Privacy and Cookies Policy

Privacy & Cookies Policy

Rampstarter

Last Updated: May 2024

This Privacy and Cookies Policy (the “Privacy Policy”) governs your use of Rampstarter’s content, features, products, and services (“Services”) branded as Rampstarter (“Rampstarter”, “we”, “our”, “us”) and encompasses your use of the website domain [www.rampstarter.com], any additional Rampstarter APIs, portal or mobile application (hereinafter collectively referred to as the “Platform”), and all documents, data, materials or other information made available on the Platform.

This Policy applies to all visitors, account holders and/or users (“User”, “you”, “your”) who act in their own personal capacity, or who are authorized to act on behalf of a corporate entity. Please read this Policy along with our Terms and Conditions carefully, and note that by using Rampstarter, you are consenting to the collection, storage, processing, and transfer of your Personal Data in accordance with this Privacy Policy.

Capitalized terms used in this Privacy Policy but not defined here, adopt the same meaning as described in our Terms and Conditions.

  1. Definitions

    1. Account” refers to the registered account opened by the User on the Platform.

    2. 2access” is an intermediary platform that operates as a unified sign-on system (SSO) enabling Users to access Third-Party Partner services and products offered on their respective platforms (the “Third-Party Partner Platforms”).

    3. Cookies” refers to a piece of information sent to your browser by a website you visit. You can set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it or otherwise. For further details on cookies, please visit All About Cookies.

    4. Third-Party Partner” means the service providers and Third-Parties with which we have service agreements to expand the range of Services and products accessible across our Platform to its Users and community members. However, each one is governed by their own terms and policies. We do not exercise any control or management over these Third-Party Partner websites. Users should display their own due diligence to read and understand each one of the legal documentation governing those products and Services.

    5. Personal Data” is defined as any information that relates directly or indirectly to a natural person whether living or deceased, who is identified or identifiable from that information, or from that and other information.

    6. Platform” refers to the domain www.rampstarter.com, its applications, and its subdomains. Any kind of redirection link to any kind of website and or platform controlled by Third Party Partner Websites is not covered by this Policy, therefore you agree to check the relevant privacy and cookies policy in place from the relevant Third Party Partner website.

    7. User” refers to any natural or legal person accessing and creating an Account on the Rampstarter Platform according to applicable terms and conditions, using any kind of technological device that allows reading, listening, and/or watching information on the Platform and/or interacting with this information in an active or passively way.

Depending on your location, this Policy might be available in languages other than English. In the event of any discrepancies between a translated version and an English version, the English version shall prevail.

  1. Purpose of the Policy

    1. We at Rampstarter know and understand how important it is for you to understand how we collect, store, process, share, and use your Personal Data.

    2. This Policy aims to outline the collection, processing, and management of Users' Personal Data through the Platform, which is crafted to deliver our Services while respecting and safeguarding the privacy of our Users' Personal Data within our Platform.

  2. Acceptance

    1. By accessing and using our Platform, you are consenting and accepting the terms of this Policy, the Terms and Conditions of the Service, and any other supplementing documentation provided related to the present document. If you do not agree or consent to receive our cookies, then this may in some cases preclude you from using our Platform, or Services, or negatively affect the display or function thereof.

    2. In any case, Rampstarter will not hold any responsibility for any errors, bugs, or malfunctions on the Platform regarding the information displayed and/or its functions, caused by your lack of consent to receive our cookies.

  3. User Login Credential Information

    1. To properly use our Platform, Users are required to create an Account through our Third-Party Partner, 2access. This process involves sharing your Personal Data not only with us but also with 2access, and any other third-party partner they collaborate with. Users should acknowledge that their responsibility encompasses reading and understanding the terms and conditions and privacy policies of each Third-Party Partner. Rampstarter does not have any discretion or control over the privacy practices of the Third-Party Partners.

    2. Users grant Rampstarter permission to use their data and information as required to create and maintain an Account on the Platform.

  4. Personal Information of the Users That We Collect and Process

    1. Some of your Personal Data is collected, processed, and stored with us in order to provide, develop, and enhance our products and Services including technical infrastructure, security, compliance, fraud prevention, and customer support, as well as to comply with our legal obligations. We are committed to exercising due diligence when dealing with every User and in the course of conducting business, we ensure that it is able to comply with all the applicable laws and regulations that are required to prevent the facilitation of money laundering and terrorist financing.

