Privacy Policy

Last Updated: June 2025

1. Introduction

MLP International Ltd ("MLP", "we", "us", or "our") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, process, and protect your personal information when you use our virtual asset services.

Company Information:

  • Legal Entity: MLP International Ltd
  • VASP License: RDWW-1785 (Poland)
  • Registration Number: 540400158
  • Registered Address: 116 Piotrkowska Street, Lodz 90-006, Poland

This Privacy Policy complies with the General Data Protection Regulation (GDPR) and Polish data protection laws.

2. Data Controller and Contact

MLP International Ltd acts as the data controller for personal data processed in connection with our services.

Data Protection Contact:

  • Address: 116 Piotrkowska Street, Lodz 90-006, Poland
  • Contact: Through our designated privacy contact channels

We have appointed a Data Protection Officer available through our main contact channels.

3. Personal Data We Collect

We collect and process personal data necessary for providing virtual asset services and meeting regulatory requirements:

3.1 Identity and Contact Information

  • Name, date of birth, nationality
  • Contact details (address, phone, email)
  • Government-issued identification documents

3.2 Compliance and Verification Data

  • KYC/AML verification documents
  • Source of funds information
  • Beneficial ownership details
  • Sanctions and PEP screening results

3.3 Financial and Transaction Data

  • Virtual asset wallet addresses
  • Transaction details and history
  • Account balances and trading information

3.4 Technical Information

  • Device and browser information
  • IP addresses and usage data
  • Platform interaction data

3.5 Business Information

  • Company registration details
  • Director and officer information
  • Business documentation

4. How We Collect Data

We collect personal data:

  • Directly from you during account setup and verification
  • Automatically through your use of our platform
  • From third-party verification and compliance service providers
  • From public sources and regulatory databases
  • From blockchain networks (publicly available transaction data)

5. Legal Basis and Purposes

We process personal data based on the following legal grounds:

5.1 Service Provision

Legal Basis: Contract performanceData Used: All categories as necessary for service deliveryPurpose: Account management, virtual asset services, transaction processing, customer support

5.2 Legal Compliance

Legal Basis: Legal compliance under Polish and EU lawData Used: Identity, compliance, and financial dataPurpose: KYC/AML verification, sanctions screening, regulatory reporting, record-keeping, cooperation with authorities

5.3 Business Operations

Legal Basis: Legitimate interestsData Used: All categories as necessary for business purposesPurpose: Risk assessment, fraud prevention, service improvement, security monitoring

6. Data Sharing

We may share personal data with:

6.1 Service Providers

  • Identity verification and compliance service providers
  • IT infrastructure and security providers
  • Professional advisors (legal, accounting, audit)

6.2 Regulatory Authorities

  • Polish Ministry of Finance and General Inspector of Financial Information
  • Other EU financial regulators
  • Law enforcement agencies
  • Courts and judicial authorities

6.3 Business Partners

  • Banking partners and financial institutions
  • Cryptocurrency exchanges and trading platforms
  • Other entities necessary for transaction processing

All third parties are bound by appropriate confidentiality and data protection obligations.

7. International Transfers

Personal data may be transferred outside the EEA to countries where our service providers operate. We ensure adequate protection through:

  • European Commission adequacy decisions
  • Standard Contractual Clauses (SCCs)
  • Other appropriate safeguards as required by law

8. Data Retention

We retain personal data only as long as necessary for the purposes collected and to comply with legal obligations.

General Retention Periods:

  • KYC/AML documentation: 7 years after account closure (Polish AML law requirement)
  • Transaction records: 7 years from transaction date
  • Business communications: 7 years from last interaction
  • Technical data: 3 years from collection
  • Marketing data: Until consent withdrawn or 3 years of inactivity

We may retain data longer when required by law or for legal proceedings.

9. Your Rights

Under GDPR, you have the right to:

  • Access your personal data and information about processing
  • Rectify inaccurate or incomplete data
  • Erase your data in certain circumstances (subject to legal retention requirements)
  • Restrict processing in specific situations
  • Data portability in structured, machine-readable format
  • Object to processing based on legitimate interests
  • Withdraw consent where processing is based on consent

Exercising Your Rights:Contact us through our designated privacy channels. We will respond within one month and may require identity verification.

Limitations:Some rights may be limited by legal retention requirements or other lawful grounds for processing.

10. Security

We implement appropriate technical and organizational measures to protect personal data, including:

  • Encryption of data in transit and at rest
  • Access controls and authentication systems
  • Regular security monitoring and assessments
  • Employee training on data protection
  • Incident response procedures

11. Cookies

We use cookies and similar technologies for:

  • Essential website functionality
  • Security and fraud prevention
  • Analytics and service improvement

You can manage cookie preferences through your browser settings. For detailed information, please see our Cookie Policy.

12. Automated Processing

We may use automated processing for initial compliance screening and risk assessment. Significant decisions always involve human review, and you have the right to request human intervention in automated decisions.

13. Children

Our services are not intended for individuals under 18. We do not knowingly collect data from children and will delete any such data promptly if discovered.

14. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will notify you of significant changes through our platform or by other appropriate means.

15. Complaints

Internal Complaints:Contact our privacy team through our designated channels. We will investigate and respond within reasonable timeframes.

Supervisory Authority:You may lodge complaints with:

  • Personal Data Protection Office (UODO)
  • Address: ul. Stawki 2, 00-193 Warsaw, Poland
  • Website: uodo.gov.pl

EU Data Protection Authorities:

  • Full list available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en

16. Contact Information

MLP International Ltd

  • Address: 116 Piotrkowska Street, Lodz 90-006, Poland
  • Contact: Through our customer service channels
  • VASP License: RDWW-1785

For privacy-related inquiries, contact us through our designated privacy contact channels.

This Privacy Policy is governed by Polish law. The English version prevails in case of conflicts between language versions.