Privacy and Cookies Policy


Last updated: 14.08.2022


Our company Peer2Profit Ltd (CompanyWeUs) respects and values your (UserYou) privacy and does all possible to ensure the safety of Your Personal Data (as defined below).

In this Privacy and Cookies Policy (Policy), We provide information about the scope of Personal Data collected, explain why it is collected and how it is used, as well as identify the third parties to whom Your Personal Data may be transferred.

This Policy is an integral part of the Terms of Use published at 

Please carefully read this Policy and contact Us if You have any questions.


If any word used in the text of this document begins with a capital letter, it shall be construed as provided in this section.

We, Company

Peer2Profit Ltd


an aggregate of the information, web forms, software, and intellectual property (including computer software, databases, graphic interface design, content, etc.) belonging to the Company that is accessible from various Users' devices connected to the Internet through special software for viewing web pages (browser) under the domain "", including the domains of the following levels, which could be used by the Users for accessing their Accounts, interaction with the Platform and communication with the Company.


a Company’s software, including any software (source code and object code), programs, tools, libraries, APIs, data, files, Application specifications, and documentation, which could be used by the Users for sharing Internet bandwidth with the Company and other Users.


an aggregate of the Website and Application that belongs to the Company and could be utilized by the Users to share their Internet bandwidth with the Company and other Users based on a remuneration basis.


any person conforming to eligibility requirements provided herein that have accepted these Terms registered an Account on the Website and installed the Application.

Personal Data

generally means any information relating to an identified or identifiable person that Users provide to Us while using the Platform, including providing feedback, information that We automatically collect about Users, and information about Users that We receive from third parties.

Personal Data Processing or Processing

means a wide range of operations performed on Personal Data, including manual or automated collection, recording, organization, structuring, storage, adaptation or modification, retrieval, consultation, use, disclosure by transfer, dissemination or other provision, matching or aggregation, restriction, deletion or destruction of Personal Data.

If any terms used in this document are not defined above or in the rest of this document, such terms shall be interpreted according to the User Agreement, applicable laws, and regulations, and only as a last resort following a generally accepted practice.


Where You agree to all and any of the Policy provisions You can accept it by placing  next to the box “I have read and accept the terms of the Privacy and Cookies Policy” during Your Account registration on the Website.

In case You at any point do not agree with any provision of this Policy, You shall immediately stop using the Platform.

What Personal Data Do We Collect? 

In the course of Your use of the Platform, We may collect the following Personal Data:


Personal Data

Communication Data

  • Email address;
  • Telegram ID;
  • Phone number;
  • Other contact details that You use to contact Us.

Registration Data

If You fill in the form:

  • Email address

If You log in through Your Google account or accounts from other third-party services:

  • Email address;
  • Other information that We are allowed to get access to according to the privacy settings on Your Google account or accounts from other third parties services.

Automatically Collected Data 

Technical information: 

  • The internet protocol (IP) address; 
  • Browser type and version;
  • Time zone setting; 
  • Browser plug-in types and versions;
  • Operating system and platform.

Usage Data: 

  • Uniform Resource Locators (URL) clickstream to, through, and from the Website (including date and time);
  • Services/information User viewed or searched for; 
  • Login history;
  • Referrals to domains;
  • Volume of traffic;
  • Page response times;
  • Download errors; 
  • Time of visits to certain pages;
  • Click-stream data;
  • Methods used to browse away from the page;
  • other data collected via cookies and similar technologies. 

Enhanced Verification Data

The data You provide to Us at Our request and(or) request of the Verification Services based on requirements imposed to Us by third parties (including regulatory authorities), and requests initiated by Us and(or) Verification Services to verify compliance with the Terms and statutory regulations.


We are constantly developing the Platform and may add new features, to get access to which You may be asked to provide Us with additional information.

You provide Us with any Personal Data voluntarily, and You may withdraw Your consent to Us for the processing of Your Personal Data at any time. In the event of Your refusal or withdrawal of consent, We cannot guarantee the effective provision of access to the Website.

What are the Purposes to Collect Personal Data?

