Privacy Policy

Introduction

This Privacy Policy explains how Valtorum ("Valtorum", "we", "our", or "us") collects, uses, stores, shares and protects personal information in connection with the Valtorum website, USDV authorization portal, issuance and redemption services, APIs, applications and all related products and services (collectively, the "Services").

Protecting your privacy and maintaining the security of your information are fundamental to the operation of a permissioned financial infrastructure. This Privacy Policy should be read together with our Terms of Use, AML & KYC Policy, Compliance & Enforcement Policy and other applicable legal notices.

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy.

1. Scope of this Policy

This Privacy Policy applies to all visitors, applicants, authorized participants, business customers, counterparties, vendors, API users and any other individuals who interact with Valtorum or the Services.

This Policy applies whether information is collected through:

The Valtorum website
USDV authorization applications
Institutional onboarding
Customer support
Email communications
APIs
Mobile or desktop applications
Compliance reviews
Identity verification processes
Business relationships
Regulatory interactions

2. Information We Collect

Depending on your interaction with Valtorum, we may collect the following categories of information.

A. Identity Information

Full legal name
Date of birth
Nationality
Government identification numbers
Passport details
National identity cards
Driver's licence information
Photographs
Selfie verification images
Signature
Tax identification numbers

B. Contact Information

Residential address
Mailing address
Email address
Telephone number
Emergency contact information where applicable

C. Business Information

For corporate applicants we may collect:

Company name
Registration number
Country of incorporation
Registered office
Directors
Shareholders
Ultimate beneficial owners
Corporate structure
Licences
Regulatory registrations
Constitutional documents

D. Financial Information

Source of funds
Source of wealth
Banking details
Payment information
Settlement instructions
Account ownership information
Reserve contribution information
Redemption information
Transaction values

E. Blockchain Information

XRPL wallet addresses
Wallet ownership verification
Transaction hashes
Ledger activity
On-chain interactions
Token holdings
Smart contract interactions where applicable

Blockchain records may be publicly visible and are generally immutable.

F. Compliance Information

KYC documentation
KYB documentation
Sanctions screening results
Politically exposed person screening
Adverse media checks
AML assessments
Risk classifications
Compliance notes
Investigation records
Internal audit records

G. Technical Information

When accessing our Services we may automatically collect:

IP address
Browser type
Device identifiers
Operating system
Language settings
Access timestamps
Website usage
Cookies
Session identifiers
Security logs

H. Communications

We may retain:

Emails
Contact forms
Support tickets
Telephone records where permitted
Live chat transcripts
Complaint submissions
Survey responses

3. How We Collect Information

Information may be collected:

Directly from you
During authorization applications
Through identity verification providers
Through banking partners
From publicly available sources
Through blockchain analytics
From regulatory databases
Through sanctions screening providers
Through fraud prevention providers
From corporate registries
Through cookies and website technologies

4. How We Use Information

We use information to:

Verify identity
Process authorization requests
Conduct KYB and KYC
Perform AML screening
Screen against sanctions
Detect fraud
Prevent financial crime
Process issuance requests
Process redemption requests
Manage customer relationships
Respond to enquiries
Improve Services
Maintain cybersecurity
Protect the integrity of USDV
Meet legal obligations
Conduct internal audits
Maintain business continuity
Resolve disputes
Exercise legal rights

5. Legal Basis for Processing

Where applicable, we process information because:

You have requested our Services.
Processing is necessary to perform contractual obligations.
Processing is necessary to comply with legal and regulatory obligations.
Processing is necessary for our legitimate business interests.
You have provided consent where required by law.
Processing is necessary to protect the rights, safety and security of Valtorum, our users or third parties.

6. Identity Verification

Valtorum may verify your identity using internal procedures and trusted third-party service providers.

Verification may include:

Document authentication
Facial matching
Liveness detection
Database verification
Government record verification
Business registry verification
Beneficial ownership verification

Failure to complete verification may result in refusal or termination of Services.

