# Privacy Policy
# 1. Introduction, Scope and Data Controller
## 1.1 Introduction
BitBank is committed to protecting the privacy and personal data of all individuals who access or use the BitBank Platform.
This Privacy Policy explains how BitBank collects, uses, stores, shares and protects personal data in connection with the Platform, its services and related products.
BitBank processes personal data in accordance with applicable data protection and privacy laws and is committed to ensuring transparency, accountability and security throughout the processing of personal information.
## 1.2 Scope
This Privacy Policy applies to all services, products and digital environments operated by BitBank, including, without limitation:
* the BitBank website;
* user accounts;
* the Marketplace;
* Swap services;
* Treasury services;
* QUSD;
* future BitBank digital assets and tokens;
* blockchain-related services;
* APIs and developer services;
* mobile applications;
* customer support services;
* promotional websites;
* BitBank Hardware Wallets;
* firmware, companion software and related device services.
This Privacy Policy applies regardless of the technology used to access the Platform.
## 1.3 Data Controller
For the purposes of applicable data protection legislation, BitBank acts as the Data Controller for personal data processed through its Platform unless otherwise expressly stated.
Where certain services involve third-party providers acting independently, those providers may act as separate Data Controllers or Data Processors under their own privacy policies.
## 1.4 Legal Framework
BitBank processes personal data in accordance with applicable privacy and data protection legislation, including, where applicable:
* the UK General Data Protection Regulation (UK GDPR);
* the Data Protection Act 2018;
* the EU General Data Protection Regulation (EU GDPR), where applicable;
* applicable anti-money laundering legislation;
* financial crime prevention regulations;
* other applicable privacy and cybersecurity laws.
Where local legislation provides additional protections, BitBank will process personal data in accordance with those mandatory legal requirements.
## 1.5 Definitions
For the purposes of this Privacy Policy:
**"Personal Data"** means any information relating to an identified or identifiable natural person.
**"Processing"** means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer or deletion.
**"Platform"** means the BitBank ecosystem, including all websites, applications, blockchain services, Marketplace, Swap services, Treasury services, digital assets and Hardware Wallet services operated by BitBank.
**"User"** means any individual or legal entity accessing or using the Platform.
**"Hardware Wallet"** means any BitBank-branded hardware device, accessory or related software designed for managing supported digital assets.
## 1.6 Acceptance
By accessing or using the Platform, Users acknowledge that they have read and understood this Privacy Policy.
Where consent is required under applicable law for specific processing activities, BitBank will obtain such consent before processing the relevant Personal Data.
## 1.7 Relationship with Other Policies
This Privacy Policy should be read together with:
* the Terms and Conditions;
* the Cookie Policy;
* the AML/KYC Policy;
* the Risk Disclosure;
* the Disclaimer;
* any additional policies published by BitBank relating to specific services or products.
Where a conflict exists between this Privacy Policy and a product-specific privacy notice, the product-specific notice shall prevail solely with respect to that service.
## 1.8 Contact
Questions regarding this Privacy Policy or the processing of Personal Data may be submitted through the official contact channels published on the BitBank website.
BitBank will respond to privacy-related requests in accordance with applicable legal requirements.
# 2. Personal Data We Collect
## 2.1 General Principle
BitBank collects only the Personal Data reasonably necessary to provide its services, comply with legal obligations, protect the security of the Platform and improve the User experience.
The categories of Personal Data collected depend on the services used by the User.
## 2.2 Account Information
When a User creates an account, BitBank may collect:
* full name;
* username;
* email address;
* telephone number;
* country of residence;
* date of birth;
* account credentials;
* language preferences;
* account settings.
## 2.3 Identity Verification (KYC)
Where identity verification is required, BitBank may collect:
* government-issued identification documents;
* passport information;
* national identity cards;
* driver's licence information;
* photographs;
* selfie verification;
* proof of address;
* tax identification numbers where legally required;
* information obtained through verification providers.
Additional documentation may be requested where required by applicable law or internal compliance procedures.
## 2.4 Financial and Transaction Information
BitBank may collect information relating to Platform transactions, including:
* wallet addresses;
* blockchain transaction hashes;
* supported digital assets;
* deposits;
* withdrawals;
* Marketplace transactions;
* Swap transactions;
* Treasury interactions;
* payment references;
* transaction timestamps;
* transaction status.
