Manimama Exchange (“Company”, “we”, “us”, and “our”) is represented by two companies:
- UAB Manimama Exchange, a company number 305935776, registered address at: Eišiškių Sodų 18-oji g. 11, LT-02194, Vilnius, an authorized virtual currency exchange and virtual currency wallet operator in Lithuania;
- BURVIX SP. Z O. O. a company number 0001131882, registered address at: ul. Stefana Batorego, nr 18, lok. 108, Warsaw, kod 02-591, an authorized virtual currency exchange and virtual currency wallet operator in Poland.
The Privacy Policy (“Policy“) outlines the practices of UAB Manimama Exchange and BURVIX SP. Z O. O. regarding the collection, handling, utilization, storage, and sharing of personal data. We care about the privacy of your data and are committed to protect it.
This Policy applies whenever individuals visit or interact with the Company’s official website, available at https://manimama.exchange/ (“Website“).
As an authorized operator, the Company provides several types of services (“Services”), in particular: Over-the-Counter trading services which are provided with the help of the OTC project – Manimama Exchange and Algorithmic Trading Bots services which are provided with the help of Burvix Traders Platform. The Company emphasizes that this Policy also applies to cases when you access or use the OTC platform and/or the Burvix Platform.
This Policy has been developed by the Company in compliance with the requirements set forth by the General Data Protection Regulation (“GDPR“), the Law of the Republic of Lithuania “On the Legal Protection of Personal Data” and other relevant laws.
The Company upholds the privacy of all individuals who use the Website, guaranteeing that their personal data is handled with utmost discretion and in full compliance with relevant laws and regulations.
The Company also advises that by visiting, accessing, or using the Website, OTC Platform, and/or Burvix Platform, individuals confirm that they have carefully reviewed, understood, and agreed to all of the provisions set out in this Policy.
If any aspect of the Policy is deemed unacceptable, the Company strongly recommends that you refrain from accessing the Website and using our Services in any way.
The Privacy Policy outlines the following information:
- legal framework governing the company’s collection of personal data;
- core values of personal data processing;
- sources of personal data;
- personal data that we collect;
- personal data we do not collect;
- individual rights concerning personal data;
- purpose behind information collection and usage;
- disclosure of personal data;
- international transfer of personal data;
- security of data;
- personal data retention;
- advertising;
- review and update the policy.
If you have any questions regarding this Privacy Policy, please contact us at info@manimama.exchange
1. LEGAL FRAMEWORK GOVERNING THE COMPANY’S COLLECTION OF PERSONAL DATA
Following the strict rules established by the legislation on personal data protection, for the purposes of this Policy, the concept of personal data is defined in accordance with Art. 4 of the GDPR, which states that such information may include “any information relating to an identified or identifiable natural person (“data subject“); an identifiable natural person means a person who can be identified, directly or indirectly, in particular by means of an identifier such as a name, an identification number, location data, an online identifier or by one or more factors relating to physical, physiological, genetic, mental, economic, cultural or social conditions”.
In accordance with the provisions of Article 6(1) of the GDPR, the Company emphasizes that personal data is processed strictly under the following conditions:
- The data subject has explicitly provided consent for their personal data to be processed for one or more specified purposes.
- Processing is essential for fulfilling a contractual obligation involving the data subject or for taking preliminary steps at their request prior to entering into a contract.
- The Company processes personal data to meet legal obligations to which it is bound.
- Processing is required to safeguard the vital interests of the data subject or another individual.
- Data processing is necessary to perform a task in the public interest or to exercise official authority legally conferred upon the Company.
- The processing is carried out to serve the legitimate interests of the Company or a third party, provided these interests do not override the fundamental rights, freedoms, or interests of the data subject that warrant the protection of personal data.
This approach ensures compliance with applicable legal frameworks while safeguarding the rights of individuals.
2. CORE VALUES OF PERSONAL DATA PROCESSING
When handling your personal data, the Company follows these guiding principles:
- Pertinence and appropriateness – personal data must be suitable and sufficient for the purposes of processing, ensuring that it is not excessive in relation to the intended objectives.
- Purpose limitation – personal data is gathered for specific, clear, and lawful purposes. It will not be processed in ways that conflict with these initial objectives.
