Privacy Policy

This Privacy Policy governs the manner in which this platform (“we”, “us”, or “our”) collects, uses, processes, stores, and discloses information received from users (“you”, “your”) through the website [WEBSITE URL] (“Website”), and associated services provided therein (“Services”). This Policy complies with the provisions of the General Data Protection Regulation (GDPR), the ePrivacy Directive, the Data Protection Act, and other applicable regulations within the European Economic Area (EEA).

1. General Definitions

• Personal Data means any information that identifies or can be used to identify an individual.
• Processing refers to any operation performed on Personal Data, whether automated or not.

2. Legal Basis and Scope

This Privacy Policy applies to all Personal Data processed in the context of providing Services, whether fully or partially automated or through manual systems that are structured. The GDPR applies regardless of whether the processing entity is located inside or outside of the EEA, provided that Personal Data of individuals within the EEA is processed in connection with service offering or behavior monitoring.

3. What Personal Data We Collect

We may collect and process the following categories of Personal Data

a. Data Provided by You:

• Full name, contact details, address, and date of birth;
• Identity verification documents (passport, ID, photo, etc.);
• Source of funds documents;
• KYC/AML screening data;
• Login credentials and account preferences.

b. Data Collected via Usage of Services:

• Transaction history;
• Device and browser data;
• IP address, geolocation;
• Time and method of access;
• Communication data (email, chat, forms, etc.);
• Website usage data (clickstream, scrolling, session length, etc.).

c. Data from Third Parties:

• Data from banks, financial institutions, payment processors;
• Data from fraud prevention and compliance service providers;
• Data from credit reference databases.

4. How We Use Personal Data

We use your Personal Data for the following purposes:

• To create and manage user accounts;
• To deliver and maintain the Services;
• To conduct KYC/AML checks;
• To fulfill legal obligations;
• To prevent fraud and ensure security;
• To communicate with users;
• To improve our Services and user experience;
• To conduct internal analytics and performance monitoring.

5. Third-Party Services

We may engage external service providers for identity verification, customer support, analytics, or infrastructure services. Each such provider operates under their own privacy policy, accessible on their official websites. We ensure that all third parties adhere to applicable data protection standards. We may transfer Personal Data to these service providers only to the extent necessary for them to provide their services to us and only under appropriate legal safeguards.

6. Direct Marketing

If you provide explicit consent, we may send you marketing communications. You may withdraw this consent at any time by using the unsubscribe option provided in such communications. We may still contact you regarding important operational or contractual matters even if you opt out of marketing messages.

7. Data Subject Rights

As a data subject under GDPR, you have the following rights:

• Right to be informed about the collection and use of your Personal Data;
• Right of access to your Personal Data and information on how it is processed;
• Right to rectification of inaccurate or incomplete data;
• Right to erasure (“right to be forgotten”) under certain conditions;
• Right to restrict processing of your Personal Data;
• Right to data portability in a structured, machine-readable format;
• Right to object to certain types of processing;
• Right to withdraw consent at any time;
• Right to non-discrimination for exercising your rights.

To exercise these rights, please contact our Data Protection Officer using the contact form provided on the Website.

8. Legal Obligations

We process certain categories of Personal Data to comply with AML, KYC, and other regulatory requirements. Failure to provide such information may result in denial of Services. We may also retain and process Personal Data to fulfill legitimate requests from law enforcement or in response to legal proceedings.

9. Security of Personal Data

We implement technical and organizational measures to protect Personal Data from unauthorized access, disclosure, alteration, or destruction. This includes:

• Encryption (in transit and at rest);
• Access controls;
• Multi-signature systems;
• Data segregation;
• Confidentiality obligations for staff and vendors.

Security measures are regularly reviewed and updated.

10. Retention of Personal Data

Personal Data is retained as long as necessary to fulfill the purposes outlined in this Policy, or longer if required by law. Data related to account activity may be stored for a defined period after account closure (e.g., up to 8 years) in compliance with financial and AML regulations. Data may also be stored in anonymized or aggregated formats for statistical and analytical purposes.

11. Sharing and Disclosure of Data

We do not sell, rent, or trade Personal Data. We may share data:

• With partners and vendors who help us operate the Services;
• With financial institutions for KYC or banking operations;
• With government or regulatory bodies when legally required;
• In connection with defending or enforcing legal rights.

All disclosures are done under applicable data protection laws and with appropriate safeguards in place.

12. Data Transfers Outside the EEA

We may transfer Personal Data to countries outside the EEA, the United Kingdom, or Switzerland. Such transfers are conducted under:

• Adequacy decisions by the European Commission; or
• Standard Contractual Clauses (SCCs) and additional security measures;
• Binding Corporate Rules approved by supervisory authorities.

13. Children’s Privacy

Our Services are not intended for use by individuals under the age of 18. We do not knowingly collect or process Personal Data of minors.

14. Updates to This Policy

We may revise this Privacy Policy at our discretion. The latest version will always be available on the Website, with the date of the most recent update stated at the top of the document. Continued use of the Website or Services after such updates shall constitute acceptance of the revised terms.