    2. Users’ Personal Data we collect and process is as follows:

Users’ Personal Information

Browser Information

Log Information

Full name

IP address

Device specific information

Date of birth

Login information

Location

Email address

Email address

System activity

Gender

Browser type and version

Uniform Resource Locator (URL)

Residence address

Time zone setting

Data collected via cookies

Nationality

Platform

Country code

Operating system

Contact number

Transaction history

Occupation and Employment Status

Pages accessed and links clicked

Referral activities on our Third-Party Partner Websites

Financial Information

Source of wealth

Credit card details

Bank account details, including institution name, branch, account name, bank identifier

Bank account number or IBAN

Passport or National ID details

Wallet address

  1. How Users’ Personal Data is Used

    1. To communicate with the User;

    2. To comply with legal and regulatory requirements;

    3. To detect and prevent fraud and credit risks;

    4. To provide, troubleshoot, and improve Rampstarter Services;

    5. To enforce the terms laid out in our Terms and Conditions;

    6. To provide customer Services;

    7. To ensure quality control;

    8. To ensure network and information security;

    9. To enhance and personalize User experience;

    10. To facilitate corporate acquisitions, mergers, or transactions;

    11. To engage in marketing activities;

    12. For Transaction Services;

    13. Purposes for which we seek User’s consent;

  2. Personal Data Storage and Transfer

    1. Personal Data is collected from wherever the User is located. We primarily store on our servers, and we may share the Personal Data with specific third parties, which include Third-Party Partners in accordance with our Terms and Conditions. Such sharing of data becomes essential for the effective delivery of our Services or in instances where a legal basis mandates such sharing. The aforementioned third parties are authorized to collect, utilize, and disclose your information as instructed by us. This ensures that the services provided are comprehensive and aligned with our standards.

    2. Your Personal Data may be subject to transfers between integrated Third-Party Partner Platforms based on the need to provide efficiency and better user experience to our community members. Your continued engagement with our Services signifies your acknowledgment and acceptance of this data transfer mechanism.

    3. The data we may share with our Third-Party Partners include:

      1. 2access User’s credentials

      2. KYC Country

      3. KYC Status

      4. Date of joining Rampstarter

      5. Wallet address details (chain, address, date of connecting)

    4. We further ensure that we comply with the applicable data protection regulations and we shall share information in the following circumstances:

      1. With competent legal or regulatory authorities. We are subject to various legal obligations and might be required to report or disclose your Personal Data when law or competent authorities require us to do so. The scope of the Personal Data disclosed depends on the authority’s request or the scope stipulated in the law. Such events include but are not limited to, events of suspicious activities or transactions such as any fraud, tax, money laundering, or terrorist financing activities or transactions such as any fraud, tax, money laundering, or terrorist financing activities. In certain cases, Rampstarter may be required to process your Personal Data for the purposes of pursuing, defending, or assisting in any claim, litigation or other proceedings related to you and such data might be disclosed to lawyers, courts, or other administrative bodies.

      2. With third-party KYC/AML service providers of Rampstarter to perform verification Services in the User onboarding process and in the ongoing transaction monitoring process. Rampstarter acquires the User’s information via Third Party Partners who conduct KYC/AML on behalf of Rampstarter.

      3. With service providers under contracts for operational purposes, for instance;

        1. Cloud storage;

        2. Network infrastructure;

        3. Transaction monitoring;

        4. Payment process;

        5. Security;

        6. Customer support;

        7. Marketing;

        8. Data analytics.

      4. With our affiliates or business partners as a general part of conducting business to offer, and improve, our Services.

      5. We transfer only the minimum amount of data necessary for a particular outsourced service provider(s) and we only cooperate with the outsourced service providers who can provide and ensure adequate level of Personal Data protection.

    5. Insofar as is reasonably practicable, Rampstarter ensures that the service providers and affiliates or business partners who process Personal Data on behalf of our Users, acknowledge the confidentiality of your Personal Data and protect your right to privacy by complying with all applicable privacy and data protection laws.

    6. Each Third-Party Partner website may have its own data transfer policies, terms of use, and privacy policies governing how your information is handled, processed, and shared. By continuing to use our Platform you acknowledge and agree to adhere to the data transfer policies of those Third-Party Partners and consent to the processing and transfer of your information outside of your country of residence as described in this policy. Additionally, you understand that the local data protection regulation may not offer the same extent of coverage or protection as the laws prevailing in your country of residence.

  3. Protection of Personal Data

    1. Rampstarter maintains physical, technical, administrative, and procedural safeguards in connection with the collection, storage, and disclosure of User’s Personal Data. We use firewall barriers, encryption techniques, and authentication procedures to maintain the security of User’s online sessions.