7. Compliance Monitoring

As part of operating a permissioned financial ecosystem, Valtorum may continuously monitor users and transactions to:

Detect suspicious activity
Prevent fraud
Identify sanctions exposure
Detect money laundering
Identify terrorist financing
Meet regulatory obligations
Protect the USDV ecosystem

Monitoring may continue after authorization has been granted.

8. Blockchain Analytics

Valtorum may analyse publicly available blockchain information relating to wallet addresses interacting with USDV.

This analysis may include:

Wallet risk scoring
Transaction history
Exposure analysis
Counterparty assessment
Behavioural monitoring
Network analysis

Blockchain information may remain publicly accessible indefinitely.

9. Cookies

Our website may use cookies and similar technologies to:

Maintain sessions
Improve website functionality
Measure performance
Detect fraud
Enhance security
Remember preferences

Users may disable cookies through browser settings, although certain features may become unavailable.

11. International Transfers

Your information may be processed or stored in jurisdictions outside your country of residence.

Where required by law, Valtorum will implement appropriate safeguards for international data transfers.

12. Information Security

Valtorum implements administrative, technical and organisational measures designed to protect information from:

Unauthorised access
Loss
Theft
Misuse
Alteration
Destruction
Disclosure

Security measures may include:

Encryption
Multi-factor authentication
Network monitoring
Access controls
Security audits
Employee training
Incident response procedures
Data minimisation practices

No electronic system can be guaranteed to be completely secure.

13. Data Retention

Information is retained only for as long as reasonably necessary to:

Provide Services
Meet legal obligations
Resolve disputes
Conduct investigations
Prevent fraud
Maintain business records
Protect legal rights

Certain information may be retained beyond termination where required by law or regulatory obligations.

Blockchain records cannot generally be altered or deleted.

14. Your Rights

Subject to applicable law, you may request:

Access to your information
Correction of inaccurate information
Deletion of information
Restriction of processing
Objection to certain processing
Withdrawal of consent where processing is based on consent
Data portability where applicable

Certain requests may be limited where retention is required by law, regulation or legitimate business interests.

15. Marketing Communications

Where permitted by law, Valtorum may send communications regarding:

Service updates
Security notices
Product announcements
Regulatory changes
Operational notifications

Users may unsubscribe from marketing communications while continuing to receive important operational or legal notices.

16. Children's Privacy

The Services are not intended for individuals under the age of eighteen or the minimum legal age applicable in the relevant jurisdiction.

Valtorum does not knowingly collect information from children.

17. Third-Party Websites

Our Services may contain links to third-party websites or services.

Valtorum is not responsible for the privacy practices, policies or content of third-party websites.

Users should review the privacy policies of those third parties independently.

18. Automated Decision Making

Valtorum may use automated systems to assist with:

Fraud detection
Identity verification
Risk scoring
Compliance screening
Cybersecurity monitoring

Final decisions affecting authorization, issuance or redemption may also involve human review where appropriate.

19. Regulatory Reporting

Where required or permitted by applicable law, Valtorum may disclose information to competent authorities without prior notice to the affected individual.

This may include reporting relating to:

Money laundering
Terrorist financing
Sanctions
Tax compliance
Court orders
Regulatory investigations
Financial crime

Where prohibited by law, Valtorum may be unable to disclose that such reporting has occurred.

20. Business Transfers

If Valtorum undergoes a merger, acquisition, restructuring, financing, sale of assets or similar corporate transaction, personal information may be transferred as part of that transaction, subject to applicable legal requirements.

21. Changes to this Policy

Valtorum may update this Privacy Policy periodically.

Updated versions become effective upon publication unless otherwise stated.

Continued use of the Services constitutes acceptance of the revised Policy.

22. Contact

Questions regarding this Privacy Policy or requests relating to your personal information may be submitted through Valtorum's official contact channels.

Important Privacy Notice

Participation in the USDV ecosystem requires identity verification and ongoing compliance monitoring. Certain personal information must be collected and processed in order to operate a secure, permissioned financial infrastructure and to comply with applicable laws relating to anti-money laundering, counter-terrorist financing, sanctions, fraud prevention and financial regulation. Refusal to provide requested information may result in denial, suspension or termination of authorization to use USDV or other Valtorum Services.

This page was last updated on May 7, 2026.