You have the right to withdraw the consent given to AllScale for processing your personal data at any time. To remove your permission, you must send an e-mail to [email protected], which must contain at least the following information and documentation:You have the right to withdraw the consent given to AllScale for processing your personal data at any time. To remove your permission, you must send an e-mail to [email protected], which must contain at least the following information and documentation:
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1. Your name and email address, or other means to communicate the answer to your request;
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2. The valid documents proving your identity (simple copy in printed or electronic format of your ID or passport) or, if applicable, a simple copy in printed or electronic form of the power of attorney of the person that will represent you, and their corresponding ID or passport;
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3. A clear and precise indication that you desire to withdraw your consent, and
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4.Any other element or document that facilitates the location of your personal data.
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To comply with your request, it will be done after authenticating your identity; AllScale will confirm the acknowledgment of your withdrawal instruction and, if possible, will destroy any personal data collected from you. Please note that if you withdraw your consent, AllScale won't be able to provide any services.

AllScale will confirm the acknowledgment of your withdrawal instruction and, if possible, will destroy any personal data collected from you. Please note that if you withdraw your consent, AllScale won't be able to provide any services.
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If you are not an adult according to your country's law, you are not entitled to our services or give us your personal data. If you are not an adult, please do not try to use or attempt to register.

We want you to understand the types of information we process when you register and use AllScale's services (hereinafter the "Data")

3.1 Information You Provide to Us at Registration
When you create an AllScale Account, you provide us with personal information that includes your identification data such as:
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Full Name and Surname without abbreviation

Date of birth, Gender, Nationality, Birth state and country

Authentication Credentials (including Username, Password, Passkeys, and Google or Email Sign-in tokens)

E-mail address

Full personal address and zip code

Financial and wealth data

Employment data (except trade union membership)

Mobile phone number

One-Time Passwords (OTP) and verification codes sent to your email or mobile device

Google authenticator to be used for 2FA verification for improved security.

Geolocation of the mobile device, or the IP address of the computer, from which you opened your account;

A valid official ID
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3.2 Information on special categories of personal data

Regarding the due functioning and to apply the proper security measures to your AllScale Account, we process your personal data relating to physical characteristics and biometrics, such as facial recognition or fingerprints. As this information is considered as a special category of personal data, we need your explicit consent to process this information.

Your express consent to process your biometric data will be interpreted if you choose to use the "biometrics security" or “Passkey” option in our AllScale App for account access or transaction signing. AllScale does not handle any other particular category of personal data without your express consent.

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3.3 Information we collect as you use AllScale Services
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3.3.1 Service Usage Information
Through your use of the Site and our different AllScale Services, we also monitor and obtain tracking information related to usages such as:
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(a) Access date & time,
(b) Device identification,
(c) Operating system,
(d) Browser type, and
(e) IP address.
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A processor collects this information under the supervision of the Controller. This service usage data helps our systems ensure that our interface is accessible for users across all platforms and can aid during criminal investigations.
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3.3.2 Transaction Information
For all AllScale User accounts, we collect transaction information, including deposit snapshots, account balances, trade history, withdrawals, order activity, and distribution history. This transaction data is monitored for suspicious trading activity for user fraud protection and legal case resolution. In addition, for transactions processed through the AllScale Checkout Services, we collect and process data generated by our automated Know Your Transaction (“KYT”) screening process, including but not limited to: the Customer’s originating wallet address, transaction hash, blockchain network identifier, the amount and type of Digital Asset transferred, the risk score and risk category assigned by the third-party KYT vendor, and the screening outcome (pass or fail). This KYT-related data is processed for the purposes of compliance screening, fraud prevention, and regulatory reporting.

