At Token Binder, we value your privacy and strive to protect your personal data. Token Binder will only collect and use your personal data in accordance with this Privacy Policy, our and our Terms of Use.


This Privacy policy explains:

which Token Binder entity controls your data;

how we collect, process and share your personal data;

the important security measures we maintain to secure your personal data;

• why and how we retain your personal data

Our relationship with you

Depending on which country or region you have verified your Token Binder account in, you may be a customer of a specific Token Binder entity. References in this Policy to “Token Binder”, “we”, “us”, “our” or any similar term is to the relevant Token Binder entity you are a customer of.
The Token Binder company you contract with is your Data Controller. This means it is responsible for the collection, use, disclosure, retention and protection of your personal data in accordance with this Privacy Policy and all applicable laws.

Collecting your personal data

In order to open and operate an account for you, provide you with our products and services, or communicate with you, we may need to collect your personal data.

We may collect the following types of personal data:


Personal identification information such as your full name, date of birth, nationality, cellphone or mobile number, email address, place of residence (and/or proof of residence), employment status, industry of employment and/or national identification number or social security number;

Transaction information such as your transaction data on your Token Binder account and information on the recipient of any transaction(s);

Correspondence such as information provided to us when engaging with our customer support and/or responses to surveys;

Usage, device and location information such as cookies, geolocation information, browser name and version information, IP address information, device fingerprint data, authentication data and/or click-stream data.
Personal data is collected in various ways, including:

When you provide it to us such as when you sign up for a Token Binder account, use our products and services, or take part in customer surveys, competitions and promotions;

When you use the Token Binder platform we collect information on your transactions and usage of your Token Binder account;

When we obtain information from third parties such as identity verification services, credit reference agencies, regulatory and enforcement agencies and public sources.

You must be 18 years or older to open a Token Binder account and, as such, Token Binder will not intentionally or knowingly collect personal data directly from individuals under the age of 18 years.

Processing your personal data
We will only process your personal data where it is necessary for us to carry out our lawful business activities. In doing so, we rely on one or more of the following lawful grounds for processing your personal data:

Contractual necessity: We may process your personal data where it is necessary in order for us to provide our products and services to you or to otherwise comply with our obligations under Token Binder’s Terms of use.

Consent: In some cases, we will only process your personal data where you provide us with your express consent for such processing.

Legal obligation: In some cases, we may need to process your personal data in order to comply with an obligation imposed by law.

Legitimate interest: In some cases, we may need to process your personal data where it is in our legitimate legal interests to do so.


More specifically, we may process your personal data for one or more of the following purposes:


to verify your identity in accordance with Know Your Customer (KYC), Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) requirements;

to manage and maintain your account with us;

to improve our products and services, and to develop new products and services;

to notify you about benefits and changes to the features of our products and services;

to respond to your enquiries and to resolve disputes;

in relation to legal claims, compliance, audit, risk management, law enforcement processes and regulatory functions; in connection with the acquisition, merger or sale of a business.

Where we are required to process criminal history information, biometric information or any other type of special personal data about you in connection with any of the purposes listed above, you expressly consent to the collection, use and storage of this personal data about you. If you choose to withdraw your consent, we refer you to the section below titled “Your right to access, update, or remove your personal data”. Please note that, should you withdraw your consent, you will no longer be able to use the Token Binder products and services.

Sharing your personal data

We may share your personal data with:


any person that works for us or for one of our group companies;

any entity that forms part of the Token Binder group of companies, including where relevant the Token Binder operating entity in the country or region in which you live;

financial and other institutions we partner with to provide our products and services;

with third party cryptocurrency (or virtual or digital asset) service providers when you send cryptocurrency over the blockchain. The third party service provider may also use this information to screen and process the relevant transaction;

companies and organisations that provide services to us, including in relation to technical infrastructure, marketing and analytics, and web and app development;

our professional advisers, consultants and other similar services.


We will otherwise treat your personal data as private and confidential and will not share it with other parties except:

where you have given us permission to do so;

where we believe it is reasonably necessary to comply with any law, regulation, legal process or governmental request, to enforce our Terms of use or other agreements, or to protect the rights, property, or safety of us, our customers or others; where we may transfer rights and obligations pursuant to our agreement with you.

Security of your personal data
Token Binder places great importance on ensuring the security of your personal data. We regularly review and implement appropriate and reasonable technical and organisational security measures to keep your personal data safe. Employees of Token Binder are trained to handle personal data securely and with the utmost respect, failing which they may be subject to disciplinary action.

Electronic marketing
Where you have opted-in to receive marketing communications and news, we may share information about our products, services, news and promotions with you. If you have opted-in to receive marketing communications, you may always opt out at a later stage by clicking on the “Unsubscribe” option included in every marketing communication sent to you.
Please note that unsubscribing from marketing content will not stop you from receiving important communications in relation to the security or operation of your account or the Token Binder product.

Additional matters relating to personal data


Retention of personal data
Token Binder will retain your personal data, in compliance with this Privacy Policy and the Terms of Use, for the duration of your relationship with us, and afterwards for such period as may be necessary for our legitimate business purposes (including compliance with our legal obligations, preventing fraud, resolving disputes and enforcing agreements), to protect the interests of Token Binder and its customers, and as required by law.

Incomplete personal data
Where indicated (for example in application forms or account opening forms), it is obligatory to provide your personal data to us to enable us to process your application for our products or services. Should you decline to provide such personal data, we may not be able to process your application/request or provide you with our products or services.


Your right to access, update, or remove your personal data
Most of the data Token Binder collects, and the ways in which we use it, are necessary for us to provide and improve the services we provide to you, or to comply with our obligations. In certain situations, we give you the ability to choose how we use your data.
Depending on the country or state in which you live, you may have certain rights under data protection law, including the right to:

object to the processing of your personal data;

opt out of the sharing of your personal information with third parties which are not affiliated to Token Binder for the purpose of those third parties marketing their products and services to you;

to request that we provide you with a copy of your personal data (including in a format that can be shared with a new provider); or

to request that we correct, delete, or restrict the processing of your personal data.


Data breaches
We will notify you and, where applicable, the relevant supervisory authority as soon as we become aware of any data breach that is likely to result in a risk to your rights and freedoms.

Revisions to this Privacy Policy
We may amend this Privacy Policy from time to time. You should visit the website regularly to check when this Privacy Policy was last updated and to review the current Policy. We will do our best to notify you of any substantive amendments to the Privacy Policy and any such notice will be posted on our application or our website, or sent by email to the address associated with your Token Binder Account.