Privacy Policy

1. Introduction

Coinly Ltd ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform and services. We are registered as a data controller with the UK Information Commissioner's Office (ICO) under registration number ZA123456.

2. Information We Collect

2.1 Personal Information

We collect information you provide directly to us, including:

• Full name and date of birth
• Email address and phone number
• Residential address
• Government-issued identification documents
• Proof of address documents
• Financial information for transactions
• Selfie/photo for identity verification

2.2 Automatically Collected Information

When you use our Services, we automatically collect:

• Device information (type, operating system, browser)
• IP address and approximate location
• Usage data and browsing patterns
• Transaction history and wallet activity
• Cookies and similar tracking technologies

3. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our Services
• Verify your identity and comply with KYC/AML requirements
• Process transactions and send related information
• Send administrative messages and security alerts
• Respond to your inquiries and provide customer support
• Detect, prevent, and address fraud and security issues
• Comply with legal obligations and regulatory requirements
• Analyze usage patterns to improve user experience

4. Legal Basis for Processing (GDPR)

Under the UK GDPR, we process your data based on:

• Contract: To fulfill our contractual obligations to you
• Legal obligation: To comply with regulatory requirements
• Legitimate interests: For fraud prevention and service improvement
• Consent: For marketing communications (where applicable)

5. Data Sharing and Disclosure

We may share your information with:

• Identity verification service providers
• Payment processors and banking partners
• Cloud hosting and infrastructure providers
• Analytics and monitoring services
• Legal and regulatory authorities when required by law
• Professional advisors (lawyers, accountants, auditors)

We do not sell your personal information to third parties.

6. International Data Transfers

Your information may be transferred to and processed in countries outside the UK and European Economic Area. When we transfer data internationally, we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the UK ICO or adequacy decisions.

7. Data Retention

We retain your personal information for as long as necessary to provide our Services and comply with legal obligations. Under UK anti-money laundering regulations, we are required to retain certain records for a minimum of 5 years after the end of our business relationship. Transaction records may be retained for up to 7 years for tax and regulatory purposes.

8. Your Rights

Under UK GDPR, you have the following rights:

• Access: Request a copy of your personal data
• Rectification: Request correction of inaccurate data
• Erasure: Request deletion of your data (with certain exceptions)
• Restriction: Request limited processing of your data
• Portability: Receive your data in a structured format
• Objection: Object to processing based on legitimate interests
• Withdraw consent: Where processing is based on consent

To exercise these rights, contact us at privacy@coinly.com. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO).

9. Security Measures

We implement industry-standard security measures to protect your data, including 256-bit SSL encryption, secure data centers, access controls, regular security audits, and employee training. However, no method of transmission over the Internet is 100% secure.

10. Contact Us

For privacy-related inquiries or to exercise your rights: