Privacy Notice

1. IMPORTANT INFORMATION

Privacy Notice

OSD-Seychelles (“OSD”) is committed to protecting the privacy and security of your personal information. For this privacy notice “OSD-Seychelles” shall include OSD-Seychelles listed below as the circumstances permit.This privacy notice (“Privacy Notice”) sets out:

  • how and why your personal information is collected, processed and stored;
  • the lawful basis for the use of your personal information;
  • what your rights are in relation to such processing and how you can exercise them; and,

This Privacy Notice applies in connection with and throughout the provision by OSD-Seychelles of various cryptocurrency trading services and instruments (“Services”) to prospective, current and former institutional, corporate client or investor clients (“Clients”), whether institutional (including their staff) or an individual (including their representatives or agents).  This Privacy Notice also applies in connection with and throughout our engagement, operating and managing relationships with:

  • trading exchanges, digital transaction service providers, token issuers, miners, trading counterparties and other market participants, and, public sector organisations (“Market Participants”);
  • third parties (including suppliers, vendors, advisors or consultants) (“Third-Party Suppliers”);
  • individuals submitting an enquiry, feedback or a complaint (“Enquirers”);
  • visitors to our website OSD-Seychelles.com (“Website”) or our offices; and/or,
  • individuals signing up to receive OSD-Seychelles’s newsletter and/or participate in our marketing activities (“Newsletter”).

This Privacy Notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can request a copy of this Privacy Notice by emailing [email protected].

This Privacy Notice only applies to the use of your personal information obtained by us, whether from you directly or indirectly from a third party. It does not apply to personal information collected by third parties during your communications with those third parties or your use of their products or services.

Please do not use our Website or Services, or register for the Newsletter, if you do not agree with the ways in which we will process your personal data and information.

Your access to and use of our Services (including any portal, account and any secure area), Website and Newsletter is also subject to our separate terms and conditions.

This Website is not intended for children, and we do not knowingly collect or process data relating to children.

2. What type of Personal Information do we collect and about whom?

Personal Information, or personal data or personally identifiable information, means any information about an individual from which that person can be identified, directly or indirectly. Personal Information includes pseudonymised data which is data that has been masked or obfuscated, or replaced with another unique identifier, but it is nevertheless still possible to identify an individual. Personal Information does not

include data where the person’s identity has been removed so the data has been anonymised.

There are certain special categories of data which are classified as a more sensitive type of Personal Information and which require a higher level of protection (“Special Categories of Data”) such as, information about your health, racial or ethnic origin, sexual orientation, or trade union membership. Information about criminal convictions should be treated to the same standard as Special Categories of Data, and for that reason, shall be included with the definition of ‘Special Categories of Data’.

Where the context allows below, when we refer to:

  • A ‘Client’ (where it is an institution), to ‘Market Participants’ and/or to ‘Third-Party Suppliers’ we may also collect Personal Information about their staff and officers;
  • A ‘Client’ (where an individual) we shall include reference to any representative or agents of an individual, where relevant;
  • The ‘Website’, it shall include reference to visitors to our Website; and/or,
  • The ‘Newsletter’, it shall include those having signed up to receive it.

We may collect the following categories of Personal Information:

2.1 For prospective Clients with whom we are not yet taking steps to enter into a contractual relationship, we may collect use, store and transfer (to the extent permitted by applicable law):

  • Identity Data such as your first name, last name and your marital status;
  • Contact Data such as your address, email address, telephone number or Telegram account name (or other social media platform account name);
  • Profile Data includes information such as your job title and work experience and otherwise related to your professional profile (such as directorship / positions / professional networks), information related to company ownership (including other shareholders and/or beneficial owners), business partners, representatives or agents; information about financial status and background; your knowledge of and experience in investment matters; your related interests and preferences; and/or,

and any other data you share with us.

