Privacy Policy

Last updated: November 5, 2024

1. Introduction

HoldersPay ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our OTC cryptocurrency trading services.

By using HoldersPay services, you consent to the data practices described in this policy.

2. Information We Collect

2.1 Personal Information

We collect personal information that you provide directly to us, including:

• Identity Information: Full name, date of birth, nationality, government-issued ID numbers
• Contact Information: Email address, phone number, residential address
• Financial Information: Bank account details, transaction history, source of funds
• Documentation: Copies of ID documents, utility bills, bank statements
• Biometric Data: Facial recognition data for identity verification (when applicable)

2.2 Transaction Information

• Trade details (amount, asset type, price, timestamps)
• Wallet addresses and blockchain transaction IDs
• Payment method and settlement information
• Communication records related to trades

2.3 Technical Information

• IP address, browser type, and device information
• Access times and referring website addresses
• Cookies and similar tracking technologies
• Usage data and interaction patterns

3. How We Use Your Information

We use collected information for the following purposes:

• Service Provision: Processing trades, generating quotes, settling transactions
• Compliance: Verifying identity, conducting KYC/AML checks, preventing fraud
• Communication: Sending trade confirmations, updates, and customer support
• Security: Monitoring for suspicious activity and protecting against unauthorized access
• Improvement: Analyzing usage patterns to enhance our services
• Legal Obligations: Complying with legal and regulatory requirements
• Marketing: Sending promotional communications (with your consent)

4. Legal Basis for Processing (GDPR Compliance)

We process your personal data based on:

• Contractual Necessity: Processing required to provide services you've requested
• Legal Obligation: Compliance with KYC/AML regulations and financial laws
• Legitimate Interest: Fraud prevention, security, and service improvement
• Consent: Where you've explicitly agreed to data processing

5. Information Sharing and Disclosure

We may share your information with:

5.1 Service Providers

• Banking Partners: JMMB Bank for fiat settlement
• Custody Providers: Fireblocks for crypto asset custody
• Compliance Services: Chainalysis for transaction monitoring
• Identity Verification: Third-party KYC/AML service providers
• Cloud Services: Secure data storage and hosting providers

5.2 Legal and Regulatory Authorities

We disclose information when required by law, including:

• Financial Services Commission (FSC) of Jamaica
• Financial Investigations Division (FID)
• Law enforcement agencies pursuant to valid legal requests
• Tax authorities as required by applicable tax laws

5.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.

6. Data Security

We implement industry-standard security measures to protect your information:

• Encryption: SSL/TLS encryption for data in transit, AES-256 for data at rest
• Access Controls: Role-based access, multi-factor authentication, and least-privilege principles
• Multi-Signature Wallets: Enhanced security for crypto asset custody
• Regular Audits: Periodic security assessments and penetration testing
• Monitoring: 24/7 security monitoring and incident response protocols

Note: No method of transmission over the internet is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

7. Data Retention

We retain your personal information for as long as necessary to:

• Provide services and maintain your account
• Comply with legal and regulatory obligations (typically 7 years for financial records)
• Resolve disputes and enforce agreements
• Prevent fraud and ensure security

After the retention period, we securely delete or anonymize your data.

8. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights:

• Access: Request a copy of the personal data we hold about you
• Rectification: Request correction of inaccurate or incomplete data
• Erasure: Request deletion of your data (subject to legal obligations)
• Restriction: Request limitation of processing in certain circumstances
• Portability: Receive your data in a structured, machine-readable format
• Objection: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent for processing (where applicable)

To exercise these rights, contact us at privacy@holderspay.com

9. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Maintain session state and user preferences
• Analyze site traffic and usage patterns
• Deliver personalized content
• Improve security and detect fraud

You can control cookie preferences through your browser settings, but disabling cookies may limit functionality.

10. International Data Transfers

Your information may be transferred to and processed in countries outside of Jamaica, including the United States and European Union. We ensure appropriate safeguards are in place, such as:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions by relevant authorities
• Binding corporate rules

11. Third-Party Links

Our services may contain links to third-party websites. We are not responsible for the privacy practices of these sites. We encourage you to review their privacy policies.

12. Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we discover we've collected data from a child, we will promptly delete it.

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically. Changes will be posted on this page with an updated "Last Updated" date. Material changes will be communicated via email or prominent notice on our platform.

14. Contact Us

For questions, concerns, or requests regarding this Privacy Policy or our data practices:

Email: privacy@holderspay.com
Compliance Officer: compliance@holderspay.com
Address: Kingston, Jamaica

Your Consent: By using HoldersPay services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your information as described herein.