1. Introduction
SYSTM VENTURES LTD ("we," "us," "our," or "Company") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, services, and products, including our agentic treasury management platform, stablecoin operations, and WhatsApp-based financial co-pilot.
This policy applies to all personal data we process, whether collected online or offline. Please read this policy carefully. If you do not agree with our practices, please do not use our services.
2. Information We Collect
We collect information in the following ways:
2.1 Information You Provide Directly
- Account Registration: Name, email address, phone number, business name, and company details
- Financial Information: Bank account details, wallet addresses, transaction history, and payment information
- Communication: Messages, inquiries, and support requests sent via email, WhatsApp, or our platform
- Verification Documents: Identity verification, business registration, and compliance documentation
2.2 Information Collected Automatically
- Usage Data: Pages visited, features used, time spent, and interaction patterns
- Device Information: Device type, operating system, browser type, and IP address
- Transaction Data: Details of payments, transfers, and financial activities on our platform
- Cookies and Tracking: We use cookies and similar technologies to enhance your experience and analyze usage
2.3 Information from Third Parties
- Payment processors and financial institutions
- Blockchain networks and smart contract interactions
- Third-party service providers (WhatsApp, analytics providers)
- Publicly available sources for verification purposes
3. How We Use Your Information
We use the information we collect for the following purposes:
- Service Provision: To deliver, maintain, and improve our treasury management, stablecoin, and payment services
- Account Management: To create and manage your account, process transactions, and provide customer support
- Communication: To send service updates, security alerts, and respond to your inquiries
- Compliance: To comply with legal obligations, anti-money laundering (AML), know-your-customer (KYC), and regulatory requirements
- Fraud Prevention: To detect, prevent, and address fraud, security issues, and technical problems
- Analytics and Improvement: To understand how you use our services and optimize our platform
- Marketing: To send promotional materials (only with your consent)
4. Legal Basis for Processing (GDPR)
Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal grounds:
- Consent: Where you have explicitly consented to the processing
- Contract Performance: To fulfill our obligations under the terms of service and user agreements
- Legal Obligation: To comply with applicable laws, regulations, and regulatory requests
- Legitimate Interests: To protect our business, prevent fraud, and improve our services
- Vital Interests: To protect your health, safety, or vital interests
5. Data Sharing and Disclosure
We do not sell your personal data. However, we may share your information with:
- Service Providers: Third-party vendors who assist us in operating our platform, including WhatsApp (Meta), payment processors, and blockchain networks
- Financial Institutions: Banks and payment networks necessary to process transactions
- Regulatory Authorities: Government agencies, law enforcement, and regulators as required by law
- Business Partners: With your consent, we may share information with partners to enhance our services
- Legal Proceedings: If required by court order, subpoena, or legal process
All third parties are contractually obligated to maintain the confidentiality and security of your data.
6. International Data Transfers
Your personal data may be transferred to, stored in, and processed in countries outside the United Kingdom and European Economic Area (EEA), including countries that may not have the same level of data protection. When we transfer data internationally, we implement appropriate safeguards, including:
- Standard contractual clauses approved by the European Commission
- Adequacy decisions where applicable
- Your explicit consent where required
By using our services, you consent to the transfer of your data as described in this policy.
7. Data Retention
We retain your personal data for as long as necessary to provide our services and fulfill the purposes outlined in this policy. Retention periods vary based on the type of data:
- Account Data: Retained for the duration of your account and for 7 years after closure for compliance purposes
- Transaction Data: Retained for 7 years to comply with financial regulations
- Marketing Data: Retained until you unsubscribe
- Cookies: Retained according to cookie settings (typically 1-2 years)
We will delete or anonymize your data when it is no longer necessary, unless we are required to retain it by law.
8. Your Rights
Under GDPR and applicable data protection laws, you have the following rights:
- Right of Access: You can request a copy of the personal data we hold about you
- Right to Rectification: You can request correction of inaccurate or incomplete data
- Right to Erasure: You can request deletion of your data (subject to legal obligations)
- Right to Restrict Processing: You can request that we limit how we use your data
- Right to Data Portability: You can request your data in a portable format
- Right to Object: You can object to certain types of processing, including marketing
- Right to Withdraw Consent: You can withdraw consent at any time
To exercise any of these rights, please contact us at hello@systm.xyz. We will respond within 30 days.
9. Data Security
We implement comprehensive security measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction:
- Encryption of data in transit (TLS/SSL) and at rest
- Secure authentication mechanisms and access controls
- Regular security audits and vulnerability assessments
- Employee training on data protection and privacy
- Incident response procedures for data breaches
While we strive to protect your data, no security system is impenetrable. We cannot guarantee absolute security.
10. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to:
- Remember your preferences and login information
- Analyze how you use our platform
- Improve user experience and performance
- Detect and prevent fraud
You can control cookie settings through your browser. Disabling cookies may affect the functionality of our services.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated policy on our website and updating the "Last Updated" date. Your continued use of our services constitutes acceptance of the updated policy.
12. Contact Us
If you have questions about this Privacy Policy, wish to exercise your rights, or have concerns about our data practices, please contact us:
- Company: SYSTM VENTURES LTD
- Company Number: 17015779
- Registered Office: 48-49 Princes Place, London, United Kingdom, W11 4QA
- Email: hello@systm.xyz
- Website: https://systm.xyz
If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.