Privacy Policy

1. Who We Are

Halofinity Ltd. ("Halofinity", "we", "us", "our") is the data controller responsible for processing personal data collected through this website and investment platform. If you have any questions about how we handle your personal data, please contact us at [email protected].

2. Information We Collect

We collect personal information in the following categories:

• Identity data: First name, last name, date of birth, nationality, government-issued ID documents.
• Contact data: Email address, telephone number, residential address.
• Financial data: Wallet addresses, transaction history, deposit and withdrawal records, investment portfolio data.
• Technical data: IP address, browser type, device information, cookies, session data.
• Usage data: Pages visited, features used, time spent on the platform.
• Communication data: Messages sent to support, correspondence records.

3. How We Use Your Information

We use personal data to:

• Create and manage your investor account.
• Process deposits, withdrawals, and investment allocations.
• Comply with KYC and AML regulatory obligations.
• Send account confirmations, OTPs, and transaction notifications.
• Respond to support enquiries.
• Detect and prevent fraud and security incidents.
• Improve our platform and services based on usage patterns.
• Send investor updates and performance reports (where consented).

4. Legal Basis for Processing

We process your personal data on the following legal grounds:

• Contract performance: Processing necessary to provide the investment platform services you have signed up for.
• Legal obligation: KYC/AML verification required by applicable regulations.
• Legitimate interests: Fraud prevention, security monitoring, platform improvement.
• Consent: Marketing communications, newsletters (where separately opted in).

5. Data Sharing

We do not sell your personal data. We may share data with:

• KYC verification providers — for identity document processing.
• Blockchain network services — wallet address verification and transaction broadcasting.
• Email delivery services — for transactional and notification emails.
• Regulatory authorities — where required by law or regulatory enquiry.
• IT and hosting providers — who process data on our behalf under data processing agreements.

All third parties are required to handle your data in compliance with applicable data protection laws.

6. Data Retention

We retain your personal data for as long as necessary to:

• Maintain your active investor account.
• Comply with legal retention obligations (typically 5–7 years post-account closure for financial records).
• Resolve disputes and enforce agreements.

Account data is deleted or anonymised upon request after applicable legal retention periods have expired.

7. Cookies

Halofinity uses essential cookies to maintain sessions and platform functionality. We do not use third-party advertising or tracking cookies. Technical data collected through cookies is not used for profiling or remarketing. You may disable cookies in your browser settings, but this may affect platform functionality.

8. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access the personal data we hold about you.
• Correct inaccurate or incomplete data.
• Request deletion of your data (subject to legal retention requirements).
• Restrict or object to certain processing activities.
• Withdraw consent for marketing communications at any time.
• Lodge a complaint with your local data protection authority.

To exercise any of these rights, contact us at [email protected].

9. International Transfers

Your data may be processed in countries outside your jurisdiction. Where we transfer data internationally, we apply appropriate safeguards in accordance with applicable data protection legislation.

10. Updates to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or a prominent notice on the platform. Continued use of the platform after the effective date of changes constitutes acceptance of the updated policy.