2.2 For new Clients with whom we are taking steps to enter into a contractual relationship, Clients we have a current contractual relationship and/or former Clients with whom we have had a prior contractual relationship, we may collect, use, store and transfer (to the extent permitted by applicable law):

  • Identity Data includes first name, last name, any previous names, family details (such as marital status, name of spouse or partner, children) or nominated person(s)), title, date of birth, gender, country of domicile, username and any internal identifiers we assign to you;
  • Contact Data includes your principal contact, business and/or billing address, email address, telephone numbers (including for your nominated person(s)) or Telegram account name (or other social media platform account name);

Profile Data includes information such as your job title, professional profile (such as directorship / positions / professional networks); information related to company ownership; your background, knowledge of and experience in financial services, in trading of investments products and services, and, your

  • understanding of the associated risks involved; your related interests and preferences;
  • Verification Data includes any documentation to confirm and verify your identity, for example only, documents; information that we may collect, includes (but is not limited to) identification documents (such as a national identity card, passport, driving licence residence permit or social security number or analogous document) and Personal Information contained in such documents (including but not limited to: address, nationality, date of birth, country of issue and photos or images of you); any relevant publicly available Personal Information to verify your identity;
  • Financial Data: includes financial information, BIC code, Swift number, IBAN, bank account numbers and sort codes or other payment routing number, any assigned identifiers for accounting purposes, information relating to your assets, wallet address, financial statements, statements of account;
  • Transaction Data includes details and records relating to transactions that are fiat to digital, digital to digital, and digital to fiat; details of Services you have taken; details of digital assets or digital instruments traded; associated transaction records;
  • Technical Data includes internet protocol (IP) address, login data, browser type, version and browser language, time zone setting and general location, browser plug-in types and versions, operating system and platform, device information (for example, device type and device identity), application log information and other technology on the devices you use;
  • Communication Data includes details of our interactions with you and the Services you use, correspondence (including electronic interactions across various channels such as e-mails, social media platforms or other messaging applications and technologies) across any device used to communicate with us, and any other records of interactions (in the case of any telephone calls between you and us this may include phone log information such as your phone number, time and date of calls and messages, duration of calls, routing information, and types of calls), as well as CCTV when attending our place of business;
  • Special Categories of Data such as your biometric information, political opinions or affiliations, religious or philosophical beliefs, and, to the extent legally permissible, information relating to criminal convictions or offences;
  • Marketing and Communications Preference Data includes any marketing or services communications preferences that you have provided to us; and/or,

and any other data you share with us.

2.3 For Market Participants

  • Identity Data includes first name, last name, any previous names and any internal identifiers we assign to you, such as your client number, and including any username or similar identifier provided to use that is a unique identifier of you;
  • Contact Data such as your business address, email address, telephone number or Telegram account name (or other social media platform account name);
  • Profile Data includes information such as your job title and otherwise related to your professional profile (such as directorship / positions / professional networks), information related to company ownership and financial background, experience in financial services and in trading of investments products and services;
  • Verification Data includes any documentation to confirm and verify your identity, for example only, documents; information that we may collect, includes (but is not limited to) identification documents (such as a national identity card, passport, driving licence residence permit or social security number or analogous document) and Personal Information contained in such documents (including but not limited to: address, nationality, date of birth, country of issue and photos or images of you); any relevant publicly available Personal Information to verify your identity;
  • Financial Data: includes financial information, BIC code, Swift number, IBAN, bank account numbers and sort codes or other routing number, any assigned identifiers for accounting purposes, information relating to your assets, wallet address, statements of account;
  • Transaction Data includes details and records relating to transactions that are fiat to digital, digital to digital, and digital to fiat; details of digital assets or digital instruments traded; associated transaction records (including counterparties);
  • Technical Data includes internet protocol (IP) address, login data, browser type, version and browser language, time zone setting and general location, browser plug-in types and versions, operating system and platform, device information (for example, device type and device identity), application log information and other technology on the devices you use;
  • Communication Data includes details of our interactions with you, including correspondence (via electronic interactions across various channels such as e-mails, social media platforms or other messaging applications and technologies) across any device used to communicate with us, and any other records of interactions (in the case of any telephone calls between you and us this may include phone log information such as your phone number, time and date of calls and messages, duration of calls, routing information, and types of calls), as well as CCTV when attending our place of business;
  • Special Categories of Data such as your biometric information, political opinions or affiliations, religious or philosophical beliefs, and, to the extent legally permissible, information relating to criminal convictions or offences, or the fact of a criminal record; and/or,

and any other data you share with us.

