Privacy Policy

Last Updated: December 17, 2024

Effective Date: December 17, 2024

1. Introduction

CoinShares AI ("Company," "we," "us," or "our") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our automated cryptocurrency trading platform, website, and related services (collectively, the "Platform").

By accessing or using our Platform, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree with our practices, please do not use our Platform.

We are committed to transparency and compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other relevant regulations.

2. Information We Collect

2.1 Information You Provide

We collect information you voluntarily provide when you:

  • Create an Account: Full name, email address, phone number, date of birth, country of residence, and account credentials
  • Complete Identity Verification (KYC): Government-issued identification documents (passport, driver's license, national ID), proof of address, selfie photographs, and verification videos
  • Make Financial Transactions: Cryptocurrency wallet addresses, transaction history, deposit and withdrawal records
  • Contact Support: Communication records, support tickets, and feedback
  • Participate in Surveys or Promotions: Survey responses, promotional preferences

2.2 Information Collected Automatically

When you access our Platform, we automatically collect:

  • Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers
  • Usage Data: Pages visited, features used, time spent on pages, click patterns, trading activity
  • Location Data: IP address, approximate geographic location, timezone
  • Log Data: Access times, error logs, referring URLs, pages viewed
  • Cookies and Tracking: Session cookies, persistent cookies, pixel tags, and similar technologies

2.3 Information from Third Parties

We may receive information from:

  • Identity verification service providers
  • Anti-money laundering (AML) screening services
  • Blockchain analytics providers
  • Payment processors
  • Publicly available databases

3. How We Use Your Information

We use the collected information for the following purposes:

3.1 Service Provision

  • Creating and managing your account
  • Processing deposits and withdrawals
  • Executing automated trades on your behalf
  • Providing customer support
  • Sending transaction confirmations and account notifications

3.2 Security and Compliance

  • Verifying your identity and preventing fraud
  • Complying with KYC/AML regulations
  • Detecting and preventing unauthorized access
  • Monitoring for suspicious activity
  • Responding to legal requests and court orders

3.3 Platform Improvement

  • Analyzing usage patterns and trends
  • Improving our AI trading algorithms
  • Enhancing user experience
  • Developing new features and services
  • Conducting research and analytics

3.4 Communications

  • Sending service-related announcements
  • Providing marketing communications (with consent)
  • Responding to inquiries and support requests
  • Notifying you of policy changes

4. Legal Basis for Processing (GDPR)

If you are in the European Economic Area (EEA), we process your data based on:

  • Contract Performance: Processing necessary to provide our Services and fulfill our contractual obligations to you
  • Legal Obligations: Processing required to comply with applicable laws (KYC/AML, tax reporting, court orders)
  • Legitimate Interests: Processing for fraud prevention, security, service improvement, and business operations, where not overridden by your rights
  • Consent: Processing based on your explicit consent (marketing communications, non-essential cookies)

5. Data Sharing and Disclosure

We may share your information with:

5.1 Service Providers

  • Cloud hosting and infrastructure providers
  • Identity verification and KYC service providers
  • Payment processors and cryptocurrency exchanges
  • Customer support platforms
  • Analytics and monitoring services
  • Email and communication service providers

5.2 Legal and Regulatory

  • Law enforcement agencies when required by law
  • Regulatory authorities for compliance purposes
  • Legal counsel for dispute resolution
  • Courts pursuant to valid legal process

5.3 Business Transfers

In connection with a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of the transaction. We will notify you of any such change and any choices you may have.

5.4 With Your Consent

We may share your information with third parties when you have given explicit consent for such sharing.

We do not sell your personal information to third parties for marketing purposes.

6. Data Retention

We retain your information for as long as necessary to:

  • Provide our Services and maintain your account
  • Comply with legal obligations (typically 5-7 years for financial records)
  • Resolve disputes and enforce agreements
  • Prevent fraud and maintain security

After account closure, we retain certain data as required by law or for legitimate business purposes. Anonymous or aggregated data may be retained indefinitely for analytics and service improvement.

7. Data Security

We implement comprehensive security measures to protect your information:

7.1 Technical Safeguards

  • 256-bit AES encryption for data at rest
  • TLS 1.3 encryption for data in transit
  • Multi-factor authentication (MFA)
  • Regular security audits and penetration testing
  • Web application firewalls and DDoS protection
  • Intrusion detection and prevention systems

7.2 Operational Safeguards

  • Strict access controls and role-based permissions
  • Employee security training and background checks
  • Incident response procedures
  • Regular security assessments
  • Data minimization practices

7.3 Asset Security

  • 95% of digital assets stored in offline cold wallets
  • Multi-signature wallet architecture
  • Geographic distribution of backup systems
  • Regular security audits by third parties

While we implement strong security measures, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security.

8. Your Privacy Rights

Depending on your location, you may have the following rights:

8.1 General Rights

  • Access: Request a copy of personal data we hold about you
  • Rectification: Correct inaccurate or incomplete information
  • Deletion: Request deletion of your personal data (subject to legal retention requirements)
  • Portability: Receive your data in a structured, machine-readable format
  • Restriction: Request limitation of processing in certain circumstances
  • Objection: Object to processing based on legitimate interests
  • Withdraw Consent: Withdraw previously given consent at any time

8.2 GDPR Rights (EEA Residents)

If you are in the European Economic Area, you have additional rights under GDPR, including the right to lodge a complaint with a supervisory authority.

8.3 CCPA Rights (California Residents)

California residents have the right to:

  • Know what personal information is collected, used, shared, or sold
  • Delete personal information held by businesses
  • Opt-out of the sale of personal information
  • Non-discrimination for exercising their privacy rights

8.4 Exercising Your Rights

To exercise your privacy rights, please contact us at privacy@coinshares-ai.com. We will respond to your request within the timeframe required by applicable law (typically 30 days).

9. Cookies and Tracking Technologies

We use cookies and similar technologies to:

  • Maintain your session and authentication
  • Remember your preferences
  • Analyze Platform usage and performance
  • Provide security features
  • Deliver relevant content

For detailed information about our use of cookies, including how to manage your preferences, please see our Cookie Policy.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws.

When we transfer data internationally, we implement appropriate safeguards:

  • Standard Contractual Clauses approved by the European Commission
  • Data processing agreements with all service providers
  • Verification that recipients maintain adequate security measures
  • Compliance with applicable data localization requirements

11. Children's Privacy

Our Platform is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child without parental consent, we will take steps to delete that information.

If you believe a child has provided us with personal information, please contact us at privacy@coinshares-ai.com.

12. Third-Party Links and Services

Our Platform may contain links to third-party websites, applications, or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal information.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons. We will notify you of material changes by:

  • Posting the updated policy on our Platform
  • Updating the "Last Updated" date
  • Sending email notification for significant changes
  • Providing in-app notifications

Your continued use of the Platform after changes constitutes acceptance of the updated Privacy Policy.

14. Contact Us

For questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

CoinShares AI - Privacy Team

Email: privacy@coinshares-ai.com

General Support: support@coinshares-ai.com

For GDPR-related inquiries, you may also contact our Data Protection Officer at dpo@coinshares-ai.com.