Effective as of June 11, 2024
Ulys Holdings Inc (referred to here as “we”, “us” or “our”) respect and protect the privacy of those who explore 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 explore, sign up for or access our “Services”, which include the services offered on our websites, includingUlysHoldings.com (each a “Site” and collectively the "Sites") or when you use the Ulys Holdings mobile app, the Ulys Holdings Card App, Ulys Holdings Exchange, Ulys Holdings Prime, Dapp Wallet, or Ulys Holdings Custody application programming interface (“API”) or third party applications relying on such APIs (together, our “Apps”) 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:
Our goal is to simplify your crypto experience. 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 in order 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 Ulys Holdings companies, as well as trusted third parties and service providers, in order to offer our Services and fulfill legal requirements.
We offer privacy tools for you to request access to or deletion of information we hold about you. You can use these tools by visiting your Privacy Rights Dashboard
Depending on where you live, you may also have other privacy rights under law.
If you have any questions, please contact us at info@UlysHoldings.com.
We collect the following personal information and documentation:
Information Category | Description |
Basic Customer Information | Name, Address, Date of birth, Nationality, Country of residence, Gender, Phone number, Email Address |
Supplemental Identification Information | Utility bills (for 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, including visa information |
Electronic Identification (“EIDV”) Information | Biometric information generated based on photos or videos you provide in order for us to verify your identity |
Financial Information | Bank account number, Payment card primary account number ("PAN"), Trading and investment experience, Tax identification number, Income/net assets/wealth verification statements |
Wallet Information | Self-custody, or multi-coin crypto wallet, we collect your Wallet address and information related to integrations that you select |
Preferences | The digital asset(s) you choose to be paid in through our Direct Deposit service, Settings and preferences you select in the Ulys Holdings app |
Transaction Information | Information about the transactions made on our Services, such as the name of the sender, the name of the recipient, the amount, currency preferences, payment method, date, and/or timestamp |
Additional information you submit to us | Communications: Survey responses, information (including call recordings) provided to our Customer Support team or User Research team Referral Information: Your contacts’ phone or email addresses if you choose to invite friends to Ulys Holdings |
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.
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. Examples of such Affiliates:
Linked Third Party Websites
Professional advisors, industry partners, authorities and regulators
Asset Transfer or Company Acquisition
Third-Party Service Providers
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.
In line with these considerations, we delete information that is no longer needed for the above purposes when you close your account, or when you request deletion of your 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, Ulys Holdings will require the relevant Customer or User to close his or her account, and will take steps to delete the individual’s information as soon as possible.
To facilitate our global operations, Ulys Holdings, its Affiliates, third-party partners, and service providers may transfer, store, and process your personal information throughout the world.
If you reside in the EEA, Switzerland, or the United Kingdom, we rely upon a variety of legal mechanisms to facilitate these transfers of your personal information (collectively, “European Personal Data”).
We rely primarily on the European Commission’s Standard Contractual Clauses to facilitate the international and onward transfer of European Personal Data to third countries, including from our EU operating entities to Ulys Holdings, Inc. in the United States. For a copy of the Standard Contractual Clauses, please contact info@UlysHoldings.com.
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, Ulys Holdings 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 your Dashboard, or by submitting a request via ourSupport Portal
Right to rectification: You may request us to rectify or update any of your personal information held by Ulys Holdings that is incomplete or inaccurate by logging in to your account and clicking the Profile or My Account tab.
Right to deletion/erasure: You may request to erase your personal information, subject to applicable law. If you close your Ulys Holdings Account, we will retain or delete information associated with your account.
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 Ulys Holdings’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 Ulys Holdings through your account settings or by submitting a request via our support portal
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 complaint:
To protect your privacy and security, we may take steps to verify your identity before complying with your request and we may decline your request if we are unable to verify your identity.
Under certain US data privacy laws, as well as in Brazil, you may also designate an authorized agent to make these requests on your behalf.
These rights are not absolute, and may be denied: (a) when granting access or assisting portability would adversely affect the rights and freedoms of others (b) to protect our rights and properties; (c) where the request is frivolous or vexatious; or (d) as otherwise permitted by law.
8. PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
If you are a California resident, you can learn more about how we use your information and your privacy rights by reviewing the California Privacy Notice. Any terms defined in the California Consumer Privacy Act (as amended) (“CCPA”) have the same meaning when used in the California Privacy Notice.
9. 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, or at info@UlysHoldings.com, or by writing to us at the address of your Ulys Holdings service provider.
10. 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.
11. OUR RELATIONSHIP WITH YOU
If you reside in the EEA or Switzerland, Ulys Holdings Ireland Limited, Ulys Holdings Europe Limited and Ulys Holdings Germany GmbH act as joint controllers in respect of your personal information. Ulys Holdings Ireland Limited is the joint controller with primary responsibility for your personal information, including with respect to providing you with information and responding to any requests you may make under the GDPR.