2.4 For Third-Party Suppliers with whom we are taking steps to enter into a contractual relationship, with whom we have a current or past contractual relationship, we may collect, use, store and transfer (to the extent permitted by applicable law):

  • Identity Data such as your first name, last name, marital status, country of domicile and any internal identifiers we assign to you;
  • Contact Data such as your business address, billing address (if different), email address, telephone numbers;
  • Profile Data includes information such as your job title and your professional profile (such as directorship / positions / professional networks); information related to company ownership;
  • Verification Data includes any documentation to confirm and verify your identity, for example only, documents; information that we may collect, includes (but is not limited to) identification documents (such as a national identity card, passport, driving licence residence permit or social security number or analogous document) and Personal Information contained in such documents (including but not limited to: address, nationality, date of birth, country of issue and photos or images of you); any relevant publicly available Personal Information to verify your identity;
  • Financial Data: includes financial information, BIC code, Swift number, IBAN, bank account numbers and sort codes or other routing number, any assigned identifiers for accounting purposes, statements of account, taxes (including tax identification information) and related financial information;
  • Technical Data includes internet protocol (IP) address, operating system and platform, device information (for example, device type and device ID), system log information, application log information, and other access management and record keeping technology on the devices or applications you use to access or connect with our systems and/or applications;
  • Communication Data includes details of our interactions with you and the services you support or provide, correspondence (including electronic interactions across various channels such as e- mails, social media platforms or other messaging applications and technologies) across any device used to communicate with us, and any other records of interactions (in the case of any telephone calls between you and us this may include phone log information such as your phone number, time and date of calls and messages, duration of calls, routing information, and types of calls), as well as CCTV when attending our place of business; and/or,

and any other data you share with us.

2.5 For Enquirers:

  • Identity Data includes first name, last name, your marital status, any username and any internal identifiers we assign to you;
  • Contact Data such as your address, email address, telephone number or Telegram account name (or other social media platform account name);
  • Verification Data includes any documentation to confirm and verify your identity, for example only, documents; information that we may collect, includes (but is not limited to) identification documents (such as a national identity card, passport, driving licence residence permit or social security number or analogous document) and Personal Information contained in such documents (including but not limited to: address, nationality, date of birth, country of issue and photos or images of you); any relevant publicly available Personal Information to verify your identity;
  • Communication Data includes details of our interactions with you, including correspondence (via electronic interactions across various channels such as e-mails, social media platforms or other messaging applications and technologies) across any device used to communicate with us, and any other records of interactions (in the case of any telephone calls between you and us this may include phone log information such as your phone number, time and date of calls and messages, duration of calls, routing information, and types of calls), as well as CCTV when attending our place of business; and/or,

and any other data you share with us.

2.6 For visitors to our Website, office premises, we may collect use, store and transfer (to the extent
permitted by applicable law):

  • Identity Data such as your first name, last name, and potentially your marital status;
  • Contact Data such as your address, email address, telephone number or Telegram account name (or other social media platform account name);
  • Technical Data includes internet protocol (IP) address, your login data, browser type, version and browser language, time zone setting and general location, browser plug-in types and versions, operating system and platform, device type and ID, and other technology on the devices you use to visit our Website, submit an enquiry, feedback or a complaint;
  • Communication Data includes details of our interactions with you via our Website, including correspondence (via electronic interactions across various channels such as e-mails and various mobile device applications, including Telegram), and any records of telephone calls between you and us (which may include phone log information such as your phone number, time and date of calls and messages, duration of calls, routing information, and types of calls);
  • Profile Data includes your interests and preferences;
  • Usage / Behavioural Data includes information about how you interact with and use our Website, e-mails and/or data that we gather through your use of them (which in may include data transmitted by your browser or device you are using and automatically recorded by our server, the referrer URL (web page that you were on when you clicked a link that sent you to our Website), details of when your current or previous sessions started including date and time of the access, content you view or engage with, the name of the accessed file as well as the transmitted data volume and the performance of the access); and/or,

and any other data you share with us.

2.7 For individuals subscribing to the Newsletter, we may collect use, store and transfer (to the extent permitted by applicable law):

  • Identity Data such as your first name, last name;
  • Contact Data such as your business name, email address, telephone number and Telegram account name; and/or,
  • Profile Data includes your interests and preferences, and any other data you share with us.

In some cases, we collect information from public registers (depending on the Service you receive from us and the country of the OSD-Seychelles entity with which you have a contractual relationship), public administration or other third-party or public sources, such as (for example only) wealth screening services, credit reference agencies, and fraud prevention agencies.

Where you are an institutional, corporate or investor Client, Market Participant or Third-Party Supplier, before providing OSD-Seychelles with any information about your directors, representatives, staff, shareholders, or any beneficial owner, you should provide a copy of this Privacy Notice to those individuals.

We may process Personal Information for analytics and measurement (including machine learning) for example by looking at information we obtain via cookies and tracking technologies. Please refer to our Cookie Notice.

