Revision 1.2, Dated 11/4/2023 – Prior Versions are Obsolete

The AmmoCrypt entities listed in Section 10 below, referred to here as “AmmoCrypt”, “we”, “us”, or “our”) respect and protect the privacy of those who visit our Services (“Users”) and Users who sign up for and access our Services (“Customers”) (together referred throughout this policy as “you” and “your”).

This Privacy Policy describes how we collect, use, and share personal information when you visit, sign up for, or access our Services (as defined within our Terms), which include the services offered on our websites, including ammocrypt.io and its subdomains (each a “Site” and collectively the “Sites”) or when you use an AmmoCrypt Token generated by AmmoCrypt (together, our “Tokens”) and related services.

If you reside outside of the UK and the European Economic Area (the “EEA”), accessing and using our Services means that you accept this Privacy Policy and its terms.  It is important that you understand how we use your information. You should read this page in full, but below are the key highlights and some helpful links:

If you do not wish for your personal information to be collected, used, or disclosed as described in this Privacy Policy, or you are under 18 years of age, you should stop accessing our Services.

We collect and use your information to provide and improve our Services and your experience, protect the security and integrity of our platform, and meet our legal obligations.

We share your information with other AmmoCrypt entities, as well as trusted third parties and service providers, to offer our Services and fulfill legal requirements.

You may request access to or deletion of certain information we hold about you. Depending on where you live, you may also have other privacy rights under law. Without respect to the above, we are entitled to retain certain information about you for purposes disclosed within this Privacy Policy.

If you have any questions, please contact us via our website or at [email protected]

1. WHAT INFORMATION WE COLLECT

We may collect the following personal information and documentation during the provisioning of Services to you:

1.1     Information You Provide to Us

We may request, collect, and process the following categories of information from you directly during the course of our providing access to our Site and Services to you.  

1.1.1    Basic Customer Information:

Basic customer information may include:  

Name, Address, Date of birth, Nationality, Country of residence, Gender, Phone number, Email Address. 

1.1.2    Supplemental Identification Information:

Supplemental customer information may include: 

Utility bills (for proof/verification of your billing address), Photographs and/or videos, Government-issued identity document, e.g. passport, driver’s license, or state identification card, Social security number, Employment information (e.g. company name), Proof of residency, firearm owner’s ID cards, gun permit, export license, import license, end-user certifications, and visa information.

1.1.3    Electronic Identification (“EIDV”) Information:

EIDV Information may include biometric information generated based on photos or videos you provide in order for us to verify your identity.

1.1.4    Business Information (if you are a Business Customer):

Business Information may include:

Employer Identification number (or comparable number issued by a government), Personal identification information for all material beneficial owners of your business, Nature and industry of your business,  Financial information (to include tax filings, financial statements, bank statements, or proof of conducting business activity). 

1.1.5    Personal Financial Information:

Personal Financial Information may include:

Bank account number, Payment card primary account number (“PAN”), Trading and investment experience, Tax identification number, Income/net assets/wealth verification statements (such as self-attestation as to your status as an “Accredited Investor” per US securities regulations).

1.1.6    Wallet Information:

When you connect a web3, self-custody, or multi-coin crypto wallet, to our AmmoCrypt web3 application, we collect your Wallet address.

1.1.7    Preferences and Settings:

When you provide us with certain preferences and settings within the AmmoCrypt Site or Services, we may collect and store this information.

1.1.8    Transaction Information:

Information about the transactions made by you or through your Wallet address on our Site or Services, such as the wallet address of the sender, the wallet address of the recipient, the amount, currency preferences, payment method, date, and/or timestamp.

1.1.9    Communications:

Survey responses, emails, texts, voice mails and voice calls sent between you and us.

1.2       Information Collected Automatically

We may collect and process certain information automatically when you interact with our Site and Services.  Categories of information collected automatically are described below.

1.2.1    App, browser, and device information:

We automatically collect certain information about the device, operating system, and browser you’re using, as well as other device characteristics or identifiers (e.g. plugins, the network you connect to), IP address, and geolocation data.

1.2.2    Activity information:

Information about what you view or click on while visiting our Sites and Apps and how you use our Services.

1.2.3    Diagnostic and Troubleshooting Information:

Information about how our Services are performing when you use them, i.e. service-related diagnostic and performance information, including timestamps, crash data, website performance logs, and error messages or reports

1.2.4    Information from cookies and similar technologies:

See our Cookies Policy for more information.

