Privacy Policy

1. Introduction

GoldEye ("we", "us", "our", or "Company") 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 platform and services (the "Services").

By accessing or using our Services, you acknowledge that you have read and understand this Privacy Policy. If you do not agree with our practices, please do not use our Services.

This Privacy Policy applies to all users of our Services, including investors, issuers, and visitors to our website. It covers information collected through our website, mobile applications, API, and any other means of interaction with our Services.

2. Information We Collect

2.1 Information You Provide Directly

We collect information that you voluntarily provide to us, including:

• Account Information: Name, email address, phone number, mailing address, date of birth, government-issued identification numbers (e.g., Social Security Number, Tax ID)
• Financial Information: Bank account details, payment card information, income information, net worth information, investment history
• Identity Verification: Government-issued identification documents, proof of address, selfie photos, and other documents required for Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance
• Accredited Investor Information: Information to verify accredited investor status, including income statements, tax returns, bank statements, and other financial documentation
• Investment Information: Investment preferences, risk tolerance, investment decisions, and transaction history
• Communications: Correspondence with us, support requests, feedback, and survey responses

2.2 Information Collected Automatically

When you use our Services, we automatically collect certain information, including:

• Device Information: IP address, browser type, operating system, device identifiers, mobile network information
• Usage Information: Pages visited, features used, time spent on pages, clickstream data, search queries, and navigation patterns
• Location Information: General geographic location based on IP address (we do not collect precise GPS location without your consent)
• Cookies and Tracking Technologies: We use cookies, web beacons, pixel tags, and similar technologies to collect information about your browsing behavior
• Blockchain Information: Public blockchain addresses, transaction hashes, and on-chain activity related to your account

2.3 Information from Third Parties

We may collect information about you from third-party sources, including:

• Identity Verification Services: Information from third-party KYC/AML providers to verify your identity and conduct compliance checks
• Credit Reporting Agencies: Credit reports and scores for account verification and fraud prevention
• Financial Institutions: Bank account information and transaction history (with your authorization)
• Public Records: Publicly available information from government databases, court records, and sanctions lists
• Social Media and Professional Networks: Public profile information if you connect your accounts
• Blockchain Analytics: Public blockchain data and analytics from blockchain explorers and analytics providers

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 Providing and Improving Our Services

• Process and maintain your account registration
• Enable you to access and use our Platform and Services
• Facilitate investment transactions and payments
• Provide customer support and respond to your inquiries
• Send you important account-related notifications and updates
• Improve, personalize, and optimize our Services
• Develop new features and functionality

3.2 Compliance and Legal Obligations

• Verify your identity and conduct KYC/AML checks as required by law
• Verify accredited investor status and eligibility for certain offerings
• Comply with applicable securities laws, regulations, and regulatory requirements
• Detect, prevent, and investigate fraud, money laundering, and other illegal activities
• Screen against sanctions lists and comply with economic sanctions programs
• Respond to legal process, subpoenas, and regulatory inquiries
• Enforce our Terms of Service and other agreements
• Protect our rights, property, and safety, as well as that of our users and others

3.3 Communication and Marketing

• Send you service-related communications (e.g., transaction confirmations, account updates)
• Send you marketing communications about our Services and investment opportunities (with your consent, where required by law)
• Provide you with information about deals, market updates, and educational content
• Conduct surveys and gather feedback to improve our Services

3.4 Security and Fraud Prevention

• Monitor and protect against fraud, security threats, and unauthorized access
• Authenticate your identity and verify transactions
• Detect and prevent suspicious or illegal activity
• Maintain security logs and audit trails

4. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

4.1 Service Providers and Business Partners

We may share your information with third-party service providers who perform services on our behalf, including:

• Identity Verification Providers: Third-party KYC/AML verification services
• Payment Processors: Payment processing and financial services providers
• Cloud Service Providers: Hosting, data storage, and computing infrastructure
• Analytics Providers: Analytics and data processing services
• Communication Services: Email, SMS, and notification service providers
• Customer Support: Customer support and helpdesk services
• Legal and Compliance Services: Legal counsel, compliance consultants, and auditors

These service providers are contractually obligated to protect your information and use it only for the purposes we specify.

