IGNIRIS Privacy Policy

This Privacy Policy explains how IGNIRIS and its affiliates (“IGNIRIS,” “we,” “us,” or “our”) collect, use, process, store, disclose, and protect Personal Data in connection with your access to and use of the IGNIRIS website, mobile applications, APIs, and other products and services provided by IGNIRIS (collectively, the “Services”).

We may be required by applicable laws, regulations, or our legitimate business and compliance requirements to collect certain Personal Data from you. Where the provision of certain information is optional, you may choose whether to provide it. However, failure to provide information that is necessary for a particular Service may prevent you from accessing or using some or all features of that Service.

1. Definitions

1.1 Virtual Financial Asset

For purposes of this Privacy Policy, “Virtual Financial Asset” refers to digital assets that may also be described as virtual currencies, cryptocurrencies, convertible virtual currencies, or digital assets, including, for example, Bitcoin and Ether.

Such assets may operate on centralized or decentralized networks, may use open-source or proprietary protocols, and may function as a medium of exchange, store of value, or for other purposes.

1.2 Personal Data

“Personal Data” means any information relating to an identified or identifiable natural person. This may include, without limitation, a person's name, identification number, contact information, location data, online identifiers, device information, or information relating to their economic, financial, social, or other personal circumstances.

2. Personal Data We Collect

IGNIRIS may collect, process, and store Personal Data when you create or attempt to create an IGNIRIS account, complete or partially complete an onboarding or identity verification process, access or use the Services, execute transactions, communicate with customer support, subscribe to marketing communications, contact us by email or telephone, or otherwise interact with IGNIRIS.

We may also obtain information from publicly available databases, identity verification providers, compliance service providers, and other third parties where permitted by applicable law.

2.1 Individual Customers

• Email address and mobile phone number
• Full legal name, including former names and local-language names where applicable
• Nationality
• Passport number or other government-issued identification number
• Date of birth
• Proof of identity
• Residential address
• Supporting verification documentation
• Additional information requested by our Compliance Team
• IP address and device identifiers
• Other information required for legal, regulatory, security, or compliance purposes

2.2 Corporate and Institutional Customers

• Legal entity name and local-language legal name where applicable
• Incorporation or registration information
• Names of directors, authorized representatives, and beneficial owners
• Registered address, principal place of business, and other business locations
• Documents proving legal existence or incorporation
• Description and nature of the business
• Ownership structure and ownership percentages
• Contact information for beneficial owners, directors, executives, and authorized representatives
• Identification documents for significant beneficial owners and authorized representatives
• Source of wealth or source of funds
• Expected fiat and digital asset deposit amounts
• Other information required for legal, regulatory, risk-management, or compliance purposes

3. Information Collected During Onboarding and Verification

We may collect information you provide during the IGNIRIS onboarding process regardless of whether the process is completed, remains incomplete, or is abandoned.

For identity verification, Anti-Money Laundering (“AML”), sanctions screening, fraud prevention, and other compliance purposes, we may verify information provided by you against government or public databases, sanctions and watchlists, identity verification databases, fraud-prevention systems, blockchain analytics services, and third-party compliance providers.

We may request additional documentation or information where reasonably necessary to comply with applicable laws or to protect the integrity and security of the Services.

4. International Collection and Transfer of Personal Data

IGNIRIS may provide Services to users located in multiple jurisdictions. As a result, your Personal Data may be collected, transferred, processed, or stored in jurisdictions other than the jurisdiction in which you reside.

Such jurisdictions may have data protection laws that differ from those applicable in your country or region. Where required by applicable law, IGNIRIS will implement appropriate safeguards for international transfers of Personal Data and obtain consent where such consent is legally required.

In certain circumstances, if you do not permit a transfer that is necessary for IGNIRIS to provide its Services or comply with applicable requirements, some or all Services may become unavailable to you.

5. How We Use Your Personal Data

IGNIRIS may use Personal Data for purposes including:

• creating and maintaining your account;
• providing, administering, and operating the Services;
• processing transactions and account activities;
• verifying your identity;
• conducting KYC, AML, sanctions, and fraud-prevention checks;
• protecting the security and integrity of accounts and the platform;
• detecting suspicious, fraudulent, or unauthorized activities;
• complying with legal and regulatory obligations;
• responding to customer support inquiries;
• communicating important account or Service information;
• improving and personalizing the Services;
• conducting internal analytics and research;
• managing risk and maintaining transaction and compliance records;
• enforcing our Terms of Service and other applicable agreements;
• developing new products and services; and
• providing information about products, promotions, or services where permitted by applicable law.