1.3       Information we obtain from Affiliates and Third Parties

We may collect information on you from Affiliates or third-parties who have collected information on you and have agreed to supply that data to us.  We collect information from third parties to provide the Site and Services, to verify information provided by you, for regulatory compliance purposes, for fraud prevention and risk mitigation, and to provide an enhanced user experience.  We do not control the information collection practices or policies of third-parties.  

1.3.1    AmmoCrypt Affiliates:

We may obtain information about you, such as Basic Customer Information, Transaction Information and Product Usage Information, from our Affiliates as a normal part of conducting business.

1.3.2    Public Database Information:

We may obtain information about you from public databases, such as the United Nations Sanctions List, US ITA Consolidated Screening List, and the SEC EDGAR, including your name, address, email address, phone number, gender, national ID number and nationality/country of residence, date of birth, job role, public employment profile, listing on any sanctions lists maintained by public authorities, and other data as necessary

1.3.3   Blockchain Data:

We may analyze public blockchain data, including timestamps of transactions or events, transaction IDs, digital signatures, transaction amounts, and wallet addresses.

1.3.4    Information from our Marketing and Advertising Partners:

We receive information such as your name and contact information from our marketing partners, including in some instances what marketing content you viewed or the actions you take on our Sites or those of third parties.

1.3.5    Information from Analytics Providers:

We receive information about your Site usage, interactions, age group, market demographic, and survey responses.

2. HOW WE USE YOUR INFORMATION

We use your personal information to deliver, personalize, operate, improve, create, and develop our Services, to provide you with a secure, smooth, efficient and customized experience as you use them, and for legal compliance, loss prevention, and anti-fraud purposes. Learn more about how we use your personal information and our legal basis for each such data use:

2.1       Data use Necessary to Provide our Services to You

We use certain information that is necessary to perform our Services as described in our Terms or other relevant contract(s) with you.

2.1.1   To Purchase AmmoCrypt Tokens from Us:

In order for you to purchase AmmoCrypt Tokens from us, we require the use of your personal information.  

2.1.2   To provide you with Business Services:

In order to provide Services to a business user, we require use of your Business Information.

2.1.3   To Provide You with Consumer Services and Support:

We require your personal information to provide you with customer service and support, to answer your questions, to assist you in your experience with the Site and/or Servicve, or to advise you which Services are available to you in your region.  

2.1.4   To send Service-Related Communications:

We use your personal information to send you communications about our Services, which can include security updates or transaction-related information, through email, telephone, or in-product/push notifications. You may not opt-out of receiving critical service communications, such as emails or mobile notifications sent for legal or security purposes.     

2.1.5   To promote the safety, security and integrity of our Services:

We use your personal information to verify accounts and related activity, find and address violations of our Terms or Policies, investigate suspicious activity, detect, prevent and combat harmful or unlawful behavior, detect fraudulent behavior and to maintain the integrity of our Services, including fraud and loss prevention.

2.1.6   To Exchange Asset Tokens for Physical Ammunition:

We use your personal information to verify that you are eligible to participate in physical delivery of ammunition and to fulfill your order request.  

2.2       Data use to comply with our legal obligations

Our Services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. If you do not provide the personal information required by law, we cannot provide Services to you.

2.2.1    To verify your identity:

We are generally required to collect various pieces of personal information to properly identify or verify your identity and comply with other specific anti-money laundering (“AML”) or sanctions laws/regulations (e.g. funds transfer rules).  Our verification processes also involve electronic identification through the comparison of your ‘selfie’ against your provided verification information.  All such information is securely maintained by AmmoCrypt and its service providers, and is only disclosed where permitted by law.

2.2.2    To determine your legal eligibility for certain regulated financial products:

When you use certain locally regulated financial products we may be required to carry out additional checks to ensure your suitability.

2.2.3    To comply with other legal and regulatory obligations:

We may access, read, preserve, and disclose information when we believe it is reasonably necessary to comply with law, legal obligations, regulations, law enforcement, governmental, and other legal requests, court orders, or for disclosure to tax authorities.

Examples of laws that may require us to collect, use or disclose your information:

Civil, commercial, criminal, or consumer protection matters: where we are in receipt of a court order to disclose information for the purposes of court proceedings or regulatory inquiries (e.g. orders or mandatory requests or subpoenas from any court with jurisdiction).

Corporate and taxation matters: obligations such as the US Internal Revenue Service code.

Regulatory matters: to comply with our regulatory obligations, including engaging with our regulators, such as (but not limited to) the U.S. Commodity Futures Trading Commission, the National Futures Association, and the U.S. Securities and Exchange Commission.      

