This Privacy Policy governs the practices of how FVC digital Ltd (referred to herein as “FVC Digital Ltd”, “we”, “our”, “ours” or “us”) collects, uses, transfers, and shares personal information related to the use of our Services by our Users (referred to herein as “you”, “your”, or “yours”). This Policy is designed to ensure the transparent, lawful, equitable, and secure management of the personal data of our Users.
Our Privacy Policy explains the kind of personal data we gather through Services, which include services you access through FVC digital Ltd websites and any other sites associated with FVC digital Ltd (collectively referred to as “the Website”), FVC digital Ltd applications and software developed by FVC digital Ltd independently or through contractual third parties, including the self-custodial wallets, web applications, mobile applications, trading platforms, and any other applications and software associated with FVC digital Ltd (collectively referred to as “the Platform”) as well as all products, smart contracts, and protocols. It demonstrates how and why we collect personal data, our purposes for its use, and the third parties with whom we may share it. Moreover, it explains how you as a data subject may exercise your rights in relation to your personal data.
Designed to adhere to British Virgin Islands’ legal provisions, our Policy ensures the transparent, lawful, just, and secure handling of our Users’ personal information.
Should any alterations be made to this Policy (alongside other policies, including our Terms of Service), we will notify you of such changes through our official communication channels, including email, and internal notifications, as well as directly on this page.
We strongly encourage you to read this Policy in its entirety to understand the processes involving your data and your associated rights. For inquiries related to this Privacy Policy, data collection and usage, data disclosure, and sharing, or any other concerns or requests related to your personal data, please do not hesitate to get in touch with us by writing to us at info@fvcdigital.com
The following section covers the basic definitions used in this Privacy Policy. It describes what is meant by your personal data and who controls and processes your personal data.
Personal Data: Personal data means any information that relates to an identified or identifiable natural person. This includes details like names, addresses, email addresses, identification numbers, and even things like IP addresses or cookie identifiers, as well as any information found online that may reveal your physical, genetic, mental, economic, cultural or social identity.
Data Subject: The data subject is the person who the personal data is about, or their representative. In simpler terms, it is you or any other individual whose personal information is being collected and processed.
Data Controller: The data controller is the one who determines the purposes and means of processing personal data. In other words, they're the boss when it comes to deciding why and how your data is used. In this case, it would be us.
Data Processor: The data processor, on the other hand, processes personal data on behalf of the data controller. In our case, they are vendors and partners we collaborate with that process your personal data for purposes determined by us.
GDPR- covered user: GDPR-covered user refers to the individuals whose personal data is subject to the protections and regulations set forth by the General Data Protection Regulation (GDPR). GDPR is the regulation in European Union (EU) law that focuses on data protection and privacy for individuals within the EU and the European Economic Area (EEA). In compliance with the European Securities and Markets Authority (ESMA) guidelines under the Markets in Crypto-Assets Regulation (MiCAR) as at April 2025, we do not accept clients from these jurisdictions unless they have independently sought our services without any prior engagement, marketing, or solicitation from us.
For Users residing in British Virgin Islands: FVC digital Ltd is the sole controller of your personal data under the British Virgin Islands Data Protection Act 2021 (“DPA”). As the sole controller, FVC digital Ltd is responsible for providing you with relevant information regarding data processing and responding to your requests and inquiries.
Please see the table below for detailed information about the FVC digital Ltd Entity. You can see more about how you can exercise your rights as a data subject under Section 8 of this Policy.
Information that You Provide
This category covers content and details that you provide while accessing and using our Services. We collect the following personal information as outlined in the table below:
Category of personal information | Examples of personal information (list non-exhaustive) |
Basic User Data | Email address |
Verification Data | Photo of identification document, Face photo |
Location Data | GPS coordinates, Location history, Wi-Fi access point data, IP addresses |
Wallet Data | Wallet address |
Usage Data | Website or Platform usage patterns, Session durations, Pages visited, Clickstream data, Error logs and crash reports |
Communications Data | Information provided to you through our official communication channels and in the course of our communication with you through these channels |
Information from Third Parties
In our continuous effort to provide you with our Services, we may obtain personal data from third-party partners and vendors. In case of such integration, the information collected by our partners is shared with us. We require our partners to have lawful purposes to collect, process, and use your personal data before sharing it with us. There are multiple instances in which we may collect personal information from third-party partners and vendors, which you can see in the table below.