    2. You are requested to protect your account password from unauthorized access to avoid unnecessary authentication issues. To circumvent loss, misuse, unauthorized acquisition, or alteration of your data, also you are further requested to choose the strongest password and to protect the account privacy data from any third parties. In the event of unauthorized access, we insist you notify our support immediately.

  4. Data Retention

    1. We are responsible for retaining either the original or a precise copy of all data and information acquired from its Users. This retention will be in a format that is readily accessible for a five (5) year period following the conclusion of your involvement with our services, as well as those offered by our Third-Party Partner Websites on which our services are engaged. Any Personal Data provided by you will be securely maintained by us throughout the retention period. Variation in this period of retention might change based on the type of interaction of each User with the platform, products and services, and compliance with requirements from governmental authorities.

    2. We shall take reasonable measures to ensure that all Personal Data is destroyed or permanently deleted if it is no longer required to provide our services for which it was processed and in certain circumstances if required by law, we may not destroy any relevant records or Personal Data even though the prescribed period for retention shall have elapsed.

    3. When an investigation into a suspicious User or a suspicious transaction has been initiated and in the event of proceeding with the investigation in respect of the User, Rampstarter shall not destroy any relevant records even though the prescribed period for retention shall have elapsed by the reporting authority, for the reason that we are subjected to certain anti-money laundering laws.

    4. Furthermore, information or data collected via technical means such as cookies, web page counters, and other analytics tools is kept for a period of up to twelve months from the expiry of the Cookies Policy, as defined under Section 12.

  5. Data Protection Law

    1. This Policy is governed by and shall be construed under the data protection laws of the British Virgin Islands. Additionally, the highest standard of data protection, as outlined in the General Data Protection Regulation ("GDPR"), shall also apply to the processing of Personal Data covered by this Policy.

    2. If you are located in the European Economic Area (EEA), you will have the rights as described below under clause 11.

  6. Your Rights Protected Under GDPR

    1. Under certain circumstances, you have rights under data protection laws in relation to your Personal Data which are set out below:

      1. Request access - This enables you to receive copies of the Personal Data we hold about you and to check that we are lawfully processing it. This is also commonly known as a "data subject access request". This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us".

      2. Request erasure - This enables you to request us to delete or remove Personal Data where there is no good reason for us to continue to process it. Please note that there may be circumstances where we may be legally entitled to retain your Personal Data.

      3. Request to Restrict Processing- This enables you to object to the processing of your Personal Data, which is processed based on our legitimate interests. In the event of such an objection, we will no longer process your Personal Data, unless we demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defense of legal claims.

      4. Request to Object Processing - You have the right to object to the processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground, as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes.

      5. Request to transfer - We will provide you, or a third party you have authorized, with a copy of your Personal Data in a structured, commonly used, machine-readable format in order to transfer the data at your request. Note that this right only applies to automated information, which you initially provided consent for us to use, or where we used the information to perform a contract with you.

      6. Right to data rectification: This gives you the authority to request correction or amendment of your Personal Data. This right ensures that personal data is accurate, up-to-date, and complete. If you discover that your Personal Data is incorrect, incomplete, or outdated, you can exercise this right by submitting a formal request to us. We are then obligated to rectify the erroneous data without undue delay, considering the purposes of the processing. This right supports the accuracy and fairness of data processing and contributes to the overall integrity and reliability of the Personal Data collected and processed by us.

      7. You may withdraw any consent you previously provided to us for the purpose of receiving marketing or communication emails, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdraw your consent.

      8. If you are located in the European Economic Area (EEA), we will comply with applicable GDPR law when transferring your Personal Data outside of the EEA.

  7. Use of Cookies

    1. Whenever you visit our Platform, we will send a Cookie to the device you are using to access our Platform, which may place tracking technologies on your device, browser, or the webpage you are viewing, in order to personalize your experience, understand usage patterns, provide, improve, and secure our Platform. Your device automatically stores the Cookie in a file located within your browser allowing us to recognize your device upon future access. Cookies set by our operators are called “First party cookies”. Cookies set by parties other than our platforms are called “Third-party cookies”. Third-party cookies enable third-party features or functionality to be provided on or through the website for instance such as advertising, interactive content, and analytics.