We collect the aforementioned Personal Data for the following purposes:

Personal Data

Collection Purpose

Communication Data

  • Providing You with relevant feedback;
  • Contacting You for administrative reasons, provide You information on Our other services.

Registration Data

  • Enabling access to the Platform;
  • Ensuring Platform security;
  • Providing service communications.

Automatically Collected Data 

  • Ensuring Platform security;
  • Ensuring normal functioning of the Platform;
  • Enhancing Your Platform experience;
  • Indicating the errors and weak points of the Platform and its development. 

Enhanced Verification Data

  • Ensuring Platform security;
  • Ensuring the safety of Users, Our safety and the safety of third parties.


We will collect and use Your Personal Data only for the purposes described above, unless the collection and use of the Personal Data are necessary for other purposes compatible with the original purpose of collecting the Personal Data, or as required by applicable laws or judicial rulings/acts of authorities.

If We need to use Your Personal Data for other purposes not mentioned above, We will notify You and explain the legal basis for such collection. 

How Do We Collect Your Personal Data? 

We may collect Personal Data from Users in a variety of the following ways: 

Personal Data

Collection Way

Communication Data

We get access to such Personal Data when You reach Us for any questions before Your Account registration to get customer service or for any other purposes (e.g., by email).

Registration Data

You provide Us with this Personal Data, when You fill in and submit relevant application forms and complete the required steps to register an Account on the Website or log in through Your account from other third-party services (e.g., Google).

Automatically Collected Data 

When You interact with the Platform, We may collect this Personal data by using cookies, server logs, and other similar technologies.

Enhanced Verification Data

We receive such Personal Data directly from You, as well as obtain it from other sources based on the Personal Data we have.

How Long Do We Keep Your Personal Data?

We will keep Your Personal Data for no longer than it is necessary for that purpose or its collection.

Generally, We will retain and delete Your Personal Data as follows:

Personal Data

Retention Period

Communication Data

We keep it until the moment We provided You with feedback.

Registration Data

We keep Your email throughout the life of Your Account and two years after You close Your Account. Other data is kept by Us strictly throughout the life of Your Account and deleted once Your Account is closed. 

Where it is required by applicable law, we may retain Your Personal Data after the Account is closed within the period prescribed by such laws.

Automatically Collected Data 

We keep Your IP address, login history, referrals to domains and volume of traffic throughout the life of Your Account and two years after You close Your Account. Other data is kept by Us strictly throughout the life of Your Account and deleted once Your Account is closed. 

Where it is required by applicable law, we may retain Your Personal Data after the Account is closed within the period prescribed by such laws.

Enhanced Verification Data

We keep it throughout the life of Your Account and two years after You close Your Account.

What is the Legal Basis for Processing Personal Data?

The processing of Personal Data is performed following privacy rights and regulations following the EU General Data Protection Regulation (GDPR), the UK Data Protection Act 2018 (DPA), and other local regulations. 

Where regulations of the country of Your locations provide for stricter Personal Data standards, the processing of Your Personal Data will be effectuated following these standards.

Generally, the legal grounds for Personal Data Processing could be listed as follows:

Your Consent. Because You have given Us Your consent to processing Your Personal Data for certain purposes, the lawfulness of such processing is based on Your consent. Giving Us consent to process Your Personal Data is voluntary. Any consent given can be withdrawn at any time. Please note that the withdrawal is only valid for the future. Withdrawal does not affect any processing of Personal Data that took place before the withdrawal.

Contract Execution. This refers to the processing of Personal Data where it is necessary for the fulfillment of contractual obligations under a contract to which You are a party, or to act on Your request before entering into such a contract. The latter includes the Terms of Use.

Our Legitimate Interest. Refers to Our interest in managing Our business processes properly and responsibly, being able to protect Our business reputation, and providing You with an appropriate level of service.

Legal Compliance. We process Your Personal Data where necessary to comply with legal or regulatory obligations.

Do We Transfer or Share Your Personal Data To (With) Others? 

