Last Updated: December 10, 2024
1. INTRODUCTION
This Privacy Policy (“Policy”) explains how Aegis Vault Ltd. (“Company,” “we,” “us,” or “our”), a company incorporated in the British Virgin Islands with registration number 2163500, collects, uses, shares, and protects your personal information. This Policy applies to all users of our services, website, applications, and platforms (collectively, “Services”).
2. DATA CONTROLLER AND CONTACT INFORMATION
2.1. Data Controller:
- Aegis Vault Ltd.
- Registration Number: 2163500
- Address: Quijano Chambers, P.O. Box 3159, Road Town, Tortola, British Virgin Islands
2.2. For privacy-related inquiries, contact our Data Protection Officer at [email protected]
3. ELIGIBILITY AND JURISDICTIONAL RESTRICTIONS
3.1. Restricted Jurisdictions
The Company does not provide services or process the personal data of persons who are:
- Residents, citizens, or located in the United States of America
- Residents, nationals, or located in jurisdictions subject to comprehensive sanctions, including:
- Cuba
- Iran
- North Korea
- Syria
- The Crimea, Donetsk, and Luhansk regions
- Russia and Belarus (subject to applicable sanctions programs)
- Listed on restricted party lists, including:
- US Treasury OFAC’s SDN List
- UN Security Council Consolidated List
- EU Consolidated Financial Sanctions List
- UK HM Treasury Consolidated List
- Any other applicable sanctions lists
3.2. User Obligations
Users must:
- Confirm they are not subject to jurisdictional restrictions
- Notify us immediately of any change in status
- Not attempt to circumvent these restrictions
- Comply with all applicable sanctions regulations
4. INFORMATION WE COLLECT
4.1. Information You Provide
- Account registration details
- Identity verification information (KYC/AML)
- Blockchain addresses and transaction data
- Communication records
- Support requests
- Compliance documentation
4.2. Information Automatically Collected
- Device and browser information
- IP address and geolocation data
- Usage patterns and analytics
- Platform interaction data
- Network and connection information
- Cookie and tracking data
4.3. Blockchain Data
- Public wallet addresses
- Transaction records
- Smart contract interactions
- Governance participation data
- On-chain activity
4.4. Compliance Information
- Sanctions screening results
- Risk assessment data
- Transaction monitoring alerts
- Compliance verification records
- Regulatory reporting information
5. LEGAL BASIS FOR PROCESSING
5.1. We process your data based on:
- Contract performance
- Legal obligations
- Legitimate business interests
- Your consent
- Public interest requirements
- Regulatory compliance
5.2. Specific Legal Bases:
- KYC/AML compliance: Legal obligation
- Transaction processing: Contract performance
- Marketing: Consent
- Security measures: Legitimate interests
- Regulatory reporting: Legal obligation
6. HOW WE USE YOUR INFORMATION
6.1. Core Service Purposes:
- Account management
- Transaction processing
- Security and fraud prevention
- Customer support
- Platform maintenance
6.2. Compliance Purposes:
- KYC/AML verification
- Sanctions screening
- Transaction monitoring
- Regulatory reporting
- Legal obligations
6.3. Business Operations:
- Service improvement
- Analytics and research
- Performance monitoring
- Technical support
- Business development
7. DATA SHARING AND TRANSFERS
7.1. Within Aegis Ecosystem
- Aegis DAO Foundation for governance
- Affiliated entities under data protection agreements
- Service providers and contractors
- Technical infrastructure providers
7.2. Third-Party Service Providers
- KYC/AML service providers
- Cloud storage providers
- Security services
- Analytics providers
- Professional services
7.3. Legal and Regulatory
- Regulatory authorities
- Law enforcement agencies
- Courts and tribunals
- Professional advisors
- Government authorities
7.4. International Transfers
We may transfer data internationally:
- Within the Aegis ecosystem
- To service providers globally
- Subject to appropriate safeguards
- Following international data protection standards
- In compliance with transfer regulations
8. DATA SECURITY
8.1. Technical Measures
- Encryption at rest and in transit
- Access controls and authentication
- Firewalls and security monitoring
- Regular security assessments
- Incident response procedures
8.2. Organizational Measures
- Staff training and policies
- Access restrictions
- Security protocols
- Regular audits
- Vendor assessment
9. DATA RETENTION
9.1. Retention Periods:
- Account data: Duration of relationship plus 5 years
- Transaction data: 7 years minimum
- Communication records: 5 years
- Compliance documents: As required by law
- Technical logs: 2 years
9.2. Deletion Criteria:
- Legal requirements satisfied
- Business purpose fulfilled
- User request (where applicable)
- Technical feasibility
10. YOUR RIGHTS
10.1. You have the right to:
- Access your personal data
- Correct inaccurate information
- Request data deletion
- Restrict processing
- Data portability
- Object to processing
- Withdraw consent
- Lodge complaints
10.2. Exercise of Rights:
- Submit requests to [email protected]
- Verify identity for requests
- Receive response within 30 days
- No fee (unless excessive requests)
11. COOKIES AND TRACKING
11.1. We use:
- Essential cookies
- Analytics cookies
- Preference cookies
- Marketing cookies (with consent)
11.2. Cookie Control:
- Browser settings management
- Cookie preference center
- Opt-out mechanisms
- Do Not Track support
12. CHANGES TO THIS POLICY
12.1. We may update this Policy:
- With prior notice
- For regulatory compliance
- To reflect service changes
- Following industry standards
12.2. Notification:
- Email notification
- Website announcement
- In-app notification
- 30 days’ notice for material changes
13. DISPUTE RESOLUTION
13.1. Resolution Process:
- Internal review
- Independent mediation
- Regulatory authorities
- BVI courts as final resort
13.2. Governing Law:
- BVI law applies
- International data protection standards
- Regulatory requirements
- Industry best practices