2.3       Data use for our Legitimate Interests

We rely on our legitimate interests or those of third parties (like our other Customers and in some cases, the general public) where they are not outweighed by your rights and freedoms. In the EEA and UK, you have the right to object to, and seek the restriction of, this processing. See Section 7. Your Privacy Rights and Choices for more information.

2.3.1    To customize your experience with our Services and otherwise improve our Services:

In order to perform core metrics, customize your experience with our Services and to generally improve our Services, we collect information about your online activity while you are using the Services (for example, when and how often pages on our Sites are visited, and our Services are used).  It is in our interest to understand how you interact with the Services to customize and/or improve our products and Services and enable accurate and reliable reporting.

2.3.2    To provide marketing communications to you:

We use your information to send you targeted marketing communications through email, mobile, in-app and push notifications or by SMS.  You may also see ads for our Services when you visit other apps and websites. It is in our interest to promote AmmoCrypt products and Services that you may be interested in.

2.3.3    To provide you with promotions:

We use your information to provide promotions, including offers or other incentives and rewards for using our Services.  It is in our interest and your interest to reward customer loyalty.

2.3.4    In support of legal requests:

We preserve and share information with others, including law enforcement, civil litigants, and others who may issue legal requests through proper channels.

Where not otherwise required by law, and depending on the circumstances, we may preserve and share your information:

In response to requests from third parties, such as civil litigants, law enforcement, and other government authorities, for example to assist authorities in the investigation of fraud;

To promote the safety, security, and integrity of our Site,  Service, network, our Customers, Users, employees, property and the public;

When we seek to protect ourselves in the context of litigation or other disputes, such as violations of our Terms and policies; and/or to respond to Customer/claimant requests or communications, and reviewing transactions for litigation disputes.

It is in our interest and the interest of the general public to prevent and address fraud, unauthorized use of the Services, violations of our Terms or policies, or other harmful or illegal activity; to protect ourselves (including our rights, AmmoCrypt personnel and property or the Service), our Customers or others, including as part of investigations or regulatory inquiries; to defend our legal rights and resolve disputes; to secure our platform and network, to verify accounts and activity, to combat harmful conduct, to detect, prevent and address fraud, abuse, spam and other bad experiences or to prevent death or imminent bodily harm.

2.3.5    To promote safety, security and integrity

We may use and analyze your information to protect the integrity of our Services. For example, we may use it to:

Log customer reports and patterns of suspicious behavior to understand techniques being used by bad actors who may wish to interfere with the Services; and

To identify and investigate patterns of suspicious behavior or violations of our policies and Terms.

It is in our interest and the interests of our Users and Customers to secure our platform and network, to verify accounts and activity, to combat harmful conduct, to detect, prevent and address fraud, abuse, spam and other bad experiences.

2.3.6    Data use based on your consent:

When we use your information based on your consent, you have the right to withdraw your consent at any time on a go-forward basis (which will not affect our prior use of your data, based on your previously given consent). You may change your consent preferences anytime as described in Section 7. Your Privacy Rights and Choices.

2.3.6.1 To enable device-based settings:

Collecting information that you allow us to receive through the device-based settings you enable (such as access to your GPS location, camera, or photos) which we use to provide the features or services described when you enable the setting.

2.3.6.2 To provide marketing communications to you:

To send you targeted marketing communications through email, mobile, in-app, and push notifications or by SMS.  You may also see ads for our Services when you visit other apps and websites.

2.3.7    Data use to protect your or others’ vital interests:

We may preserve, review, and share information with law enforcement and others in circumstances where we reasonably believe someone’s vital interests require protection, such as in the case of emergencies.

3. HOW AND WHY WE SHARE YOUR INFORMATION

We work with service providers, partners and other third parties to help us provide our Services, and as a result we need to share certain information with these third parties.

3.1       Affiliates

Personal information that we process and collect may be transferred between companies, Services, and employees affiliated with us as a normal part of conducting business and offering our Services to you. See Section 10. Our Relationship With You for a list of our affiliated companies and Services.

3.2       Linked Third Party Websites

When you use third-party services or websites that are linked through our Services, the providers of those services or products may receive information about you that AmmoCrypt, you, or others share with them. Please note that when you use third-party services or AmmoCrypt Affiliate Services which are not governed by this Privacy Policy, their own terms and privacy policies will govern your use of those services and products.