- Legality and integrity – the processing of personal data is conducted in compliance with legal standards and is carried out fairly.
- Accuracy – personal data should be correct and, where necessary, updated. Reasonable efforts will be made to ensure that inaccurate data is promptly corrected or deleted, especially if it no longer aligns with the processing goals.
- Data retention – personal data is kept only for as long as necessary to fulfill the purposes for which it was collected, and will not be stored in a way that allows the identification of individuals once those purposes have been achieved.
- Privacy and data protection – personal data is processed with adequate security measures to protect it from unauthorized access, unlawful processing, or accidental loss, damage, or destruction, through the implementation of suitable technical or organizational safeguards.
In addition to these principles, the Company is committed to openness and accountability in all aspects of data processing. Regular audits and assessments are conducted to ensure that data processing practices are consistent with these principles and that the Company continues to maintain the highest standards of data protection. The company remains vigilant in adapting to new challenges and regulatory developments, ensuring that all measures are in place to protect personal data in an ever-changing digital landscape. This approach fosters trust and promotes a safe environment for users interacting with the Website.
3. SOURCES OF PERSONAL DATA
Personal data is any information relating to an identified or identifiable natural person as mentioned in Article 4(1) of the GDPR.
To provide users with the best possible experience, the Company collects personal data from a variety of sources during its operations. This multi-source approach allows the Company to gain a deeper understanding of user needs, customize its Services, and enhance overall interactions with its Website.
Generally, you provide us with your information in person by interacting with us directly:
- by visiting our website;
- by using any of our Services;
- when you give us any feedback or contact us.
In addition, we will also rely on third parties and/or public sources to receive data relating to you. Any of the below sources may be used by us:
- public authorities;
- publicly available information;
- fraud and crime prevention agencies;
- public blockchain.
By combining data from these different sources, the Company strives to offer a seamless and customized experience while ensuring compliance with relevant privacy laws and regulations.
4. PERSONAL DATA THAT WE COLLECT
Manimama Exchange is committed to being transparent and compliant with privacy regulations. It ensures that users are well-informed about the personal data collected and the purposes for which this data is processed.
Manimama Exchange collects your personal data when you use our site. Failure to submit the required information and documents or provision of incorrect or incomplete information and documents, or failure to comply with our other requests will result in our services being unavailable to you.
There are two types of information you may provide to us when you visit the Manimama Exchange site:
- personal data that you voluntarily share; and
- data collected automatically when you use our Website or our Services.
We will exclusively collect and process data for specific and lawful purposes, and only to the extent that is appropriate and necessary for fulfilling the purposes outlined in this Privacy Policy. These purposes include providing services to you and/or meeting legal obligations.
The Company collects the following personal data:
- Personal data you provide us during the registration process: e-mail.
- Personal data we collect through verification flow: name, surname, date of birth, passport or another personal ID, tax number, address, proof of address, information about source of funds, source of wealth, liveness check and selfie.
- Personal data we collect through our Telegram Support: Telegram nickname; phone number (if any); photo of your account (if any); correspondence with you, for example, screenshots.
- The personal information gathered when you settle an invoice includes your: name and surname; address.
- The personal information submitted for payment purposes: crypto wallet address, bank account details.
- Personal data we collect through your use of our Website: device information such as operating system, unique device identifiers, the mobile network system; browser settings; date and time of visits; he pages you visit, the length of the visit, your interactions with the page (such as scrolling, clicks and mouse-overs), methods to browse away from our website, and search engine terms you use; IP address.
5. PERSONAL DATA WE DO NOT COLLECT
The Company would like to clarify that it does not collect or process special categories of personal data:
- Sensitive information such as racial or ethnic origin, political opinions, religious, philosophical, or other beliefs, trade union membership, as well as data related to an individual’s health, sexual life, or criminal convictions.
- Information about children under the age of 18. Our Website and Services are not intended for use by minors or children. Your use of our Website and Services is a representation that you have the legal capacity to form a binding contract. If we become aware that we have collected personal data from children without confirmation of parental consent, we will take steps to delete such information.
If you find out that Manimama Exchange has collected such type of information, please contact us directly info@manimama.exchange without delay and request its deletion.
6. INDIVIDUAL RIGHTS CONCERNING PERSONAL DATA
In line with GDPR and other relevant data protection laws, Manimama Exchange acknowledges and respects individuals’ fundamental rights regarding their personal data.
