Privacy Policy

We may collect the following types of personal information:

• Identification information, such as your full name, date of birth, gender, nationality, and government-issued identification details (for example, ID card or passport numbers and document images), where required for verification purposes.
• Contact information, such as your residential address, email address, and phone number.
• Biometric and verification information, such as a facial scan and liveness-check images or video collected during identity verification, photographs, and identity documents. Biometric data is collected and processed only after we (or our verification provider) obtain your consent.
• Financial and transaction information, such as your bank account details (in your own name), transaction amounts, currencies, digital asset wallet addresses, and source-of-funds or source-of-wealth information.
• Account and usage information, such as username, account settings, login timestamps, IP address, and device information.
• Technical information, such as browser type, operating system, and information collected through cookies and similar technologies.
• Screening information, such as data generated from checks against sanctions lists, politically-exposed-person ("PEP") lists, and adverse-media sources.

You may choose not to provide certain information, but this may limit or prevent your ability to use the Services, including the ability to be onboarded.

We use your personal information for the following purposes:

• To create and manage your account and to provide the Services you request.
• To conduct identity verification, onboarding, and other "know-your-customer" ("KYC") and anti-money-laundering ("AML") checks, including sanctions and PEP screening, and to comply with applicable legal and regulatory obligations.
• To process, settle, and record your transactions, including communicating necessary information to banks, payment providers, and other service providers.
• To operate, maintain, and improve the Services, including troubleshooting, data analysis, testing, and security monitoring.
• To communicate with you about your account, the Services, and changes to our terms, policies, or features.
• To detect, prevent, and investigate fraud, abuse, or other harmful or unlawful activities, and to protect our rights, property, and safety and those of our users and others.
• To comply with any applicable law, regulation, legal process, or enforceable governmental request.

We will only process personal information where we have a lawful basis to do so under applicable data protection laws, such as your consent (where required, including for biometric data), the performance of a contract with you, compliance with legal obligations, or our legitimate interests.

We may share your personal information with the following categories of recipients:

• Identity verification and KYC/AML providers, as described in Section 4.
• Banks, payment institutions, payment gateways, and liquidity providers, where it is necessary to process, settle, or pay out a transaction. To complete an On/Off-Ramp transaction, necessary information such as your name, bank account details, and transaction amount may be shared with these parties.
• Service providers who perform services on our behalf, such as cloud hosting, data storage, security, analytics, and customer support.
• Professional advisers, such as lawyers, auditors, and consultants, where reasonably necessary for compliance, risk management, or the establishment, exercise, or defence of legal claims.
• Government authorities, regulators, law enforcement agencies, or courts, where we believe disclosure is required by applicable law, regulation, or legal process, or where it is necessary to protect our rights or the rights of others.

We do not sell your personal information to third parties. Service providers who process personal information on our behalf are required to use the information only in accordance with our instructions and to implement appropriate security measures.

Depending on your jurisdiction and applicable law, you may have certain rights in relation to your personal information, which may include:

• the right to access and obtain a copy of your personal information;
• the right to request correction or updating of inaccurate or incomplete information;
• the right to request deletion of your personal information, subject to certain exceptions (including the statutory retention obligations described in Section 7);
• the right to object to or request restriction of the processing of your personal information;
• the right to withdraw consent where processing is based on your consent, including consent to process biometric data (without affecting the lawfulness of processing before withdrawal);
• the right to data portability, where applicable; and
• the right to lodge a complaint with a competent supervisory authority.

To exercise any of these rights, you may contact us using the details in the "Contact Us" section below. We may need to verify your identity before responding. Your rights may be subject to limitations under applicable law.