We also collect, use and share aggregated data such as statistical or demographic data which is not Personal Information as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage / Behavioural Data to calculate the percentage of users accessing a specific Website feature to analyse general trends in how users are interacting with our Website to help improve the Website and our service offering.

3. How is Personal Information collected?

We use different methods to collect data from and about you including through:

  • Your interactions with us. You may give us your Personal Information however you correspond with us whether by post, phone, email or otherwise. This includes Personal Information you provide when you:
  • contact us with enquiries, feedback or a complaint;
  • complete our forms;
  • apply to become, or are on-boarded as, a Client;
  • instruct us to trade or otherwise use our Services;
  • engage in any discussions for the purposes of taking steps to enter into a contract with us;
  • and we discuss, operate and manage our commercial relationship, or prospective commercial relationship in any meeting;
  • communicate with us in any way, including (but not limited to) via electronic interactions across various channels such as e-mails, social media platforms or other messaging applications and technologies, and telephone;
  • subscribe to our Newsletter via the Website; and/or,
  • request marketing or informational material to be sent to you.
  • Providers of digital transaction services and exchanges. Financial and Technical Data can be collected from Market Participants globally, including when engaging with OSD-Seychelles as trading counterparty or when buying, selling, or confirming the authenticity of any transaction;
  • Automated technologies or interactions. As you interact with our technical and technology systems (including but not limited to our Website and social media applications and platforms), we may automatically collect Technical Data and Usage / Behavioural Data about your equipment, interaction and browsing behaviour, actions and patterns. Currently we use automated processing to collect Personal Information in connection with recruitment (please see our separate candidate privacy notice), identity confirmation and verification, as well as in connection with an instruction to trade and transaction processing. We collect this Personal Information by using cookies and other similar technologies. Please see our Cookie Notice for further details.
  • Commercial third parties. We may receive Personal Information about you from third parties. Such third parties may include (but are not limited to) analytics providers that provide technical services to us (for example, email customer relationship management platforms), which support us in conducting our business.
  • Publicly available sources. Identity, Contact and Profile Data is collected from the following (non-exhaustive list of) publicly available sources:
    • in the UK, such as:
    • His Majesty’s Revenue and Customs;
    • The Electoral Register;
    • Disclosure and Barring Service;
    • Credit Reference Agencies;
    • Companies House;
    • Crypto industry specific sources (such as, for example only: Crunchbase, Coingecko) and including crypto exchanges;
    • Open-source intelligence; and,
    • Comply Advantage;
    • Any like, equivalent or similar source (without limitation in scope) of those sources as listed above for the UK, but applicable to any relevant jurisdiction;
    • Anywhere in the world:
      • Professional societies, associations and/or business-related social media (for example only, such as LinkedIn);
      • Speeches at events or other speaking events;
      • Published articles;
      • Media reports;
      • News stories; and/or,
      • Posts on social media platforms, for example only, X (formerly Twitter) and LinkedIn.

4. Legal grounds for processing

The law requires us to have a legal basis for collecting and using your Personal Information. We rely on one or more of the following legal bases:

  • Performance of a contract with you: Where we need to perform a contract, we have entered into with you, or we are about to enter into with you.
  • Legitimate interests: We may use your Personal Information where it is necessary to conduct our business and pursue our legitimate interests, for example to enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
  • Legal obligation: We may use your Personal Information where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
  • Consent: We rely on consent only where we have obtained your active agreement to use your Personal Information for a specified purpose, for example if you subscribe to our email newsletter.

5. How do we use your Personal Information, and why?

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  1. Where we need to perform the contract, we have entered into with you.
  2. Where we need to comply with a legal obligation.
  3. Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

  1. Where we need to protect your interests (or someone else’s interests).
  2. Where it is needed in the public interest or for official purposes.

We have set out below, in a table format, a description of all the ways we plan to use (“Purpose”) the various categories of your Personal Information (“Type of Data”), and which of the legal bases (“Legal Basis”) we rely on to process Personal Information. We have also identified what our legitimate interests are where appropriate.

Table: Purposes for how we use your Personal Information

Purpose Type of Data Legal Basis
To register and on-board you as a new client.

(This includes (as a non-exhaustive list) verifying your identity, assessing your application, for legal and regulatory compliance checks, for example, anti-money laundering regulations, counter terrorist financing and to prevent fraud).

