Privacy policy

This privacy policy (“Policy”) describes how Avenir, a.k.a. Avenir Labs Inc.. (“Avenir” “Company”, “we”, “our”, “us”) collects, uses, shares, and stores personal information of users of this website, www.avenirapp.co/offramp (the “Site”) and users of the Avenir widget and API (together, the “Software”), which can be used to interact with various third parties that offer fiat-to-cryptocurrency conversion services (“Fiat Gateways”). Use of the Avenir widget, API, or any of the software components built by Avenir shall be further referred to as usage of the Software. By using the Software, you (the “End User” / “You”) accept the terms of this Privacy Policy and our Terms of Use, and consent to our processing, use, disclosure, and retention of your information as described in this Policy.

What Personal Information do we collect?

We do not currently collect any personally identifiable information from you directly. However, we still collect data that, while it doesn’t qualify as personally identifiable information, is treated with the highest standard of care. The (categories of) data we may, now, or in the future, process are:

• Transactional Data: information about your transaction history with Fiat Gateways, incl. the type of virtual financial assets involved, the order volume, price, value, and information on which bank is used for a transaction identified through the processing of a part of your credit card number. This does not include any Personally Identifiable Information.
• Information we collect automatically about how you use our Site and/or Software, (“Product Usage Data”), including information on the device(s) you may use (“Device Information”) and information on when, where and how you use our Site and/or Software, including your IP address and info such as your browser type (“Log Data”). For a more specific overview of what information is collected automatically, see the section named ‘Cookie Policy’ below.

The processing of any other data inserted by End-users when making use of services provided by Fiat Gateways is governed by the privacy policies of the individual Fiat Gateway(s) used by the End User. With regards to this data, Avenir does not act as a data controller.

While Avenir does not collect any personal information from you, the Fiat Gateways do, as covered by their privacy policies. Those Fiat Gateways may share data with Avenir. This can include your phone number, country, your email address and your name, but does not include credit card numbers or any other PAN or CVC data. To learn more about the data processing that occurs when making use of the services offered by Fiat Gateways, see Ramp’s privacy policy, TransFi’s privacy policy.

What do we use your data for?

We may process Usage Data, Transactional Data, Device Data, and Log Data for us to:

• perform user analytics to keep track of usage and better understand our users; carry out research and development to improve our Site and/or Software,
• identify IT or network issues,
• identify mal-intended usage of our Site and/or Software,
• manage our Site and/or Software, system administration, and security,
• provide actionable data insights to Business Users,
• improve the way Fiat Gateways are selected and shown to the users,
• prevent fraud, money laundering or unauthorized use of our Software, and
• to customize the content and layout of the Websites.

What is the legal basis for the processing of your data?

The processing of your Product Usage Data, Transactional Data, Device Information, and Log Data occurs for the purposes described above, based on our legitimate interests. These interests include improving, maintaining, providing and enhancing our Site and Software, our marketing interests, our need to contact Business Users with regards to use of our API/widget, our interests concerning ensuring the security of the Software and our Site, as well as our legitimate interest in being able to provide data insights to Business Users. We limit our collection of processing of data to what is necessary for these purposes, and this processing of personal information for our legitimate interests is not disproportionate to your data-protection interests, fundamental rights, and/or freedoms.