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Privacy Policy
Last Updated: 05/01/2026
PRIVACY POLICY
Last Updated: 04/01/2026 Compliance: GDPR (EU 2016/679) & MiCA Data Standards
1. DATA CONTROLLER
AURUMRWA Ltd. 123 Finance Street, Dublin, Ireland DPO Contact: dpo@aurumrwa.com
2. DATA WE COLLECT
2.1 Information You Provide
- Identity Data: Name, Passport/ID, Selfie, Address (for KYC).
- Contact Data: Email, Phone number.
- Financial Data: Source of funds, Tax ID, Bank account details.
2.2 Automated Collection
- Blockchain Data: Public wallet address, transaction history (on-chain data is public).
- Device Data: IP address, Browser type, Time zone.
3. HOW WE USE YOUR DATA
- Service Provision: To process investments and manage token ownership.
- Regulatory Compliance: To comply with AML/CFT (Anti-Money Laundering) directives (5AMLD/6AMLD).
- Security: To detect fraud and unauthorized access.
Legitimate Interest: We analyze on-chain activity to prevent market abuse (MiCA Art. 87).
4. BLOCKCHAIN & DATA IMMUTABILITY
WARNING: Data written to the blockchain (Wallet Address, Transaction Amounts) is immutable and publicly visible.
- We cannot erase data from the blockchain.
- By using the service, you acknowledge this inherent characteristic of DLT (Distributed Ledger Technology).
- We do NOT store your name or physical address on-chain.
5. DATA SHARING
We share data with:
- KYC Providers: Sumsub, Onfido (for identity verification).
- Custodians: If assets are held by third-party custodians.
- Regulators: When required by law (e.g., Suspicious Activity Reports).
6. YOUR RIGHTS (GDPR)
- Access: Request a copy of your data.
- Rectification: Correct errors (mostly off-chain data).
- Erasure: "Right to be forgotten" (applies to off-chain databases only).
- Portability: Receive your data in JSON/CSV.
To exercise rights, utilize the Data Request Form in your dashboard settings.
7. SECURITY MEASURES
We use AES-256 encryption, role-based access control (RBAC), and regular penetration testing. However, no system is 100% secure.