1. Who we are
This Privacy Policy explains how V3 Finance LLC ("V3 Finance", "we", "us", or "our") handles personal data in connection with our website and our software product, V3 Custody.
V3 Finance LLC is registered in [jurisdiction] under [company/registration number], with its registered office at [registered address]. You can reach us using the details in the Contact us section below.
2. What we do — and what we do not do
V3 Finance is a technology provider. V3 Custody is software that our customers deploy and operate to manage their own digital-asset treasury operations — policy controls, ledger, reporting and related tooling.
To make our role clear:
- We are not a custodian. We do not take custody of, hold, or control any digital assets.
- We do not hold, generate, or have access to our customers' private keys.
- We do not onboard our customers' end users and do not perform KYC/AML checks on them. Where such obligations apply, they rest with our customer.
- In most deployments the software runs in our customer's own environment (self-hosted). Personal data processed inside a customer's instance is controlled by that customer, who acts as the data controller. V3 Finance generally has no access to that data and, where it does process it, acts only as a processor on the customer's documented instructions.
This Policy covers the personal data for which V3 Finance itself decides the purposes and means of processing — primarily data relating to our website, our marketing, and our business relationships. It does not cover how our customers process personal data within their own V3 Custody deployments; for that, please refer to the relevant customer's own privacy notice.
3. Who this Policy applies to
We may process personal data about:
- visitors to our website;
- people who contact us or request a demo, documentation, or other information;
- people who subscribe to updates, newsletters, or events;
- representatives of our customers, prospects, partners, suppliers, and vendors;
- job applicants, where you apply to us directly or through our website.
4. The personal data we collect
We keep the personal data we collect to what we need. Depending on how you interact with us, this may include:
Information you give us directly
- Identity and contact details: name, work email address, company name, job title, phone number.
- The content of your enquiry: anything you include in a demo request, contact form, email, or other message to us.
- Marketing preferences: whether you have subscribed to updates or events.
- Recruitment data (if you apply for a role): the information in your CV, application, and any accompanying messages.
Information we collect automatically when you use our website
- Technical data: IP address, browser type and version, device and operating system, and similar identifiers.
- Usage data: pages viewed, referring pages, and interactions with the site.
- Cookies and similar technologies (see the Cookies section).
Information from third parties
- Limited business-contact information from sources such as our customers or partners (for example, when a customer names you as a contact), or publicly available professional sources.
What we do not collect: because we are not a custodian, we do not collect identity-verification documents (such as passports or IDs), wallet balances, transaction records, or KYC/AML data of end users in the ordinary course of running our website and business.
5. Why we process personal data, and our legal bases
Where the GDPR or a similar law applies, we rely on the following legal bases:
- To respond to your requests and provide information, demos, or documentation you ask for — on the basis of taking steps at your request before entering into a contract, or our legitimate interest in responding to enquiries.
- To manage our relationship with customers, partners, suppliers, and vendors — on the basis of performance of a contract, or our legitimate interest in running the business.
- To send you updates, event invitations, or marketing about products and services that may interest you — on the basis of your consent, or a legitimate interest where permitted, and always with a way to opt out.
- To operate, secure, and improve our website — on the basis of our legitimate interest in a functioning, secure site, and, for non-essential cookies, your consent.
- To handle job applications — on the basis of taking steps at your request before a possible employment relationship, or our legitimate interest in recruitment.
- To comply with legal obligations and to establish, exercise, or defend legal claims — on the basis of our legal obligations and legitimate interests.
6. Cookies and analytics
We use cookies and similar technologies for the security, operation, analytics, and improvement of our website. Non-essential cookies (such as analytics) are set only where you have given consent through our cookie banner. You can change your choice at any time. For details of the specific cookies we use, see our Cookie Policy.
We use [analytics provider — e.g. Plausible / Google Analytics 4 / none] to understand how our site is used. [If applicable: this provider may process technical data as described in its own privacy documentation.]
7. How we share personal data
We do not sell your personal data. We may share it with:
- Service providers who process data on our behalf — for example website hosting, analytics, email delivery, and customer-relationship or support tools. They may only use the data to provide services to us and under appropriate confidentiality and data-protection terms.
- Professional advisers such as lawyers, auditors, and accountants, where needed.
- Authorities or other parties where we are required to do so by law, or to establish, exercise, or defend legal claims.
- A successor entity in connection with a merger, acquisition, financing, or sale of assets, subject to appropriate protections.
8. International transfers
We may process personal data in, or transfer it to, countries other than the one where you are located. Where we transfer personal data across borders in a way that engages the GDPR or a similar law, we put appropriate safeguards in place — such as [Standard Contractual Clauses / an adequacy decision / other mechanism] — so that your data remains protected.
9. How long we keep personal data
We keep personal data only for as long as we need it for the purposes described in this Policy, and then delete or anonymise it. How long that is depends on the type of data and why we hold it — for example, the length of our relationship with you, and any legal, accounting, or reporting requirements that apply. [Add specific retention periods once decided, e.g. enquiry data retained for X months, customer records for the relationship plus Y years.]
10. How we protect personal data
We maintain appropriate technical and organisational measures designed to protect personal data against loss, misuse, and unauthorised access, disclosure, or alteration. No method of transmission or storage is completely secure, but we work to protect the data in our care and to review our measures over time.
11. Your rights
Depending on where you are and the law that applies, you may have some or all of the following rights over your personal data:
- to access the personal data we hold about you;
- to have inaccurate data corrected;
- to have data deleted in certain circumstances;
- to restrict or object to certain processing;
- to data portability;
- to withdraw consent at any time, where we rely on consent; and
- to complain to a data protection authority.
To exercise any of these rights, contact us using the details below. We may need to verify your identity before responding. We will respond within the time required by applicable law.
For personal data we process only as a processor on a customer's behalf (data inside a V3 Custody deployment), please direct your request to the relevant customer, who is the controller of that data; we will support them as required.
[If you have California or other US state users:] residents of certain US states may have additional rights, including the right to know what personal information is collected and how it is used, the right to deletion, the right to correct, and the right not to be discriminated against for exercising these rights. We do not sell or "share" personal information as those terms are defined under applicable US state privacy laws. [Confirm and expand with counsel if you serve these users.]
12. Children
Our website and V3 Custody are intended for businesses and professional users. They are not directed at children, and we do not knowingly collect personal data from children.
13. Changes to this Policy
We may update this Policy from time to time. When we do, we will change the "Last updated" date above and, where appropriate, provide additional notice. Please review it periodically.
14. How to contact us
If you have questions about this Policy or how we handle personal data, or if you want to exercise your rights, contact us at:
V3 Finance LLC
[Registered address]
Email: [privacy contact email]
[Data protection officer / representative details, if applicable]