    2. We use Cookies to:

      1. Optimize your trading experience, including remembering your preferences, location, preferred language, browser, and other details;

      2. Authenticate your identity for security purposes;

      3. Maintain our website and certain functions available on it;

      4. Analyse and track the use of our Services;

      5. Adjust our platform according to your trading habits and our regulatory requirements.

    3. We use the following Cookies to operate our Platform:

      1. Session Cookies are temporary and expire once you close your browser. It stores information for the time, or session when you are on our Platform;

      2. Persistent Cookies encompass all Cookies that remain on your hard drive until you erase them or your browser does. It depends on the Cookie’s expiration date. All persistent cookies have an expiration date written into their code, but their duration can vary;

      3. First-Party Cookies are put on your device directly by the Platform you are visiting;

      4. Third-Party Cookies are placed on your device, not by our Platform, but by a third party like an advertiser or an analytic system. Generally, Third-Party Cookies consist of tracking Cookies used to identify online behavior, understand interests, and then customize advertising for the User on other Platforms. Any information obtained from Third-Party Cookies is processed by the respective Collaborative Partners;

      5. Google Analytics Cookies to measure our User’s interactions with the content on our Platform. These cookies collect information about your interactions with our Platform, such as unique visits, repeat visits, session duration, and Platform activity;

      6. Facebook Pixel processes information about a User’s activity on our Platform, such as the Platform visited, Facebook identity, browser data, and more. The information processed from Facebook pixel is used to serve ads based on your interests through Facebook, as well as to measure cross-device conversions and User interactions on our Platform;

      7. Essential Cookies are known as strictly necessary Cookies for you to browse our Platform and use its features, such as accessing secure areas of our Platform. These Cookies are generally First-Party Session Cookies. These cookies do not require consent from you. Essential Cookies helps to make our Platform easy to use by providing basic functions such as page navigation, language selections, authorization, and filling in forms. Our Platform will not function without these Cookies and they cannot be disabled. These Cookies do not reveal the User’s identity or collect information. They are stored on the User’s device until the browser is closed;

      8. Functionality Cookies allow our Platform to remember choices you have made in the past like what language you prefer, what region you would like, or what username and password are so you can automatically log in. We use Cookies for navigation and to facilitate your access to and use of this site. These Cookies are necessary for the transmission of communications on the network or to supply Services whatever requested by you. Further, they help us to know which pages are the most and least popular and see how visitors move around the Platform;

      9. Performance Cookies collect information about how you use our Platform, like which page you visited and which link you clicked on. None of this type of information can be used to identify you. The sole purpose of performance cookies is to improve our Platform functions. Analytics may collect information through log data, such as; (i) IP address, (ii) Type of browser and device, (iii) Operating system, (iv) Name of the Internet Service Provider, (v) Country information, (vi) Date and time of visit, (vii) Web page origin and exit.

      10. Marketing Cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an advertisement. These Cookies can share information with other organizations or advertisers. These cookies may be set through the Platform by our advertising partners. If you do not allow these cookies, you will experience less targeted advertising. These cookies are set on your device for up to two (2) years or deleted if you erase your browser cookie data.

    4. You reserve the right to decide whether to accept or reject Cookies from our Platform. You can exercise your Cookie rights by setting your preferences in the Cookie Consent Manager. However, you will not be able to reject the Essential Cookies and still access the Platform, as they are strictly necessary to provide you with our Services. Should you opt to decline Cookies, you retain the option to utilize our Platform; however, access to certain functionalities and areas may be limited. You can configure or modify your web browser settings to accept or reject Cookies. Exercise caution when rejecting or disabling Cookies, as it may impact the functionality of our Platform. Consequently, it is advisable not to disable Cookies.

  8. Privacy Terms in Using Digital Assets and Blockchain Technology

    1. The digital assets and/or digital tokens are recorded on a public blockchain. It is a ledger which means a chain of blocks where each block contains the recording of any data transmission. Blockchains are decentralized or third-party networks that are not controlled or operated by any Third-Party Partner service provider affiliates or business partners of Rampstarter, and we have no access or authority to erase, modify, or alter any personal data that could be available in such networks.

    2. We make no claims to ensure the protection of such data that utilizes blockchain technology, and we bear no liability for breaches of such data should they occur.

    3. By using the Platform, you expressly acknowledge and accept that the data on the blockchain is irreversible and you consent to the permanent record of data being stored on such a blockchain.

  9. Modifications

    1. We reserve the right, at our sole discretion, to modify, amend, supplement, or replace this Policy at any time and such update details shall be indicated at the top of this page. Our Platform Policies and Terms may be revised or updated periodically to meet the necessary requirements and standards. We encourage you to regularly visit our Platform to stay informed about any changes to these Policies and the Terms. Your continued access to the Platform means that you agree to the updated content and to abide by the updated Policy.

  10. Contact Information

    1. In the event of any comments, questions, inquiries, or complaints regarding this Policy, the User has the right to submit questions and/or concerns, by raising a ticket via the Platform or by contacting [support@rampstarter.com].

Last updated