ELP SA is committed to protecting your personal data. Your personal data is treated with the utmost care and in full compliance with the obligations arising from the current regulations for the protection of personal data. This Privacy Policy ("Policy") explains how we acquire and process your personal data when you use the services we offer. This Policy applies to all users of the website www.moneyswapp and has been drafted in accordance with the Federal Act on Data Protection (FADP). We encourage you to read this Policy together with the Disclaimer, the General Terms and Conditions, and the Cookie Policy.
1) External Links
Our services may contain links to websites of other companies and services they offer. These companies may have different privacy policies from ours. We hereby disclaim any responsibility for the data protection practices of such third parties or the content of any product or service they offer or provide.
2) What Personal Data Do We Collect?
For individuals, we collect the following personal data: IP address, first name, last name, email address, telephone number, nationality, type of identification document (passport or identity card), identification document number, expiration date of the identification document, date of birth, complete residential address (street or square or other, city, postal code, and country), PEP (Politically Exposed Person) status, US citizen or US person status, IBAN, and name of the destination bank (one or more, depending on the number of bank accounts the Client registers in their reserved area). As provided by the OAD PolyReg Regulation, we will ask each Client to complete the KYC (Know Your Customer) profile with the information required by current regulations.
For legal entities, we collect the following data: IP address, company name, identification number in the Swiss commercial register, number of employees, business sector, name, last name, email address, and phone number of the contact person, registered office address (street/square, etc., city, postal code, country of registration), annual turnover in CHF, PEP or US citizen or US person status for one of the Directors and Beneficial owners, listing on a national or international stock exchange, IBAN, and name of the destination bank.
3) What Purposes Do We Use Personal Data For?
The collection of data concerning you is strictly related to the nature of our services. Therefore, we may collect personal data for the following purposes: To comply with legal obligations as a financial intermediary (Federal Act on Combating Money Laundering, Federal Act on Financial Institutions, Federal Act on Financial Services, Federal Act on the Exercise of the Profession of Trustee, the OAD PolyReg Regulation, Federal Act on Data Protection). We may be legally required to disclose personal data in compliance with the terms of a legal process or at the request of a government entity. Such disclosure may occur without the Client's consent, without prior notice to the client, and/or without prior notification, in compliance with the terms of a legal process; For training and quality assurance purposes: we may also monitor and record our communications with you, including emails and phone conversations; To offer you new products and services. We may need to communicate upcoming news about certain features of our products, services, or promotions that may be of interest to you, such as particularly rapid exchange rate movements (email, SMS, WhatsApp, push or pull notifications), automatic insertion methods of exchange requests (point 7 of the Terms and Conditions of Service), adoption of FINMA Circular 2016/7 regarding video identification to modernize the KYC procedure, and so on.
4) Who Can We Disclose Your Personal Data To?
To provide our services, we may disclose personal data, in accordance with current regulations, to the following parties:
a) Employees of ELP SA. The number of our employees who have access to customers' personal data is limited to a select group specifically authorized. As of the last update of this privacy policy, the number of employees who have access to users' personal data is seven (7). These employees may only access the data strictly necessary to ensure the provision of the service,
b) Regulatory authorities, financial sector regulatory authorities, accountants, and auditors,
c) Parties acquiring control of our company. If another company were to acquire or take over the activities of ELP SA, that company would obtain the personal data collected by ELP SA, assuming all rights and obligations related to your personal data as described in this Policy. In certain specific cases, we may also be legally required to disclose personal data to authorities or other third parties,
d) Providers of traffic-tracking, marketing and/or advertising services, such as those described in the table below for services such as tracking direct user traffic on our site and creating ad-hoc advertising campaigns. To such service providers we may have to provide personal data such as gender, nationality, residence, age. Where and when possible, all data provided to third parties is anonymised.
Functionalities supplied |
Scope of the service supplied |
Name of the service supplied |
Supplier |
Privacy policy link |
Marketing, traffic traking , advertising |
Tracking technologies that make it possible to determine: how visitors to our website interact with it, which pages and/or content generate the most traffic and views, which channels are the most popular, improve the performance of advertising campaigns. |
Google Tag Manager |
Google Inc. |
|
Google Ads |
Google Inc. |
|||
Google Analytics |
Google Inc. |
|||
LinkedIn Insight |
Microsoft Inc |
|||
GoTo Webinar, GoTo Meeting |
Technologies Ireland Unlimited Company |
|||
Facebook Ads |
Meta Inc. |
|||
Facebook Analytics |
Meta Inc. |
|||
Invio di messaggi di alert riguardo il tasso di cambio |
|
Meta Inc. |
||
Sistema di raccolta recensioni verificate |
TrustPilot reviews |
Trustpilot A/S |
||
Direct e-mail marketing |
Mailchimp emails |
The Rocket Science Group LLC |
||
Invio di e-mail automatiche riguardati lo status delle operazioni e alert via SMS |
Brevo |
Sendinblue SA |
5) How Do We Protect Personal Data?
We are committed to protecting your personal data and have taken appropriate measures to do so. These solutions include password protection, encryption, firewalls, antivirus programs, intrusion detection, anomaly detection, and access controls by our employees.
6) How Long Do We Store Personal Data?
We normally keep customer data and related financial transactions for a period of 10 years, unless current regulations require us to keep them for a different period.
7) Your Rights
You have the right to know what personal data concerning you is in our possession. Where permitted by current regulations, we may charge you administrative fees for providing such data. You also have the right to request the cessation of the processing of your personal data for direct marketing purposes. If you no longer wish to be contacted by our direct marketing staff, please contact us. Please visit the "Contacts" section of our website. We remind you that by objecting to or requesting the cessation of the processing of your personal data, in some cases, we may not be able to continue providing our services to you. For any comments, requests for information regarding this Policy, or to request access to your personal data held in our archives, please contact us at the email address support@moneyswapp.com
8) Data Controller and Data Processor
Regarding the processing of personal data, the data controller is
ELP SA
Corso San Gottardo 8A,
6830 Chiasso
Tel.: 0041 (0) 91 922 81 69
Email: support@moneyswapp.com
The data processor is:
Mr. Filippo Cova
Tel.: 0041 (0) 91 922 81 69
Email: filippo.cova@moneyswapp.com