Category of personal information | Examples of personal information (list non-exhaustive) |
Blockchain Data | We may collect publicly available blockchain data to monitor and detect illegal activities, including those defined by applicable laws and regulations. This data may include blockchain transaction details, public wallet addresses, and other relevant blockchain information. |
Analytics Data | This data includes information we receive from our analytics partners and service providers to help us gain insights into how you use and interact with |
Category of personal information | Examples of personal information (list non-exhaustive) |
| our Services. Information received from such partners may include Website usage statistics, Interactions, Questionnaire and survey responses, and Age groups. |
Research Data | In some cases, we will use the services of third-party providers to conduct research related to our Services to learn of how our Users interact with our Services, their expectations of using the Services, and User experiences. We ensure that the information we receive from such partners is always pseudonymized. |
Information Collected Automatically
This type of information is collected from you without the involvement of us or our third-party partners, mainly by your access to the Website and the Platform and the use of our Services. Such information includes the following categories and examples:
Category of personal information | Examples of personal information (list non-exhaustive) |
Platform, Website, and Device Data | Device characteristics and identifiers, Device information, Operating system information, Browser type and information, IP addresses, Information about the network used, Plugin data, etc. |
Activity Data | Clickstream information, or the information about what you click on when interacting with the Website and the Platform |
Troubleshooting Data | This includes data related to the diagnostic and performance information, such as crash logs, timestamps, performance logs, error messages, etc. |
Cookies Data | This data includes information received from the use of cookies. |
Communications
If you reach out to us directly, we may request additional information such as your name, email address, personal address, phone number, and other relevant personal details. Whenever we ask for this information during communication, we will clearly explain the reasons behind it.
Please note that we will never ask you to provide your private keys when communicating with you.
You should exercise caution and responsibility regarding the handling and safeguarding of your
cryptocurrency wallet's private keys. In the event of a private key loss or compromise, we cannot intervene or rectify the situation. You are solely responsible for the protection and retention of your private keys.
You understand and agree that by creating an Account and using our Services, you expressly consent to the collection and processing of your data in accordance with this Policy. We process your data with your explicit consent.
Processing without consent may occur when any of the following exceptions are met:
the prevention or detection of crime or for the purpose of investigations;
the apprehension or prosecution of offenders; or
the assessment or collection of any tax or duty or any other imposition of a similar nature.
Lawful Basis
In the table below you will find the list of purposes for which we may use your data, and what lawful bases we may invoke for its use.
Lawful Basis | How we use your data | Category of Personal Information |
Performance of a contract, and Consent | Creating your FVC digital Ltd Account: in order to ensure your access to and use of our Services and the entire functionality of the FVC digital Ltd ecosystem. | Basic User Data, Location Data, Wallet Data |
Providing and Maintaining Services: Managing the operation and maintenance of our Services to ensure their functionality and availability, including the availability of the FVC digital Ltd ecosystem and its components as well as maintenance and operability of the Platform and the Website. | Basic User Data, Location Data, Wallet Data, Usage Data, Communications Data, Blockchain Data, Analytics Data, Research Data, Platform, Website, and Device Data, Activity Data, Troubleshooting Data, | |
|
| Cookies Data |
| Providing Customer Support: Communicating with you for customer support, responding to your questions and inquiries via email and through our other official channels of communication. | Basic User Data, Location Data, Usage Data, Communications Data |
| Sending Service Notifications: Providing information and notifications regarding changes and updates to the Services, and important service-related information. | Basic User Data, Usage Data, Communications Data, |
| Sending User Notifications: Sending various communications, including notifications, reminders, and confirmations, to keep you informed about your activities | Basic User Data, Usage Data, Communications Data, |
Lawful Basis | How we use your data | Category of Personal Information |
| involving our Services. |
|
Ensuring Safety and Security: Promoting the safety, security, and integrity of our Services and data through protective measures and ongoing monitoring, including those aimed at preventing fraud and misuse of our Services. | Basic User Data, Location Data, Usage Data, Communications Data, Platform, Website, and Device Data, Activity Data, Troubleshooting Data, Cookies Data | |
