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Privacy Policy

Draft. This document is a working draft pending legal review and is not yet in effect.

Effective [Effective date] · Operated by [Legal entity name]

1. Who we are

[Legal entity name], registered in [Jurisdiction] ([Company registration no.]), [Registered address], is the controller of personal data processed through DJYTL Capital. Contact: [privacy contact email].

2. Data we collect

  • Account data: email address, password (stored as a salted hash) and account settings.
  • Verification data: identity and company documents, beneficial ownership and screening results where KYC/KYB is required.
  • Transaction data: orders, trades, balances, deposits, withdrawals, redemptions and linked wallet addresses.
  • Technical data: IP address, device and browser information, and logs needed to secure the Services.
  • Communications: messages you send to support.

Hydra Wallet keys and recovery phrases stay in your browser. We never collect them.

3. How we use data

  • To provide and secure your account and the Services.
  • To meet legal obligations, including anti-money laundering and sanctions screening.
  • To process trades, redemptions and deliveries.
  • To respond to support requests.
  • To improve the Services using aggregated information.

4. Legal bases

We process data to perform our contract with you, to comply with legal obligations, and for our legitimate interests in operating a secure service. [Jurisdiction-specific lawful basis wording — counsel to confirm]

5. Sharing

We share data only as needed with: custodians, warehouses and logistics providers (for redemptions); identity verification and screening providers; infrastructure and hosting providers; professional advisers; and authorities where the law requires. We do not sell personal data.

Transactions on public blockchains, including DJYTL Chain, are visible to anyone and cannot be erased.

6. Retention

We keep account and transaction records for as long as your account is open and afterwards for the period required by law ([retention period]).

7. Your rights

Depending on where you live, you may have the right to access, correct, delete or port your data, and to object to or restrict processing. To exercise these rights, contact [privacy contact email]. You may also complain to your data protection authority.

8. International transfers

[Hosting locations and transfer safeguards]

9. Cookies and local storage

We use browser storage that is strictly necessary to keep you signed in, remember your wallet session and cache prices. We do not use advertising cookies.

10. Changes

We will post updates on this page and notify you of material changes.