Blockchain records are generally public and may remain permanently accessible on the relevant blockchain.
## 2.5 Hardware Wallet Information
Where Users purchase, activate or use BitBank Hardware Wallets, BitBank may collect:
* device serial number;
* device model;
* firmware version;
* activation status;
* warranty information;
* support history;
* shipping information;
* repair or replacement records;
* device diagnostics submitted by the User.
Private keys, recovery phrases and PIN codes are **not** intentionally collected or stored by BitBank.
Where supported Hardware Wallet models include biometric authentication, biometric templates are intended to remain stored locally within the secure hardware of the device and are not transmitted to BitBank unless expressly stated for a specific service.
## 2.6 Technical Information
BitBank may automatically collect technical information, including:
* IP addresses;
* browser type;
* operating system;
* device identifiers;
* application version;
* language settings;
* login timestamps;
* session identifiers;
* crash reports;
* security logs;
* performance metrics.
## 2.7 Communications
When Users communicate with BitBank, Personal Data may be collected through:
* customer support requests;
* email correspondence;
* live chat;
* contact forms;
* support tickets;
* surveys;
* feedback submissions.
Communications may be recorded where permitted by applicable law for quality assurance, fraud prevention or regulatory compliance.
## 2.8 Cookies and Similar Technologies
BitBank may collect information through:
* cookies;
* local storage;
* session identifiers;
* analytics technologies;
* security cookies;
* similar tracking technologies.
Additional information is available in the BitBank Cookie Policy.
## 2.9 Information from Third Parties
BitBank may receive Personal Data from trusted third parties, including:
* identity verification providers;
* blockchain analytics providers;
* payment processors;
* fraud prevention services;
* sanctions screening providers;
* business partners;
* public blockchain networks;
* publicly available sources where legally permitted.
## 2.10 Information We Do Not Intentionally Collect
Except where expressly required for a specific service, BitBank does **not** intentionally collect or store:
* Hardware Wallet recovery phrases;
* private cryptographic keys;
* wallet PIN codes;
* wallet passwords;
* decrypted wallet contents;
* biometric templates stored locally on supported Hardware Wallets.
Users remain solely responsible for safeguarding this information.
## 2.11 Accuracy of Information
Users are responsible for ensuring that the Personal Data provided to BitBank remains accurate, complete and up to date.
BitBank may request updated information where necessary to maintain compliance with legal, security or operational requirements.
## 2.12 Children's Data
The Platform is not intended for individuals who are not legally permitted to use BitBank services under applicable law.
BitBank does not knowingly collect Personal Data from children or other individuals who are legally ineligible to use the Platform. Where such data is identified, BitBank will take reasonable steps to delete it in accordance with applicable legal requirements.
# 3. How We Use Personal Data
## 3.1 General Purposes
BitBank processes Personal Data only where necessary to operate the Platform, provide requested services, comply with legal obligations and protect the security of its Users and infrastructure.
Personal Data is processed only for legitimate and lawful purposes.
## 3.2 Account Management
BitBank may use Personal Data to:
* create and manage User accounts;
* authenticate Users;
* verify account ownership;
* maintain account security;
* recover accounts;
* provide customer support;
* manage account preferences.
## 3.3 Marketplace Services
Personal Data may be processed to:
* facilitate Marketplace transactions;
* verify participants;
* prevent fraudulent activity;
* process transaction records;
* resolve disputes;
* improve Marketplace functionality.
## 3.4 Swap Services
BitBank may process Personal Data to:
* execute swap transactions;
* interact with supported blockchain networks;
* calculate applicable fees;
* monitor transaction status;
* verify transaction integrity;
* manage liquidity operations.
## 3.5 Treasury Services
Personal Data may be processed in connection with:
* issuance of digital assets;
* redemption operations;
* treasury reconciliation;
* blockchain settlement;
* reserve management;
* transaction verification;
* operational auditing.
## 3.6 QUSD and Future BitBank Digital Assets
BitBank may process Personal Data to administer QUSD and any future BitBank-issued digital assets, including:
* issuance;
* transfers;
* redemption;
* compliance verification;
* transaction monitoring;
* blockchain reporting;
* security controls.
The same processing principles apply to future BitBank tokens unless otherwise stated in a product-specific privacy notice.