4.2 Legal and Regulatory Requirements

We may disclose your information when required by law or in response to:

• Subpoenas, court orders, or other legal process
• Regulatory inquiries or requests from government authorities
• Investigations of potential violations of law or our Terms of Service
• Protection of our rights, property, or safety, or that of our users
• Compliance with applicable securities laws and regulations
• Reporting requirements to regulatory agencies

4.3 Business Transfers

If we are involved in a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such transfer and any choices you may have regarding your information.

4.4 With Your Consent

We may share your information with third parties when you have given us explicit consent to do so, such as when you authorize us to share your information with specific issuers or investment opportunities.

4.5 Aggregated and De-Identified Information

We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you for research, analytics, or other purposes.

5. Data Security

We implement appropriate technical, administrative, and physical safeguards to protect your information from unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit and at rest using industry-standard encryption protocols
• Secure data storage and access controls
• Regular security assessments and vulnerability testing
• Employee training on data security and privacy
• Multi-factor authentication for sensitive operations
• Monitoring and logging of system access and activities
• Incident response procedures for security breaches

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for all activities that occur under your account.

6. Your Privacy Rights and Choices

Depending on your location, you may have certain rights regarding your personal information:

6.1 Access and Portability

You have the right to access and receive a copy of the personal information we hold about you. You may also request that we provide your information in a structured, commonly used, and machine-readable format.

6.2 Correction and Updates

You can update or correct your account information at any time through your account settings. If you believe any information we hold about you is inaccurate, please contact us to request correction.

6.3 Deletion

You may request deletion of your personal information, subject to our legal and regulatory obligations to retain certain information for compliance purposes, dispute resolution, and enforcement of our agreements.

6.4 Opt-Out of Marketing

You can opt out of receiving marketing communications from us by following the unsubscribe instructions in our emails or by updating your communication preferences in your account settings. You will continue to receive service-related communications.

6.5 Cookies and Tracking Technologies

You can control cookies through your browser settings. However, disabling cookies may affect the functionality of our Services. For more information, please see our Cookie Policy.

6.6 Exercising Your Rights

To exercise any of these rights, please contact us at privacy@goldeyec.com. We will respond to your request within a reasonable timeframe and in accordance with applicable law. We may require verification of your identity before processing your request.

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. We may retain your information for:

• As long as your account is active or as needed to provide you with Services
• As required by applicable law, regulation, or regulatory requirements (e.g., securities laws, tax laws, AML requirements)
• To resolve disputes, enforce our agreements, and protect our legal rights
• To comply with record-keeping requirements for financial and securities transactions

When we no longer need your information, we will securely delete or anonymize it in accordance with our data retention policies.

8. International Data Transfers

Your information may be transferred to, and processed in, countries other than your country of residence. These countries may have data protection laws that differ from those in your country. We take appropriate safeguards to ensure that your information receives an adequate level of protection, including:

• Implementing standard contractual clauses approved by regulatory authorities
• Ensuring service providers are subject to appropriate data protection obligations
• Complying with applicable data transfer regulations

9. Children's Privacy

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

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by:

• Posting the updated Privacy Policy on our website
• Sending you an email notification (if you have provided an email address)
• Displaying a prominent notice on our Platform

The "Last Updated" date at the top of this Privacy Policy indicates when it was last revised. Your continued use of our Services after the effective date of any changes constitutes your acceptance of the updated Privacy Policy.

11. Contact Us

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

12. Additional Rights for Residents of Certain Jurisdictions

12.1 California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including:

• The right to know what personal information we collect, use, disclose, and sell
• The right to delete your personal information
• The right to opt-out of the sale of personal information (we do not sell personal information)
• The right to non-discrimination for exercising your privacy rights
• The right to correct inaccurate personal information
• The right to limit the use of sensitive personal information

12.2 European Economic Area (EEA) and UK Residents (GDPR)

If you are located in the EEA or UK, you have additional rights under the General Data Protection Regulation (GDPR), including:

• The right to access your personal data
• The right to rectification of inaccurate data
• The right to erasure ("right to be forgotten")
• The right to restrict processing
• The right to data portability
• The right to object to processing
• Rights related to automated decision-making and profiling

Our legal basis for processing your personal data includes: (1) performance of a contract; (2) compliance with legal obligations; (3) legitimate interests; and (4) your consent, where applicable.