Privacy Policy

PRIVACY POLICY

Effective Date: April 22, 2025 Last Updated: April 22, 2025

INTRODUCTION
Halcyon Reserve Capital ("we," "us," "our," or "Company") is committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our financial services platform. Please read this policy carefully. If you disagree with its terms, please discontinue use of the Platform immediately.

1. INFORMATION WE COLLECT

We collect information that you provide directly to us, including your full legal name, date of birth, national identification number or passport details, residential address, email address, phone number, employment information, source of funds, and bank account or payment card details. We also collect information automatically when you use the Platform, including your IP address, browser type, device identifiers, operating system, pages visited, time spent on pages, transaction history, and login timestamps. Additionally, we may collect information from third-party identity verification services, credit reference agencies, fraud prevention databases, and publicly available sources as required for KYC and AML compliance.

1. HOW WE USE YOUR INFORMATION

We use the information we collect to create and manage your account, process transactions and payments, verify your identity in compliance with KYC and AML regulations, provide customer support, send transactional and account-related communications, detect and prevent fraud and unauthorized access, comply with legal and regulatory obligations, improve our Platform and services, and send promotional communications where you have consented to receive them.

1. LEGAL BASIS FOR PROCESSING

We process your personal data on the following legal bases: performance of a contract, where processing is necessary to provide you with our services; legal obligation, where processing is required to comply with applicable financial regulations; legitimate interests, where processing is necessary for fraud prevention, security, and service improvement; and consent, where you have explicitly agreed to specific processing activities such as marketing communications.

1. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information to third parties. We may share your information with service providers who assist us in operating our Platform, including payment processors, identity verification providers, cloud hosting services, and customer support tools. We may also share your information with regulatory authorities, law enforcement agencies, and financial intelligence units as required by applicable law, with fraud prevention agencies and credit reference bureaus, with successor entities in the event of a merger, acquisition, or sale of assets, and with professional advisors including lawyers, auditors, and insurers under strict confidentiality obligations.

1. INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and processed in countries outside your country of residence. Where such transfers occur, we ensure appropriate safeguards are in place in accordance with applicable data protection laws, including standard contractual clauses approved by relevant regulatory authorities.

1. DATA RETENTION

We retain your personal information for as long as your account is active and for a minimum of five years after account closure, as required by applicable financial regulations and AML laws. Transaction records may be retained for up to seven years. Where retention is no longer necessary, we securely delete or anonymize your data.

1. YOUR RIGHTS

Depending on your jurisdiction, you may have the following rights regarding your personal data: the right to access the personal data we hold about you, the right to request correction of inaccurate or incomplete data, the right to request deletion of your data where there is no legal obligation to retain it, the right to object to or restrict certain processing activities, the right to data portability, and the right to withdraw consent at any time where processing is based on consent. To exercise any of these rights, please contact us at privacy@halcyonreservecapital.com. We will respond to your request within 30 days.

1. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies to operate and improve our Platform, remember your preferences, analyze usage patterns, and deliver relevant content. You can control cookie settings through your browser preferences. Disabling certain cookies may affect the functionality of the Platform. We use the following types of cookies: strictly necessary cookies required for the Platform to function, performance cookies that help us understand how users interact with the Platform, functional cookies that remember your preferences, and analytics cookies that provide insights into Platform usage.

1. SECURITY OF YOUR INFORMATION

We implement industry-standard technical and organizational security measures to protect your personal information, including 256-bit SSL encryption, multi-factor authentication, regular security audits and penetration testing, access controls and role-based permissions, and secure data centers with physical access controls. While we take all reasonable precautions, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security and encourage you to use strong passwords and protect your account credentials.

1. CHILDREN'S PRIVACY

Our Platform is not intended for individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have collected data from a person under 18 without parental consent, we will take immediate steps to delete that information.

1. THIRD-PARTY LINKS

Our Platform may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties and encourage you to review their privacy policies before providing any personal information.

1. AUTOMATED DECISION MAKING

We may use automated systems to assess transactions for fraud detection, credit risk evaluation, and AML screening. Where automated decisions have a significant effect on you, you have the right to request human review of that decision by contacting us at privacy@halcyonreservecapital.com.

1. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify you of material changes by posting the updated policy on our Platform and sending a notification to your registered email address at least 30 days before the changes take effect. Your continued use of the Platform after the effective date constitutes acceptance of the revised policy.

1. REGULATORY COMPLIANCE

Halcyon Reserve Capital complies with applicable data protection and financial privacy regulations, including but not limited to the General Data Protection Regulation (GDPR), applicable local data protection laws, Financial Action Task Force (FATF) recommendations, and relevant national AML and KYC regulations. If you are located in the European Economic Area, you have the right to lodge a complaint with your local data protection authority if you believe your rights have been violated.

1. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Officer at:
Halcyon Reserve Capital Attn: Data Protection Officer Email: privacy@halcyonreservecapital.com Email: legal@halcyonreservecapital.com Website: halcyonreservecapital.com