LAST UPDATED: 1 April 2024


1.1.The SeedHunter website is available at, including any of its subdomains (the “Website”) and any functionality and services provided via the Website (hereinafter collectively, the “Platform”) are provided by SeedHunter Inc., a company incorporated in the Republic of Panama, having its company registration number 155748785, and the registered office address at Ricardo Arias Street, Advanced Tower, Floor 1, Office CD, Panama City, Panama, P.O. Box 0823-03548 (the “Company”, “we”, “us”, “our”). With respect to personal data collected on the Platform, we act as a data controller, meaning that we determine the purposes and means of processing your personal data.

1.2.This Privacy Policy (“Policy”), as amended from time to time, sets out the types of personal data that we hold on you, how we collect and process such data, how long we keep it, and other relevant information about your personal data being processed in connection with your access to and use of the Platform. Personal data or personal information means any information directly or indirectly identifies you as an individual. In this Policy, we use “personal data” and “personal information” as synonyms.

1.3.Please read this Policy carefully to understand our practices regarding your personal information and how we treat it. If you do not agree with this Policy, or you do not have the right, power, or authority to act on behalf of and bind the business, organization, or other entity you represent, do not access or otherwise use the Platform. This Policy also explains how we use cookies.

1.4.This Policy is effective upon the date of its publication on the Website. Please read this carefully as this Policy is legally binding. By accessing or using the Platform and the Website you accept this Policy and agree to comply with its terms.


We reserve the right at our sole discretion to revise, amend, or supplement this Policy at any time and without prior written notice to you to reflect necessary changes in law, our personal data collection and usage practices, the features of our services or the Platform, or certain advances in technology. If any material changes are made to this Policy, we may notify you via email or other means. Unless otherwise notified by us, the changes to this Policy are effective when they are published on the Website. You can determine when this Policy was last revised by referring to the “LAST UPDATED” legend at the top of this Policy. Your continued access or use of the Platform after such changes conclusively demonstrates your full acceptance of those changes.


Our Platform is not directed to collect any data from people under the age of 18 years. We do not knowingly allow anyone under the age of 18 years to submit any data to our Platform. If you believe your child may have provided us with their personal data, you can contact us using the information in the Contact section of this Policy and we will delete the data from our Platform.


This Policy applies to all your interactions with us via the Website and the Platform, and your interactions with us in connection therewith.


By providing your personal data, you are granting consent for its processing. Furthermore, you explicitly acknowledge and agree that we may process your personal data for our legitimate interests, such as safeguarding the Company, its users, customers, clients, and other entities' property, rights, or safety.


6.1.The primary purpose in collecting personal data is to provide you with a secure, smooth, efficient, and customized experience. We use your personal data to provide services to you on the Platform or to comply with our legal obligations or with your consent.

6.2.We will use your information for any other purpose only on receiving your consent and then, only for the purpose(s) for which grant consent unless we are required to do otherwise by law.


7.1.We collect information you provide during the Platform on-boarding process, which may be a completed, incomplete, or abandoned process. We also collect personal data when you communicate with us through customer support, subscribe to marketing communications, correspond with us by phone, email, or other communication channels, or when you conduct a transaction on the Platform, or use our Website. We may collect, use, store, or transfer your personal data, which may include, without limitation, the following:

● Personal identification information such as full name, email address, phone number, nationality, date of birth, address, utility bills, photographs and a video recording of you. We may also obtain this information if you choose to use a social login service, such as Facebook, Apple, Google, Microsoft Login, to create or access your account;

● Sensitive and biometric personal data, such as biometric information, for example to verify your identity by comparing the facial scan data extracted from your selfie or video with the photo in your government issued identity document;

● Government issued identity documents, such as passport, national identification number, national identity card details, drivers license numbers;

● Institutional Information, such as corporate legal name, corporate registration information, government identification number, proof of identity and legal existence, address, business description, personal identification data for all material beneficial owners, personal data about the board of directors, senior persons responsible for the operations of the body corporate;

● Financial Information, such as bank account information, source of funding, source of wealth;

● Transaction Information, such as transaction amount, wallet addresses or account details of sender and recipient, transaction status, transaction history, etc.;

● Social Media Accounts Information, such as name of social media accounts, handles, number of subscribers, views;

● Correspondence Information, such as communication with our Customer Support team, including call recordings with our customer support team, and response to user survey;

● Information required by regulatory agencies such as state and federal licensing authorities and consumer protection agencies;

● Employment Information, such as job title, employment history, curriculum vitae, salary; and

● Information from Cookies, please see Section 14 for more information.

