USD.estate Privacy Policy
Draft: not legally reviewed
Structural draft for review by counsel, including under the Cayman Islands Data Protection Act (2021 Revision) and, where applicable, the GDPR.
Effective: [date]
This Privacy Policy explains how USD.estate Foundation, a Cayman Islands foundation company ("we", "us"), collects, uses and shares personal information when you use usd.estate, app.usd.estate, docs.usd.estate and related services (the "Service"). We are the controller of your personal information.
1. Information We Collect
1.1 Information You Provide Directly
- Contact details you send us (name, email, messages)
- Approved institutions: entity and beneficial-owner KYC/KYB information, authorised signatories, source-of-funds documents, allowlisted wallet addresses
- Prospective issuers: business contact and KYB information submitted for bond eligibility review
1.2 Information Collected Automatically
- Wallet addresses and onchain transactions associated with them
- IP address, approximate location and device data, including to enforce access restrictions for sanctioned jurisdictions, US persons and persons in the United Kingdom
- Usage and log data, cookies and similar technologies
1.3 Information from Third Parties
- Identity verification, sanctions, PEP and adverse-media screening providers
- Blockchain analytics providers
- Issuers, paying agents and service providers, where needed to operate the holding structure (entity-level data)
2. How We Use Your Information
2.1 Provision and Operation of the Service
To provide the App, process institutional mint and redemption, and operate the Protocol's holding structure.
2.2 Compliance and Legal Obligations
To meet AML, sanctions, tax and regulatory obligations, and to enforce geographic access restrictions.
2.3 Security and Integrity
To detect and prevent fraud, abuse, exploits and security incidents.
2.4 Communication
To respond to enquiries and send service notices.
2.5 Analytics and Improvement
To understand how the Service is used and to improve it.
3. Legal Basis for Processing
Performance of a contract, compliance with legal obligations, our legitimate interests (security, geo-restriction enforcement, improving the Service), and your consent where required.
4. Disclosure of Personal Information
4.1 Service Providers and Processors
Hosting, analytics, identity verification, blockchain analytics, attestation and professional advisers, under appropriate contractual safeguards.
4.2 Affiliated Entities
The Holding Subsidiary and the Operating Company that provides services to us.
4.3 Legal and Regulatory Disclosure
Where required by law, court order or a regulator, or to protect rights and safety.
4.4 Bond Issuers
Issuers and their agents receive KYB information about the Holding Subsidiary, not about sUSDest holders. We do not share personal information about individual holders with bond issuers.
4.5 Business Transfers
In connection with a merger, restructuring or transfer of the Service.
4.6 Public Blockchain Data
Transactions on public blockchains are public and permanent. We cannot delete or change them.
5. Data Retention
KYC/KYB and transaction records: at least five years after the relationship ends, or longer if required by law. Logs: up to 24 months. Onchain data: permanent.
6. Cookies and Tracking Technologies
We use essential cookies, and analytics cookies where permitted. You can control cookies through your browser settings.
7. Security
We use reasonable technical and organisational measures, but no system is completely secure.
8. Your Rights and Choices
Depending on your location, you may have rights to access, correct, delete, restrict, port or object to the processing of your personal information, and to complain to a supervisory authority, such as the Cayman Islands Ombudsman. Contact us to exercise them.
9. International Data Transfers
Your information may be processed outside your jurisdiction, with appropriate safeguards such as standard contractual clauses.
10. Third-Party Sites and Services
Third-party sites, wallets, liquidity venues and issuers' materials are governed by their own privacy policies.
11. No Collection from Minors
The Service is not intended for anyone under 18.
12. Contact Information
USD.estate Foundation (registered office in the Cayman Islands), privacy@usd.estate
13. Amendments to this Policy
We may update this Policy and will post the updated version with a new effective date.