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Privacy Policy

Effective: November 2025 · Version 2.0

This Policy explains how VANK Technologies LLC processes your personal data when you use the VANK platform. It is an integral part of the Terms and Conditions.

1. Data controller

VANK Technologies LLC (incorporated in Delaware, United States) is the controller of your personal data. Email: legal@vank.co.

To provide the service, VANK relies on providers that act as data processors (identity verification, payment processing, technology infrastructure, analytics). These processors handle data following VANK's instructions and under confidentiality and security obligations. The specific list of processors is available on request via legal@vank.co.

2. What data we process

  • Identification: name, ID document, date of birth, nationality, signature.
  • Contact: email, phone, address.
  • Company (KYB): legal name, tax ID/registration, ultimate beneficial owners, representatives.
  • Financial and operational: accounts, transactions, amounts, counterparties, source and destination of funds.
  • Verification (KYC): identity documents, biometric data (when applicable), liveness check.
  • Technical: IP address, device, browser, activity logs, cookies.

3. Sensitive and biometric data (express authorization)

3.1. Some identity-verification processes may require processing biometric data (e.g., facial image, liveness check) and other sensitive data.

3.2. By accepting this Policy and completing verification, you authorize, in a prior, express and informed manner, the processing of such data for the sole purpose of verifying your identity and complying with legal obligations and the prevention of fraud, money laundering and terrorist financing.

3.3. You are not required to provide sensitive data. However, where such data is necessary to verify identity, prevent fraud or comply with obligations, refusing to provide it may prevent the opening, maintenance or use of the Account. You may exercise your rights over this data under Section 9.

4. What we use your data for (purposes)

(a) Create and manage your Account; (b) verify your identity (KYC/KYB); (c) execute and provide traceability for your Operations; (d) comply with legal and regulatory obligations and the prevention of money laundering, terrorist financing and sanctions; (e) prevent fraud and protect security; (f) communicate with you; (g) improve the service and analytics; (h) handle PQRs and authority requests.

5. Authorization and legal basis

Processing is based on your authorization, the performance of the contract (the Terms), compliance with legal obligations and VANK's legitimate interest in preventing fraud and operating securely. Your authorization is granted by accepting this Policy and using the Platform.

6. Who we share data with

We share data only with: (a) data processors (providers that perform services on behalf of VANK); (b) regulated partners necessary to execute an Operation; (c) competent authorities when required by law; and (d) VANK affiliates for operation and support. We do not sell your personal data.

7. International data transfer

7.1. VANK operates internationally. Your data may be transferred, stored or processed in countries other than your country of residence, including the United States, where the controller is located.

7.2. By accepting this Policy, you expressly authorize the international transfer of your data for the purposes described here. VANK adopts reasonable measures so that such transfers have adequate levels of protection and contractual confidentiality and security obligations with those who receive the data.

8. Retention

We retain your data while the relationship exists and for the periods required by law (especially compliance, accounting and anti-money-laundering obligations). Once those periods expire, we delete or anonymize it securely.

9. Your rights (habeas data)

9.1. You may access, update, rectify and delete your data, request proof of authorization, be informed of its use, file complaints and revoke your authorization where applicable.

9.2. Deletion or revocation will not proceed where there is a legal or contractual duty to retain the data (e.g., compliance obligations).

9.3. To exercise your rights: write to legal@vank.co with the subject "Privacy". We will respond within the applicable legal terms.

10. Security

We apply reasonable technical, administrative and organizational measures to protect your data against unauthorized access, loss or alteration. No system is 100% infallible; in the event of an incident affecting you, we will act in accordance with applicable law.

11. Cookies

The use of cookies and similar technologies is governed by the Cookie Policy.

12. Minors

The Platform is not directed at minors. We do not knowingly process minors' data; if we detect one, we will delete the information.

13. Changes

We may update this Policy and will notify you through the Platform or by email. Continued use after it takes effect implies acceptance.

14. Contact
VANK Technologies LLC — Privacy and personal data: legal@vank.co (subject: "Privacy").