleSwap: The Client shares information with other Clients of SimpleSwap by way of voluntarily disclosing information on the Service (including but not limited to information in his/her Client’s profile). It is in the Client’s discretion to choose the information to be disclosed with the Service and SimpleSwap rescinds from responsibility for the other Clients of the Service regarding the way they might use such information, disclosed by the Client.
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Facilitation of Product’s delivery. SimpleSwap may share Client’s Personal Data with courier service providers in order to fulfill SimpleSwap’s obligations in relation to the Product’s delivery.
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Third-party advertising services. SimpleSwap uses the following services (list of services is provided alongside with privacy policies of the relevant services):
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Google Analytics
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Amplitude
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Mixpanel
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Third-party analytics services. SimpleSwap uses the following services (list of services is provided alongside with privacy policies of the relevant services):
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Google Analytics
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Amplitude
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Mixpanel
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Cloud services providers:
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Cloudflare
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Client support services.
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Providing Client’s data by law: SimpleSwap may disclose Client’s Personal Data when such disclosure is required by law and is reasonably necessary:
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in order to establish, exercise, defend or enforce legal rights of the Service;
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to comply with a legal process such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements;
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to assist in the prevention or detection of crime (subject in each case to applicable law);
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to protect the safety or vital interests of an individual
6.2. SimpleSwap ensures appropriate contractual control over third parties assisting the Service in processing the Client’s Personal Data, securing that rights of Clients of the Service are upheld, their Personal Data is secure, appropriate security and privacy arrangements are in place.
6.3. In the event of change in the corporate structure of the Service, resulting in transfer of the Client’s Personal Data to a third party, all the Clients of the Service would be notified of such changes via email and through a notice posted on the Service’s website. Respective notice would explain the identity of the new data controller and the Client’s options regarding disposal of their Personal Data.
7. Client’s rights
7.1. Every Client of the Service is a data subject and thus has ultimate rights over his/her Personal Data.
7.2. The rights of data subject over his/her Personal Data are as follows:
Client’s rightDescription
AccessA right to know whether Personal Data concerning the Client is being processed by the Service, right to get information regarding processing of Personal data, right to request a copy of Personal Data being processed.
RectificationA right to ask the Service to correct Client’s Personal Data in a situation when such data available to the Service or disclosed to third parties is inaccurate or incomplete.
ErasureA right to request ‘to be forgotten’, meaning deletion of the Client’s Personal Data from the database of the Service so that the Service is not able to continue processing and storing of such data, with exceptions, provided by applicable law.
Restrict processingRight to introduce the restriction regime on the processing of the Client’s Personal Data, so that in each case the data may be processed only upon separate consent from the Client.
Data portabilityRight to request for the Personal Data provided to the Service to be given in a machine-readable format so that it could be transferred to another service provider or transfer directly to a third party designated by the Client.
ObjectRight to object to processing his/her Personal Data in a case when the corresponding processing is not performed on the basis of the Client’s consent.
Withdraw consentRight to withdraw consent to processing of his/her Personal Data by SimpleSwap and/or third party processors of Personal Data. The Client should note that withdrawal of consent to the processing of his/her will result in the deletion of his/her profile with the Service and the termination of his/her use of the Service.
7.3. The abovementioned rights are not absolute. In order to exercise some of the rights, the Client should meet certain conditions and requirements, specified by the law.
7.4. For more information regarding his/her rights over Personal Data, the Client/User of the Service should contact Emily@simpleswap.io. In order to exercise his/her rights, the Client should submit a request to Emily@simpleswap.io.
7.5. The Client/User of the Service should also be acknowledged of his/her right to complain to a data protection regulator in his/her jurisdiction.
8. Protection measures
8.1. When using the Website, Client’s personal data is transferred by the Service to the domain www.simpleswap.io.
8.2. SimpleSwap works hard to protect its Clients from unauthorized access to or alteration, disclosure or destruction of their Personal Data. Yet, as any other technology companies, although SimpleSwap takes steps to secure Clients’ information, it could not be promised or guaranteed, that unauthorised access, hacking, data loss, or other breaches will never occur.
