Last updated: October 7th, 2022

A note on privacy from the Recap Team

Recap champions user privacy and places this at the centre of our design philosophy and decision making. We carefully choose partners that protect user privacy wherever we can, and we share the minimum data required to ensure that our services are delivered securely for our customers.

We encrypt all sensitive user data using your unique recovery-phrase, only you have access to this phrase meaning we have no way to decrypt your data. This approach means it's impossible for us to connect a users email address or other personally identifiable information with your transaction history.

In short (unless you choose to share your recovery-phrase with us) it's impossible for us to see your transaction data or link any trading history back to you.

Privacy and Cookie Policy

Recap Technologies Limited ("us", "we", or "our") operates the https://recap.io website and the Recap App (https://app.recap.io) (hereinafter collectively referred to as the "Service").

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://recap.io.

Definitions

  • Service is the website (https://recap.io) operated by Recap Technologies Limited and the Recap App (https://app.recap.io).
  • Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
  • Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Cookies are small files stored on your device (computer or mobile device).
  • Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
  • Data Processors (or Service Providers) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
  • Data Subject (or User) is any living individual who is using our Service and is the subject of Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

  • Email address
  • Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.

Usage Data

We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer'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.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our 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 portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

Use of Data

Recap Technologies Limited uses the collected data for various purposes:

  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Recap Technologies Limited legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Recap Technologies Limited may process your Personal Data because:

  • We need to perform a contract with you
  • You have given us permission to do so
  • The processing is in our legitimate interests and it is not overridden by your rights
  • To comply with the law

Retention of Data

Recap Technologies Limited 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.

Recap Technologies Limited 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 periods.

Transfer of Data

Your information, including Personal Data, 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 from those of your jurisdiction.

If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to United Kingdom and process it there.

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

Recap Technologies Limited will take all the 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.

Disclosure of Data

Legal Requirements

Recap Technologies Limited may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Recap Technologies Limited
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability.

Security of Data

The security of your 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.

Our Policy on "Do Not Track" Signals under the California Online Protection Act (CalOPPA)

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Recap Technologies Limited aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

  • The right to object. You have the right to object to our processing of your Personal Data.

  • The right of restriction. You have the right to request that we restrict the processing of your personal information.

  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

  • The right to withdraw consent. You also have the right to withdraw your consent at any time where Recap Technologies Limited relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyse the use of our Service.

  • Fathom Analytics (https://usefathom.com)

    Fathom is a privacy-focused web analytics service that tracks and reports website traffic. Fathom doesn’t collect personal data or use cookies.

    Visit https://usefathom.com/gdpr-ccpa-pecr-compliant to learn more about their approach.

Cloud services and Hosting

  • Amazon Web Services

    Amazon Web Services is used for operating the Recap website and supporting services. For more information about Amazon’s privacy practices, see their privacy page. https://aws.amazon.com/privacy/

  • Postmark

    Postmark is a transactional email service provided by Wildbit, LLC. Postmark handles all of Recap's transactional email. For more information about Postmark's privacy practices, see their privacy page. https://wildbit.com/privacy-policy .

  • Auth0

    We use Auth0 for authentication and user management. User emails, names and login details are stored on their EU infrastructure. For more information about Auth0's privacy practices, see their privacy page. https://auth0.com/privacy

  • Chargebee

    We use Chargebee for billing management. Prior to subscription payments this stores user emails and names, and upon subscription includes payment details. For more information about Chargebee's privacy practices, see their privacy page. https://www.chargebee.com/privacy/

  • Stripe

    We use Stripe for payment processing. Upon payment Stripe will store user emails, names, and payment details. For more information about Stripe's privacy practices, see their privacy page. https://stripe.com/en-gb/privacy-center/legal

  • PayPal

    We offer users the ability to pay using PayPal. If you opt to pay with PayPal, PayPal will store user emails, names, and payment details. For more information about PayPal's privacy practices, see their privacy page. https://www.paypal.com/uk/webapps/mpp/paypal-and-your-data

  • Covalent

    We use Covalent for blockchain address indexing. User wallet addresses are used to automatically retrieve transaction activity. For more information about Covalent's privacy practices, see their privacy page. https://www.covalenthq.com/privacy-policy/

  • Alchemy

    We use Alchemy for blockchain address indexing. User wallet addresses are used to automatically retrieve non fungible token metadata and images activity. For more information about Alchemy’s privacy practices, see their privacy page. https://www.alchemy.com/policies/terms

  • EtherScan

    We use EtherScan for blockchain address indexing. User wallet addresses are used to automatically retrieve on-chain transaction activity. For more information about EtherScan’s privacy practices, see their privacy page. https://etherscan.io/privacyPolicy

