Privacy Notice

PlaceholderMM ("we", "us", or "our") is committed to handling personal information responsibly and transparently. This Notice explains what data we collect, why we collect it, how long we keep it, and what rights you have. It applies to clients, counterparties, suppliers, website visitors, and enquirers.

We act as the data controller for the personal data covered by this Notice, operating in compliance with the GDPR and applicable data protection legislation.

1. Data We Collect

Clients & Counterparties

• Identity: Full name, date of birth, nationality, government-issued ID
• Contact: Email, phone, business address, messaging handles
• KYC / AML: Passports, proof of address, regulatory documents
• Financial & Trading: Wallet addresses, bank details, trading history
• Communication: Emails, calls, video meetings, and messages

Website Visitors

• Technical: IP address, browser type, device, operating system
• Usage: Pages visited, time on page, referrer URL

Newsletter Subscribers & Enquirers

• Name, email address, and the content of your message

2. How We Use Your Data

We only process personal data when we have a valid legal basis — contract performance, legal obligation, legitimate interests, or your consent. We use your data to:

• Set up, manage, and deliver our market-making and liquidity services
• Carry out KYC and AML checks as required by law
• Execute and settle transactions and maintain accurate records
• Detect and prevent fraud and unauthorised access
• Comply with regulatory, legal, tax, and reporting obligations
• Send newsletters and service updates where you have consented

3. Cookies

Our website uses strictly necessary cookies to function, preference cookies to remember your settings, and analytics cookies to understand how visitors engage with our content. We do not use advertising cookies or share browsing data with ad networks.

You can configure your browser to block cookies at any time, though some parts of the site may not work correctly without them.

4. Who We Share Your Data With

We do not sell personal data. We share it only where necessary:

• Regulators and law enforcement — where required by law or court order
• Professional advisers — lawyers, auditors, and compliance consultants bound by confidentiality
• Technology providers — cloud hosting, identity verification, AML screening, and analytics tools, under data processing agreements
• Transaction counterparties — exchanges and clearing systems necessary to process a trade

5. How Long We Keep Your Data

6. Your Rights

Under applicable data protection law you have the right to access, correct, erase, restrict, or port your personal data. You may also object to processing and withdraw consent at any time. To exercise any of these rights, contact us at compliance@placeholdermm.com. We will respond within one month.

If you are unsatisfied with our response, you may lodge a complaint with the Information Commissioner's Office at ico.org.uk.

7. Changes to This Notice

We review and update this Notice periodically. The effective date at the top of this page always reflects the most recent version. For material changes we will notify affected individuals directly where possible.

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