Who we are
BayChange is operated by [Company legal name], registered in [Jurisdiction] under number [Registration number], at [Registered address] (“we”, “us”). We decide how and why your personal data is used, so we are the data controller.
Privacy questions: [privacy@baychange.com]. [Data protection officer or local representative, if required].
What this policy covers
This policy covers baychange.com and the tools on it: quotes, orders, order tracking and support. It is part of our Terms of Use. It doesn't cover the Protocols that execute swaps, blockchains, block explorers, or the wallets and exchanges you use — they have their own privacy policies.
What we collect
Order details
The asset and network you send and receive; amounts; your payout and refund addresses; the deposit address; the order ID; hashes of the deposit, payout and any refund transactions; the route; the order status and timestamps.
Screening results
The outcome of checking your payout and refund addresses — and, where possible, the address you sent from — against sanctions lists and blocklists: the address, the result, the sources checked and the time.
Location and technical data
Your IP address, which we use to determine your country; browser and device information that your browser sends automatically; and request logs used for security and to limit abuse.
Email address (optional)
If you enter it — when you create an order or later on the order page — we use it only to email you about that order: when your deposit arrives, and when the exchange is done or your coins are returned. We don't email you if the order expires without a deposit, and we never use the address for marketing. You don't need an account, and one order has one address: you can change or remove it on the order page at any time, or unsubscribe with the link in any of these emails. The order page shows only a masked version of the address (for example, j•••@gmail.com), so someone with your order link can't see it.
To avoid sending the same update twice, we keep a short record of which updates were sent for an order — the order number, the type of update and the time, without the email address. To limit abuse, we count how often an address is added to orders using a keyed hash, not the address itself.
Support messages
What you write to us by email or in the support chat, your email address, the order number if you add it, and any details you choose to share. For the chat we keep a salted hash of your IP address for up to 2 days to limit spam; we don't store the IP address itself. When you email any of our addresses, we keep the whole message as it arrives — the sender and recipient addresses, the subject, date and other headers, the text and any attachments — together with our replies.
Account (optional)
If you create an account: your email address; a sign-in session, kept as a cookie on your device and as a hash of it on our side; the orders you start while signed in; and your points and level. One-time sign-in codes are stored only as a hash and expire after 10 minutes. To stop abuse of sign-in, we count requests per email address and per IP address using keyed hashes, not the email or IP address itself.
Partner program (optional)
If you join it: your partner code, the orders made through your link or widget, your earnings, and the payout address and transactions of the payouts you request. We screen payout addresses like any other address. Every time a payout is requested, we email your account address with the amount and the last characters of the payout address, so you can stop a payout you didn't ask for.
If you open BayChange through a partner's link or widget, we record the partner's code with your order so we can credit the partner. The partner sees the date, coins, amount in US dollars and status of the exchange — not your addresses, email or order number. A partner's page that shows our widget receives the order number when you create an order there.
What we don't collect
- Your name, date of birth, ID documents, phone number or bank details.
- Private keys or recovery phrases. We will never ask for them.
- Access to your funds. If you connect a wallet, the page sees only its public address; every transfer is shown to you and signed by you in your wallet. We don't store which wallet you connected on our servers.
Why we use it
| Purpose | Data | Legal basis |
|---|---|---|
| Create and run your order, show its status | Order details; email, if given | Performance of a contract |
| Email you updates about your order, if you ask for them | Email, order number, status, amounts, the last characters of your addresses | Performance of a contract; you can stop it at any time |
| Warn partners about payout requests, to protect their earnings | Account email, payout amount, coin, last characters of the payout address | Legitimate interests in keeping accounts secure |
| Screen addresses against sanctions lists and prevent financial crime | Addresses, screening results, country | Legal obligation; legitimate interests in keeping the Service from being used for crime |
| Block access from restricted regions | IP address, country | Legal obligation; legitimate interests |
| Keep the Service secure and prevent abuse | IP address, technical data, logs | Legitimate interests |
| Run your optional account: sign-in, points, levels and fee discounts | Email, sign-in session, orders linked to the account, points | Performance of a contract |
| Run the partner program: credit and pay partners, prevent abuse | Partner code on orders, earnings, payout addresses | Performance of a contract; legitimate interests |
| Answer support requests and complaints | Messages, order details | Performance of a contract; legitimate interests |
| Keep records required by law and respond to lawful requests | Order details, screening results | Legal obligation |
| Understand how the Service is used, in aggregate | Aggregated order data, not linked to individuals | Legitimate interests |
Legal bases follow the GDPR model and will be adapted to [applicable data protection law].
