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Privacy policy

Revision date — 23.09.2026

1. General Provisions

1.1. This Privacy Policy (hereinafter, the "Policy") sets out the principles of the collection, use, storage, transfer and protection of Users' Personal Data by the Company.

1.2. Terms used in this Policy with a capital letter and not defined directly herein have the meanings set out in the User Agreement (Sections 1–3).

1.3. By using the Service, the User confirms that they have read this Policy and gives Consent to the Processing of their Personal Data in accordance with its terms and the applicable laws of the Republic of Panama, in particular Law No. 81 of 26 March 2019 "On Personal Data Protection" (Ley 81 de Protección de Datos Personales).

1.4. The Service is intended exclusively for persons who have reached the age of 18 or full legal capacity under the laws of their jurisdiction. The Company does not collect or process the Personal Data of persons under the age of 18.

2. Data Collected

2.1. Telegram Profile Data

During interaction with the Telegram bot, the User's unique Telegram identifier, their name, profile photo and other data available via the Telegram API are collected. When the User uses the web version of the Service and enables two-factor authentication (2FA), the Company also processes the User's email address.

This information is used solely to identify the User and to ensure the operation of the Service.

2.2. Transaction Data

When the User performs operations such as the exchange or transfer of virtual assets, the Company may record wallet addresses, transaction hashes and currency types. This information is necessary for the technical execution of transactions and compliance with AML requirements.

2.3. AML/KYC Data

The Company does not carry out regular KYC verification upon registration and by default does not collect or store the User's identity documents. In exceptional cases — upon receipt of a notification from a Partner Exchange or Liquidity Provider that a wallet is on a blacklist or that funds have been subject to a Freeze, upon Blocking of a Custodial Wallet in accordance with clause 10.6 of the User Agreement, and at the request of competent public authorities — the Company may request minimal identification information from the User solely for the purpose of resolving the relevant situation. Such data, if collected, is processed confidentially and stored for the period set out in Section 5 of this Policy and applicable AML/CFT legislation.

At the same time, for the functioning of the Custodial Service, the Company stores operational data related to the User's Custodial Wallets: their addresses, operation history and technically protected private keys. This data does not constitute identity documents and is used solely for the provision of services and compliance with requirements.

The procedure for AML/KYC checks is determined by the AML/KYC Policy.

2.4. Activity Logs

Information about the User's actions on the Service is collected, including commands sent and operations performed. This is used to ensure the proper operation of the system and technical support.

2.5. Principle of Minimal Storage

The Company stores the data necessary for the functioning of the Custodial Service and compliance with requirements: the Telegram ID, the linking of Custodial Wallets to the User, transaction history, and technically protected private keys to wallets under the Company's management.

The Company does not store identity documents on a permanent basis and does not collect excessive Personal Data beyond what is necessary to provide services and to comply with AML/legal requirements.

3. Use of Data

3.1. User data is used exclusively for:

  • providing services and ensuring the functionality of the Service;
  • technical maintenance, ensuring the security and improvement of the Platform;
  • responding to legal or regulatory requests in the cases provided for by law.

3.2. Personal Data is processed on the basis of:

  • the User's Consent given when using the Platform;
  • the necessity of performing the agreement with the User;
  • the fulfilment of the Company's legal obligations, including in the field of AML/CFT.

4. Data Sharing

4.1. The Company does not sell Users' Personal Data. The transfer of data to third parties is limited to providers of blockchain analytics services (AML checks) and Partner Exchanges / Liquidity Providers to the extent necessary to execute an operation, as well as to the cases provided for in clauses 4.2 and 4.4 of this Policy.

4.2. To ensure the functioning of the Card Service (Office Card module), the Company may transfer the minimum necessary technical data (Telegram ID, language settings, technical identifiers) to the Card Service Operator — Financial Services LTD (jurisdiction of registration: England and Wales, registration number: 15556128), as well as to the joint support service.

4.3. The transfer and Processing of the said data are carried out on the basis of an agreement on the processing and transfer of data (Data Processing Agreement / DPA) concluded between the Company and Financial Services LTD (England and Wales), which guarantees compliance with equivalent standards of information protection, as well as in accordance with the Privacy Policy of the Office Card Service.

4.4. The Company discloses Users' Personal Data to public authorities solely on the basis of a legally binding and duly executed request from authorised authorities of the Republic of Panama, within the framework of mutual legal assistance procedures recognised by the Republic of Panama, as well as in other cases where such disclosure is mandatory under applicable law. The Company verifies each request for compliance with the established requirements and may refuse to provide data or require that the request be duly executed if it lacks sufficient legal grounds or has been executed in breach of the established procedure.