We may also create aggregated, anonymized, or de-identified information from Personal Data for statistical, analytical, security, or business purposes where such information no longer identifies an individual.

6. How We Share Personal Data

6.1 Service Providers

We may share information with third-party service providers that assist us with identity verification, KYC and AML compliance, payment processing, blockchain analytics, cloud infrastructure, cybersecurity, technical support, customer support, data storage, communications, marketing, or other operational services.

6.2 Legal and Regulatory Requirements

We may disclose Personal Data to regulators, law enforcement agencies, courts, tax authorities, government agencies, or other competent authorities where disclosure is required or permitted by applicable law, regulation, court order, legal process, or lawful request.

6.3 Enforcement and Protection

We may disclose information where reasonably necessary to enforce our Terms of Service, investigate fraud or misconduct, prevent security incidents, protect the rights, property, or safety of IGNIRIS, its users, or third parties, or maintain the integrity of the Services.

6.4 Corporate Transactions

Personal Data may be transferred or disclosed in connection with a merger, acquisition, corporate restructuring, financing, asset sale, transfer of business, bankruptcy, or similar corporate transaction.

7. Anti-Money Laundering and Regulatory Compliance

IGNIRIS implements measures designed to prevent money laundering, terrorist financing, fraud, sanctions evasion, financial crime, and other unlawful use of the Services.

For these purposes, we may conduct customer due diligence and enhanced due diligence using information obtained directly from you and information provided by third-party compliance, identity verification, risk intelligence, or blockchain analytics providers.

8. Third-Party Services and SDKs

Certain features of the Services may rely on third-party technologies, software development kits (“SDKs”), or service providers. Where such third-party services process Personal Data, their own privacy policies may also apply.

Where the Share functionality utilizes MobTech's ShareSDK, information relating to that functionality may be processed in accordance with the applicable ShareSDK privacy policy. Users are encouraged to review the privacy policies of relevant third-party service providers when using such functionality.

9. How We Protect and Store Personal Data

IGNIRIS maintains administrative, technical, organizational, and physical safeguards designed to protect Personal Data from unauthorized access, accidental or unlawful destruction, loss, alteration, unauthorized disclosure, and misuse.

Our security measures may include encryption, access controls, network security mechanisms, monitoring systems, employee confidentiality requirements, and other security practices.

9.1 Physical Security

Where Personal Data is maintained in physical form, access to such information is restricted and appropriate physical security measures are applied.

9.2 Electronic Security

Electronic records containing Personal Data are stored within systems and storage environments subject to access controls and security restrictions. Where appropriate, encryption and other industry-standard security technologies may be used.

9.3 Organizational and Administrative Security

Access to Personal Data is limited to employees, contractors, and service providers who require such access for legitimate business purposes. Authorized personnel are subject to confidentiality obligations and applicable internal data protection policies.

9.4 Network Security

IGNIRIS may utilize firewalls, access controls, monitoring technologies, and other network-security measures designed to protect its systems and infrastructure.

10. User Security Responsibilities

Although IGNIRIS takes reasonable measures to protect Personal Data, no system or method of electronic transmission or storage can be guaranteed to be completely secure.

We recommend that you:

• use strong and unique passwords and PINs;
• never disclose your login credentials to another person;
• enable available account security features;
• keep your operating system and security software up to date;
• use reputable antivirus, anti-malware, and firewall software;
• avoid installing software from unknown or untrusted sources;
• regularly back up important information;
• use encryption where appropriate for sensitive information;
• log out after completing a session;
• avoid suspicious links and email attachments;
• avoid providing financial or Personal Data to suspicious websites;
• avoid using untrusted devices or public/shared computers for financial services.

If you believe your account credentials or Personal Data may have been compromised, you should immediately secure your account and contact IGNIRIS Customer Support.

11. Data Retention

IGNIRIS retains Personal Data for as long as reasonably necessary to provide the Services, maintain your account, fulfill the purposes described in this Privacy Policy, comply with applicable legal and regulatory obligations, maintain financial and transaction records, resolve disputes, enforce agreements, and prevent fraud or other unlawful activities.

