Cookie Policy
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Scope and Consent
This Privacy Policy governs the processing of personal data by [Company Name] in compliance with the General Data Protection Regulation (GDPR), Swiss Federal Data Protection Act (nFADP), and the California Consumer Privacy Act (CCPA). By accessing our services, you consent to the practices described herein.
Data We Collect
- Identity Data: Full name, date of birth, nationality, government-issued ID, and source of wealth documentation.
- Financial Data: Wallet addresses, transaction history, counterparty details, and portfolio snapshots.
- Technical Data: IP address, browser fingerprint, device identifiers, and API usage logs.
Purpose & Legal Basis
We process data for KYC/AML screening (legal obligation), trade execution and settlement (contract performance), risk management (legitimate interest), and regulatory reporting (legal obligation). Automated decision-making is used for transaction monitoring and sanctions screening.
Data Sharing & Third Parties
We may share data with custodians (Fireblocks, Copper), blockchain analytics providers (Chainalysis, Elliptic), and regulators upon lawful request. We do not sell personal data. Cross-border transfers are safeguarded by Standard Contractual Clauses (SCCs).
Your Rights
Under GDPR, you have rights to access, rectification, erasure, restriction, portability, and objection. For CCPA, you may opt-out of data sharing (though we do not sell) and request deletion. Exercising rights may impact service provision.
Data Retention
We retain personal data for the duration of the business relationship plus five years post-termination to comply with regulatory audit trails. Anonymized aggregate data may be retained indefinitely.