We don't use your data for advertising or build profiles about you. One decision is automated: if an address matches a sanctions list, we don't create the order. You can ask us to review that decision — see the AML & Sanctions Policy.
Public blockchain data
Addresses, amounts and transactions are recorded on public blockchains and on the Protocol's own public ledger. Anyone can see them, and nobody — including us — can change or delete them. The Protocol's ledger also shows which deposit led to which payout.
Your rights to correct or delete data don't extend to data recorded on a blockchain.
How long we keep it
| Data | How long we keep it |
|---|---|
| Order details and screening results | [5 years] after the order, to meet record-keeping duties and handle disputes |
| Email address for order updates | Deleted [90 days] after the order ends (completed, refunded, failed or expired), and in any case no later than 92 days after the order was created. Deleted straight away if you remove it on the order page or unsubscribe. |
| Record of order emails sent (no email address) | 90 days |
| Country linked to an order | As long as the order record |
| IP addresses in security and server logs | Up to [30 days]. We don't store your IP address with your order. |
| Support chat messages | Deleted 90 days after the last message |
| Emails to our addresses, and our replies | Deleted 1 year after each message is received or sent, or earlier if we delete it |
| Account email, points and level | While your account exists. When you delete it, we delete the email, sessions and points straight away; your orders are kept as above but no longer linked to you. Accounts without sign-in for [3 years] are deleted. |
| Sign-in codes | 10 minutes, or until used |
| Sign-in sessions | 30 days after your last visit, or until you sign out |
| Sign-in limit counters (keyed hashes of email and IP address) | About 2 hours |
| Partner payout records | [5 years] after the payout, for accounting — also after the account is deleted, but without the email |
| Settings stored on your device | Until you clear them |
We may keep data longer if the law requires it, or if it's needed for a legal claim or an investigation.
International transfers
Our providers may process data outside your country, including in [countries]. Where the law requires, we protect these transfers with [safeguards, for example Standard Contractual Clauses].
Your rights
Depending on where you live, you may have the right to:
- get a copy of your personal data;
- correct data that is wrong;
- ask us to delete it;
- restrict or object to how we use it;
- receive it in a portable format;
- complain to a data protection authority — [lead supervisory authority] or the authority where you live.
How to ask
If you have an account, you can see your data in it and delete the account yourself on the account page. For anything else, write to [privacy@baychange.com] and include your order ID. Most orders are made without an account, so we may ask you to show the order is yours — for example, by writing from the email address used on the order, or by confirming details only the sender would know. We reply within [30 days].
Limits
We can't delete records the law requires us to keep, such as order and screening records, until the retention period ends. We can't change data recorded on a blockchain.
Security
We use encryption in transit (HTTPS), limit access to the people who need it, and keep only the data we need. No system is perfectly secure. If a data breach affects you, we'll tell you and the authorities where the law requires.
Children
The Service is not for anyone under 18. We don't knowingly collect data from children. If you believe a child has used the Service, contact us and we'll delete what we can.
Changes to this policy
We may update this policy. We'll publish the new version on this page with a new “Last updated” date. If a change significantly affects how we use data we already hold, we'll explain it on this page before it applies.
Contact
- Privacy questions and requests: [privacy@baychange.com]
- Post: [Company legal name], [Registered address]
See also: Your rights · Terms of Use · AML & Sanctions Policy