5. Data Storage

The Company stores data only for as long as is necessary for:

  • fulfilling legal and operational purposes;
  • fulfilling the obligation to retain records and documentation under AML/CFT requirements;
  • processing requests as part of customer support.

Data obtained under AML/CFT procedure requirements, as well as transaction history and AML check results, are stored for the period established by the applicable laws of the Republic of Panama, but not less than 5 (five) years from the termination of the relationship with the User. Other data is stored for the term of the User's account.

6. Security

The Company applies reasonable and sufficient organisational and technical protection measures by storing the private keys to Custodial Wallets using encryption and access control. Access to the keys is limited to a circle of authorised persons and is granted solely to the extent necessary for the functioning of the Service.

At the same time, the Company cannot guarantee 100% security of data transmission via the Internet, including Telegram.

In the event of a breach of Personal Data security capable of creating a risk to the User's rights, the Company notifies the affected Users within the time limits established by the applicable laws of the Republic of Panama, describing the nature of the breach and the measures taken.

7. User Rights

7.1. In accordance with Law No. 81 of the Republic of Panama of 26 March 2019 "On Personal Data Protection" and Executive Decree No. 285 (Decreto Ejecutivo No. 285), the User has the following rights:

  • to request and receive information about the User's Personal Data processed by the Company;
  • to demand the modification, clarification or updating of incorrect, incomplete or outdated Personal Data;
  • to demand the deletion of their Personal Data from the Company's systems if it is no longer required for the purposes for which it was collected, or upon withdrawal of Consent;
  • to object at any time to the Processing of their data or to withdraw previously given Consent to its Processing;
  • to receive their Personal Data in a structured form;
  • to lodge a complaint with ANTAI (National Authority for Transparency and Access to Information).

7.2. Procedure for Exercising Rights and Limitations

Requests may be sent via the official contact channel or by email to info@crypto-office.com, indicating the Telegram ID. The Company considers requests within a reasonable period not exceeding 10 (ten) business days from the date of receipt of the request (in accordance with the requirements of Law No. 81).

The right to deletion of data and withdrawal of Consent is limited and does not extend to information that the Company is obliged to retain in fulfilment of legal obligations to counter the laundering of proceeds of crime and the financing of terrorism (AML/CFT/AML), including transaction history and check records retained for the period established by law.

8. International Data Transfer

To ensure the operation of the Company, Personal Data may be processed or stored on servers located outside the Republic of Panama, in jurisdictions with equivalent data protection standards. By using the Service, the User gives express Consent to the cross-border transfer of minimal technical data to servers and structures located outside the Republic of Panama, including England and Wales (for the operation of the Card Service), in jurisdictions ensuring equivalent standards of information protection.

9. Amendments to this Policy

The Company may make amendments to this Privacy Policy. The new version is published on the Website indicating the revision date.

Scheduled amendments take effect upon the expiry of 7 (seven) calendar days from the date of publication. Before they take effect, a User who does not agree with the amendments may stop using the Service and withdraw their assets.

Amendments arising from the requirements of applicable law, orders of competent public authorities, requirements of Partner Exchanges or Liquidity Providers, as well as the need to eliminate threats to the security of the Service, take effect from the moment of publication. In this case, a User who does not agree with the amendments may stop using the Service and withdraw their assets, except in the cases provided for in clause 10.6 of the User Agreement.

Continued use of the Service after the amendments take effect constitutes the User's acceptance of the new version.

10. Governing Law, Language and Contacts

10.1. Governing Law

This Policy is governed by the laws of the Republic of Panama.

10.2. Prevailing Language of the Policy

This Policy has been drawn up in the English language. Other versions are provided solely for the convenience of Users. In the event of disagreements in the interpretation of the provisions of this Policy, in the exercise of data subjects' rights, and in the consideration of disputes and requests by the National Authority for Transparency and Access to Information of the Republic of Panama (ANTAI) or other competent authorities, the English version shall be decisive.

10.3. Contact Information

For all questions related to the use of the Service, the User may contact the Company using the following contact details:

Legal name: SoftVision Innovations S.A.

Registered address: 10th Floor, Plaza 2000 Tower, 50th Street, Panama, Republic of Panama

Registration number (RUC): 155765203

Phone: +971 52 725 0099

Email: info@crypto-office.com

Website: https://crypto-office.com

Support: via Telegram bot @office_app_support_bot