3PSmart LTD Privacy Policy

Applies to all services provided by 3PSmart LTD, including websites, APIs, applications, and related financial services.

This Privacy Policy (“Policy”) describes how 3PSmart LTD (“Company”, “we”, “our”, or “us”) collects, uses, stores, protects, and discloses personal information obtained through our services, website, applications, APIs, and related business operations.

By creating an account, accessing, or using any services offered by 3PSmart LTD, users acknowledge that they have read and understood this Policy together with our Terms and Conditions and any additional legal notices that may apply.

3PSmart LTD is an Anjouan limited liability company providing virtual currency depository and exchange operation services. We are committed to protecting the privacy and confidentiality of our users while complying with applicable financial crime prevention, AML, KYC, and regulatory obligations.

CHAPTER I – DEFINITIONS

For the purpose of this Privacy Policy:

• “Personal Information” means any information relating to an identified or identifiable natural person.
• “Processing” means any operation performed on personal information, whether automated or manual.
• “User”, “Customer”, or “Data Subject” refers to any person using our services or providing personal information to us.
• “Services” refers to all products, platforms, APIs, applications, and financial services provided by 3PSmart LTD.
• “Business Account” refers to accounts opened on behalf of legal entities, corporations, partnerships, or other organizations.

CHAPTER II – INFORMATION WE COLLECT

To provide our services and comply with applicable legal and regulatory obligations, including Anti-Money Laundering (“AML”) and Know Your Customer (“KYC”) requirements, we may collect the following categories of information.

A. Information Provided by Users

When registering or using our services, users may provide:

• Full legal name
• Email address
• Telephone number
• Residential address
• Date of birth
• Government-issued identification documents
•Selfies and identity verification images
• Wallet addresses and transaction details
• Banking details and payment information
• Source of funds documentation
• Proof of address documentation

We may request additional documentation where necessary to comply with regulatory requirements or internal compliance procedures.

B. Information Automatically Collected

When users interact with our systems, we may automatically collect:

• IP addresses
• Device identifiers
• Browser information
• Session activity
• Usage statistics
• Login history
• Geographic location information
• Cookies and analytical data

C. Information for Business Accounts

For legal entities and corporate accounts, we may additionally collect:

• Company legal name
• Registration number or EIN
• Corporate formation documents
• Shareholder and ownership information
• Details regarding directors and authorized signatories
• Proof of identity of beneficial owners
• Operational and business activity information

CHAPTER III – COOKIES AND ANALYTICS

Our website and applications may use cookies, server logs, and similar technologies to improve performance, user experience, and security.

Cookies may be used to:

• Maintain session authentication
• Remember user preferences
• Analyze website traffic and performance
• Detect fraudulent or suspicious activity
• Improve platform functionality

Users may disable cookies through their browser settings. However, certain functionalities of the website or services may become unavailable or limited.

We may also use analytics providers and monitoring tools to better understand user interaction with our services and improve operational performance.

CHAPTER IV – PURPOSE OF PROCESSING

We process personal information for legitimate business, legal, and operational purposes.

We process personal information based on contractual necessity, legal obligations, legitimate interests, and, where applicable, user consent. 

This includes:

• Providing and maintaining our services
• Processing transactions and payments
• Conducting identity verification (KYC)
• Performing AML and fraud prevention checks
• Complying with regulatory and legal obligations
• Monitoring suspicious or prohibited activities
• Improving platform functionality and user experience
• Responding to support requests and disputes
• Protecting the security and integrity of our systems

Certain compliance and fraud prevention checks may involve automated systems. However, final decisions involving account restrictions or escalations are reviewed by authorized personnel.

CHAPTER V – SHARING OF INFORMATION

We may share personal information with third parties where necessary for operational, regulatory, or legal purposes.

This may include:

• Financial institutions and payment providers
• Banking partners
• KYC and AML verification providers
• Blockchain analytics providers
• Cybersecurity and hosting providers
• Government authorities and regulators
• Law enforcement agencies where legally required

We do not sell personal information to third parties for advertising purposes.

All third-party service providers are expected to maintain adequate security and confidentiality standards.

CHAPTER VI – DATA RETENTION

We retain personal information only for as long as reasonably necessary to fulfill legal, regulatory, contractual, and operational obligations.

Customer identification records, transactional information, and compliance documentation may be retained for a minimum period of five (5) years or longer where required by law or regulatory authorities.

Where retention is no longer required, personal information will be securely deleted, anonymized, or destroyed according to internal procedures.

CHAPTER VII – DATA PROTECTION AND SECURITY

3PSmart LTD implements technical and organizational measures designed to protect personal information against unauthorized access, misuse, loss, disclosure, or alteration.

Security measures may include:

• TLS-secured communications
• Encryption of sensitive information
• Two-factor authentication (“2FA”)
• Firewall and DDoS protection
• Restricted internal access controls
• Password management policies
• Continuous monitoring systems
• Business continuity and cybersecurity procedures

Employees and contractors with access to customer information are subject to confidentiality obligations and security training.

While we implement reasonable safeguards, no method of electronic transmission or storage is entirely secure.

CHAPTER VIII – RIGHTS OF DATA SUBJECTS

Subject to applicable laws and regulations, users may have the following rights:

• Right of access
• Right to rectification
• Right to erasure
• Right to restrict processing
• Right to object to processing
• Right to data portability
• Right to withdraw consent
• Right to lodge complaints with competent authorities

Requests related to personal information may be submitted to our support team or designated compliance contacts.

Certain rights may be limited where processing is required for AML, fraud prevention, legal compliance, or regulatory obligations.

CHAPTER IX – INTERNATIONAL TRANSFERS

Personal information may be processed or stored in jurisdictions outside the user’s country of residence, including jurisdictions where our infrastructure providers, partners, or service providers operate.

By using our services, users acknowledge that such transfers may occur where necessary for the provision of services or compliance obligations where permitted under applicable law.

CHAPTER X – THIRD-PARTY SERVICES

Our services may integrate or interact with third-party applications, websites, or financial service providers.

Where users authorize such integrations, third parties may receive certain information necessary to provide their services. Third-party platforms operate under their own privacy policies and terms, and 3PSmart LTD is not responsible for their independent practices.

CHAPTER XI – POLICY UPDATES

We reserve the right to amend or update this Privacy Policy at any time to reflect operational, legal, regulatory, or technological changes.

Material changes may be communicated through email notifications, platform announcements, or updates published on our website.

Continued use of the services after updates become effective constitutes acceptance of the revised Policy.

CHAPTER XII – CONTACT INFORMATION

For questions regarding this Privacy Policy, data protection practices, or personal information requests, users may contact:

3PSmart LTD
Email: support@3psmartltd.com
Website: https://www.3psmartltd.com

APPENDIX – REGULATORY DISCLOSURE

3PSmart LTD is licensed and regulated by the Anjouan Offshore Finance Authority (“AOFA”) in the Union of the Comoros.

All collection, processing, retention, and reporting obligations are subject to applicable laws and regulations of Anjouan, including financial crime prevention and AML requirements.

Services are not available in restricted or sanctioned jurisdictions, including jurisdictions identified as prohibited under internal compliance procedures or FATF restrictions.