Unless a different retention period is required or permitted under applicable law, certain Personal Data may be retained for up to five years following closure of an account. In some circumstances, applicable legal, regulatory, tax, accounting, AML, sanctions, litigation, or compliance requirements may require us to retain information for a longer period.

12. Access, Correction, and Deletion of Personal Data

Subject to applicable law, you may have the right to request access to Personal Data held about you, obtain a copy of your Personal Data, request correction of inaccurate or incomplete Personal Data, request deletion, request restriction of certain processing activities, object to certain processing activities, request portability of certain Personal Data, or withdraw consent where processing is based on consent.

Certain rights may be limited where IGNIRIS is required to retain or process information for legal or regulatory compliance, AML or KYC obligations, fraud prevention, establishment, exercise, or defense of legal claims, transaction recordkeeping, or other legitimate purposes permitted by applicable law.

13. Identity Verification for Privacy Requests

To protect your Personal Data and prevent unauthorized disclosures, IGNIRIS may need to verify your identity before processing a request relating to your Personal Data.

Verification procedures may include confirming information associated with your account, responding through the email address registered with your account, telephone verification, identity documentation, or other reasonable verification measures.

We will use reasonable efforts to respond to verified requests within the period required by applicable law. Where permitted by applicable law, we may decline requests that are manifestly unfounded, excessive, repetitive, fraudulent, or otherwise legally exempt.

14. Marketing Communications

Where permitted under applicable law, IGNIRIS may send you information concerning company updates, promotions, campaigns, new products, new services, and other marketing communications.

Users may withdraw from receiving marketing communications at any time by contacting support@igniris.com or using any unsubscribe functionality included in the relevant communication.

Opting out of marketing communications will not prevent IGNIRIS from sending essential non-marketing communications, including security alerts, transaction notifications, account-related notices, legal notices, Terms of Service updates, Privacy Policy updates, and important operational announcements.

15. Cookies and Similar Technologies

When you access IGNIRIS, we may use cookies and similar technologies. Cookies are small data files stored on your browser or device that allow us to recognize your browser or device and improve the Services.

We may use cookies and similar technologies to maintain login sessions, remember preferences, provide personalized functionality, understand how users interact with the Services, improve performance and user experience, detect suspicious or unusual account activity, enhance account security, and support compliance and fraud-prevention activities.

Most browsers automatically accept cookies. You may be able to disable or restrict cookies through your browser settings. However, disabling certain cookies may affect the availability or functionality of some IGNIRIS Services.

16. Communications Required for the Services

Certain communications are necessary for the proper operation, security, and administration of the Services. You generally cannot opt out of essential communications relating to account security, transactions, changes to legal terms or policies, regulatory requirements, system maintenance, risk-management measures, or material operational changes.

17. Privacy Rights for Users in the European Economic Area

Users located in the European Economic Area (“EEA”) may have additional rights under applicable data protection laws, including the General Data Protection Regulation (“GDPR”).

Depending on the circumstances, these rights may include the right of access, rectification, erasure, restriction of processing, data portability, objection to processing, and withdrawal of consent.

You may also have the right to lodge a complaint with the competent data protection authority in your jurisdiction regarding unresolved concerns relating to our processing of your Personal Data.

18. Contacting IGNIRIS About Privacy

If you have questions, concerns, or requests regarding this Privacy Policy or IGNIRIS's processing of your Personal Data, please contact:

Please provide sufficient information for us to understand and respond to your request. For security purposes, we may require additional information to verify your identity.

19. Changes to this Privacy Policy

IGNIRIS may amend this Privacy Policy from time to time to reflect changes to the Services, changes in applicable laws or regulations, developments in privacy and security practices, changes in our business operations, or other operational or compliance requirements.

The revised Privacy Policy will be published through the IGNIRIS website, application, or other appropriate channels. Where required by applicable law or where changes are material, we may provide additional notice.

We encourage users to periodically review this Privacy Policy for updates. The date displayed at the beginning of this Privacy Policy indicates when it was most recently updated.

20. Language

This Privacy Policy may be made available in multiple languages. Unless otherwise required by applicable law, if there is any inconsistency or discrepancy between the English version and a translated version, the English version will prevail.