Data Privacy Policy

Agant Finance Limited ("Agant", "Company," "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 web platform (the "Platform"). By accessing or using the Platform, you agree to the terms of this Privacy Policy.

1. Who we are

1.1 This Privacy Policy applies to all information we collect, use and process about you in relation to our platform and services (the "Platform").

1.2 Agant Finance Limited ("Agant", "we", "us" or "our") is the data controller in respect of personal information that we process in connection with our business.

1.3 Our registered office is 10 Albert Place, Stirling, Scotland, FK8 2QL. You can contact us at [email protected].

1.4 "Personal information" means information about a living individual who can be identified from that information (either by itself or when combined with other information).

1.5 We have not appointed a data protection officer. Privacy queries should be sent to [email protected].

2. The information we process

2.1 We collect and process personal information at the start of and for the duration of our relationship with you and your institution, and beyond (subject to the retention periods below). We limit collection and processing to what is necessary for the purposes set out in this Policy.

2.2 Personal information may include:

(a) basic personal information, including name, date of birth, nationality and contact details;

(b) identification and verification information, including copies of passports or other identity documents, photographs, and the results of identity, sanctions and politically exposed person checks;

(c) information about your role and your institution, including job title, ownership and control information, and source of funds or wealth information;

(d) transaction and account information, including wallet addresses, blockchain transaction history, issuance and redemption instructions and account history;

(e) communications between you and us; and

(f) online and device information, including IP address, browser type, device information and information about how you use the Platform.

2.3 Some of this information is required by law (for example, to meet anti-money laundering and sanctions obligations) or is needed to enter into and perform a contract with you. If you do not provide it, we may not be able to onboard you, operate your account or provide our products and services to you.

3. How we obtain information

3.1 We obtain personal information:

(a) directly from you, when you or your institution apply for or use our products or services, communicate with us or use the Platform;

(b) from your institution and other individuals connected with your institution;

(c) from third party service providers, including identity verification, sanctions screening, fraud prevention and blockchain analytics providers;

(d) from public sources, including company registers, sanctions lists and publicly available information; and

(e) from regulators, law enforcement, courts and other public bodies.

4. How we use your information and our lawful basis

4.1 We use your information to lawfully carry out our business, including to:

(a) onboard you and your institution and provide our products and services;

(b) operate, maintain and improve the Platform;

(c) comply with our legal and regulatory obligations, including anti-money laundering, counter-terrorist financing, sanctions, fraud prevention, tax reporting and record-keeping obligations;

(d) prevent, detect and investigate financial crime, fraud and misuse of the Platform, including by conducting blockchain analysis;

(e) manage our relationship with you and respond to your queries;

(f) protect our rights and property and the security of the Platform; and

(g) send you communications about our services and, where you have agreed, marketing communications.

4.2 We rely on one or more of the following lawful bases under the UK GDPR:

(a) performance of a contract with you or your institution;

(b) compliance with a legal or regulatory obligation;

(c) our legitimate interests, including in running, protecting and developing our business, preventing fraud and financial crime, ensuring the security of the Platform and conducting blockchain analysis, where these are not overridden by your interests or rights; and

(d) your consent, where we ask for it.

5. Your rights

5.1 You have the following rights under UK data protection law:

(a) to request access to your personal information;

(b) to request correction of inaccurate or incomplete information;

(d) to request restriction of processing;

(e) to object to processing based on legitimate interests, including direct marketing;

(f) to request portability of information you provided to us;

(g) to withdraw consent at any time, where we rely on consent; and

(h) to lodge a complaint with the Information Commissioner's Office (www.ico.org.uk).

5.2 To exercise any right, contact us at [email protected]. We ask that you raise any complaint with us before contacting the Information Commissioner's Office.

6. Changes to the way we use your information

6.1 We may change this Policy from time to time. Where we believe you may not reasonably expect a change, we will notify you and allow a period of at least 30 days for you to raise any objection before the change takes effect.

7. Sharing your information

7.1 We will not share your information with anyone outside Agant except:

(a) where we have your permission;

(b) where required to provide our products or services to you;

(c) with law enforcement agencies, judicial bodies, government entities, tax authorities, regulators and trade bodies in the UK and overseas;

(d) with third parties in relation to fraud, financial crime or other criminal activity, or suspected fraud, financial crime or other criminal activity, or the monitoring, prevention and investigation of the same;

(e) with third parties providing services to us, including identity verification, sanctions screening, blockchain analytics, banking and custody, cloud hosting and IT services, communications and customer support, and professional advisers;

(f) with third parties to whom we may transfer or sell parts of our business or assets, or who may acquire our business or assets; and

(g) where required or permitted by law.

8. Transferring information overseas

8.1 We may transfer your information to organisations in other countries on the basis that anyone to whom we pass it protects it in the same way we would and in accordance with applicable laws.

8.2 In the event that we transfer information to countries outside the UK, we will only do so where:

(a) the UK has decided that the country or the organisation we are sharing your information with will protect your information adequately;

(b) the transfer has been authorised by the relevant data protection authority; and/or

(c) we have entered into a contract with the organisation with which we are sharing your information (on terms approved by the UK) to ensure your information is adequately protected. If you wish to obtain a copy of the relevant data protection clauses, please contact us at [email protected].

9. How long we keep your information

9.1 When you or your institution apply for or we provide products or services to you, we create records that contain your information.

9.2 We manage our records to help us serve you well and to comply with legal and regulatory requirements.

9.3 Retention periods are determined based on the type of record, the nature of the activity, product or service, and applicable legal or regulatory requirements. We normally keep account records for up to six years after your relationship with us ends, while other records are retained for shorter periods. Retention periods may be changed from time to time based on business or legal and regulatory requirements.

9.4 We may on exception retain your information for longer periods, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators.

9.5 For more information about how long we keep your information, please contact us at [email protected].

10. Cookies

10.1 We use cookies and similar technologies on the Platform. Strictly necessary cookies are used to operate the Platform. Other cookies are used only with your consent, which you can give or withdraw at any time.

11. Marketing

11.1 Where we have your permission, we may send you marketing communications about our products and services. You can withdraw your permission at any time by contacting us at [email protected] or by using the unsubscribe link in our marketing emails.

11.2 We will not share your information with third parties for their own marketing purposes without your permission.

12. Automated processing

12.1 We may process your personal information by automated means. This means we may use software to automatically evaluate information about you or your transactions to identify risks or prevent financial crime. Examples include:

(a) sanctions, politically exposed person and other screening checks;

(b) fraud detection;

(d) decisions about whether to onboard you, process a transaction or maintain your account.

12.2 Where we make a decision about you based solely on automated means and that decision has a legal or similarly significant effect, the logic involves automated comparison of information about you and your transactions against risk indicators, public sanctions and watchlists, and patterns of suspicious activity. The consequences may include refusing to onboard you, blocking or delaying transactions, restricting your access to the Platform or terminating your relationship with us.

12.3 You have the right to request human review of any decision made solely by automated means that has a legal or similarly significant effect on you. To exercise this right, please contact us at [email protected].

13. Contact us

13.1 If you have any questions about this Policy or want to exercise your rights, please contact us at:

Agant Finance Limited
10 Albert Place
Stirling
Scotland
FK8 2QL
[email protected]

By using the Platform, you acknowledge that you have read and understood this Policy.