The Privacy Statement applies to all processing of personal data within Nxchange B.V. and Stichting Escrow Nxchange (together: Nxchange). Nxchange ensures that it complies with all applicable privacy laws and regulations, including the General Data Protection Regulation (AVG), the Financial Supervision Act (WFT) and all other applicable codes of conduct and guidelines.

Nxchange considers it extremely important to deal with user data in a responsible manner. Personal data is carefully processed and protected. The Privacy Statement has been adjusted in line with the entry into force of the General Data Protection Regulation (AVG) as of May 25, 2018. In this statement you can read, among other things, what information Nxchange collects and why. You are not obliged to read this, but Nxchange recommends that you do so. You can read the Privacy Statement at www.nxchange.com at any time.

If changes occur in the law or in our services and products, these may affect the way in which Nxchange uses your personal data. In that case, the Privacy statement will be adjusted and Nxchange will inform you via the website.

Nxchange processes personal data and may share your personal data:

• with ABN AMRO Clearing (AACB). Your personal data is processed by AACB with the aim to open a Cash Trading Account (CTA) with AACB which is being used in combination with your securities account at Nxchange
• with Triple IT. Your personal data is stored by Triple IT, the external and ISO-certified data center, that Nxchange has made very strict agreements about privacy, security and continuity
• with Mailchimp to send out newsletters after you signed up for this
• with Gmail to provide support
• to improve the service to you. Nxchange stores data about users and their surfing behavior on the website in files, with the aim of analyzing this data in order to improve the website in such a way that Nxchange can further optimize its services. If you have given your consent, Nxchange can also use the information in question to keep you informed about interesting products and services, news, information about products and services from other departments of Nxchange, and products and services of business partners
• because the law says it must do so or to comply with our duty of care

When we refer to 'processing', this may mean the collection and / or the storage, modification, consultation, provision and deletion of personal data. The Privacy statement does not refer to company details since this type of data is not covered by the legal rules for privacy protection. However, the personal details of the ultimate beneficial owners (UBOs) and / or authorized representatives or employees of these companies is.

At the moment you open a Cash Trading Account (CTA) with ABN AMRO Clearing Bank N.V. (AACB) you become a customer of AACB and the privacy statement of AACB will be applicable. For your Cash Trading Account, ABN AMRO Clearing is the processor of your personal data. For more information about how ABN AMRO Clearing processes your data please visit: https://www.abnamro.com/clearing/en/product/privacy-statement-clearing

Do you have questions about this privacy statement? Then you can contact Nxchange, by post, via support@nxchange.com or by telephone at +31 (0)20-240 4360.

Nxchange B.V.
Herengracht 450
1017 CA, AMSTERDAM

What is personal data?

Personal data is all data that correspond to an identification or identifiable living natural person. For example, this can be your name and bank account number, but also data that can be linked to you, such as your telephone number or IP address.

Why does Nxchange collect personal data?

As a financial institution, Nxchange requires according to law your personal data to be able to offer its services to you. Think of name and address details, but also your bank account number, BSN and identity document. Nxchange obtains this information online via its customer portal or occasionally by letter or e-mail. In addition, Nxchange also collects information from its customers in order to optimize its services. Nxchange does this by using certain cookies. You also provide personal data when you visit the website. You can read more about cookies in the Nxchange Cookie Policy below. It is also possible that Nxchange receives your personal data from third parties. For example, Nxchange can consult registers (such as Chamber of Commerce) or public sources when you enter into an agreement with Nxchange.

On what grounds does Nxchange process data?

Nxchange does not just process your personal data for the sake of it. The law also stipulates that this is only allowed when there is a basis for the processing. Nxchange only processes your data on the basis of one or more of the following four points:

1. Rulebook

Nxchange needs your personal data for opening an Nxchange account and executing the Rulebook.

2. Law

Nxchange must comply with legal rules as a financial institution. Some examples of legal obligations that must be met: identification to prevent money laundering, fraud and terrorism registering data in the context of closing transactions reporting transactions on the platform requesting data for information reporting to the tax authorities

3. Agreement

If you make an agreement with Nxchange, we need certain personal data to be able to execute this agreement.

4. Justified interest

Nxchange may use your personal data if they have a legitimate interest in doing so. When Nxchange processes on the basis of the above mentions points, it makes a careful assessment of whether there is a legitimate interest for each processing category or processing case. This consideration must be demonstrably made. It makes this assessment, for example, when they want to process your data in order to make an efficiency improvement in its systems.

5. Permission

For the processing of data that Nxchange does not process on the basis of agreement or law, it needs your permission. You can think of personal data that are used to optimize its services, provide information services to relevant third parties, and support business partners of Nxchange, in order to provide more targeted and personalized services to users. For cookies, Nxchange requests permission through its website. See the Cookie Policy.