3.4 Information Related to Non-Custodial Wallet Services
AllScale utilizes third-party cryptographic infrastructure (Turnkey, https://www.turnkey.com ) to generate and manage your non-custodial smart contract wallet.a) Private Key Storage: Your wallet's private keys are generated and stored within a secure cryptographic enclave managed by our infrastructure partner, Turnkey. You can also export your private key via AllScale software for backup. Neither AllScale nor Turnkey has access to your unencrypted private keys or fund. Your keys are accessible only by you through the verification of your authorized credentials (such as Passkeys, Google Sign-in, or Email Sign-in). (b) Authentication & Transaction Signing: When you register or sign a transaction using Google Sign-in, Email Sign-in, or Passkeys, AllScale and Turnkey process these authentication signals to verify your identity. This process may involve sending a One-Time Password (OTP) to your registered email address for verification.(c) Public Blockchain Data: To provide our service, we process publicly available information from the blockchain associated with your wallet's public address. This includes transaction history and balances, which we display to you through the AllScale interface. Additionally, information stored on-chain may be public, immutable, and not easily removed or deleted and, in many cases, cannot be deleted. Your public keys may reveal information about you and this information can potentially be correlated now or in the future by any party who chooses to do so, including law enforcement. If you are unfamiliar with blockchain technology and its transparent and public nature, we strongly encourage you to conduct your own research into blockchain before electing to use our services.

3.5 Information Related to Invoicing Services
When you generate an invoice, we process the information you provide, which may include the recipient's name, wallet address, email address, the description of goods or services, and the payment amount.

We also process transaction information related to the payment of the invoice, which is collected for all AllScale User accounts.

3.5A Information Related to Checkout Services
‍When you use the AllScale Checkout Services to accept payments in supported Digital Assets from your Customers, we collect and process the following information:(a) Merchant Configuration Data: information you provide when setting up the Checkout Services, including your designated Non-Custodial Wallet address for receiving payments, API credentials, hosted payment link configurations, and any payment preferences or parameters you configure through the AllScale Dashboard or API.(b) Customer Transaction Data: when a Customer initiates a payment through an AllScale checkout link or API, we process the Customer’s originating wallet address, the Digital Asset type and amount transferred, the blockchain network used, the transaction hash, and the timestamp. AllScale does not collect the Customer’s name, email address, or any other personally identifiable information directly from the Customer through the Checkout Services; only on-chain and transaction-level data is processed.(c) Generated Address Data: the Checkout Services may generate temporary, single-use Digital Asset Addresses (including Transit Addresses used for KYT screening) to facilitate individual transactions. We process the address, its associated transaction records, and routing outcomes.(d) Payment Discrepancy Data: records of underpayments, overpayments, and network fee deductions associated with Checkout transactions, which are retained for dispute resolution and record-keeping purposes.Please note that the Checkout Services operate on a strictly non-custodial basis. AllScale does not take custody, possession, or control of any Digital Assets at any point during the checkout process (including when Digital Assets transit through a Transit Address for KYT screening). AllScale acts solely as the provider of the payment routing software. The Merchant is solely responsible for implementing any Know Your Customer (KYC) or identity verification procedures for its own Customers if required by the laws applicable to the Merchant’s jurisdiction and line of business.

3.6 Information Related to Reward System
If you participate in the AllScale Reward System, we collect and process data regarding your interactions with the platform (including but not limited to your on-chain activities, trading volume, login frequency, and feature usage) to calculate your "AllScale Points." This data is processed solely for the purpose of administering the loyalty program and distributing rewards. We do not guarantee there will be or will be not a distribution of rewards.

3.7 Information Related to KYT (Know Your Transaction) Screening
As a standard component of the AllScale Checkout Services, AllScale applies automated Know Your Transaction (“KYT”) screening to incoming Customer payments in supported stablecoins. In connection with this screening, we collect and process the following categories of data:

(a) Transaction Data: the Customer’s originating wallet address, the destination Transit Address, the transaction hash, blockchain network, the type and amount of Digital Asset, and the timestamp of the transaction.

(b) KYT Screening Results: the risk score, risk category, screening decision (pass or fail), and any flags or alerts generated by the third-party KYT vendor in relation to the transaction.

(c) Routing Outcome Data: whether the Digital Assets were forwarded to the Merchant’s Non-Custodial Wallet (KYT pass) or returned to the Customer’s originating wallet address (KYT fail), and the associated on-chain transaction hashes for such routing.

This data is shared with our third-party KYT compliance vendor(s) for the sole purpose of conducting the automated risk screening. AllScale retains KYT screening records for the period required by applicable anti-money laundering (AML), counter-terrorist financing (CTF), and sanctions regulations, or as otherwise required by law. Please note that certain transaction data processed in connection with KYT screening is recorded on-chain and is therefore publicly accessible, immutable, and cannot be deleted.

4.1 To provide and maintain our services
We use the information collected to deliver the best quality of our services and verify user identity. This now includes processing public wallet data to display within the non-custodial wallet interface and processing invoice data to facilitate payment collection between parties. Without processing this information, we would be unable to offer these services.