## 3.7 Hardware Wallet Services
Where Users purchase or use BitBank Hardware Wallets, Personal Data may be processed to:
* register devices;
* activate warranty coverage;
* deliver firmware updates;
* provide technical support;
* manage repairs or replacements;
* verify ownership;
* investigate hardware issues;
* improve device security.
BitBank does not intentionally process Users' private keys, recovery phrases or locally stored biometric templates.
## 3.8 Identity Verification and Compliance
Personal Data may be processed to:
* perform KYC verification;
* comply with AML and CTF obligations;
* conduct sanctions screening;
* perform risk assessments;
* detect suspicious activity;
* satisfy regulatory reporting obligations;
* respond to lawful requests from competent authorities.
## 3.9 Security and Fraud Prevention
BitBank processes Personal Data to:
* detect unauthorized access;
* prevent fraud;
* monitor cybersecurity threats;
* investigate security incidents;
* protect digital assets;
* secure Platform infrastructure;
* maintain audit logs.
Automated systems may assist in identifying suspicious activity requiring further review.
## 3.10 Service Improvement
BitBank may process Personal Data to:
* improve Platform performance;
* analyze service usage;
* identify technical issues;
* optimize user experience;
* develop new products and services;
* improve Hardware Wallet functionality;
* perform internal testing.
Where reasonably possible, aggregated or anonymized information may be used for analytical purposes.
## 3.11 Communications
BitBank may use Personal Data to:
* respond to support requests;
* provide service notifications;
* send security alerts;
* communicate important legal or operational updates;
* notify Users of changes affecting their accounts or services.
Where required by applicable law, marketing communications will only be sent with the appropriate legal basis or consent.
## 3.12 Legal Bases for Processing
Depending on the circumstances, BitBank processes Personal Data on one or more of the following legal bases:
* performance of a contract;
* compliance with legal obligations;
* legitimate business interests;
* protection of vital interests;
* consent, where required;
* any other lawful basis recognized under applicable data protection legislation.
BitBank limits processing to what is reasonably necessary for each identified purpose.
# 4. Data Sharing, International Transfers, Security and Retention
## 4.1 General Principle
BitBank does not sell Personal Data.
Personal Data is shared only where reasonably necessary to operate the Platform, provide requested services, comply with legal obligations or protect the legitimate interests of BitBank and its Users.
## 4.2 Service Providers
BitBank may share Personal Data with carefully selected service providers that assist in operating the Platform, including:
* cloud infrastructure providers;
* hosting providers;
* customer support providers;
* payment processors;
* identity verification providers;
* blockchain analytics providers;
* cybersecurity providers;
* software development and maintenance providers;
* communication service providers;
* logistics and shipping providers for Hardware Wallet products.
All service providers are required to process Personal Data only in accordance with applicable contractual and legal obligations.
## 4.3 Blockchain Networks
Certain transaction information is transmitted to public blockchain networks in order to process digital asset transactions.
Blockchain networks operate independently of BitBank and may permanently record transaction data.
BitBank cannot modify or delete information that has been recorded on a public blockchain.
## 4.4 Regulatory Authorities
BitBank may disclose Personal Data where required or permitted by applicable law, including disclosures to:
* courts;
* law enforcement agencies;
* financial intelligence units;
* tax authorities;
* regulatory agencies;
* supervisory authorities;
* government bodies.
Such disclosures may occur without prior notice where legally permitted or required.
## 4.5 Business Transfers
If BitBank undergoes a merger, acquisition, corporate restructuring, financing transaction or sale of assets, Personal Data may be transferred as part of that transaction, subject to applicable legal requirements.
Users will be informed where required by law.
## 4.6 International Data Transfers
Personal Data may be processed or stored in countries outside the User's country of residence.
Where applicable data protection legislation requires safeguards for international transfers, BitBank will implement appropriate measures, which may include:
* adequacy decisions;
* Standard Contractual Clauses (SCCs);
* International Data Transfer Agreements (IDTAs);
* other legally recognized transfer mechanisms.
## 4.7 Security Measures
BitBank implements reasonable technical and organizational security measures designed to protect Personal Data, including, where appropriate:
* encryption;
* secure communication protocols;
* access controls;
* authentication mechanisms;
* network security monitoring;
* audit logging;
* vulnerability management;
* backup and disaster recovery procedures.
Despite these measures, no electronic system or internet transmission can be guaranteed to be completely secure.
