Privacy Policy

PRIVACY POLICY

 Kingdom Trust is committed to maintaining the privacy and security of your personal information. During the application, investments processes and through your use of our website, we collect personal information, as outlined below. We will also ask for similar information about beneficiaries to assist us in locating them in the future should the need arise. Please know that this information is collected only for our internal reference and will not be disseminated except as required by law or as discussed below.

The information we collect will be used in our processing operations to establish your account and to carry forward your investment directions. It is also used in our statutory reporting obligations, which include responding to requests for information from governmental and quasi-governmental agencies and to insure proper billing of our services to you. We will, from time to time, use the information to provide you with marketing and promotional material and to deliver correspondence we have received concerning your account or assets held within your account. It will also be used to answer questions that you may have concerning your account or the assets held within your account. 

Personal Information We Collect

As used herein, “Personal Information” means information that identifies or is reasonably capable of identifying an individual, directly or indirectly, and information that is being associated with an identified or reasonably identifiable individual.

Personal Information we collect from you. We may collect the following categories of Personal Information directly from you:

  • Identification Information, such as name, email, phone number, postal address, government identification numbers (which may include Social Security Number or equivalent, driver’s license number, passport number);
  • Commercial Information, such as trading activity, order activity, deposits, withdrawals, account balances;
  • Financial Information, such as bank account information, routing number;
  • Correspondence, such as information that you provide to us in correspondence, including account opening and customer support;
  • Sensory Information, such as images collected for identity verification, audio recordings left on answering machines;
  • Employment Information, such as job title, source of wealth; and
  • Institutional Information, such as for institutional customers, we may collect additional information, including: institution’s legal name, Employer Identification Number (“EIN”) or any comparable identification number issued by a government, and proof of legal existence (which may include articles of incorporation, certificate of formation, business license, trust instrument, or other comparable legal document).

Personal Information we collect automatically

We may collect the following categories of Personal Information automatically through your use of our services:

  • Online Identifiers, such as IP address; domain name;
  • Device Information, such as hardware, operating system, browser;
  • Usage Data, such as system activity, internal and external information related to Choice by Kingdom Trust pages that you visit, clickstream information; and
  • Geolocation Data. 

Our automatic collection of Personal Information may involve the use of Cookies, described in greater detail below.

Personal Information we collect from third parties

We may collect and/or verify the following categories of Personal Information about you from Third Parties:

  • Identification Information, such as name, email, phone number, postal address, government identification numbers (which may include Social Security Number or equivalent, driver’s license number, passport number);  
  • Financial Information, such as bank account information, routing number;
  • Transaction Information, such as public blockchain data (bitcoin, ether, and other Digital Assets are not truly anonymous. We, and any others who can match your public Digital Asset address to other Personal Information about you, may be able to identify you from a blockchain transaction because, in some circumstances, Personal Information published on a blockchain (such as your Digital Asset address and IP address) can be correlated with Personal Information that we and others may have. Furthermore, by using data analysis techniques on a given blockchain, it may be possible to identify other Personal Information about you); and
  • Additional Information, at the discretion of our Compliance Team to comply with legal obligations, which may include criminal records or alleged criminal activity.

Personal Information you provide during the registration process may be retained, even if your registration is left incomplete or abandoned.

Accuracy and retention of Personal Information

We take reasonable and practicable steps to ensure that your Personal Information held by us (i) is accurate with regard to the purposes for which it is to be used, and (ii) is not kept longer than is necessary for the fulfillment of the purpose for which it is to be used.

 

How We Use Your Personal Information

The Personal Information we collect and the practices described above are done in an effort to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve Choice by Kingdom Trust. We may use your Personal Information to:

  1. Provide you with our services. We use your Personal Information to provide you with our Services pursuant to the terms of our User Agreement. For example, in order to facilitate fiat transfers into and out of your account, we need to know your financial information.
  2. Comply with legal and regulatory requirements. We process your Personal Information as required by applicable laws and regulations. For example, we have identity verification requirements to fulfill our obligations under the anti-money laundering laws of numerous jurisdictions.
  3. Detect and prevent fraud. We process your Personal Information to detect and prevent fraud on your account, which is especially important given the irreversible nature of cryptocurrency transactions.
  4. Protect the security and integrity of our services. We use your Personal Information to further our security-first mentality. Maintaining the security of your account and the Exchange requires us to process your Personal Information, including information about your device and your activity on the Exchange, and other relevant information.
  5. Provide you with customer support. We process your Personal Information anytime that you reach out to our Customer Support team with issues arising from your account.
  6. Optimize and enhance our services. We use your Personal Information to understand how our products and Services are being used to help us improve our Services and develop new products.
  7. Market our products to you. We may contact you with information about our Products and Services. We will only do so with your permission, which can be revoked at any time.
  8. Other business purposes. We may use your information for additional purposes if that purpose is disclosed to you before we collect the information or if we obtain your consent.