3.3       Professional advisors, industry partners, authorities and regulators

We share your information described in Section 1. What Information We Collect with our advisors, regulators, tax authorities, law enforcement, government agencies, and industry partners to:

Respond pursuant to applicable law or regulations, court orders, legal process or government requests;

Comply with our reporting and information sharing obligations with industry partners, including other Virtual Asset Service Providers (“VASPs”) and regulatory authorities;

Detect, investigate, prevent, or address fraud and other illegal activity or security and technical issues; and

Protect the rights, property, and safety of our Customers, AmmoCrypt and its Affiliates, or others, including to prevent death or imminent bodily harm.

3.4       Asset Transfer or Company Acquisition

We may choose to buy or sell assets and may share and/or transfer information about our Customers in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, merged, reorganized, or if we go out of business, enter bankruptcy, or go through some other change of control or similar event, your personal information could be one of the assets transferred to the acquiring party.

3.5       Third-Party Service Providers

We work with third-party service providers to help us provide our Services. When we share information with third-party service providers in this capacity, we require them to use your information on our behalf in accordance with our instructions and terms and only process as necessary for the purpose of the contract. We work with different types of third-party service providers, including:

4. HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We retain your information as needed to provide our Services, comply with legal obligations, or protect our or others’ interests. While retention requirements vary by country, we maintain internal retention policies on the basis of how information needs to be used. This includes considerations such as when the information was collected or created, whether it is necessary in order to continue offering you our Services, whether we are required to hold the information to comply with our legal obligations, including AML/KYC compliance or other financial regulatory obligations, or information preservation requirements. We also keep certain information where necessary to protect the safety, security and integrity of our Services, Customers, and Users.

We retain biometric information (as part of our retention of Supplemental Identification Information) for the period required for financial regulatory compliance or otherwise as required by applicable law. Our third-party identity verification service providers retain this information for as long as set out in their applicable notices/policies. In line with these considerations, we delete information that is no longer needed for the above purposes, or when you request deletion of your information.

5. CHILDREN’S PERSONAL INFORMATION

The Sites and Services are not directed to persons under the age of 18, and we do not knowingly request or collect any information about persons under the age of 18. If you are under the age of 18, please do not provide any personal information through the Sites or Services. If a User or Customer submitting personal information is suspected of being younger than 18 years of age, we will take steps to cease the user’s interaction with the Site and will take steps to delete the individual’s information as soon as possible.

6. INTERNATIONAL TRANSFERS

To facilitate our global operations, AmmoCrypt, its Affiliates, third-party partners, and service providers may transfer, store, and process your personal information throughout the world.

7. YOUR PRIVACY RIGHTS AND CHOICES

Depending on where you live, you may be able to exercise certain privacy rights related to your personal information. If any of the rights listed below are not provided under law for your operating entity or jurisdiction, AmmoCrypt has absolute discretion in providing you with these rights.

Right to access and portability:

You may request that we provide you a copy of your personal information held by us through submitting a request to [email protected]. You may further request transfer of your personal information in a digital format to you or a third party of your choice.

Right to rectification:

You may request us to rectify or update any of your personal information held by AmmoCrypt that is incomplete or inaccurate through submitting a request to us.

Right to deletion/erasure:

You may request to erase your personal information, subject to applicable law.  We will retain or delete your personal information as described in Section 4. How Long We Keep Your Personal Information.

Right to withdraw your consent:

To the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time. The lawfulness of AmmoCrypt’s processing before you withdraw your consent will not be affected by such withdrawal.

Right to object to or restrict processing:

You may have the right to restrict or object to us using or transferring your personal information based on our legitimate interests, in the public interest, or for direct marketing. We may continue to process your personal information where permitted or required by applicable law. You can opt-out of receiving marketing communications from AmmoCrypt through your privacy settings, by clicking the unsubscribe link on any marketing communication, or by submitting a request via our Contact Us page.

Right to non-discrimination:

We will not discriminate against you for exercising any of your rights provided to you under law.

Right to Lodge a Formal Complaint:

If you would like to submit a complaint about our use of your personal data or our response to your requests regarding your personal data, you may contact us at [email protected].

For UK and EU users:  You also have the right to lodge a complaint with a data protection supervisory authority. You can find information about your EEA data protection supervisory authority here or the UK Information Commissioner’s Office here.

Unsubscribe from Email Alerts:

Should you receive an email alert from us, you may unsubscribe from receiving additional email communications by following the unsubscribe instructions in the emails we send. Additionally you may send us a message requesting to unsubscribe by contacting us. Please note that even if you opt-out of receiving email alerts from us, we may continue to send you other email communications related to your business with us.