There are such individual rights that you have with regard to the personal data we collect and process about you:
- Individual has the right to access your personal data: you are entitled to obtain information about the sources and types of personal data we have collected from you, why we process it, and the data recipients to whom the data is or was disclosed at least within the past year; thus, it is your right to request a copy of your personal data that we process. The first copy will be supplied for free and all following copies will be subject to a charge adequate to cover our costs of producing them.
- Individual has the right to request information: you can communicate with us to confirm that we process your personal data and to find out which categories of your personal data we process; the purpose of the processing; where we obtained your personal data, if we did not receive the personal data from you; who we transfer your personal data to and/or categories of such recipients; the retention period for the personal data, or, in the event that it is not possible to specify the exact period, the criteria by which you can identify it.
- Individual has the right to request the correction of inaccurate personal data: you have the right to request us to correct your personal data that you find to be inaccurate. In case you consider your data to be incomplete, you also have the right to ask us to supplement your data by giving us the missing information.
- Individual has the right to object to the processing of personal data: where the processing of your personal data is based on another legal basis than consent, you have the right to object to it, and in such a case you must give us written notification of your objection to the processing of personal data. We will immediately stop processing your personal data if your objection is legally justified, except as provided by law. Where the basis for the processing of personal data is legitimate interest, we may continue to process personal data only if such processing does not breach your right to privacy and protection of personal data.
- Individual has the right to withdraw your consent to the processing of personal data: if consent was the basis for the processing of your personal data, you have the right to withdraw such consent at any time. Such withdrawal will not impact the lawfulness of the processing that preceded the withdrawal. But it will likely affect the services we can provide to you. As an example, where we need your consent to provide certain services, once you withdraw it, we may no longer be able to provide those services to you.
- Individual has the right to request a restriction on the processing of his personal data under certain conditions:
- if the accuracy of the personal data is disputed, for a period that allows the Company to verify its accuracy;
- in cases of unlawful processing, when you oppose erasure and request the limitation of data usage;
- when personal data is no longer necessary for the processing purposes but is required for establishing, exercising, or defending legal claims;
- if you have objected to the processing, pending the verification of whether the Company’s legitimate grounds override your interests.
- Individual has the right to receive personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller without hindrance from the Company: this right applies when the processing is based on the user’s consent; the processing is carried out by automated means.
- Individual has the right to request the deletion of their personal data without undue delay (“right to be forgotten”): the Company is obligated to erase personal data without delay under the following circumstances:
- the data is no longer needed for the purposes for which it was originally collected or processed;
- you have withdrawn your consent, and there is no other legal reason to continue processing the data;
- the personal data has been processed unlawfully;
- you have objected to the processing, and there are no overriding legitimate grounds to continue.
- Individual has the right to file a complaint: if you find that we have breached your rights, you are recommended to contact us at info@manimama.exchange in the first instance so that we can try to resolve your issue or dispute in an informal manner. Additionally, users have the right to file a complaint with the relevant supervisory authority.
We encourage users to familiarise themselves with their rights as described in this section and to contact the Company with any questions, concerns or requests regarding the processing of their personal data. Manimama Exchange is committed to ensuring the protection of personal data and to resolving any issues that may arise in the course of its processing.
The Company aims to address all inquiries promptly, usually within one month. However, if additional time is needed due to the complexity of the request, the response time may be extended by up to two months. In such cases, Manimama Exchange will notify the individual within one month of receiving the request. To verify the identity of the requester, the Company may ask for an identity document in accordance with applicable legal requirements.
7. PURPOSE BEHIND INFORMATION COLLECTION AND USAGE
Manimama Exchange only collects personal data that is necessary to provide the services requested by users that you request. The main purpose of collecting this data is to ensure the safe, efficient and uninterrupted provision of services.
We are committed to transparency and accountability in our data processing activities and adhere to the highest standards of data protection and privacy compliance.