  1. Identity Data,
  2. Contact Data,
  3. Verification Data,
  4. Financial Data (where relevant),
  5. Profile Data, and,
  6. Special Categories of Data (where applicable).
  1. Performance of a contract with you
  2. Compliance with law
  3. Legitimate interests (to ensure that we can provide you the Services in a secure, efficient and compliant manner)
  4. Substantial Public Interest
  5. Consent (to process data relating to political exposed persons, and criminal allegations, convictions or offences)
To supply our Services, maintaining user databases and recording how our Services are used.

(This includes crypto market trading (including OTC derivatives), algorithmic trading, risk management and the provision of portfolio solutions; sending service communications, administrative or account-related information; informing you of security issues or updates or providing other transaction-related information.)

  1. Identity Data,
  2. Contact Data,
  3. Financial Data (where applicable),
  4. Transaction Data,
  5. Technical Data,
  6. Communication Data, and,
  7. Profile Data.
  1. Performance of a contract
  2. Legitimate interests (to ensure that we provide the Services in an effective, secure and compliant manner)
Where you work for a Market Participant or Third-Party Supplier, to engage with you for the purposes of, or otherwise in connection with the receipt and use by us of your products and/or services for the purpose of running our business.
  1. Identity Data,
  2. Contact Data,
  3. Verification Data,
  4. Financial Data (where applicable),
  5. Technical Data (where applicable),
  6. Communication Data, and,
  7. Profile Data.
  1. Performance of a contract with you
  2. Compliance with law
  3. Legitimate interests (to ensure that we have the ability to supply effective, secure and compliant Services to Clients, and conduct, process and complete digital asset transactions).
To ensure quality control of our Website, Newsletter and Services
  1. Identity Data
  2. Contact Data
  3. Financial Data
  4. Transaction Data
  5. Technical Data
  6. Communication Data
  7. Profile Data
  8. Usage/Behavioural Data, and,
  9. Any other Personal Information you volunteer
  1. Performance of a contract
  2. Legitimate interest (to use Personal Information to ensure we provide a good quality Service, have an effective working relationship with you / your organisation, and supply relevant Services in an efficient, secure and compliant way).
To manage our relationship with you and/or your organisation

(Includes communicating with you with regards to the Services taken, handling requests, complaints, enquiries and other queries; notifying you about changes to our terms or Privacy Notice, managing your account(s); and processing of your Personal Information for the purposes of relationship management).

  1. Identity Data
  2. Contact Data
  3. Verification Data,
  4. Financial Data (if applicable)
  5. Transaction Data (if applicable)
  6. Technical Data,
  7. Communication Data,
  8. Profile Data, and,
  9. Marketing and Communication Preference Data
  1. Performance of a contract with you
  2. Necessary to comply with a legal obligation
  3. Legitimate interests (to maintain / enhance relationship as well as assess eligibility of Services, to achieve increased Client understanding and engagement and improve our Services; to facilitate the safe, effective and compliant operation of our business; to share, conduct, process and complete transactions with Market Participants; to engage with Third-Party Suppliers; and to keep our records updated, and, manage our relationship with you (including but not limited to the establishment and defence of legal claims)
To comply with our legal and regulatory obligations or in connection with the administration of our business, the provision and delivery of the Services to you / your organisation including operation of our systems and processes, engagement with Market Participants, provision of the Website and engagement of our Third-Party Suppliers.
  1. Identity Data
  2. Contact Data
  3. Verification Data
  4. Financial Data
  5. Transaction Data
  6. Technical Data
  7. Profile Data
  8. Usage / Behavioural Data
  9. Communication Data
  10. Special Categories of Data, and,
  11. Marketing and Communication Preference Data
  1. Performance of a contract with you
  2. Legitimate interest (to comply with our legal obligations (including under Substantial Public Interest grounds), to detect and prevent the misuse of our Services, to maintain the security of our systems architecture, networks and staff, enforce compliance with law and legal rights, to protect the rights of third parties, to use in connection and (where appropriate) share with Third-Party Suppliers for the safe effective and compliant provision of our Services, to share with Market Participants to conduct, process and complete transactions, to use in connection with any enquiry, investigation, claim or query, and/or in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets)
  3. Compliance with law (otherwise than as above, which may include data relating to criminal convictions or offences)
  4. Substantial Public Interest
  5. Consent (to process data relating to political exposed persons, and criminal convictions or offences)
To administer our security measures (including CCTV and building access controls).

(Data captured are securely stored, accessed on a need-to-know basis and typically (e.g. for CCTV images) are automatically overwritten after a short period of time).

