Holyheld Privacy Policy

Last Update: 07.12.2023

UAB Holyheld Financial, business identity code 306129001, a company incorporated in Lithuania with its registered office at Gabijos Str. 32, Vilnius, 06155, Lithuania is the data controller responsible for the collection of your personal data.

This privacy policy (“Privacy Policy”) provides an insight into how Holyheld (“Holyheld”, “We”, “us”, “our”) and all platforms affiliated with Holyheld, including but not limited to the Holyheld Websites, and Applications(collectively “Platforms”) collect, share or use data about you (“user(s)”, “You”, “your”) with connection to the Platforms.

The Privacy Policy, together with our Terms and Conditions (“Terms”) insert link governs the processing of your data and is applicable to all the information collected through the Platforms, upon the use of such Platforms, (collectively, the “Services”).

What information is collected?

When you use our Services, we may automatically log standard data whether directly provided by users, collected automatically, or collected from third parties, as described below.

In certain cases, your consent to use personal information may be required, which may be withdrawn at any time, by reaching out to us via the contact details provided in this Privacy Policy or our Platforms. We shall get in touch with you every time we need your consent to process any data, which is the case when sensitive data is collected. We adhere to SCA requirements, and also follow PCI DSS Level 2 requirements.

We may also need to collect and process additional personal information in order to provide services, perform any contractual obligations, or form any/all legal compliance. In such cases, we shall get in contact with you directly.

How is the information collected?

Information provided directly by users

We collect personal data that the user provides directly, including wallet address, application access password, terms of usage or privacy policy consent signature, user settings, messages sent to support chat directly linked to the user wallet address and images uploaded to support chat linked to a wallet address.

Information collected automatically

We collect personal data automatically, including IP address, User-Agent ID, Service authentication cookie, wallet transaction history related to our smart contracts, approved and control addresses action logs, card transaction logs, and application type.

Information collected from third parties

We also collect personal data from third parties. This information may include but is not limited to KYC and AML verification data, fraudulent actions archive & detection results, connected wallet balances, Banking data: account, transactions, balances.

How is the information used?

We may use the collected information for the following purposes:

Providing services to you, which include, but are not limited to open an account, process payments, operating and managing the services; performing services requested by you such as responding to your comments, questions, and requests, and providing information support; sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages; detecting, preventing, and addressing fraud, breach of Terms, and threats, or harm; and compliance with legal and regulatory requirements.
marketing and business activities in relation to our services, including but not limited to newsletters sending, updates, marketing communications and other information that may be of interest to you;
complying with legal and regulatory obligations, including KYC/AML requirements.
monitoring the use of Platforms for business purposes which may include analysis of usage, measurement of site performance and generation of marketing reports;
for legitimate business interests, such as business research and analysis, managing our Platforms and Services;
looking into any complaints or queries;
preventing and responding to actual or potential fraud or illegal activities;
operating our Platforms, customer support, marketing and research services related to the Platforms;
Cookies used are strictly necessary for the smooth functioning of the Platforms and Services;
Protecting the security and integrity of the Services; improving the Services and other websites, apps, products and services.
exercising or defending any legal rights;

We share personal information with and third-party service providers, including our banking partner that assists us in providing service. This may include, but is not limited to, sharing information with third-party contractors, bound by obligations of confidentiality, in connection with the processing of your personal information for the purposes described in this Privacy Policy, such as but not limited to, IT and communications service providers, third parties relevant to the services that we provide including regulators, authorities and governmental institutions.

We may transfer personal information outside Europe. In such cases, we shall ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information.

Your consent does not preclude the exercise of your rights under any data privacy laws and regulations applicable to you and also under this Privacy Policy.

How is your information secure?

We ensure that your personal information collected by us is subject to appropriate security measures. As per the PCI DSS security standard requirements we regularly conduct external vulnerability scanning services operated by an Approved Scanning Vendor (ASV) duly qualified by the PCI DSS, that uses specialist security tools to find any weaknesses or holes in our systems that hackers may attempt to exploit.

Professional Advisors - we share information for audits and legal compliances with our professional advisors.

Security and Compelled Disclosure - Information stored by us is shared with public officials for legal compliance enforcement and authorised security concerns.

We only store your information for a limited period of time and strictly only for as long as is necessary for the relevant purpose and/or for as long as it is necessary to comply with legal obligations, laws or regulations.

Fulfilling your Requests - we may share your information with you with your consent at your request or direction.

Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law.

How do we use cookies?

Cookies are sent to your browser from the Platforms and stored on your device. Tracking Technologies such as beacons, $holytags, and scripts are used to collect and track information and to improve and analyse our Services.

We may use and integrate third-party applications with our platforms to improve the user experience. Cookies by such a third party may be placed on your browsing device, and they can be managed by checking the third party’s website for more information about cookie management and how to "opt-out" of receiving cookies from them.

You may instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

How do we store or transfer information?

The personal information collected by us may be transferred to and processed in countries outside the European Economic Area (“EEA”) and the United Kingdom (“UK”). We will take all necessary steps to ensure that your personal information is treated securely and in accordance with this Privacy Policy.

For any transfers of data outside the EEA or the UK, the data transfer will be under the European Commission’s model contracts for the transfer of personal information to third countries (i.e., the standard contractual clauses) (the “Model Clauses”), or any equivalent contracts issued by the relevant competent authority of the UK.

For how long do we keep your data?

We may keep your personal data for a maximum period of 7 (seven) years in compliance with the applicable laws and regulations.

How do we protect and ensure your rights?

You are entitled to a certain number of legal rights concerning the personal information we may hold about you. These rights can be exercised at any time by contacting us. The following rights apply regarding the collection of your personal information:

Right to Access: you have the right to access your personal information stored with us, how we use it, and who we share it with.

Right of Portability: you have the right to receive a copy of all your personal information stored by us in a structured, commonly used and machine-readable format and/or request transfer of the same to a third party, in certain circumstances and with certain exceptions. Right to Rectification: you have the right to correct any inaccurate personal information.

Right to Deletion of Data and Right to be Forgotten: In certain circumstances, you have the right to delete your personal information stored with us. There may be circumstances where you ask us to erase personal information, but we are legally entitled to retain it; in such circumstances, the same shall not be erased.

Right to restrict processing: you have the right to require us to stop processing the personal information we hold about you, other than for storage purposes, in certain circumstances.

Right to Objection: you have the right to object to our processing of your personal information. There may be circumstances where you object to or ask us to restrict the processing of personal information, but we are legally entitled to refuse that request.

Objection to marketing: you can object to marketing at any time by opting out using the unsubscribe/opt-out function displayed in our communications to you.

Withdrawal of consent: Where we rely on consent to process your personal information, you have the right to withdraw this consent at any time. In certain circumstances it may be lawful for us to continue processing without consent if we have a legitimate reason (other than consent) for doing so.

The aforementioned rights are not absolute and may be limited by law.

Contact Us:

For further information on the collection, use, disclosure, transfer or processing of personal information or the exercise of any of the rights listed above, please contact Holyheld by sending an email to privacy@holyheld.com.

If you have complaints about how we process your personal information, please contact us and we will respond to your request as soon as possible.