Personal data is collected and processed strictly for the following legitimate purposes:
- to protect the integrity and security of the Website including addressing security risks, verifying identities or access, and ensuring compliance with relevant security regulations;
- to detect, prevent, and report suspicious, fraudulent, or unlawful activities;
- to maintain, support, and enhance the functionality of the Website;
- to fulfill our legal obligations and protect our legitimate interests where necessary;
- to monitor and evaluate business performance, improve operational efficiency, and generate internal reports;
- to facilitate communication by responding to user requests and keeping users informed about important security issues, upgrades, and relevant suggestions;
- to send marketing content in line with the user’s preferences for promotional material.
8. DISCLOSURE OF PERSONAL DATA
Manimama Exchange may disclose your personal data to comply with legal obligations, respond to requests from governmental or public authorities, or as part of legal proceedings.
We provide third parties with the minimum amount of personal data necessary only to provide the required service. In particular, personal data may be disclosed to the following parties:
- our present or future parent companies, subsidiaries, affiliates and other companies that are under common ownership or control with us or our international offices;
- law enforcement agencies (courts, prosecuting authorities), public authorities (tax authorities, banks), etc.;
- in connection with auditing;
- fraud or crime prevention agencies to assist in combating crimes, which include fraud, money laundering and terrorist financing.
We may also disclose your personal data if we determine that such disclosure is necessary or appropriate for national security, law enforcement or other socially important reasons.
Whenever possible, we will notify you in advance before making any such disclosures.
9. INTERNATIONAL TRANSFER OF PERSONAL DATA
When using the Company’s Services, you provide consent for your data to be transferred to other countries, including those with privacy and data protection laws that may differ from the regulations in their home country. In such cases, the Company commits to safeguarding and processing personal data in accordance with the provisions outlined in this Policy.
10. SECURITY OF DATA
Manimama Exchange takes the necessary measures to ensure that the level of security is appropriate to the risks associated with the processing of personal data. The Company’s primary objective is to protect personal information collected through its platforms from unauthorized access or interference by third parties not affiliated with the Company. To achieve this, the Company employs a variety of electronic, administrative, and technical measures to ensure that only authorized employees have access to personal data. These employees are also required to maintain confidentiality to further protect the data.
In addition, we utilize encryption to protect personal information and ensure our security during both transmission and storage. Personally identifiable data is securely stored either on our own servers or, in some cases, on third-party servers located in protected data centers.
We implement reasonable measures to safeguard personal data. However, it is crucial to recognize that no method of Internet or email communication is entirely secure or error-free. Therefore, users are encouraged to exercise caution when transmitting sensitive information via email. Additionally, the Company cannot be held responsible for any breaches of privacy or security that may occur on third-party websites.
Manimama Exchange is committed to safeguarding your privacy while providing its Services. However, once you leave our Website through any external links, this Policy no longer applies. It is important to note that the Company does not endorse any third-party websites, products, or services linked from its platform. Therefore, users are encouraged to review the privacy policies of any third-party websites, products, or services to understand how they handle personal information. Manimama Exchange cannot be held responsible for the privacy practices of these external entities.
We may retain your personal data for longer than required by law if it is in our legitimate business interests and is not prohibited by law.
11. PERSONAL DATA RETENTION
We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected. This includes meeting legal, accounting, or reporting obligations, complying with Anti-Money Laundering regulations, and resolving disputes or legal claims. The retention period may vary depending on factors such as the type of data, its purpose, and applicable legal or operational requirements.
Additionally, in accordance with our legal and regulatory obligations, as well as international data retention standards, you consent to the storage of your personal data for the duration of our business relationship and for up to five years following its termination.
12. ADVERTISING
With your consent, the Company may use your personal information for marketing purposes. This includes sending you newsletters, promotional materials, and updates about new products and services. These communications are designed to enhance your experience and keep you informed about the Company’s latest offerings.
Additionally, we may share your personal data with marketing partners for purposes such as targeted advertising, analytics, and other promotional activities. However, you have the right to opt out of receiving marketing communications at any time. You can do this by following the opt-out links provided in the messages or by contacting us directly at email: info@manimama.exchange.
13. REVIEW AND UPDATE THE POLICY
The Company reserves the right to periodically update this Policy. Any changes will take effect once they are posted on this page. Notifications of such updates will be provided to you while using the services. If you continue to use the services within one week of receiving notice of the updates, it will be considered as your acceptance of the revised terms and your agreement to comply with the updated Policy. Should you disagree with any modifications, the Company asks you to cease using services of the Company.