Data protection and privacy framework for users.
Article 1: Identification of Data Controller This policy defines the data processing protocols maintained by Promenade Earnd ("the Platform", "we", or "our").
Registered Office: Level 3, Grand Canal House, 12 Upper Grand Canal Street, Dublin 4, D04 W6H2, Ireland.
Compliance: We act as a data controller under the General Data Protection Regulation (GDPR) and the Irish Data Protection Act 2018.
Article 2: Categories of Personal Information Collected In accordance with the principle of data minimisation, we collect:
Identity Metrics: Full legal name, date of birth, nationality, and government-issued ID for mandatory KYC/AML verification.
Financial Telemetry: Source of funds, digital asset wallet addresses (public keys), and detailed transaction history.
Digital Footprint: IP addresses, hardware specifications, and interaction logs with our analytical interfaces.
Article 3: Legal Basis for Processing Our collection and use of information are based on:
Contractual Necessity: Essential for account management and service delivery.
Statutory Obligations: Compliance with Irish Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) regulations.
Legitimate Business Interests: Proactive fraud prevention and network security enhancement.
Explicit Consent: For personalized market insights and non-essential analytical cookies.
Article 4: Advanced Security and Sovereignty
Encryption: All data at rest is stored using AES-256 cryptographic protocols.
Transmission: Secured via TLS 1.3 end-to-end encryption.
Hosting: Data is exclusively hosted on redundant, high-security servers within the European Economic Area (EEA), ensuring protection under EU data sovereignty laws.
Article 5: Retention and Your Rights We retain identity and financial records for a period of five (5) to seven (7) years after account closure to satisfy Irish Revenue and AML requirements. Under GDPR, you possess the following rights:
Right of access, rectification, and erasure.
Right to data portability.
Right to lodge a complaint with the Data Protection Commission (DPC) of Ireland.