Privacy Policy

Last revised: Mar 8th 23 2:40:01 pm

EXD Privacy Policy

March, 6th, 2023 updated


EXD (“EXD”, “we”, or “us”) is committed to protecting the privacy of our customers, and we take our data protection responsibilities with the utmost seriousness.

This Privacy Policy describes how EXD collects and processes your personal information through the EXD websites that reference this Privacy Policy. EXD refers to an ecosystem comprising EXD websites, clients. 

“EXD Operators” refer to all parties that run EXD, including but not limited to legal persons, unincorporated organizations and teams that provide EXD Services and are responsible for such services. “EXD” as used in this Privacy Policy includes EXD Operators.

This Privacy Policy applies to all Personal Information processing activities carried out by us, across platforms, websites, and departments of EXD and EXD Operators.

To the extent that you are a customer or user of our services, this Privacy Policy applies together with any terms of business and other contractual documents, including but not limited to any agreements we may have with you.

To the extent that you are not a relevant stakeholder, customer or user of our services, but are using our website, this Privacy Policy also applies to you together with our Cookie Policy.



1. What personal information does EXD collect and process?


- email address;

- name;

- gender;

- date of birth;

- home address;

- phone number;

- nationality;

- device ID;

- a video recording of you and a photographic image;

- transactional information;

- the Internet protocol (IP) address used to connect your computer to the Internet;

- login, e-mail address, password and location of your device or computer;

- EXD Services metrics (e.g., the occurrences of technical errors, your interactions with service features and content, and your settings preferences);

- version and time zone settings;

- transaction history;

- Information from other sources: we may receive information about you from other sources such as credit history information from credit bureaus;

- Information about your activity we may process information about you on your behaviour and your activity for marketing and advertising purposes.


2. Why does EXD process my personal information?

- Transaction services. We use your personal information to process your orders, and to communicate with you about orders and services;

- Communicate with you. We use your personal information to communicate with you in relation to EXD Services;

- We collect and process identity information and Sensitive Personal Data (as detailed in section I) to comply with our Know Your Customer (“KYC”) obligations under applicable laws and regulations, and Anti-Money Laundering laws and regulations;

- Provide, troubleshoot, and improve EXD Services. We use your personal information to provide functionality, analyse performance, fix errors, and improve the usability and effectiveness of EXD Services.

- Fraud prevention and credit risks. We process personal information to prevent and detect fraud and abuse in order to protect the security of our users, EXD Services and others. We may also use scoring methods to assess and manage credit risks.

- Improve our services. We process personal information to improve our services and for you to have a better user experience;

- Recommendations and personalisation. We use your personal information to recommend features and services that might be of interest to you, identify your preferences, and personalise your experience with EXD Services;


* Legal Basis for our use of personal information (EU and UK GDPR)

Performance of a contract when we provide you with products or services, or communicate with you about them. This includes when we use your personal information to take and handle orders, and process payments.

Legal obligation; to comply with our legal obligations under applicable laws and regulations, and Anti-Money Laundering laws and regulations.

Your consent when we ask for your consent to process your personal information for a specific purpose that we communicate to you. When you consent to processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing your personal information for that purpose. 

The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.


Our legitimate interests and the interests of our users when, for example, we detect and prevent fraud and abuse in order to protect the security of our users, ourselves, or others;

Performance of a contract when we provide you with products or services, or communicate with you about them. This includes when we use your personal information to take and handle orders, and process payments.


3. Can Children Use EXD Services?

EXD does not allow anyone under the age of 18 to use EXD Services and does not knowingly collect personal information from children under 18.


4. What About Cookies and Other Identifiers?

We use cookies and similar tools to enhance your user experience, provide our services, enhance our marketing efforts and understand how customers use our services so we can make improvements. Depending on applicable laws in the region you are located in, the cookie banner on your browser will tell you how to accept or refuse cookies. 


5. Does EXD Share My Personal Information?

We may share your Personal Data with third parties if we believe that sharing your Personal Data is in accordance with, or required by, any contractual relationship with you or us, applicable law, regulation or legal process. 

We may share personal information with the following persons:

Third party service providers: We employ other companies and individuals to perform functions on our behalf. Examples include analysing data, providing marketing assistance, processing payments, transmitting content, and assessing and managing credit risk. These third-party service providers only have access to personal information needed to perform their functions, but may not use it for other purposes. 

Further, they must process the personal information in accordance with our contractual agreements and only as permitted by applicable data protection laws.

Legal Authorities: We may be required by law or by Court to disclose certain information about you or any engagement we may have with you to relevant regulatory, law enforcement and/or other competent authorities. We will disclose information about you to legal authorities to the extent we are obliged to do so according to the law. We may also need to share your information in order to enforce or apply our legal rights or to prevent fraud.

Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy (unless, of course, the user consents otherwise). Also, in the unlikely event that EXD or substantially all of its assets are acquired by a third party, user information will be one of the transferred assets.

Protection of EXD and others: We release accounts and other personal information when we believe release is appropriate to comply with the law or with our regulatory obligations; enforce or apply our Terms of Use and other agreements; or protect the rights, property or safety of EXD, our users or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction.


6. International transfers of Personal Information

To facilitate our global operations, EXD may transfer your personal information outside of the European Economic Area (“EEA”), UK and Switzerland. The EEA includes the European Union countries as well as Iceland, Liechtenstein, and Norway. Transfers outside of the EEA are sometimes referred to as “third country transfers”.

We may transfer your personal data within our Affiliates, third-party partners, and service providers based throughout the world. In cases where we intend to transfer personal data to third countries or international organisations outside of the EEA. EXD puts in place suitable technical, organizational and contractual safeguards (including Standard Contractual Clauses), 

to ensure that such transfer is carried out in compliance with applicable data protection rules, except where the country to which the personal information is transferred has already been determined by the European Commission to provide an adequate level of protection.

We also rely on decisions from the European Commission where they recognise that certain countries and territories outside of the European Economic Area ensure an adequate level of protection for personal information. These decisions are referred to as “adequacy decisions”. We transfer personal data to Japan on the basis of the Japanese Adequacy Decision.


7. How Secure is My Information?

We design our systems with your security and privacy in mind. We have appropriate security measures in place to prevent your information being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We work to protect the security of your personal information during transmission and while stored by using encryption protocols and softwares. 

We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personal information. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.

Our security procedures mean that we may ask you to verify your identity to protect you against unauthorised access to your account password. We recommend using a unique password for your EXD account that is not utilized for other online accounts and to sign off when you finish using a shared computer.


8. What About Advertising?

In order for us to provide you with the best user experience, we may share your personal information with our marketing partners for the purposes of targeting, modelling, and/or analytics as well as marketing and advertising. You have a right to object at any time to processing of your personal information for direct marketing purposes.


9. What Rights Do I Have?

Subject to applicable law, as outlined below, you have a number of rights in relation to your privacy and the protection of your personal information. You have the right to request access to, correct, and delete your personal information, and to ask for data portability. You may also object to our processing of your personal information or ask that we restrict the processing of your personal information in certain instances. 

In addition, when you consent to our processing of your personal information for a specified purpose, you may withdraw your consent at any time. If you want to exercise any of your rights, please contact us at 

These rights may be limited in some situations - for example, where we can demonstrate we have a legal requirement to process your personal data.

Right to access: you have the right to obtain confirmation that your personal information are processed and to obtain a copy of it as well as certain information related to its processing;

Right to rectify: you can request the rectification of your personal information which are inaccurate, and also add to it. You can also change your personal information in your Account at any time.

Right to delete: you can, in some cases, have your personal information deleted;

Right to object: you can object, for reasons relating to your particular situation, to the processing of your personal information. For instance, you have the right to object where we rely on legitimate interest or where we process your data for direct marketing purposes;

Right to restrict processing: You have the right, in certain cases, to temporarily restrict the processing of your personal information by us, provided there are valid grounds for doing so. We may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law;

Right to portability: in some cases, you can ask to receive your personal information which you have provided to us in a structured, commonly used and machine-readable format, or, when this is possible, that we communicate your personal information on your behalf directly to another data controller;

Right to withdraw your consent: for processing requiring your consent, you have the right to withdraw your consent at any time. Exercising this right does not affect the lawfulness of the processing based on the consent given before the withdrawal of the latter;

Right to lodge a complaint with the relevant data protection authority: We hope that we can satisfy any queries you may have about the way in which we process your personal information. However, if you have unresolved concerns, you also have the right to complain to the Irish Data Protection Commission or the data protection authority in the location in which you live, work or believe a data protection breach has occurred.

If you have any questions or objection as to how we collect and process your personal information, please contact

10. How Long Does EXD Keep My Personal Information?

We keep your personal information to enable your continued use of EXD Services, for as long as it is required in order to fulfil the relevant purposes described in this Privacy Policy, and as may be required by law such as for tax and accounting purposes, compliance with Anti-Money Laundering laws, or as otherwise communicated to you.


11. Contact Information

Our data protection officer can be contacted at, and will work to address any questions or issues that you have with respect to the collection and processing of your personal information.


12. Policies and Revisions

If you have any concerns about privacy at EXD, please contact us, and we will try to resolve it. Our business changes regularly, and our Privacy Policy may change also. You should check our websites frequently to see recent changes. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account.