1. INTRODUCTION:
Hashtag Ltd (“we”, “our” or “the Company”), a company registered in the United Kingdom, works in collaboration with FCA-regulated and authorised partners, ensuring full regulatory compliance and transaction security. This policy describes how we collect, use, protect and transfer the personal data of users, visitors to our website and customers of our services.
We are committed to treating your personal data securely and in accordance with applicable law, in particular the UK GDPR and the Data Protection and Digital Information Bill 2023 (DPDI Bill).
2. Data We Collect:
2.1 Data provided directly
Identifying information: name, surname, date of birth, address.
Identity documents: passport, driving license, identity card.
Contact information: email address, phone number.
Financial information: bank account details, transaction history.
Professional information: occupation, source of income.
2.2 Data collected automatically
Technical data: IP address, browser type, operating system, preferred language.
Usage data: interactions with our site or applications.
Location data: approximate geographic location (if permitted).
Cookies and Tracking: Use of essential cookies and tracking tools for analytics and marketing (see Section 5).
2.3 Biometric data
If requested, we may collect biometric data for authentication (e.g. face scans or fingerprints), always with your explicit consent.
3. Legal Basis and Purpose of Processing:
We process your personal data for the following purposes:
- Contract performance: Provide the requested services and manage transactions.
- Legal Obligations: Compliance with regulations such as FSMA 2023, AML (Anti-Money Laundering ) and KYC (Know Your Customer).
- Legitimate interests: To improve our services, prevent fraud and ensure the security of the site.
- Explicit consent: For the use of analytical cookies, marketing and biometric data collection.
Practical examples:
- We use identifying information to verify your identity.
- We use contact data for operational and promotional communications (with consent).
- Financial data is processed to ensure the security of transactions.
4. International Transfers:
When we transfer data outside the UK:
- We use the International Data Transfer Agreement (IDTA 2022) or the UK Addendum to the new EU SCCs .
- We carry out Transfer Impact Assessments (TIAs) to ensure an adequate level of protection.
These transfers may include countries such as the United States, EU or other jurisdictions with equivalent guarantees.
5. Cookies and Tracking Technologies:
- Essential Cookies: Necessary for the functioning of the site, do not require consent.
- Analytical and marketing cookies: They require explicit consent, which you can provide via our cookie banner.
You can manage your cookie preferences through our preference control center.
6. Data Security:
We take advanced measures to protect personal data:
- Encryption: Used to protect sensitive data.
- Controlled access: Data accessible only to authorized personnel.
- Contingency Plans: In the event of a violation, we will notify users within 72 hours.
Our practices comply with the safety standards set forth in FSMA 2023 and the DPDI Bill.
7. Data Retention:
We only keep your data for as long as necessary:
- Legal Requirements: Minimum 5 years retention for AML/KYC compliance.
- Minimization: We apply the DPDI Bill criteria to minimize the data retained.
Unused data will be deleted or anonymized.
8. Your Rights:
You have the following rights under the UK GDPR and the DPDI Bill 2023:
- Access: Request a copy of your personal data.
- Rectification: Correct any inaccurate or incomplete data.
- Erasure: Request removal of your personal data.
- Portability: Transfer your data to another provider.
- Opt-out: Opt-out of having your data used for specific purposes.
To exercise these rights, please contact us at support@hashtagwallets.com
9. Policy Changes:
We will update this policy if:
Legislative or regulatory changes.
Changes to our services or how we process data.
We will notify you via site notifications or email.
10. Contacts and Complaints:
For questions, concerns or complaints, contact:
- Support : support@hashtagwallets.com
- UK Information Commissioner’s Office (ICO): www.ico.org.uk
- Financial Conduct Authority (FCA): [Insert FCA reference].
11. Compliance Monitoring:
We work with regulated partners to ensure that data is processed in compliance with contractual agreements. Compliance is ensured through periodic audits and monitoring of activities.