Legitimate Interest, and Consent | Service Improvement: Continuously improving the quality, performance, and features of our Services to grow our business continuously, to implement the industry's best practices and adhere to its standards, to attract potential customers and users to use the Services. | Basic User Data, Location Data, Usage Data, Communications Data, Analytics Data, Research Data |
Research and Development: Conducting research and development activities related to our Services, including the development of new features, functionalities of the Platform, and the introduction of new products and services; to improve the functionality of our Services, to ensure the competitiveness of our Services, to grow our business and attract potential customers and users by introducing novel features and ensuring continuous development of the Services. | Basic User Data, Location Data, Usage Data, Communications Data, Analytics Data, Activity Data | |
Measurement and Analytics: Performing measurement and analytics to understand how our users interact with our Services, analyze user behavior, and identify user preferences, to learn how users interact with and use our Services, the Website and the Platform, to conduct studies, to develop marketing strategy and implement amendments to the Services, fixes, and new features | Basic User Data, Location Data, Usage Data, Communications Data, Analytics Data, Research Data | |
Personalization: Tailoring user experiences based on preferences and behaviors for personalized offers and recommendations, to ensure that our users receive information and content that they opt to see, to enhance user experience and customer satisfaction. | Basic User Data, Location Data, Communications Data, Analytics Data, Research Data, Activity Data, Cookies Data | |
Engaging Third-Party Service Providers: Engaging third-party service providers for specific tasks such as research, marketing, analytics, Website and Platform management, development and operability, and customer support. | Basic User Data, Location Data, Usage Data, Communications Data, Blockchain Data, Analytics Data, Research Data, Platform, Website, and Device Data, Activity Data, Troubleshooting Data, Cookies Data |
Lawful Basis | How we use your data | Category of Personal Information |
| User Feedback: Collecting user feedback to improve our services and gather valuable insights, to gather feedback from our users to learn of errors, issues and problems arising from the use of Services, to implement fixes, to develop new features and ensure the customer satisfaction with our Services. | Basic User Data, Location Data, Communications Data, Platform, Website, and Device Data, Activity Data, Troubleshooting Data |
Partnerships and Collaborations: Sharing data with partners, collaborators, or affiliates for joint initiatives, promotions, or integrated services, to ensure certain functionality of our Website and Platform, to develop and grow our business. | Basic User Data, Communications Data, Blockchain Data, Analytics Data, Research Data | |
User Education and Manuals: Providing educational resources and materials to enhance user knowledge and promote secure service usage. | Basic User Data, Research Data | |
Compliance with Our Legal Obligations | Compliance with Laws and Regulations: Ensuring compliance with relevant laws and regulations, including anti-money laundering, terrorism financing, fraud prevention, and other financial crime regulations. Ensuring that we do not deal with funds resulting from proceeds of crime, such as money laundering or terrorist financing, and do not assist in or facilitate in any manner any financial crime and other criminal activities. | Basic User Data, Location Data, Wallet Data, Usage Data, Communications Data, Blockchain Data, Analytics Data, Research Data, Platform, Website, and Device Data, Activity Data, Troubleshooting Data, Cookies Data, Verification Data |
Record-Keeping: Maintaining records for auditing, accounting, and compliance purposes in accordance with applicable laws. | Basic User Data, Location Data, Wallet Data, Usage Data, Communications Data, Blockchain Data, Platform, Website, and Device Data, Activity Data, Troubleshooting Data, Cookies Data |
We do not share or sell any information for purposes of economic gain; however, there will be times in which we will have to disclose your personal information to a third party such as:
We have obtained your clear and written authorization first.
It is necessary to comply with any lawful legal action and/or is required by authorities, such as law enforcement bodies, supervisory authorities and any other authorized person performing public functions.
In the event that we employ the services of a third party to help us provide our online services, or send promotional items to you.
Vendors and Service Providers
We collaborate with vendors and service providers who assist us in maintaining and optimizing our business. These service providers encompass a range of functions, including web and mobile analytics services, advertisers, IT partners, such as hosting and software providers as well as sales and marketing products.
Advertisers
In our commitment to providing you with a seamless experience, we may share certain information with an advertiser who plays a role in enhancing our Services. The information shared with the advertiser may include user preferences, interaction patterns, engagement with advertising campaigns, and interest-based data. Our collaboration with this advertiser aims to provide you with advertisements that align with your preferences and interests.