Sometimes We may need to share Your Personal Data with third parties, an exhaustive list of which is set forth below:

  • Affiliates and Counterparties of the Company

When We share Your Personal Data, We notify the individuals listed above that We are sharing Your Personal Data with them and require them to comply with all statutory obligations concerning the Processing of Your Personal Data. We do not allow such persons to use Your Personal Data for their purposes and only allow them to process Your Personal Data for certain purposes and following Our instructions.

  • Courts and(or) Government Authorities and(or) Law Enforcement Officials

We will only use and share Your Personal Data with these parties where it is necessary for the lawful conduct of Our business. We may be requested to share this data by authorities in case where Users breach Terms and use Internet bandwidth for purposes violating legal requirements.

  • Analytical and Search Engine Providers

We share Your Personal Data with such parties in depersonalized from only in order to improve and optimize the Platform.

We can assure You that We will not sell, trade, or share Your Personal Data with third parties without Your explicit consent.

Do We Transfer Your Personal Data Overseas?

We store Your Personal Data primarily in the UK. However, to facilitate our global operations, Our Company may use the services of overseas data processing service providers, unless Your jurisdiction laws and regulations limit such data transfer. 

We hereby warrant You that We will only transfer Your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal data. We will make all possible efforts to ensure the protection of Your Personal Data under this Privacy Policy wherever Your Personal Data is processed and will take appropriate contractual or other steps to protect the relevant Personal Data following applicable laws. 

Where such service providers are not established in a country ensuring an adequate level of protection within the meaning of GDPR and DPA, such as the United States, the transfers will be covered by the standard data protection clauses adopted by the US and EU or by another appropriate safeguard mechanism such as the Privacy Shield Framework.

How We Secure Your Personal Data?

We have implemented several technical, organizational, and administrative measures to ensure the confidentiality, integrity, availability, and privacy of Your Personal Data and to protect Your Personal Data from loss, theft, unauthorized access, misuse, alteration, or destruction which are generally accepted by the industry to protect the Personal Data in its possession. 

These measures include but are not limited to the implementation of current security technologies: Secure Sockets Layered (SSL) technology to ensure that Your Personal Data is fully encrypted and sent across the Internet securely, secure coding principles, and regular penetration testing. 

We also use encryption (HTTPS/TLS) to protect data transmitted to and from Polyx Exchange. Transport Layer Security (TLS) is a protocol that provides privacy and data integrity between two communicating applications. It's the most widely deployed security protocol used today and is used for Web browsers and other applications that require data to be securely exchanged over a network, such as file transfers, VPN connections, instant messaging, and voice-over IP.

Only authorized Company personnel have access to the Personal Data, and this personnel are required to treat the Personal Data as confidential. The security measures in place will, from time to time, be reviewed in line with legal and technical developments.

Your Rights

You have the following basic rights as the subject of Personal Data:

  1. Access and Portability. You may ask Us to provide You with a copy of Your Personal Data to which We have access. We will provide such information to You within a reasonable time and may require You to reimburse Us for the costs associated with collecting the information in the system.
  2. Rectification of Incomplete or Inaccurate Personal Data. You may request changes or updates to any of Your Personal Data. You may do so by contacting Us directly. The Company reserves the right to refuse personal assistance if the functionality of the Website allows modifications to Personal Data.
  3. Erasure. You may ask Us to delete Your Personal Data. Please note that in some cases the Company automatically deletes Your Personal Data. Please note that We may not always be able to comply with Your request for deletion due to applicable legal requirements, of which You will be notified, in response to Your request.
  4. Withdraw Consent. To the extent that the processing of Your Personal Data is based solely on Your consent, You may withdraw Your consent at any time. This will not affect the legality of any processing that has taken place before the withdrawal of consent. Please note that any Personal Data that is processed under a basis other than Your consent will continue to be processed.
  5. Restriction of Processing. In some jurisdictions, applicable law may give You the right to restrict or object to Our processing or transfer of Your Personal Data under certain circumstances. We may continue to Process Personal Data if necessary to protect Our rights or as otherwise required by applicable law.

You can make privacy rights requests relating to Your Personal Data by contacting Us via email provided at the end of this document or through other means provided on the Website.