How does Nxchange deal with my personal data?

Because Nxchange processes important personal data, data protection of its account holders and other relationships have always been an important part of how it deals with personal data and how it organizes its processes. Nxchange provides appropriate technical and organizational measures to protect your personal data against loss or any form of unlawful processing, for example to prevent unauthorized persons having access to personal data. All Nxchange employees have a duty of confidentiality and process your data with great care. In addition, Nxchange has concluded a processor agreement with Triple IT that meets the recently amended laws and regulations. All personal data is treated strictly confidentially and, only if necessary, shared with a trusted third party with whom Nxchange has an agreement and / or obligation, such as Triple IT and the Tax Authorities. Nxchange will only provide the minimum data to an external party to be able to execute the agreement that it has with you. Nxchange can also share your personal data with, for example, a supervisor if required to do so.

How long is personal data stored?

Nxchange does not store your personal data longer than is necessary for achieving the aforementioned purposes or to comply with laws and regulations.

What rights do I have with regard to my personal data?

• Right to access personal data. You can request a copy of your personal data that Nxchange has. Nxchange will share it with you as soon as possible and in any case within four weeks.
• Right to adapt personal data. If you think that your personal data is not correct with us, you can change this via the customer portal on Nxchange.
• Right to limited processing. You can request Nxchange to have less personal data processed. Nxchange will agree to this if it is not obliged to process such personal data pursuant to an agreement or law.
• Right to data portability. This is the right not only to view your personal data, but also to receive it in a form that makes it easy for you to reuse or pass it on to another organization.
• Right of objection. In some cases you can object to the processing of your personal data. If Nxchange does not process the personal data on the basis of the law or an agreement with you, Nxchange will agree with you on which processing of which personal data will be discontinued.
• Right to delete personal data. You can request Nxchange to have your personal data removed from our systems. The extent to which Nxchange can meet such requests may depend on the type of information that the request sees. In most cases for example, Nxchange as a financial institution is legally obliged to keep your data for at least five to seven years.
• Right to withdraw consent. Insofar as Nxchange processes your personal data on the basis of your consent, you can always withdraw this consent.
• Right to file a complaint. If you have a complaint about the way in which Nxchange has processed your personal data, you can of course contact Nxchange. You can also submit a complaint to the Dutch Data Protection Authority when you think there is a violation of the law (www.autoriteitpersoonsgegevens.nl).

Nxchange is the administrator of www.nxchange.com (the website). Like many other websites, Nxchange uses 'cookies' in electronic services. You can set the browser to notify you when a cookie is placed or you can choose not to accept cookies, but this choice limits the possibilities of the website. The domain name under which cookies are stored is Nxchange.com. The validity of the cookies varies from the duration of your visit to the website to an unlimited period.

What are cookies?

A cookie is a small file that is stored on the hard disk of your computer, in order to recognize you when you visit the site again. A cookie has a unique number to which data can be linked. There are a few types of cookies: functional cookies and analytical cookies. Here you can read more about which cookies Nxchange uses and the purpose of the cookies.

Why does Nxchange use cookies?

Nxchange can use cookies for the following purposes:

• To be able to inform you about our services in a better and personal way
• To improve the website
• To analyze the use of the website

What kind of cookies does Nxchange use?

• Functional cookies

  We use these functional cookies to help us remember certain actions you undertake on our website. We also use these cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf. Functional cookies ensure that the website works properly. For example, you do not have to enter your login details every time. Nxchange also uses functional cookies to detect abuse of our website and services, for example by registering a number of consecutive unsuccessful log-in attempts.

• Analytical cookies

  These cookies help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We use the demographics and interest reporting of Google Analytics and IP addresses are processed for our functional and analytical cookies. The statistics and reports resulting from this can not be traced back to individuals.

How long do I consent to cookies?

Nxchange determines whether you have given permission to place a cookie. Every year you are asked again if you accept cookies. You can then again give your consent for the placing of cookies. This also applies to cookies that are valid for longer than 1 year.

Does Nxchange share my information from cookies with other parties?

Because Nxchange uses cookies from third parties (see section 'What type of cookies does Nxchange use?'), Nxchange shares your information from cookies with other parties.

Can I refuse cookies?

Do you not want Nxchange to place cookies on your computer? Then you have to adjust your browser settings. You will then receive a warning before cookies are placed. You can also set your browser to refuse all cookies or only cookies from third parties. Finally, you can delete cookies that have already been placed. Note that you must adjust the settings separately for each browser and computer you use.