  1. Identity Data
  2. Contact Data
  3. Verification Data (if applicable)
  4. Communication Data and,
  5. Any other Personal Information you volunteer
  1. Performance of a contract
  2. Compliance with law
  3. Legitimate interests (to process your Personal Information so that we can keep our premises secure and provide a safe environment for your visit).

 

To administer and protect our staff, business, premises, the on-boarding portal and the Website, plus troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
  1. Identity Data
  2. Contact Data
  3. Verification Data (if applicable)
  4. Technical Data, (if applicable)
  5. Communication Data
  6. Any other Personal Information you volunteer
(a) Legitimate interests (to safely and effectively run our business, staff, premises, the provision of administration and IT services, network security (for example, to prevent or detect crime), and, for any business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To use data analytics help us understand and improve our Website and social media platform(s) (such as LinkedIn, X and/or Telegram)

(We use your data to help us understand how you use / navigate our Website and social media, which parts are more or less popular, to improve the structure and navigation of the Website, improve user experience, and to measure the effectiveness of our communications and marketing).

Please see ‘5.6Cookies’ below to learn more about how we use cookies, web beacons, pixel tags and other technologies to help us understand more about the use and effectiveness of our Website.

The relevant social media platform may also be a controller in respect of your Personal Information. For details about the relevant social media platform’s use your Personal Information, please see their privacy notice.

  1. Identity Data
  2. Technical Data
  3. Communication Data
  4. Usage / Behavioural Data
  1. Legitimate interests (to study and gain insights about how our Website and social media is used by Clients, to keep our Website secure effective and updated, to optimise user experience, to inform our marketing strategy to develop and growth our business, and, for training purposes)
We may send you marketing communications by email

(We may use your Personal Information to send you (or the organisation you represent) marketing communications by email. Our marketing may include information about events, our newsletter, our Website, our Services, company news, market commentary and will always include functionality enabling you to unsubscribe or otherwise change your preferences).

  1. Identity Data,
  2. Contact Data, and,
  3. Usage / Behavioural Data, (where applicable),
  4. Profile Data,
  5. Marketing and Communication Preference Data
  1. Legitimate interests (to send marketing content we think may appeal to Clients who have purchased our Services)
  2. Consent (where you have signed up to receive the Newsletter)
If you have a general question or need help with our Services

(There are various ways in which you can contact us (see Our Contact Details you can contact us via the Website at Contact us – OSD-Seychelles.

If you have a technical issue concerning our Website, we may also collect and process Usage / Behavioural Data and Technical Data to help us diagnose any technical issues you have so we can resolve them in an efficient way. We use this information to manage and respond to your enquiry).

  1. Identity Data,
  2. Contact Data and
  3. Communication Data
  4. Usage / Behavioural Data (where applicable)
  5. Any other Personal Information you volunteer
  1. Legitimate interests (to help you with your enquiry, provide a good standard of service and improve our customer services)
  2. Consent

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your Personal Information.

Additionally, we do use automated decision making in connection with:

  • Identity verification: machine learning has been trained on data sets to create a software algorithm that has the ability to accurately assess, analyse and evaluate an identity document to authenticate it. This algorithm categorises the government issued identity, performs a suite of technical checks (for example only, image checks) and analyses the relevant security features, the information provided on the identity and then assesses whether there are any signs of tampering or forgery, and, provides a report for review on the authenticity of an identity document. Where the algorithm returns a result other than the government issued identity is authentic, such result is flagged for an internal manual review by a OSD-Seychelles employee; and/or,
  • Transaction monitoring: where instructions to place a trade can be quarantined and flagged for review.  The automated decision making for transaction monitoring is more rules based than machine learning and is based around customisable pre-set parameters.  Once flagged, a transaction is reviewed by an appropriate OSD-Seychelles member of staff in the Legal & Compliance team to confirm or override the suggested automated decision taken (to conduct the trade or not).

We also use automated decision making in connection with recruitment, for which, please see our separate candidate privacy notice.

We comply in all material respects with the law applicable to automated processing and automated decision making.

Please also see our Cookie Notice for how and why we use which cookies.

5.1 If you fail to provide your Personal Information or information about you

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as provide with relevant Services) or otherwise decline to provide Services because we may be prevented from complying with our legal obligations (such as our compliance and background checks).

5.2 Changing the purpose for which we process your Personal Information

We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.3 Direct marketing

Currently we do not send marketing communications to you about our Services where you have purchased Services from us, and you have not opted out of receiving the marketing. We may do so in the future.