 

How We Share Your Personal Information

We will not share your Personal Information with third parties, except as described below:

  1. Service Providers. We may share your Personal Information with service providers for business or commercial purposes. Your Personal Information may be shared so that they can provide us with services, including: identity verification, fraud detection and prevention, security threat detection, payment processing, customer support, data analytics, Information Technology, advertising, marketing, data processing, network infrastructure, storage, transaction monitoring, and tax reporting. We share your Personal Information with these service providers only so that they can provide us with services, and we prohibit our service providers from using or disclosing your Personal Information for any other purpose. Our third-party service providers are subject to strict confidentiality obligations. Service providers we may work with to deliver service include: Google, Twitter, LinkedIn, Facebook, Snapchat, Reddit, Dianomi, CJ Affiliate, TapJoy, App Samurai, HubSpot, Kickoff Labs, AdRoll, Mixpanel, Stripe, Plaid, and TrustPilot. In the case of Mixpanel: We collect personally identifiable information such as your email address and your user activity through the use of Mixpanel. Mixpanel’s ability to use and share information is governed by the Mixpanel Terms of Use, available at https://mixpanel.com/terms/, and the Mixpanel Privacy Policy, available at https://mixpanel.com/privacy/. You can opt-out of Mixpanel’s services by clicking on the following link: https://mixpanel.com/optout/. If you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers) You may also clear the Mixpanel opt-out cookie. Plaid: In addition to our normal forms and procedures, we offer the ability for clients to leverage ‘Plaid’ to facilitate the account funding process. Plaid is a 3rd party, not affiliated with Kingdom Trust or Choice by Kingdom Trust, and maintains their own privacy policy which can be found for review here: https://plaid.com/legal/#end-user-privacy-policy. Stripe: We use Stripe for identity document verification. Stripe collects identity document images, facial images, ID numbers and addresses as well as advanced fraud signals and information about the devices that connect to its services. Stripe shares this information with us and also uses this information to operate and improve the services it provides, including for fraud detection. You may also choose to allow Stripe to use your data to improve Stripe’s biometric verification technology. You can learn more about Stripe and read its privacy policy at https://stripe.com/privacy. Stripe retains a copy of all the data provided as part of a verification. You may also have consented to allow Stripe to use your data to improve their technology. You can delete your information from Stripe’s servers or revoke your consent by visiting https://support.stripe.com. In the case of TrustPilot: We pass along Name and Email of selected users, using its email engine to generate requests for reviews. TrustPilot Privacy Policy can be reviewed at https://legal.trustpilot.com/for-reviewers/end-user-privacy-terms.

We may share your Personal Information with our affiliates, for the purposes outlined above, and as it is necessary to provide you with our Services.

  1. Law Enforcement. We may be compelled to share your Personal Information with law enforcement, government officials, and regulators.
  2. Corporate Transactions. We may disclose Personal Information in the event of a proposed or consummated merger, acquisition, reorganization, asset sale, or similar corporate transaction, or in the event of a bankruptcy or dissolution.
  3. Professional Advisors. We may share your Personal Information with our professional advisors, including legal, accounting, or other consulting services for purposes of audits or to comply with our legal obligations.

We may share or disclose your information with your consent. If we decide to modify the purpose for which your Personal Information is collected and used, we will amend this Privacy Policy.

Cookies

When you access Choice by Kingdom Trust, we may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, “Cookies”) on your computer or other devices used to visit Choice by Kingdom Trust. We use Cookies to help us recognize you as a customer, collect information about your use of Choice by Kingdom Trust to better customize our services and content for you, and collect information about your computer or other access devices to: (i) ensure compliance with our Bank Secrecy Act (“BSA”) and anti-money laundering (“AML”) program (“BSA/AML Program”) (ii) ensure that your account security has not been compromised by detecting irregular, suspicious, or potentially fraudulent account activities; (iii) assess and improve our services and advertising campaigns.

You also can learn more about cookies by visiting https://www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies on different types of browsers and mobile devices. Please note that if you reject cookies, you will not be able to use some or all of Choice by Kingdom Trust. If you do not consent to the placing of Cookies on your device, please do not visit, access, or use Choice by Kingdom Trust.

Kingdom Trust reserves the right to disseminate information derived from the aggregation of the information it collects. An example of this would be to include in a report or marketing piece the total number of accounts held or the average age of our account holders. In these instances, no account holder will be identifiable nor will specific personal information be used. At any time, you may request, in writing, a summary of the personal information Kingdom Trust maintains about you. You may also request, in writing, that your information be modified, corrected or removed. Your use and continued use of our website constitutes your acceptance of this Privacy Policy and any changes made to it by us.

CLIENT INFORMATION PROTECTION

Kingdom Trust adheres to all applicable legal standards and utilizes state-of-the-art technology to ensure the security of your personal information. Except as stated in this Policy, Kingdom Trust will not disseminate your personal information to anyone not affiliated with the company except as authorized by you or as permitted or required by law.

LEGAL COMPLIANCE

We reserve the right in our sole discretion to disclose information about you without notice, including sensitive or personally identifiable information, if it is necessary or appropriate to comply with applicable law, respond to legal claims and the legal process (including subpoenas), protect our rights, interests, or property, or if we believe in good faith that it is necessary to protect the personal safety of any person, including but not limited to: your safety, the safety of our officers, owners, or employees, the safety of the public, or the safety of any third party.

POLICY CHANGES

As required by federal law and regulation, Kingdom Trust will notify you of our privacy policy annually. Kingdom Trust reserves the right to modify its Privacy Policy and related procedures at any time in accordance with applicable federal and state laws. You will be notified of any such changes.

 

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