Error Reporting

  • Sentry

    We use Sentry, an error tracking tool from Functional Software Inc., 132 Hawthorne St, San Francisco, CA 94107, USA. To improve the accessibility and technical stability of our website by monitoring system stability and detecting code errors, we may automatically send the following information to Sentry in the event of a software failure:

    • Device information (operating system)
    • The IP address of the device
    • Email
    • Date and time of the error
    • The error body

    The legal basis of the aforementioned data processing is Art. 6(1) f) of the GDPR. There is no explicit analysis for advertising purposes in this process. The information that is collected is not used for personal reasons and is subsequently deleted. This analysis helps us continuously improve our application and fix hidden code errors. Such processing is in our legitimate interest because the data is used solely for identifying and analysing errors. For more information on Sentry’s data processing and how it works, see Sentry’s privacy policy: https://sentry.io/privacy/

Customer Engagement

  • Intercom

    We use Intercom to help understand your usage of our services. In particular, we provide a limited amount of your information (such as sign-up date and some personal information like your email address) to Intercom, Inc. (“Intercom”) and utilise Intercom to collect data for analytics purposes when you visit our website or use our product.

    As a data processor acting on our behalf, Intercom analyses your use of our website and/or product and tracks our relationship by way of cookies and similar technologies so that we can improve our service to you. For more information on Intercom’s use of cookies, please visit https://www.intercom.com/terms-and-policies#cookie-policy.

    We may also use Intercom as a medium for communications, either through email, or through messages within our product(s). As part of our service agreements, Intercom collects publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience.

    For more information on the privacy practices of Intercom, please visit https://www.intercom.com/terms-and-policies#privacy. Intercom’s services are governed by Intercom’s terms of use which can be found at https://www.intercom.com/terms-and-policies#terms . If you would like to opt out of having this information collected by or submitted to Intercom, please contact us.

  • Trustpilot

    We use Trustpilot to collect customer reviews of our products and services. In particular, we provide your email address to Trustpilot to enable them to contact you on our behalf and ask you to submit a review. We do not share any other data with Trustpilot.

    As a data processor acting on our behalf, Trustpilot may use cookies and similar technologies to provide their service to you. For information about Trustpilot’s privacy policy please visit https://uk.legal.trustpilot.com/for-businesses/business-privacy-policy.

Market Research

  • Google Forms

    We use Google Forms to better understand our customers though surveys.

    We never correlate answers to email addresses without explicit consent.

    As a data processor acting on our behalf, Google collects our forms results and tracks completion of the survey through cookies and local storage.

    For more information on Google’s use of cookies please visit https://policies.google.com/technologies/types?hl=en. For more information on the privacy practices of Google, please visit https://policies.google.com/privacy?hl=en.

    Google’s services are governed by Google terms of use which can be found at https://policies.google.com/terms?hl=en. If you would like to opt out of having this information collected by or submitted to Google please contact us.

Other

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click 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.

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

Children's Privacy

Our Service does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy

We 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 "effective 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.

Cookies Policy

Recap Technologies Limited ("us", "we", or "our") uses cookies on the https://recap.io website (the "Service"). By using the Service, you consent to the use of cookies.

Our Cookies Policy explains what cookies are, how we use cookies, how third-parties we may partner with may use cookies on the Service, your choices regarding cookies and further information about cookies.

What are cookies

Cookies are small pieces of text sent to your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you.

Cookies can be "persistent" or "session" cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.

How Recap Technologies Limited uses cookies

When you use and access the Service, we may place a number of cookies files in your web browser.

We use cookies for the following purposes:

  • To enable certain functions of the Service

  • To provide analytics

We use both session and persistent cookies on the Service and we use different types of cookies to run the Service:

  • Essential cookies. We may use cookies to remember information that changes the way the Service behaves or looks, such as a user's language preference on the Service.

  • Analytics cookies. We may use analytics cookies to track information how the Service is used so that we can make improvements. We may also use analytics cookies to test new advertisements, pages, features or new functionality of the Service to see how our users react to them.

Third-party cookies

In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on.

What are your choices regarding cookies

If you'd like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.

Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

Where can you find more information about cookies?

You can learn more about cookies at the following third-party websites:

Our details

This website is owned and operated by Recap Technologies Limited.

We are registered in England and Wales under registration number 11218777, and our registered office is at 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ.

Our principal place of business is at Office 4, Mosaic, Thomas Parker House, 13-14 Silver Street, Lincoln, LN21DY.

Contact Us

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

  • By email: dataprotection@recap.io