We use the IP address and unique identifiers stored in your device's cookies to help us authenticate your identity and provide our service. Given our legal obligations and system requirements, we cannot provide you with services without data like identification, contact information, and transaction-related information.

‍4.2 To protect our users
We use the information collected to protect our platform, AllScale User's accounts, and archives.

We use IP addresses and cookie data to protect against automated abuse such as spam, phishing, and Distributed Denial of Service (DDoS) attacks.

We analyze trading activity to detect suspicious behavior early to prevent potential fraud and loss of funds to bad actors.

‍4.3 To comply with legal and regulatory requirements
Respect for the privacy and security of data you store with AllScale informs our approach to complying with regulations, governmental requests, and user-generated inquiries. We will not disclose or provide any personal information to third-party sources without review from our legal case team and/or prior consent from the user.

In accordance with and as permitted by applicable law and regulations, we will retain your information as long as necessary to serve you, to maintain your account for as long as your account is active, or as otherwise needed to operate our business. When you close your account, we may continue to communicate with you about our Services, give you important business updates that may affect you, and let you know about products and services that may interest you, unless you have opted out of receiving marketing communications. We may also continue to use some of your information for business purposes and to improve our offerings or in some cases to develop new ones. We will retain and use your information as required by applicable regulations and AllScale's records and information management policies to comply with our legal and reporting obligations, resolve disputes, enforce our agreements, complete any outstanding transactions and for the detection and prevention of fraud.

To comply with global industry regulatory standards including Anti-Money Laundering (AML), Know-Your-Customer (KYC), and Counter-Terrorist Financing (CTF), AllScale requires user accounts to undergo user identity authentication for both Personal & Enterprise-level accounts. These services are conducted by a processor who delivers all the results to AllScale.

‍4.4 To measure Site performance
We actively measure and analyze data to understand how our services are used. This review activity is conducted by our operations team to continually improve our platform's performance and to resolve issues with the user experience.

We continuously monitor our systems' activity information and communications with users to look for and quickly fix problems.

‍4.5 To communicate with you
We use personal information collected, like an e-mail address, to interact with users directly when providing customer support on a ticket or to keep you informed on logins, transactions, and security.

‍4.6 To deliver our newsletter, which includes publicity and sales, when chosen
‍Subscribing to our news and publicity services is voluntary. You will always have the option to opt out.

‍4.7 To enforce our AllScale User Agreement and other agreements and policies
‍AllScale reserves the right to terminate the provision of service to any user found engaging in activities that violate our policies.

4.8 To Administer the Reward System
‍We process your platform usage data to track your eligibility for AllScale Points and to execute the distribution of rewards in accordance with our User Agreement.

4.9 To Conduct KYT (Know Your Transaction) Screening
We process transaction data and share it with independent, third-party KYT compliance vendors to conduct automated risk screening of incoming stablecoin payments through the AllScale Checkout Services. The purpose of this processing is to assess the risk profile of incoming transactions, detect and prevent the receipt of funds derived from illicit activities (including but not limited to money laundering, terrorist financing, sanctions evasion, and fraud), and to comply with applicable AML, CTF, and sanctions regulations. The legal bases for this processing include: (a) our legitimate interest in maintaining the integrity and security of the AllScale platform and protecting our Merchants and their Customers; (b) compliance with legal obligations under applicable AML/CTF laws; and (c) the performance of the Checkout Services contract between AllScale and the Merchant, which incorporates KYT screening as a standard feature.

