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Privacy Policy

Introduction

This privacy notice applies to the processing activities performed by Digital Card Services to the personal data of its clients, prospective clients, users of Digital Card Services’ products that run on-chain, and website visitors.

Your privacy is of the utmost importance to us. It is our policy to safeguard the confidentiality of information and respect the privacy of individuals.

 

Please see below for information about how we manage personal data, and for information about your rights with respect to the processing of your personal data.

Definitions

The following terms are defined as follows:

2.1 “AML” means anti-money laundering.

 

2.2 “Digital Asset” means any digital representation of value that may be traded via Digital Card Services’ services, excluding non-fungible tokens.

 

2.3 “Digital Card Services”, “We”, “Us”, refers collectively to Digital Card Services Inc. and its subsidiaries.

 

2.4 “Personal data” refers to any information relating to an identified or identifiable natural person, including names, identification numbers, location data, an online identifier, or to one or more factors specific to the physical, economic, cultural, or social identity of a natural person.

Your Data Controller

Our products and services are provided through local operating entities that are part of the Digital Card Services group of companies.

 

You are contracting with Digital Card Services as specified in our Terms of Service — in that case, these Terms of Service apply.

 

The company you are contracting with is your Data Controller, and is responsible for the collection, use, disclosure, retention, and protection of your personal data in accordance with our global privacy standards, this Privacy Notice, and any applicable national laws.

Important Information We May Collect About You

We obtain information about you in a number of ways through your use of our products and services, our websites, the account opening process, webinar sign-up forms, event subscriptions, news and updates subscriptions, and from information provided in the course of ongoing support service communications.

 

In order to open an account with us, you must first complete and submit a “create account” form. By completing this form, you are requested to disclose personal data in order to enable Digital Card Services to assess your application and comply with applicable laws and regulations.

 

The minimum information required for entering into a contract governing your use of our products and services, and for enabling us to comply with our statutory obligations in respect of anti-money laundering and crime and fraud prevention, includes:

 

- Biographical information and contact information

- Financial Information

- PEP (Politically Exposed Person) Information

- Verification Information

 

Without this information, we cannot commence or continue to perform our services or provide our products to you.

 

The information that we collect from you may include:

- Full name, residential address, and contact details (e.g., email address, telephone number), date of birth, place of birth, gender, residency, citizenship (“Biographical information and contact information”);

- Bank account information, wallet addresses, credit card details, source of funds, assets and liabilities, and information related to economic and trade sanctions lists (“Financial information”); Trading account balances, trading activity, and custodial activity (“Trading information”);

 

- Information on whether you (or someone close to you) hold a prominent public function (“PEP information”); Verification information, including documents to verify your identity (e.g., passport, driver’s license, government-issued ID card), selfie photos/videos, and login credentials, which may be processed using technologies that extract biometric data (“Verification information”); Information collected during interactions with support service channels, including online chat, phone, email, direct messages, or other communication methods (“Support service communications”);

- Digital Card Services Pay information, including username (e.g., PayTag), profile picture, email address, name, phone number, contacts (if enabled), transaction records, payment descriptions, comments, and attachments (“Digital Card Services Pay information”); Card services information, including card details such as PAN (Primary Account Number), card issuer ID, and transaction records (“Card information”); On-chain attestations, such as DeFi trading volume, liquidity provision, transaction metrics, wallet verification status, wallet addresses used for attestations, and related metadata (e.g., timestamps, schemas) (“Attestation information”); Other personal, commercial, or identification information that we, in our sole discretion, determine is necessary to comply with legal obligations under AML frameworks (e.g., the EU 5th AML Directive, UK Money Laundering Regulations 2017, U.S. Bank Secrecy Act) (“Other information”).

 

Information We Collect Automatically

 

Browser information – Automatically collected via analytics systems, including your IP address, domain name, referring websites, login data, browser type and version, time zone, plug-in types, operating system, and platform (“Browser information”);

Log information – Automatically generated and stored from your use of Digital Card Services websites, applications, tools, or services. This may include:

 

- Device information: device ID, OS, model, MAC address, SIM info

- Usage signals: user interactions, marketing identifiers, battery usage, network address location and system activity

- Website interactions: full URL clickstreams, page response times, errors, duration of visits, scrolling, clicks, mouse-overs, and navigation methods (“Log information”).

Information We Receive from Other Sources

We may also receive your personal data from third parties, including:

- Banks or financial institutions you use to send funds, which may provide us with your name, address, and account information.

- Business partners who may share your name, address, and financial details.

- Our card-issuing partners, who provide transaction details and fraud-risk signals to help us display your activity, investigate disputes, and meet compliance requirements.

- Advertising networks, analytics providers, and search providers, who may supply de-identified or anonymized data to help us understand how you found or use our services.

- Service providers who assist with fraud prevention, security, AML, sanctions, or identity verification and may provide confirmation of identity attributes or risk factors.

- Credit reference agencies, which may provide us with personal data during credit checks.

 

We may also collect and store data written on blockchains, public ledgers, or any information otherwise available in the public domain.

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