Privacy Policy

Latest Update: August 1st, 2023

Trasferium (defined below under “our entities and relationship to you” is committed to protecting the privacy of visitors to our websites and our partners.) This Privacy Policy describes how we handle your personal data when you access our services, which include our content on the websites located at trasferium.com, any other websites, pages, features, or content we own or operate (collectively, the “Site(s)”), or any Trasferium Application Programming Interface or third party applications relying on such an API, and related services (referred to collectively hereinafter as “Services”).

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

By email: support@trasferium.com
By visiting this page on our website: trasferium.com

1. Our Entities

Trasferium operates through AlterFi Solutions Ltd (“Trasferium”, “we”, “us”, “our”) in order to provide Services to our customers.

Trasferium may share your personal data with its other entities and use it in accordance with this Privacy Policy.

Address: Republic of Marshall Islands

2. Collecting and Using Your Personal Data

2.1 Types of Data Collected
2.1.1 Personal Data
Personal data means any data which relates to a living individual who can be identified from that data, or from that data and other information which is in the possession of, or is likely to come into the possession of, Trasferium (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Trasferium or any other person in respect of an individual. The definition of personal data depends on the relevant law applicable to your physical location.

2.1.2 Usage Data
Usage Data is collected automatically when using the Service.

Usage Data may include information such as your device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.

2.1.3 Data from Third-Parties
This includes information Trasferium may obtain about you from third party sources. The main types of third parties we receive your personal data from are:

Public Databases, Credit Bureaus & ID Verification Partners in order to verify your identity in accordance with applicable law. ID verification partners such as BASIS ID use a combination of government records and publicly available information about you to verify your identity. Such information may include your name, address, job role, public employment profile, credit history, status on any sanction’s lists maintained by public authorities, and other relevant data.
Blockchain Data to ensure parties using our Services are not engaged in illegal or prohibited activity and to analyse transaction trends for research and development purposes.
Marketing Partners & Resellers so that we can better understand which of our Services may be of interest to you.

2.1.4 Tracking Technologies and Cookies
Trasferium use Cookies and similar tracking technologies to track the activity on our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service. The technologies we use may include:

Cookies or Browser Cookies. A cookie is a small file placed on your service. you can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Service. Unless you have adjusted your browser setting so that it will refuse Cookies, our Service may use Cookies.
Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about your preferences or your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies.
Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

2.2 Use of Your Personal Data
2.2.1 How We Use Your Personal Data
Trasferium may use your personal data in the following ways and for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.
To maintain legal and regulatory compliance, we need to process your personal data in order to comply with anti-monetary laundering and security laws. We also process your personal data in order to help detect, prevent, and mitigate fraud and abuse of our Services and to protect you against account compromise or funds loss.
For the performance of a contract, the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Service.
To contact you via email, telephone calls, SMS, or other equivalent forms of electronic communication, such as service updates regarding administrative or account-related information, security issues, or other transaction-related information. These communications are important to share developments that may affect how you can use our Services. You cannot opt-out of receiving critical service communications.
To provide communications and customer services according to your preferences and in compliance with applicable law, we may send you marketing communications to inform you about events, to deliver targeted marketing and to share promotional offers. If you are a new client or partner, we will contact you by electronic means for marketing purposes only if you have consented to such communication. If you do not want us to send you marketing communications, please submit a request via email at support@trasferium.com
We also process your personal information when you contact us to resolve any questions, disputes, or to troubleshoot problems. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.
For business transfers, we may use your data to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Service users is among the assets transferred.
For other purposes: We may use your data for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving our Service, products, services, marketing and your experience.

2.2.2 Disclosing your Personal Data to Third Parties
Trasferium may share your personal data in the following situations:

With Service Providers: We may share your personal data with Service Providers to monitor and analyze the use of our Service, to contact you.
With Affiliates: We may share your data with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with us. Our contracts require these service providers to only use your data in connection with the services they perform for us and prohibit them from sharing your data with anyone else.
With Business Partners: We may share your data with our business partners to offer you certain products, services or promotions. This includes Financial institutions which we partner with to process payments you have authorized.
Business Transfers: If we are involved in a merger, acquisition or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different Privacy Policy
Law enforcement: Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency)
Other legal requirements: We may disclose your personal data in the good faith belief that such action is necessary to:
Comply with a legal obligation
Protect and defend our rights or property
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability
With your consent: We may disclose your personal data for any other purpose with your consent.

3. Transfer of Your Personal Data

Your personal data is processed at Trasferium’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Trasferium will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

4. Retention of Your Personal Data

Trasferium will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

5. Security of Your Personal Data

The security of your personal data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

Trasferium implement and maintains reasonable measures to protect our information and information systems. Customer files are protected with safeguards according to the sensitivity of the relevant information. Reasonable controls (such as restricted access) are placed on our computer systems. Physical access to areas where personal information is gathered, processed or stored is limited to authorised employees.

We may store and process all or part of your personal data and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers, anywhere in the world where our facilities or service providers are located. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.

As a condition of employment, Trasferium’s employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive personal information is limited to those employees who need to it to perform their roles. Unauthorised use or disclosure of confidential customer information by a Trasferium employee is prohibited and may result in disciplinary measures.

When you contact an Trasferium employee about your file, you may be asked for some personal details. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your file. You also play a vital role in protecting your own personal information; do not reveal personal data to any third-parties and immediately notify us if you become aware of any unauthorised access to or use of your account.

6. Children’s Personal Data

Trasferium does not knowingly request to collect personal data from any person under the age of 18. If a user submitting personal information is suspected of being younger than 18 years of age, Trasferium will require the user to close his or her account and will not allow the user to continue using our Services. We will also take steps to delete the data as soon as possible. Please notify us if you know of any individuals under the age of 18 using our Services so we can take action to prevent access to our Services.

7. Cross Border Transfers

Trasferium is an international business with worldwide operations. This means we may transfer to locations outside of your country. When we transfer your personal information to another country, we will ensure that any transfer of your personal information is compliant with applicable data protection law.

8. Your Privacy Rights

Depending on applicable law of where you reside, you may be able to assert certain rights related to your personal data These rights include:

the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
the right to withdraw your consent to the processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so. For example, we may need to retain personal information to comply with a legal obligation.
in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided directly to Trasferium;
the right to request that we rectify your personal data if it is inaccurate or incomplete;
the right to request that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data, but we are legally entitled to retain it;
the right to object to, or request that we restrict, our processing of your personal data in certain circumstances. There may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to refuse that request;
the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us;
You can exercise your rights by contacting us via email at support@trasferium.com. Further information about your rights may be obtained by contacting the supervisory data protection authority located in your jurisdiction.

9. Links to Other Websites
Our Service may contain links to other websites that are not operated by Trasferium. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

Trasferium has no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

10. Changes to this Privacy Policy
Trasferium may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.