> For the complete documentation index, see [llms.txt](https://docs.strikebit.xyz/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://docs.strikebit.xyz/strikebit_refund_policy/strikebit-privacy-policy.md). # STRIKEBIT - PRIVACY POLICY Version 1.0 ยท Effective \[DATE] ### 1. Who controls your data Two companies, jointly: | Entity | Role | | ------------------------------------------- | ------------------------------------------------------- | | StrikeBit FZ-LLC - RAKEZ, UAE, licence \[ ] | Account registration, evaluations, payments, support | | StrikeBit Global Ltd - BVI, reg. \[ ] | Funded accounts, identity verification, reward payments | Contact for any privacy matter: *** ### 2. What we collect You give us: name, email, phone, date of birth, country of residence, username and password. When your Funded Account is activated: government photo ID, and a selfie or short video to confirm the document is yours. We do not ask for proof of address as a matter of course. Where you live: you tell us when you buy an evaluation and confirm it again when you request payment. We do not require a document to support it, unless the IP addresses recorded on your account are materially inconsistent with what you told us - in which case we may ask for proof of address before paying you. What we do not use: we do not restrict or profile you on the basis of your nationality, passport, place of birth or ethnic origin. Your identity document may show a citizenship - we use it to confirm you are who you say you are, and to screen your name against sanctions lists. It is not used to decide whether you may use the service. That decision turns on where you live and where you are. We generate: your simulated trading history, results, rule breaches, reward calculations and payment records. We collect automatically: IP address, device and browser fingerprint, session and usage data, and geolocation derived from IP. Blockchain data: the wallet addresses you pay from and receive rewards to, and public on-chain data associated with them. We do not collect bank account details, card numbers, or any trading deposit - because we do not take any. *** ### 3. Why we use it, and on what basis | Purpose | Basis | | ---------------------------------------------------------------------------------------------------------------------------------------- | -------------------------------------------------------------------------------------- | | Provide the platform and run your evaluation | Performance of our contract with you | | Take payment and pay rewards | Performance of our contract | | Verify identity, screen sanctions and PEP lists | Legal obligation and legitimate interest in preventing financial crime | | Check the IP addresses on your account against the residence you declared, before activating a Funded Account and before paying a reward | Legitimate interest in enforcing our territory rules and preventing false declarations | | Detect multi-accounting, account sharing and coordinated activity | Legitimate interest in enforcing the rules fairly for everyone | | Restrict access from restricted territories, using your IP address | Legal obligation and legitimate interest | | Support and complaints | Performance of our contract | | Product improvement and security | Legitimate interest | | Marketing emails | Your consent, withdrawable at any time | We do not sell your personal data. We do not share it with advertisers or data brokers. *** ### 4. Device fingerprinting - said plainly We use device and browser fingerprinting, IP analysis and behavioural analytics to detect users operating multiple accounts, sharing accounts, or coordinating trades between accounts. We do this because those practices let a small number of people extract rewards at the expense of everyone trading honestly. We say so here rather than burying it, because you should know before you sign up. *** ### 5. Who we share it with * Identity verification - KYCAID: your ID document, your selfie or short video, and the result of the check * Payments in and out - 0xProcessing, operated by 14partners Ltd. (Seychelles). When you pay an Access Fee you are taken to their payment page, where they receive your IP address and payment details. They act as our processor, except where they act as controller for their own anti-money-laundering, fraud and legal compliance purposes. * Sign-in with Google - Google OAuth, where you choose that option * Website analytics - Google Analytics and Google Tag Manager, subject to your cookie choices * Cloud hosting and databases - our infrastructure provider, in Frankfurt, Germany (EU) * Content delivery, security and file storage - our CDN and security provider * Transactional email - our email delivery provider, for the messages we send you * Corporate email and support - our business email and helpdesk tooling * Fraud prevention and blockchain analytics - specialist providers who help us detect multi-accounting, account sharing and payments connected to illicit activity. We do not name these providers, because doing so would tell the people we are trying to detect what to work around. * Internal operational alerting - our internal messaging tool * Between our two entities, under a data sharing agreement * Professional advisers - lawyers, auditors, accountants * Authorities, where legally required Each processor is bound by contract to process only on our instructions.
*** ### 6. Where your data goes Stored and processed in \[JURISDICTION - confirm hosting location], and shared between the UAE and the BVI under our data sharing agreement. If you are in a jurisdiction with data transfer restrictions, contact us and we will explain the safeguards that apply. *** ### 7. How long we keep it | Data | Period | | ---------------------------------------------- | ------------------------------------------------------------------------------------- | | Account and trading records, including IP logs | 5 years after account closure | | Identity verification records | 5 years after the last transaction - retained to meet AML record-keeping expectations | | Payment and reward records | 7 years | | Support correspondence | 3 years | | Marketing consent records | Until withdrawn, plus 2 years | Retained longer only where required by law or to defend a legal claim. *** ### 8. Your rights Subject to local law, you may ask us to: give you a copy of your data; correct it; delete it; restrict or object to processing; export it in a portable format; or withdraw consent to marketing. Email . We respond within 30 days. What we cannot delete: identity verification and transaction records within the retention periods above, because we are required to keep them. We will delete everything else. *** ### 9. Security Encryption in transit and at rest; access controls on identity documents limited to staff who need them; logging of access to verification data; two-factor authentication available on your account and recommended. No system is perfectly secure. If a breach affects your data materially, we will notify you and any relevant authority without undue delay. *** ### 10. Cookies Essential cookies for login and security, and analytics cookies to understand how the site is used. You can refuse analytics cookies without losing access. Details in the Cookie Notice. *** ### 11. Children The service is for adults 18 and over. We do not knowingly collect data from minors, and will delete it if we discover it. *** ### 12. Changes Material changes take effect 14 days after we notify you by email or on the site. *** ### 13. Complaints first. If you are unsatisfied you may complain to the data protection authority in your country, where one exists.