Crypto Services Privacy Policy

1. Introduction

BitBloom ("BitBloom", "we," "us," or "our") is committed to protecting the privacy of our users, clients, and partners (collectively, "Participants"). We strive to safeguard your data and provide high-quality professional services ("Services") to all our Participants. This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal information when you use our Services, including our Crypto Services outlined here, including our Know Your Customer (KYC) and Know Your Business (KYB) verification processes.

2. Information We Collect

To comply with legal obligations and provide our services, we may collect the following documentation and information:

Basic Personal Information

• Full Name
• Residential Address
• Date of Birth
• Nationality
• Country of Residence
• Gender
• Phone number
• Email address

Identity Verification Information

• Government-issued identity document (e.g., passport, driver's license, or state identification card)
• Social Security number
• Employment information (e.g., company name)
• Proof of address (utility bills, bank statements)
• Photographs and/or videos

Electronic Identification Information ("EIDV")

• Facial recognition data or biometric information (where applicable and with explicit consent)

Organization Information

(if you are working with us on behalf of an organization, entity, business, or institution)

• Organization name and registration details
• Personal identification information for all material beneficial owners
• Company address
• Ownership information
• Tax identification numbers
• Financial statements
• Beneficial ownership information
• Company directors and officers information

Financial Information

• Bank Account Numbers
• Investment and financial experience
• Tax Identification Number
• Income/net assets/wealth verification statements

Technical Information

• Access information
• IP address
• Device information
• Browser type
• Usage data
• Cookies and similar tracking technologies

Crypto Services Information

• Bank information (account numbers, routing numbers)
• Proof and availability of funds
• Financial statements
• Cryptocurrency wallet information
• Payment preferences
• Transaction logs

Information from Third-Party Sources

• Verification Provider Information: Results of KYC/KYB verification performed by third-party service providers
• Public Database Information: Information from UN Sanctions List, US ITA Consolidated Screening List, SEC EDGAR, etc.
• Blockchain Data: Public blockchain data including transaction IDs, timestamps, wallet addresses, etc.
• Blockchain Analytics: Analysis using tools like Elliptic and Chainalysis
• Credit Bureaus: Credit scores, credit reports, outstanding debt information

3. How We Use Your Information

We use your information to:

• Register you with Crypto Services: Verify identity and compliance with regulations
• Verify your assets: Confirm legitimacy and ownership of wallets and assets
• Verify your clients and customers: Perform due diligence on your business relationships
• Service Provision: Deliver high-quality services tailored to your needs
• Customer Support: Provide assistance and answer inquiries
• Security and Fraud Prevention: Protect against unauthorized access and illegal activities
• Compliance: Meet legal obligations and regulatory requirements
• Research and Innovation: Improve our services and platform
• Marketing and Communication: Send updates and promotional materials (with consent)
• Risk Assessment: Evaluate risks associated with providing services

4. Sharing Your Information

We may share your information with:

• Third-Party Service Providers: Vendors assisting with KYC, AML/CTF, KYB, and blockchain analysis
• Trusted Identity Verifiers: Including Onfido and Idenfy
• Financial Institutions: To facilitate transactions and comply with regulations
• Professional Advisors and Industry Partners: With your consent
• Authorities and Regulators: When required by law
• Linked Third Party Services: Secure platforms for tax reporting, telecommunications, security, payments, etc.

5. Data Security

We implement appropriate technical and organizational measures to protect your information from unauthorized access, disclosure, alteration, and destruction. We use highly secure online platforms that adhere to ISO27001 standards and/or conduct SOC 2 Type 2 Audits.

6. International Data Transfers

As we operate globally, we may transfer, store, and process your personal information throughout the world, including Ireland, Germany, Singapore, the UK, the US, and the Philippines. We take appropriate measures to ensure your information is protected in accordance with applicable laws.

We rely primarily on the European Commission's Standard Contractual Clauses for international data transfers. For a copy, please contact crypto@noahsinc.net.

EU-US, UK-US, and Swiss-US Data Privacy Framework

BitBloom complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF). To learn more about the Data Privacy Framework (DPF) program, visit https://www.dataprivacyframework.gov

7. Data Retention

We retain your personal information as needed to provide our Services, comply with legal obligations, and protect the interests of our Participants. Retention requirements vary by country and are based on regulatory compliance requirements, including AML/KYC obligations. We delete information that is no longer needed when you close your account or request deletion.

8. Your Rights

Depending on where you live, you may exercise certain privacy rights:

• Access and portability: Request a copy of your information
• Rectification: Request correction of inaccurate information
• Deletion/erasure: Request deletion (subject to legal obligations)
• Object to or restrict processing: Object to how we process your information
• Withdraw consent: Withdraw consent at any time
• Lodge a complaint: File a complaint with your supervisory authority
• Reject automatic decision-making: Request human review
• Non-discrimination: We will not discriminate for exercising your rights

9. Specific Jurisdictional Information

European Union (GDPR)

• Legal Basis: Legal obligations, contractual necessity, legitimate interests, and consent
• Data Subject Rights: As outlined in Section 8
• Data Transfers: Standard Contractual Clauses

California (CCPA/CPRA)

• Consumer Rights: Right to know, delete, and opt-out
• We do not sell your personal information

Other Jurisdictions

We comply with applicable data privacy laws in all jurisdictions where we operate, including Canada (PIPEDA), Australia (Privacy Act), and other relevant regulations.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post changes on this page and provide reasonable notice of material changes. The effective date at the top of this document indicates when the policy was last updated.

11. Contact Us

If you have questions or concerns about this Privacy Policy, please contact us at:

• Email: crypto@noahsinc.net
• General: info@noahsinc.net