Law Enforcement
In exceptional circumstances and as required by applicable laws and regulations, we may share your information with law enforcement agencies and competent authorities. This is done to support investigations, maintain legal compliance, and ensure the safety and security of our Services and Users. It may be necessary in the case of court proceedings, complying with a legal order or other legal process, as well as for the purposes of financial crime, money laundering and terrorism financing prevention, if we have strong grounds to believe any natural or legal person to be involved in or associated with the said forms of crime.
Transfers, Mergers, and Acquisitions
In cases of our insolvency, bankruptcy, acquisition, transfer of ownership, sale of assets or succession, your personal information may be disclosed to the new owner, acquirer or successor of the company or other relevant third parties.
We consider the security of your personal information to be of paramount importance. We employ a range of technical, organizational, and administrative measures designed to safeguard your data against unauthorized access, disclosure, alteration, and destruction. These security measures include:
➔ The nature of blockchain technology itself, which inherently provides transparency, immutability, and decentralization. In other words, your transactional and personal data is stored securely across multiple nodes, reducing the risk of unauthorized alterations or data breaches.
➔ Conducting regular audits and updates to identify and mitigate potential vulnerabilities or weaknesses in the Website’s and the Platform's infrastructure.
➔ Data minimization, which means that we collect and store only the minimum amount of personal information necessary to facilitate your transactions and provide our Services. Unnecessary data is not retained, reducing the potential impact of any security incidents.
➔ User education, meaning that we actively provide resources and guidance to educate you about the nature of our Services and blockchain technology in general, blockchain security best practices, and the responsible management of private keys and cryptocurrency assets. In the long term, this self-awareness helps you understand and protect your data.
If you ever have concerns about the security of your data, suspect any unauthorized activity, or would like to know the specific measures undertaken to secure your personal data, please don't hesitate to contact us via email at info@fvcdigital.com
Your personal information is held and stored securely for the duration of your active account with us. We are committed to retaining your personal information only for the period necessary to fulfill the specific purposes for which it was collected. Retention periods may vary depending on the type of personal data, but will not be processed for more than 10 years after the original purpose of collection has been achieved, unless there are specific requirements stipulating otherwise for certain data. After this period, your personal data will only be retained if it has been anonymized.
If you request to delete your account and there is no history of participation in our Services, we will promptly remove your email address from our records. However, if your account contains history, we may retain your email address for archive purposes and to comply with applicable laws and regulations, including anti-money laundering policies. In addition, user data may be anonymized after 12 months of inactivity, and non-essential information is systematically purged during quarterly data reviews to ensure ongoing compliance with our data minimization practices and to enhance user privacy.
As a User of our Services, you have certain rights regarding the personal data that we collect and use. These rights are designed to provide you with control and transparency over your data. The following are your rights as a data subject; you hold the discretion to claim them as long as this does not affect any third-party rights:
Right to Access: You have the right to request access to the personal data we hold about you. This includes the right to obtain confirmation of whether we are processing your personal data and, if so, access to specific details of that processing.
Right to Rectification: If you believe that the personal data, we hold about you is inaccurate or incomplete, you have the right to request the correction or completion of such data.
Right to Erasure (Right to Be Forgotten): You have the right to request the deletion of your personal data under certain circumstances. This right is not absolute and may be subject to legal requirements or legitimate interests that override your request.
Exercising Your Rights
To exercise any of the rights outlined above, or if you have any questions or concerns regarding the processing of your personal data, please contact us via our official communication channels. Our designated personnel will assist you with data-related inquiries and ensure that your rights as a data subject are respected.
Upon receiving a written request from you for access to your personal data, we will inform you in writing within thirty (30) days whether access to all or part of the personal data will be granted, in accordance with the applicable provisions of the DPA. If access is granted, we will provide the requested personal data upon payment of the prescribed fee, if applicable. However, we reserve the right to refuse access to personal data on any of the grounds permitted under Section 16 of the DPA.
We may extend the time limit for compliance with a request for access to personal data to an additional thirty (30) days if:
meeting the original time limit would unreasonably interfere with the operations of the public body or private body; or
consultations are necessary to comply with the request that cannot reasonably be completed within the original time limit; or
by such period of time as is reasonable, if the additional time is necessary for converting the personal data into an alternative format.