## 4.8 Hardware Wallet Privacy
BitBank Hardware Wallets are designed to maximize User privacy.
Unless expressly required for a specific service, BitBank does **not** receive or store:
* private cryptographic keys;
* recovery phrases;
* wallet PIN codes;
* locally stored biometric templates;
* decrypted wallet contents.
Certain diagnostic information may be transmitted only where the User voluntarily requests technical support or explicitly enables diagnostic services.
## 4.9 Data Retention
BitBank retains Personal Data only for as long as reasonably necessary to:
* provide Platform services;
* fulfill contractual obligations;
* comply with legal and regulatory requirements;
* resolve disputes;
* prevent fraud;
* protect legal rights;
* maintain security records.
Retention periods vary depending on the nature of the data and applicable legal obligations.
## 4.10 Secure Deletion
When Personal Data is no longer required and no legal obligation requires continued retention, BitBank will securely delete, anonymize or irreversibly de-identify the data using reasonable technical and organizational measures.
Certain blockchain transaction records cannot be deleted because they are permanently recorded on decentralized blockchain networks.
## 4.11 Confidentiality
Access to Personal Data is limited to authorized personnel and service providers who require such access to perform their legitimate duties.
All persons processing Personal Data on behalf of BitBank are subject to appropriate confidentiality obligations.
## 4.12 Continuous Review
BitBank regularly reviews its security measures, data processing practices and retention procedures to maintain compliance with evolving legal requirements, technological developments and industry best practices.
# 5. User Rights and Final Provisions
## 5.1 User Rights
Subject to applicable data protection laws, Users may have the right to:
* access their Personal Data;
* obtain a copy of their Personal Data;
* request correction of inaccurate or incomplete Personal Data;
* request deletion of Personal Data;
* request restriction of processing;
* object to certain processing activities;
* request data portability;
* withdraw consent where processing is based on consent.
The availability of these rights may vary depending on the applicable legal framework.
## 5.2 Exercising Your Rights
Users may exercise their privacy rights by contacting BitBank through the official communication channels published on the BitBank website.
BitBank may request reasonable proof of identity before responding to requests in order to protect Personal Data from unauthorized disclosure.
## 5.3 Response Time
BitBank will respond to privacy requests within the timeframes required by applicable law.
Where a request is particularly complex or involves multiple requests, BitBank may extend the response period where legally permitted and will inform the User accordingly.
## 5.4 Withdrawal of Consent
Where Personal Data is processed on the basis of consent, Users may withdraw that consent at any time.
Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
Certain services may become unavailable if consent is withdrawn and no alternative legal basis exists for the processing.
## 5.5 Complaints
Users who believe that their privacy rights have been violated may contact BitBank to seek resolution.
Where provided by applicable law, Users also have the right to lodge a complaint with the competent data protection authority in their jurisdiction.
## 5.6 Cookies
BitBank uses cookies and similar technologies to:
* operate the Platform;
* enhance security;
* remember User preferences;
* improve performance;
* analyze Platform usage.
Further information regarding cookies is available in the BitBank Cookie Policy.
## 5.7 Hardware Wallet Privacy
BitBank Hardware Wallets are designed to maximize User control over digital assets and sensitive information.
Except where a User voluntarily enables optional cloud-based or support-related services, confidential wallet information remains under the User's exclusive control.
Users remain solely responsible for securely storing:
* recovery phrases;
* private keys;
* PIN codes;
* backup credentials.
BitBank cannot recover this information if it is lost.
## 5.8 Changes to this Privacy Policy
BitBank may update this Privacy Policy from time to time to reflect:
* changes in applicable law;
* new Platform services;
* future BitBank digital assets;
* Hardware Wallet products;
* technological developments;
* security improvements;
* operational requirements.
Updated versions will be published on the BitBank website and will become effective on the date specified unless otherwise required by applicable law.
## 5.9 Contact Information
Questions regarding this Privacy Policy, Personal Data or privacy rights may be submitted through the official contact channels published on the BitBank website.
BitBank will make reasonable efforts to respond to all legitimate privacy inquiries in accordance with applicable law.
## 5.10 Effective Date
This Privacy Policy becomes effective on the date specified by BitBank and remains in force until amended or replaced.
By accessing or using the BitBank Platform, Users acknowledge that they have read, understood and accepted this Privacy Policy.