8. HOW TO CONTACT US WITH QUESTIONS

If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, please contact us on our Support Portal, at [email protected], or by writing to us at the address of your AmmoCrypt service provider (provided in Section 10. Our Relationship With You ) below.

9. CHANGES TO THIS PRIVACY POLICY

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well. We post any changes we make to our Privacy Policy on this page and, where appropriate, we will provide you with reasonable notice of any material changes before they take effect or as otherwise required by law. The date the Privacy Policy was last updated is identified at the top of this page.

We may provide additional “just-in-time” disclosures or information about how we collect or use your information in the context of specific Services; these in-product notices may supplement or clarify our privacy practices or may provide you with additional choices about how we use your information.

10. OUR RELATIONSHIP WITH YOU

Contact for all privacy related concerns and matters:

11. LOCALE SPECIFIC NOTICES

11.1    NOTICE TO CALIFORNIA RESIDENTS

California residents have the privacy rights listed below. The rights granted under the California Consumer Privacy Act and Shine the Light are not the same. To exercise your rights, you will need to follow the directions specific to each law.

11.1.1  CALIFORNIA CONSUMER PRIVACY ACT (“CCPA”)

Please note that the CCPA provides certain exceptions with respect to the personal information we collect in connection with providing products or services to, or receiving products or services from, other businesses. Similarly, it does not apply to information we collect in the context of a person’s role as a job applicant, employee, contractor, officer or director of AmmoCrypt. With respect to the personal information collected in connection with the above individuals or circumstances, you may not have any or all of the privacy rights listed below.

COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION IN THE PAST 12 MONTHS

The CCPA requires that we make certain disclosures about our general collection, use and disclosure of California consumer personal information over the past 12 months. Accordingly, in the past 12 months:

• We collected the categories of personal information detailed in “What Information We Collect” above.
• We did not sell any personal information, as we understand the term “sale” in the CCPA and its implementing regulations.
• We disclosed to the entities described in “How We Share Personal Information,” the following categories of personal information: A. Identifiers, B. Personal information listed in the California Customer Records Statute, D. Commercial Information, F. Internet or other similar network activity, G. Geolocation data.

You have the right to request to know more specific disclosures about your personal information as detailed under “Request to Know” below.

CALIFORNIA PRIVACY RIGHTS

You have the following privacy rights under the CCPA:

• Request to Know. You have the right to request to know the following information about our practices over the past 12 months: (i) the categories of personal information we collected about you; (ii) the categories of sources from which we collected the personal information about you; (iii) the categories of third parties with which we share personal information, (iv) the categories of personal information we sold or disclosed about you and for each category, the categories of third parties to which we sold or disclosed that particular category of personal information; (v) our business or commercial purpose for collecting or selling your personal information; and (vi) the specific pieces of personal information we collected about you.You may exercise your right to request to know twice a year, free of charge. If we are unable to fulfil your request to know, we will let you know the reason why. Please note, in response to a request to know, we are prohibited from disclosing your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions or answers, and unique biometric data generated from measurements or technical analysis of human characteristics.
• Request to Delete. You have the right to request that we delete the personal information that we have collected from you. We may deny your request under certain circumstances, such as if we need to retain your personal information to comply with our legal obligations or if retaining the information is necessary to complete a transaction for which your personal information was collected. If we deny your request to delete, we will let you know the reason why.

• Right to Non-Discrimination. If you choose to exercise any of these rights, we will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of our Websites.

If you would like to make a Request to Know or Request to Delete or are an authorized agent of a California consumer who would like to make such a request, contact us at [email protected].

We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfil your request unless you have provided sufficient information for us to reasonably verify that you are the individual about whom we collected personal information. If you have an account with us, we will use our existing account authentication practices to verify your identity. If you do not have an account with us, we will not require you to create an account with us but we may request additional information about you so that we can verify your identity. We will only use the personal information you provide to verify your identity and to process your request, unless you initially provided the information for another purpose.

You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your personal information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. You may also make a verifiable consumer request on behalf of your minor child.

SHINE THE LIGHT

California residents may also request information from us once per calendar year about any personal information shared with third parties for the third party’s own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To request this information, please contact us at [email protected] or by postal mail sent to the address specified in Section 10.  Our Relationship with You.

Your inquiry must specify “Shine the Light Request” in the subject line of the email or the first line of the letter, and include your name, street address, city, state and ZIP code.