We do not ordinarily charge a fee for processing such requests. However, if a request is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee based on the administrative cost of compliance. Alternatively, we may refuse to comply with such a request and will provide a written explanation for our decision in such circumstances.
If the request contains insufficient information or is erroneous, we may request additional details from the data subject. If such additional information is not provided within the timeframe specified under applicable law, the request will be deemed not to have been made.
In addition to the means of exercising your rights outlined above, you have the right to lodge a complaint about our practices with the competent authorities of the country where you reside:
If you reside in British Virgin Islands, your data protection authority is the Office of the Information Commissioner.
If you reside in the EEA or Switzerland, you have the right to lodge a complaint with the data protection authority of your country. You can find the list of data protection authorities of the EU and EEA countries with contact details here:
https://dataprivacymanager.net/list-of-eu-data-protection-supervisory-authorities-gdpr/. In the UK, the supervisory authority is the Information Commissioner’s Office, see the ICO’s official website for more detailed information at https://ico.org.uk/.
What is a cookie?
We use cookies on our website to gather information about our users' interaction with our Services. Information we collect via cookies may include your use of the Website and Platform features, the frequency of your visits, your interaction with the functionalities of the Services, and other relevant information.
Cookies are small pieces of text sent by your web browser when you visit our Website. Cookies may store user preferences and other information. Cookies provide a convenience feature to save you time or tell the Web server that you have returned to a specific page. A cookie file is stored in your web browser and allows the Service or a third party to recognize you and make your next visit easier and the Service more useful to you.
Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.
In addition to persistent and session cookies, cookies can be categorized into first-party and third-party. Cookies set directly by us are called “first-party cookies”. Cookies set by parties other than the website owner are called “third-party cookies”. Third-party cookies enable third-party features or functionality to be provided on or through the website.
When accessing the Website, you will be asked to confirm your choice regarding cookie preferences, such as what cookie categories you wish to accept and which cookies you want to decline, or a choice to decline all cookies altogether. If you choose to accept all or some of these cookies, please note that the following information contained in this Section relates to cookies used on our Website and the Platform only and does not apply to any other pages and websites that may be hyperlinked to our Website. To read more about the categories of cookies used on our Website, please refer to the next subsection. For more general information about cookies and their use, you may visit All About Cookies.
Types of Cookies We Use
We use the following types and categories of cookies on the Website:
● Essential cookies, which are strictly necessary for the proper functioning of the Website and provide basic functionalities such as page navigation and access to secure areas of the website.
● Functional cookies, which are used to enhance website functionality and provide personalized features. For example, these cookies may remember user preferences and settings.
● Session cookies, which are essential for maintaining secure user sessions and enabling functionalities such as user authentication, login persistence, and seamless navigation during a single browsing session.
● Analytics cookies, which are used to gather information about the Website usage and traffic patterns. This data is aggregated and anonymous, helping us understand how visitors interact with the Website and the Platform, gather statistical information, and use it to improve the quality and relevancy of our services.
How You May Control and Delete Cookies
You have a right to change the categories of cookies you consented to, withdraw your consent from the choice made earlier, or refuse to accept cookies altogether even if you consented to some or all of them in the past. You can change your cookie preferences at any time by following the link: https://fvcdigital.com/cookiesettings .
Alternatively, you may choose to block all cookies by accessing the relevant feature in the browser you use to access the Website. Blocking cookies can be done in various ways, depending on the browser and device you're using: to learn about how you can block cookies through the browser of your choice, please visit the settings page of your browser or the dedicated help page.
Please note that if you choose to block all cookies or opt out of their use altogether, some of the functionalities of our Website may become unavailable to you, and we will not be able to provide you with the full range of features and services.
We may periodically update this Privacy Policy to reflect changes in our data processing practices, legal requirements, or to improve transparency and clarity. When we make significant changes to this policy, we will notify you through the Website interface as well as via email associated with your account as soon as the changes are implemented. These notifications will provide a summary of the changes and a link to the updated Privacy Policy for your review.
For any inquiries, requests, or concerns related to this Privacy Policy or our data processing practices, you may always submit written notifications at info@vcdigital.com —we’ll be happy to answer your questions.