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Version 1 - September 5, 2023

This Privacy Policy sets forth the information which the Company (as defined below) is required under the Bermuda Personal Information Protection Act 2016 (“PIPA”) to provide to you concerning the policy and procedures of XBTO Global Ltd. and its affiliates (including but not limited to  XBTO International Ltd., Stablehouse Ltd., SH UK Strategies Ltd., Stablesend Services EU Limited) (collectively, the “Company”) with respect to personal information that the Company may collect through this website (including any mobile application or version of the website, collectively, the “Site”).

This Privacy Policy may be changed at any time, provided that if we make any substantial change to this Privacy Policy, we will post a prominent announcement on the Site and will post the updated Privacy Policy here. This Privacy Policy applies only to the personally identifiable information of individuals (the “Personal Information”), not the trade secrets or other intellectual property of any person.

We may collect the following types of Personal Information from you:

  1. Personal Identification Information: Full name, date of birth, nationality, gender, signature, utility bills, photographs, phone number, residential address, and/or email.
  2. Formal Identification Information: Government issued identity documents such as Passport, Driver's License, and/or any other information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws.
  3. Institutional Information: Employer Identification number (or comparable number issued by a government), proof of legal formation (e.g. Articles of Incorporation), personal identification information for all material beneficial owners, controllers or directors.
  4. Financial Information: Bank account information, source of wealth, annual income, payment card primary account number (PAN), transaction history, trading data, and/or tax identification.
  5. Transaction Information: Information about the transactions you make on our Site, such as the name of the recipient, your name, the amount, purpose and/or timestamp.
  6. Employment Information: Office location, name of employer, job title, and/or description of role.
  7. Correspondence: information provided to our customer support team.
  8. In supplying this information, you consent to this information being collected, used, disclosed, transferred to our affiliates and related companies (including XBTO Trading LLC and its affiliates), and stored by us, as described in our Terms and this Privacy Policy.
  9. Information we collect from you automatically:
  10. To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with the Site. This information helps us address customer support issues, improve the performance of our Site, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access.
  11. Information collected automatically includes:
  12. Online Identifiers: Geo location/tracking details, browser name and version, and/or personal IP addresses.
  13. Usage Data: Authentication data, security questions, click-stream data, public social networking posts, information about your behaviour and other data collected via cookies and similar technologies
  14. You acknowledge that by providing your Personal Information and other Information to the Company that you consent to the processing of your data in accordance with this Privacy Notice.
  15. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access.

The Company may collect, use and share relevant Personal Information in accordance with this Privacy Policy and our User Agreement, with your knowledge and consent typically for the following purposes:

  1. To notify you about our products and services, features, new updates and improvements of our products and services.
  2. To manage and maintain your account with us.
  3. To process transactions and applications you make.
  4. To enable user analytics and tracking of user behaviour.
  5. To make risk assessments, perform onboarding and provide customer service.
  6. To provide information to our KYC/KYT third party service providers to assist us with performing identity verifications, due diligence, watchlist and negative media screenings in accordance with our KYC, AML/ATF requirements.
  7. To provide KYC information to our related or third party business partners such as token issuers or other related product providers to streamline your onboarding process with them.
  8. To comply with applicable laws in any country and fulfil our obligations with any regulatory, legal, or good practice requirement.
  9. To comply with our obligations under any reporting agreement entered with any tax authority or revenue service(s).
  10. To prevent and detect money-laundering, terrorism, fraud, or other crimes.

The Company does not disclose any of the Personal Information to anyone, other than to its affiliates, and except as permitted by law, to the Company’s attorneys and regulators and to certain third party service providers that we have a contractual relationship who will process the Personal  Information for the purposes identified above. In particular, we use third party providers that provide the services below (including but are not limited to): (i) hosting of this Site; (ii) ID verification and watchlist / sanctions screening services such as Onfido Inc., Sum and Substance Ltd. and IVXS UK Limited (trading as ComplyAdvantage); (iii) Know-Your- Transactions (“KYT”) services such as Chainalysis and TRM Labs Inc.; (iv) Travel Rule compliance services such as Notabene; (v) certain third party stablecoin issuers; (vi) wait list and referral services; (vii) data analytics and tracking services on the Site; (viii) customer identity management solutions for login; and (ix) customer support and any other marketing services.

Third party sites are governed by their own privacy policies and we have included links below for your information:

  1. Onfido
  2. SumSub
  3. ComplyAdvantage
  4. Chainalysis
  5. TRM Labs
  6. Notabene
  7. Auth0 / Okta
  8. Heap
  9. Zendesk

Your information will only be provided to a third party where we are satisfied that such party has adequate measures in place to protect Personal Information. We regularly review and implement up-to-date technical security measures when processing your Personal Information.

The Company retains data for a minimum of five years, however we will not keep your Personal Information for longer than necessary for our purposes. Certain data can be retained for longer periods as required by the laws of Bermuda (Regulations 15 and 16 of the Bermuda Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Regulations 2008.

Your Personal Information is stored in Ireland and accessed via secure connections only. Where Personal Information is transferred overseas, the Company continues to ensure compliance with PIPA in relation to that information.

This Site may use “cookies,” which may automatically collect certain information and data. “Cookies” are small pieces of data sent to your computer browser from the Company’s web server and stored on your computer’s hard drive. The data identifies you as a unique user and facilitates your ongoing access to and use of this Site. Cookies also help the Company diagnose problems with the Company’s server. By using this Site you consent to the Company collecting and using Cookies for these purposes.

The Company seeks to carefully safeguard your Personal Information and, to that end, restrict access to nonpublic Personal Information to those employees and certain other persons, including service providers, such as a third party that hosts this Site, who need to know such information. Third parties must in all cases agree to a strict duty to keep all Personal Information confidential and to use it only for the purpose for which it was obtained.

Under certain circumstances and subject to certain exceptions, you have the right to:

  1. Request access to the personal information which we hold about you
  2. Request correction of any inaccurate or incomplete personal information that we hold about you
  3. Request that we cease or not begin the use of your personal information for the purposes of advertising, marketing or public relations, or where the use is causing or likely to cause substantial damage or distress
  4. Request erasure of your personal information where that personal information is no longer relevant for the purpose of its use.

The Company has appointed Stephanie Shih as our Privacy Officer, to oversee compliance with this Privacy Notice. If you have any questions or comments about this Privacy Notice, or wish to make use of any of your Personal Information rights referred to above, please feel free to contact the Privacy Officer at:

Email: legal@stablehouse.com

Address: Ideation House, G/F, 94 Pitts Bay Road, Pembroke,  Bermuda HM08