Currently you will only receive information about our Services where you have either requested we send you the information or have signed up via the Website to our Newsletter.

Please also see the table Purposes for how we will use your Personal Information above.

5.4 Third-party marketing

We will never sell your Personal Information to any third party for their own direct marketing purposes.

5.5 Opting out of marketing

As above currently we do not send marketing communications to you about our Services. You may still receive service-related communications that are essential for administrative or customer service purposes, for example, trade order confirmations.

If you have subscribed to the Newsletter you can ask to stop sending it to you at any time by following the ‘Unsubscribe’ link or clicking the ‘Update Your Preferences’ link within any email sent to you. Clicking on ‘Update Your Preferences’ will enable you to adjust and tailor your preference profile by unchecking relevant individual boxes.

5.6 Cookies

For more information about the cookies, we use and how to change your cookie preferences, please see our Cookie Notice.

6. Disclosures of your Personal Information

We only share Personal Information with others when we are legally permitted to do so.

We may share your Personal Information where necessary (as set out below) for the purposes set out in the table Purposes for how we will use your Personal Information above. The list in the table below is non-exhaustive and there may be circumstances where we need to share Personal Information with other third parties.

Who we share with When we share your Personal Information
Law enforcement or other government and regulatory agencies and bodies We share Personal Information with law enforcement, other public, government and/or regulatory agencies and/or lawful authorities with jurisdiction or other third parties as required by applicable law or regulation. Occasionally, we may receive requests from third parties to obtain certain Personal Information to check that we are complying with applicable law and regulation, to investigate an alleged crime, or, in the course of establishing, exercising or defending legal rights. We will only fulfill requests in accordance with applicable law or regulation.
Third parties in transaction processing  We share Personal Information with third parties who assist us with transaction processing including with:

  • a party acquiring interest in, or assuming risk in or in connection with, an asset or transaction, their representative or agents;
  • an issuer or seller of digital assets or tokens (including third parties appointed by them) in which you have an interest, including where such assets are held by third parties for you;
  • transaction recipients, beneficiaries, account nominees, intermediaries and/or their agents; and/or,
  • Exchanges, market counterparties clearing or settlement systems and other third-party financial services institutions.
Professional advisers and consultants We share Personal Information with auditors, lawyers, insurers, accountants and other professional services firms or consultants who advise and assist us in relation to the lawful and effective management of our organisation, as well as in relation to any dispute we may become involved in.
Third-party business acquirers Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Information in the same way as set out in this Privacy Notice.
Third-Party Suppliers We share Personal Information with third party service providers with whom there is a commercial relationship and who are contractually bound to confidentiality, such as cloud services providers, providers of software-as-a-service, error tracking software, analytics software, information technology, identity management, public databases, ID verification partners, credit reference services, anti-fraud databases, data analysis, insight analytics, data back-up, security and storage services, logistics, Website hosting and management, marketing and communication providers (such as  third-party post/email marketing and customer relationship specialists who help us in managing our marketing database, sending marketing communications and account-related communications) and others. (The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and Personal Information may be stored in any one of them).

7. International transfers

We may have to share your data with third parties, including Third-Party Suppliers and other entities in the OSD-Seychelles.We require third parties to respect the security of your Personal Information and to treat it in accordance with the law.

We may transfer your Personal Information outside the UK.

If we do, you can expect a similar degree of protection in respect of your Personal Information.

We may share your Personal Information within the OSD-Seychelles and may share it with our Third-Party
Suppliers (where necessary) in order to run our business, provide our Services and the Website.

When you submit Personal Information to us you acknowledge that your Personal Information may be
transferred outside the UK where it may be stored and processed by us, the OSD-Seychelles and/or our Third-
Party Suppliers for the purposes set out in this Privacy Notice.

When transferring your Personal Information outside the UK, we will, where required by applicable law,
implement at least one of the safeguards set out below which give your Personal Information the same protection it has in the UK.

Adequacy decisions We may transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the UK Government.
Standard Contractual Safeguards Where we use certain service providers, we may use specific contractual clauses approved by the ICO (the UK International Data Transfer Agreement, or the Addendum to the EU standard contractual clauses, when EU standard contractual clauses are used).

Please contact us if you would like further information on the specific mechanisms used by us when transferring your Personal Information outside the UK.

8. Data security

We have put in place appropriate security measures to prevent any accidental or unlawful destruction, loss, alteration, from any unauthorised disclosure of, or access to your Personal Information however it is transmitted, stored or otherwise processed.

