Datenschutzerklärung

This Privacy Policy explains how Ethiq Labs Inc. (“Company”, “we”, “us”, or “our”) collects, uses, stores, discloses, and protects personal data in connection with your access to and use of ENTRY.FI, including the website available at entry.fi and any related applications, interfaces, tools, or services (collectively, the “Interface”). By accessing or using the Interface, you acknowledge that you have read and understood this Privacy Policy.

1. Data Controller

The data controller responsible for the processing of personal data under this Privacy Policy is:

• Ethiq Labs Inc.
• Registered address: 55st Street East, SL55 Building, 21st Floor, Office 3, Panama City, Republic of Panama.
• Contact email: contact@entry.fi.

2. Scope and Application

This Privacy Policy applies to all users of the Interface and governs all processing of personal data carried out by the Company in connection with the operation of the Interface. It does not apply to third-party services, protocols, platforms, or websites that may be accessed through the Interface. Such third parties operate independently and under their own privacy policies, and the Company bears no responsibility for their data processing practices.

3. Personal Data We Collect

Depending on your interaction with the Interface, we may collect and process the following categories of personal data:

1. contact information, such as email address, where voluntarily provided;
2. technical and device data, including IP address, browser type, operating system, device identifiers, and session data;
3. usage data, including interaction logs, feature usage, navigation patterns, and performance metrics;
4. blockchain-related data, including public wallet addresses, transaction hashes, and on-chain interaction metadata;
5. compliance and risk-related data, including geolocation indicators, sanctions screening results, and fraud prevention signals, where required by law or for legitimate security purposes;
6. identity verification data, including government-issued identity documents such as passports and national IDs, liveness check data, and facial images and biometric templates generated for identity matching, collected where verification is required to access specific products such as the card. The specific data set varies by jurisdiction, product and verification level.

The Company does not collect, store, or have access to users’ private keys, recovery phrases, or credentials for non-custodial wallets.

4. Purposes of Processing

The Company processes personal data strictly for legitimate and proportionate purposes, including to provide, operate, maintain, and improve the Interface, to ensure its security and technical integrity, to prevent fraud, abuse, and unauthorized access, to comply with legal and regulatory obligations, to conduct internal analytics and diagnostics, and to communicate with users regarding technical updates, service notices, and security alerts.

Personal data is not processed for direct marketing purposes unless you have provided explicit and informed consent, and such consent may be withdrawn at any time.

5. Legal Bases for Processing

Personal data is processed on the basis of one or more lawful grounds, including the necessity of processing for the performance of a contract or to take steps prior to entering into a contract, compliance with applicable legal obligations, the legitimate interests of the Company in ensuring security, fraud prevention, service optimization, and business continuity, and, where required, your explicit consent.

Where processing is based on legitimate interests, the Company has balanced such interests against your fundamental rights and freedoms and determined that such processing is proportionate and justified.

6. Data Sharing and Disclosure

The Company may disclose personal data on a limited and need-to-know basis to trusted third-party service providers, including cloud hosting and infrastructure providers that host the Interface and store data on our behalf, cybersecurity and fraud-prevention vendors, and analytics and error-monitoring providers that receive technical and usage data such as device identifiers, session data and crash reports. Identity verification data described in Section 3 is not shared with analytics or error-monitoring providers.

Identity verification data is shared only with identity verification providers and with regulated partners whose services you have requested, including card issuers and program managers, payment partners, third-party exchange services and on/off-ramp providers, and only where verification or onboarding with that partner is necessary to provide the service you have requested.

Such sharing may be carried out through automated verification networks operated by our identity verification provider, including Sumsub Reusable KYC, under which your verified profile and identity records may be transmitted directly to the partner in order to avoid repeating identity checks you have already completed. These transfers are executed on the basis of your request for the relevant service and may occur without a separate prompt at the moment of transfer.

Personal data may also be disclosed to professional advisers such as legal and audit firms where necessary for the establishment, exercise or defence of legal claims or for compliance with accounting and audit obligations, and to competent regulatory, supervisory, law enforcement, or judicial authorities where required by applicable law, legal process, or binding regulatory obligation.

The Company does not sell personal data, does not trade in personal data, and does not share personal data for targeted advertising or behavioral profiling purposes.

7. International Data Transfers

Your personal data may be transferred to and processed in jurisdictions outside your country of residence, including jurisdictions that may not provide the same level of data protection.

Where required by law, we implement appropriate safeguards, including standard contractual clauses or equivalent mechanisms, to ensure adequate protection of personal data.

8. Data Retention

The Company retains personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy, including compliance with legal, regulatory, accounting, and reporting obligations, after which such data is securely deleted or anonymized, unless a longer retention period is required or permitted by law.

9. Data Security

The Company applies appropriate technical and organizational security measures designed to protect personal data against unauthorized or unlawful processing, accidental loss, destruction, or damage. These measures include access controls, encryption, monitoring, and internal security policies.

However, no system is entirely secure, and the Company cannot guarantee absolute security of personal data, particularly where data transmission involves public networks or blockchain-based systems. You acknowledge and accept these inherent risks.

10. User Rights

Subject to applicable data protection law, you may have the right to request access to your personal data, request rectification or erasure, restrict or object to certain processing activities, request data portability, and withdraw consent where processing is based on consent.

Requests may be submitted to email. The Company may require reasonable verification of identity before acting upon any request, in order to protect user data from unauthorized disclosure.

11. Cookies and Tracking Technologies

The Interface uses cookies and similar technologies that are strictly necessary for functionality, performance, and security. Analytical tools may be used to understand usage patterns and improve the Interface. You may control cookie settings through your browser, although disabling certain cookies may impair functionality.

12. Children’s Data

The Interface is not intended for individuals under the age of eighteen (18), and the Company does not knowingly collect personal data from minors. If such data is identified, it will be promptly deleted.

13. Changes to This Privacy Policy

The Company may update this Privacy Policy from time to time to reflect legal, regulatory, or operational changes. Material changes will be communicated through the Interface or website. Continued use of the Interface after such changes constitutes acceptance of the revised Privacy Policy.

14. Contact

If you have any questions regarding this Privacy Policy or the Company’s data processing practices, you may contact: contact@entry.fi.