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SimpleSwap reserves the right to suspend the Client’s address without notice if there is a reasonable suspicion of breach of security. If you believe that your address or information is no longer secure, please notify SimpleSwap immediately by sending a message to Emily@simpleswap.io.
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8.3. The Client should take reasonable steps in order to keep his/her Personal Data safe.
9. Cookies
9.1. In order to guarantee an optimal level of usability and performance and to ensure relevance of promoted services, SimpleSwap uses cookies and similar technologies in order to track the interaction of Clients with the Website. This section explains the different types of cookies that may be set when the Client uses the Website, helping to understand and manage them as he/she wishes.
9.2. A cookie is a small file that is stored locally at the Client’s technical device as soon as the Website is being visited. Cookies function by saving particular sets of data, such as, for example, the Client’s language selection. Should the Client open the Website again later, a cookie will transmit this data back to the Website. The Website’s cookies don't store personal information like the Client’s name or address.
9.3. Types of Cookies
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SimpleSwap’s Website uses different types of cookies:
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Session cookies only last only while the Client is visiting the Website and help SimpleSwap to learn more about Client’s use of the Website during a single session and to help the Client to use the Website more efficiently.
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Persistent cookies have a longer lifespan and aren't automatically deleted when the Client closes the Website. These cookies are primarily used to help the Client to sign-in into the Website again quickly, for security and analytical purposes. SimpleSwap does not use any information whilst the Client is logged off the Website.
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SimpleSwap uses first-party cookies that is when the cookies are placed on the Client’s device directly by the Service. For example, first-party cookies are used to adapt the Website to the language preferences and analyze user experience of the Client.
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Third-party cookies are placed on the Client’s device by SimpleSwap’s partners and service providers.
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9.4. The Client can at any time reset device identifiers by activating the appropriate setting on his/her mobile device. The procedure for managing device identifiers is slightly different for each device.
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9.5. Below is information about how SimpleSwap uses Clients’ cookies in the Website:
Necessary cookies
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These cookies are strictly necessary to provide the Client SimpleSwap’s services.
Authentication cookies
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These persistent cookies help the Service to identify the Clients so that the Client could log into the Website automatically.
Analytics cookies
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These cookies help the Service to understand how the Website is being used, and help us customize and improve the Service.
Google Analyticshttps://policies.google.com/privacy
Amplitudehttps://amplitude.com/privacy
Mixpanelhttps://mixpanel.com/legal/privacy-policy
Cloudflarehttps://www.cloudflare.com/privacypolicy/
Satismeterhttps://www.satismeter.com/privacy-policy/
Sentryhttps://sentry.io/privacy/
Advertising cookies
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These cookies are used to make advertising messages more relevant to the Client. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, selecting advertisements that are based on the Client’s interests and measuring the number of ads displayed and their performance, such as how many people clicked on a given ad.
Social networking cookies
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These cookies are used to enable the Client to connect the Client’s address to third party social networks.
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9.6. Below is information about how SimpleSwap uses Clients’ cookies on the simpleswap.io website:
Necessary
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Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
NameProviderPurposeExpiryType
__cfduidCloudflareUsed by the content network, Cloudflare, to identify trusted web traffic.29 daysHTTP Cookie
CookieConsentSimpleswapStores the user's cookie consent state for the current domain.1 yearHTTP Cookie
Local StorageSimpleswapStores the user's cookie consent state for the current domain.1 yearHTTP Cookie
10. Cross-border data transfer
10.1. Disclosure of SimpleSwap’s Clients’ Personal Data, as provided in section 6 of these Terms of Service sometimes involves cross-border data transfers, for instance to Andorra, Argentina, Faroe Islands, Israel, New Zealand, Switzerland, Russian Federation and other jurisdictions. SimpleSwap uses standard contract clauses approved by the European Commission or other suitable safeguard to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of Client’s Personal Data.