Privacy Policy

Effective date: 7 March 2025

1 This Privacy Policy

1.1. About this Privacy Policy

AquaBlockChain Ltd and its related bodies corporate (collectively, AquaBlockChain, we, us and our) understand that your privacy is paramount, and are committed to protecting your privacy.

This privacy policy (Privacy Policy) describes the handling of personal information by us, including through our website (https://blockchainaqua.com/) (Website), the AquaBlockChain self-directed trading portal and the AquaBlockChain App.

Unless you notify us otherwise, by accessing our services or providing your personal information, you consent to the collection, use and disclosure of your personal information as described in this Privacy Policy.

We may modify or revise this Privacy Policy from time to time, including whenever there are changes to regulations or our business operations. Any changes published on the Website will be taken to be effective when they are published and the changes supersede all prior versions. We recommend you check our Website regularly to ensure you are aware of the current Privacy Policy.

1.2. Personal information controller

AquaBlockChain is the personal information controller for the information it collects from you in accordance with this Privacy Policy:

Aqua Blockchain
C. 45 Este, Panamá,
Provincia de Panamá,
Panama

2 What personal information do we collect?

2.1. Personal information

When we refer to personal information, we mean information or an opinion about an individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in material form or not.

Examples include:

• name
• date of birth
• residential address
• email address
• cryptocurrency wallet ID, address and transactions
• mobile phone number
• identification documents
• purpose of cryptocurrency transactions and source of funds
• financial information (bank account, credit card details)
• politically exposed persons match results
• qualifications and employment history (for job applicants)

2.2. Sensitive information

We may also collect sensitive information (e.g., biometric data, racial/ethnic origin in ID documents) if you consent or where permitted by law.

3 How we collect your personal information

We collect information directly (phone, video call, email, Website, AquaBlockChain App) or via third parties (identity verification providers, regulators, referees).

4 Collection of information through our Website

Our servers may automatically collect:

• IP address
• date/time of visit
• pages accessed
• actions taken
• operating system/browser

Cookies may also be used. Rejecting cookies may limit functionality.

5 Collection of information through the AquaBlockChain App

We may collect:

• device IP address
• operating system
• mobile browser type
• usage data
• GPS location (for city-level services/ads)

Cookies may also be used in the App.

6 How we use your personal information

We use personal information to:

• communicate with you (orders, confirmations, alerts, surveys)
• market AquaBlockChain services (https://blockchainaqua.com/, funds.blockchainaqua.com)
• provide market updates (newsletters, reports)
• protect against fraud/security incidents
• support technical issues
• assess job applications
• enhance services and develop new ones
• resolve disputes (via transcripts/call recordings)
• produce anonymised analytics/reports
• make decisions (e.g., IP-based access restrictions, scam detection)
• comply with legal obligations (AML/CFT laws, investigations)

7 How we hold your personal information

We store data in IT systems, secured databases, and third-party cloud providers with safeguards (passwords, restricted access, monitoring).

8 How we share your personal information

8.1 Disclosure to third parties

Shared with:

• related entities
• service providers (identity verification, payments, IT, marketing)
• financial institutions
• parties you request
• prospective partners
• government/regulators/law enforcement

We do not sell your personal information.

8.2 Overseas disclosure

Data may be transferred outside Australia with safeguards (contractual obligations).

8.3 Disclosure to law enforcement/government

We may disclose data if required by law/court order. Notice will be given where legally possible.

8.4 Disclosure of de-identified information

Aggregated/anonymised data may be shared for research/analytics.

9 Accessing and correcting your personal information

Depending on jurisdiction, you may:

• withdraw consent/object to processing
• access data we hold
• correct/update data
• request deletion/restriction

Requests: su*****@************in.com (subject line “Data Subject Request”). Verification required.

10 Complaints

Email su*****@************in.com.

11 Opt out of communications

You may unsubscribe from promotional communications. Transactional/legal/security alerts will still be sent.

12 Our contact details

Data Protection Officer
Aqua Blockchain
C. 45 Este, Panamá,
Provincia de Panamá,
Panama

13 Jurisdiction specific terms

13.1 Children’s Personal Information and Online Privacy

Our services are not directed to persons under 18. We do not knowingly collect data from children. If discovered, accounts will be closed and data deleted.

13.2 Gramm-Leach-Bliley Act

We comply with GLBA requirements. Contact su*****@************in.com for questions.

State Notes

Vermont: If you are a customer residing in Vermont, we will not share information we collect about you with companies outside of AquaBlockChain Limited, unless the law allows. We will not disclose information about your creditworthiness to affiliates or disclose personal/financial/credit/health information to non-affiliated third parties for marketing without your authorization.