AllScale may transfer its customers' personal data to other companies or authorities for the purposes set out in this Privacy Policy. These data transfers include the following:
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(a) Affiliates
Since AllScale is part of an international group, your personal data may be communicated to other companies within the same corporate group and under the same data privacy policy, including our affiliates. Our affiliates have implemented data protection measures and policies consistent with ours, complying with applicable laws in each country, and adhering to this Privacy Notice.
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(b) Service Providers
AllScale may send all or part of your personal data to processors or service providers who assist us with certain data processing activities. These service providers may include (i) technology companies that provide communication or infrastructure services, and (ii) companies that manage publicity or loyalty programs. In all these cases, AllScale ensures that service providers are contractually obligated to protect customers' personal data. (iii) wallet infrastructure providers: we share specific authentication data (such as your email address or unique user identifier) with our wallet infrastructure partner, Turnkey, solely to facilitate the generation of your secure wallet credentials and to send One-Time Passwords (OTPs) required for account registration and transaction signing. Turnkey is contractually prohibited from using your personal information for any purpose other than providing these security services.
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(i) technology companies that provide communication or infrastructure services, and (ii) companies that manage publicity or loyalty programs. In all these cases, AllScale ensures that service providers are contractually obligated to protect customers' personal data. (iii) wallet infrastructure providers: we share specific authentication data (such as your email address or unique user identifier) with our wallet infrastructure partner, Turnkey, solely to facilitate the generation of your secure wallet credentials and to send One-Time Passwords (OTPs) required for account registration and transaction signing. Turnkey is contractually prohibited from using your personal information for any purpose other than providing these security services.
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(c) Legal Authorities
AllScale may transfer personal data to administrative or judicial authorities when required for safeguarding public interest, protecting AllScale's or third parties' rights, or for the enforcement and administration of justice. AllScale may also disclose personal data when we believe, in good faith, that it is required by law or necessary to protect you, respond to claims, or safeguard AllScale's property, its affiliates, or third parties' rights.

(d) Corporate Transactions
Customer information may be communicated or transferred to third parties in the course of a corporate transaction, such as a merger, asset sale, or acquisition, always with the aim of protecting the users' best interests.

(e) Consent or Legal Requirement
In other cases, when permitted by applicable law or with your express consent.

(f) Third-Party Service Providers
AllScale may share your personal data with third parties, including payment providers, onramp and offramp service provider and with other companies within the financial technology ecosystem, including banks, digital wallets, and exchanges. In these cases, AllScale will share only the information necessary to complete the transaction you initiated, and you will be asked to provide your consent for such transfers. Please note that these third parties operate under their own privacy policies.

(g) KYT (Know Your Transaction) Compliance Vendors
As a standard component of the Checkout Services, AllScale shares transaction data with independent, third-party KYT compliance vendors to conduct automated risk screening of incoming stablecoin payments. The data shared with KYT vendors includes the Customer’s originating wallet address, transaction hash, blockchain network, the type and amount of Digital Asset transferred, and associated metadata necessary for the risk assessment. KYT vendors process this data solely for the purpose of generating a risk score and screening decision. AllScale does not share any personally identifiable information (such as names, email addresses, or government-issued identification) with KYT vendors; only on-chain transaction data and wallet addresses are transmitted. KYT vendors are contractually obligated to process the data in accordance with applicable data protection laws and are prohibited from using the data for any purpose other than providing the KYT screening service. Please note that KYT vendors operate under their own privacy policies and data retention practices.

AllScale uses third-party software solutions for multifactor authentication, including “Passkeys” provided by third parties, such as Google or Apple. Your use of Passkeys is governed by the relevant Passkey provider’s terms of service agreements and privacy policies. We cannot, and do not, make any representations or warranties of any kind regarding the security of any third-party Passkey service or its data collection and security practices. Your use of Passkeys in concert with AllScale is solely at your own risk.

When you use our invoicing service, the information contained in the invoice will be shared with the intended recipient. If the recipient chooses to pay via credit card or another on-ramp method, we will share necessary transaction data with our third-party payment partners to process the payment.

To use these on-ramp payment services, you or the party paying the invoice may be redirected to our partner's platform to complete a Know-Your-Customer (KYC) and identity verification process. This process is governed by the partner's own privacy policy. AllScale may receive confirmation of the verification status but does not typically collect the underlying identity documents provided to the partner.

When you use the AllScale Checkout Services to accept payments from Customers, the incoming transaction data is automatically shared with our third-party KYT compliance vendor(s) to conduct real-time risk screening before the funds are settled to your Non-Custodial Wallet. If the transaction fails the KYT screening, the Digital Assets are automatically returned to the Customer’s originating wallet address; the transaction data and screening results are retained by AllScale and the KYT vendor for compliance and regulatory reporting purposes. You acknowledge that this KYT screening is a standard, non-optional component of the Checkout Services and that the associated data processing occurs automatically without requiring separate consent for each transaction.

In all such cases, AllScale will only share the information required to complete the transaction you initiated, and you will be asked for consent for these transfers. Please note that these third parties operate under their own privacy policies.