Please note that none of the aforementioned rights are absolute, which allows Us to deny You the exercise of such right if Our exercise of such right would not comply with the legal obligations applicable to Us and Our legitimate interests. If We decide to deny Your request, We will inform You and explain the reasons for Our decision.


What are ‘cookies’?

Cookies are small text files that are stored on Your device when You visit the Website. These text files store certain information, such as Your language preference. When You visit the Platform again, this file is sent to the Platform. In this way, the Platform recognizes Your browser and can, for example, remember Your language preferences.

How long do cookies stay on Your Device?

Cookies usually have an "expiration date" which indicates how long they are stored on Your device. Some cookies are automatically deleted when You close the browser (session cookies), while others remain on Your device for a longer period, sometimes until You manually delete them (permanent cookies).

Why do We use cookies?

We use three types of cookies:

  • Functional cookies;
  • Analytical and operational cookies;
  • Communication and marketing cookies.

Functional cookies are necessary for the normal functioning of the Platform. The Company uses such cookies to authenticate Users or enable the normal operation of certain functions of the Platform.

Analytical and operational cookies: We may use cookies to recognize repeat visits to the Platform by Users, the type of Content viewed on the Platform and the links to other Partners' sites from the Platform, the time of opening each section of the Platform, as well as the use of certain functionality of the Platform.

We use Google Analytics for analytical purposes. When the User moves between web pages, Google Analytics provides website owners with specific JavaScript tags (libraries) to record information about the page the User viewed, such as the URL of the page (for more information, see Google Analytics' website privacy overview). Google Analytics uses cookies on websites and/or see the Google Privacy and Data Protection Overview for more information about the data collected by Google Analytics).

In addition, We receive certain information during sessions conducted through Your browser to access Our Website and other content provided by or on behalf of the Company on other websites, or when reading emails. Collecting this information allows Us to better understand Our Users, identify the resource through which the Platform is accessed, and learn how Users use the Platform. We use this information for analytical purposes and to improve the Platform. Such information includes:

  • Technical information, including the Internet Protocol (IP) address used by Your computer or device to access the Internet, browser type and version, time zone settings, plug-in types and versions, and operating system platform;
  • Information about Your visit or opening an email, including the Uniform Resource Locator (URL), history of links to or from Our website or exits (including date and time of visit); page response time, load failures, duration of visits to certain pages, page usage information (such as scrolling, clicking or hovering), and how You exit the website page.

How do I know which cookies have been placed on my device and how do I delete them?

If You wish to find out which cookies are installed on Your device or wish to delete them, You may use Your browser settings.

Please note, that when You delete or refuse the use of cookies, You agree that You may lose access to some features of the Website.

You can block Your browser from accepting certain cookies, require Your browser's consent before a new cookie is placed in Your browser, or block cookies altogether by selecting the appropriate setting in Your browser's privacy settings menu. To disable cookies in the browser of Your mobile device, You need to refer to its respective user manual.

Most web browsers allow You to view and delete cookies through Your browser settings. To learn more about cookies, including what cookies have been set, visit or

For Your information, We have also provided links to the cookie settings of the most common browsers below:

To find information regarding other browsers, visit the website of the browser developer.

To opt-out of tracking Google Analytics on all websites, visit


The Platform may contain links to external websites/platforms maintained by third-party service providers, whose Personal Data and privacy practices are different from Ours. 

The Company is not responsible or liable for the Personal Data or privacy practices employed by such third parties. We strongly recommend You read the privacy statements of all third-party websites before using such websites or submitting any Personal Data or any other information on or through such websites.


The Company hereby reserves the right to amend this Policy by publishing an updated version of the Policy on the Website with a new date of the last update on the first page of the document.

The User acknowledges that his/her/its continued use of the Platform after the publication of the updated version of the Policy on the Website is deemed to be his/her unconditional and unequivocal consent to all the provisions of the updated Policy (acceptance of the amended Policy).

The User hereby undertakes regularly to check the Website for updates in this Policy and read the amended text of this Policy.

The Company is not obliged to notify the User of any changes to this Policy.


If You have any questions regarding Our processing of Your Personal Data and any provisions of this Policy, You may contact Us via email: [email protected], as well as through messengers and other contact means provided on the Website.