In addition, we limit access to your Personal Information to those of our staff and other third parties who have a business need to know. They will only process your Personal Information on our instructions, and they are subject to a duty of confidentiality and to keep your Personal Information secure.

Before we share your Personal Information with any member of the OSD-Seychelles or a Third-Party Supplier we take steps to put contractual arrangements and security mechanisms in place that ensure they meet our data protection, confidentiality and security standards and obligations so that your Personal Information remains secure.

Each OSD-Seychelles and Third-Party Supplier must comply with a list of technical and organisational security measures, irrespective of their location, including measures relating to: (i) information security management; (ii) information security risk assessment and (iii) information security measures (e.g., physical controls; logical access controls; malware and hacking protection; data encryption measures; backup and disaster recovery management measures).

We do not allow any other business to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.

We have put in place procedures to deal with any suspected or actual Personal Information breach and will notify you and any applicable regulator of a breach where required to comply with law.

9. Data retention: How long will you use my Personal Information for?

We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying or complying with any legal, regulatory, compliance, tax, accounting, reporting or internal policy requirements (which comply with the minimum requirements of applicable law and regulation) and/or risk management purposes.

To determine the appropriate retention period for Personal Information, we consider: the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and/or the applicable legal, regulatory, compliance, tax, accounting or other requirements.

If you are a prospective Client we shall keep your Personal Information for as long as you consent, otherwise for a maximum of twelve months from our last contact with you.

We will keep your Personal Information for as long as you remain a Client in the case of new or current Clients, otherwise for as long as is required to meet our regulatory requirements or in compliance with applicable law.

Once our relationship with you has ended (for example, after your account has closed or following a transaction, your application for a product is refused, or you decide not to go ahead with an application), we will only keep your Personal Information for a period that is appropriate, being a minimum of 5 years, and in some cases up to 10 years.  The same is true for any Personal Information relating to any Market Participants.

If you unsubscribe from our newsletter we endeavour to update our records within twenty-four hours. To learn more about how long cookies persist, please see our Cookie Notice.  We keep records of visitors to our offices in accordance with the requirements of local law.

We may retain your Personal Information for a longer period in the event of an enquiry, feedback or complaint or if we reasonably believe there is any litigation (or the prospect of any litigation) in respect to our relationship with you.

In some circumstances you can ask us to delete your data: see ‘Your legal rights’ below for further information.

In some circumstances we will anonymise your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. Your legal rights

You have a number of rights under data protection laws in relation to your Personal Information.

You have the right to:

  • Request access to your Personal Information (“subject access request“). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your Personal Information in certain circumstances. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including were we carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
  • You also have the absolute right to object any time to the processing of your Personal Information for direct marketing purposes (see Opting Out of Marketing” in Section 5.5 for details of how to object to receiving direct marketing communications).
  • Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your Personal Information (see the table in Section 5 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain of the Services to you. We will advise you if this is the case at the time you withdraw your consent.
  • Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in one of the following scenarios:
    • If you want us to establish the data’s accuracy;
    • Where our use of your Personal Information is unlawful, but you do not want us to erase it;
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • You have objected to our use of your Personal Information, but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please see Contact details (Section 14).

Please also note that the above rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse requests, which may include not providing some or all of the Personal Information that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to where there may be any legal or regulatory restrictions on us informing you.

No fee usually required

You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

11. Third-party links

Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the Privacy Notice of every website you visit.

12. Changes to your Personal Information

We are committed to keeping your Personal Information accurate and up to date. Therefore, if your Personal Information you gave us changes, for example a new email address, please inform us of the change as soon as possible.

13. Personal Information of minors

As above, OSD-Seychelles the Website is not intended for use by, or targeted at, minors (individuals under the age of 18). We do not knowingly collect or process Personal Information of minors. If we receive Personal Information of minors, we will comply with all applicable laws and regulations relating to the processing of Personal Information of minors. Please contact us if you believe that a minor may have submitted Personal Information to us.

14. Our contact details

If you have any questions about this privacy notice or about the use of your Personal Information or want to
exercise your privacy rights, please contact the Data Protection Officer or their team in the following ways:

15. Complaints

You have the right to make a complaint at any time if you feel the processing of your Personal Information infringes applicable privacy and data protection law:

In the case of the United Kingdom, you can complain to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk).

We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority so, please contact us in the first instance.

16. Updates to this Privacy Notice

We reserve the right to update this Privacy Notice at any time, and we will make a new Privacy Notice available to you when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

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