7.2.You are required to provide accurate, lawful and up-to-date information to us and to comply with all applicable laws when sharing personal data with us. The source of personal data is you or someone on your behalf. In case you choose not to share certain personal data with us, we may not be able to provide you with our services. We will hold the above information for as long as it is necessary in order to deal with any specific issues that you may raise or otherwise as is required by the applicable laws or regulations.


8.1.We may share your data with members of our group, service providers and our key partners. Some of these third parties may be in a jurisdiction not covered by the laws stated in this Policy, in which case we will take all reasonably necessary steps to ensure that your personal information is treated securely and that such transfers are permitted under the applicable data protection laws.

8.2.We may also use any or all of the personal information above to administer and manage our business in general, and to enforce our terms of use, terms of services, or any other contract to which we may be a party to.


9.1.We may have to share your personal data with a selected and trusted group of third party/parties to fulfill our obligations under this Policy, and to meet government, regulatory and law enforcement requests. We will only disclose your personal information to third party service providers under strict terms of confidentiality. We do not allow our third party service providers to use your personal data and information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

9.2.We may have to share or transfer your personal information in the specific circumstances listed below:

9.2.1. Applicable Law, Government Requests, etc. Where we are legally required to do so, we may disclose your personal data to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements), or where we find it is necessary to investigate, prevent or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved disclose your personal information. Additionally, we may disclose your personal data to enforce our terms of use,terms of services, or to protect the rights, safety, and security of the Company, our users, other persons or the public;

9.2.2.Merger, Acquisition etc . In connection with, or during negotiations of, any merger, sale of the Company assets, financing, acquisition of all or a portion of our business to another company, any dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, your personal data may also be transferred as a business asset forming part of our goodwill. If another company acquires us, our business or assets, that company will possess the personal information collected by us and will assume the rights and obligations held by us regarding your personal information, as described in this Policy.

9.2.3.Affiliates . We may share your personal information with our affiliates, in which case we will require those affiliates to honour this Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us. We may share your information with our business partners to offer you certain products, services or promotions.

9.2.4.Select Third Party Vendors . We may share your personal information with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples of such third parties include but are not limited to data analysis, email delivery, KYC service providers, hosting services, quality assurance testing, technical support, operational support and maintenance services and marketing efforts.


Our Website, the Platform, or communications may contain links to other third-party websites which are not owned or operated by us and are regulated by their own privacy policies. If you click on a third-party link, you will be directed to that third party’s website. We strongly advise you to review the privacy policy of every website you visit. We are not responsible for the privacy policies of these third-party websites, regardless of whether they were accessed using the links from our Website, the Platform, or communications. We have no control over and assume no liability for the content, privacy policies or practices of any third-party websites or services.


11.1.The personal data we collect will be stored on the cloud based servers in the European Economic Area.

11.2.If you are based in the United Kingdom (“UK”), the European Union (“EU”) or the European Economic Area (“EEA”), any storage, processing and transfer of your personal data outside these territories will adhere to the relevant legal requirements, particularly the GDPR, as and however applicable and/or required.

11.3.Many of our external third-party service providers may also be based outside of the UK, EU, or EEA, so their processing, storage and transfer of your personal data will involve the transfer to and from and storage of data outside the UK, EU, or EEA. We reiterate that by using our Website and the Platform, you accept the terms of their individual privacy policies, cookies policies, as well as applicable terms and conditions.

11.4.Some of the international organizations and countries to which your personal data may be transferred do not benefit from an appropriate data protection regulatory framework. For such international organizations and countries, we shall transfer your personal information only upon ensuring that a suitable degree of protection is afforded to it through the implementation of the necessary safeguards to protect your personal data. These safeguards include an adequacy decision by the relevant authority, adequate binding corporate rules or through the inclusion of standard contractual clauses in our agreements with such organizations and countries. We shall notify you with regards to the specific safeguard we shall adopt in transferring your personal information to such an international organization and/or country if you must require such data.

11.5.In respect of GDPR compliance (if applicable): we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe.

11.6.Please contact us at if you want further information on the specific mechanism used by us when transferring your personal information.


If you are a citizen of the EU, then you have these rights under the GDPR:

12.1.Right to be informed: This means you have a right to know:

a. The identity and the contact details of the Company;

b. The contact details of our data privacy officer;

c. The purposes of the processing your personal information as well as the legal basis for the processing;

d. The legitimate interests pursued by us or by a third party who processes your personal information;

e. The recipients or categories of recipients of your personal data;

f. Our intention to transfer your personal data to a third country or international organization and the existence or absence of an adequacy decision by the relevant supervisory authority, or where applicable, reference to the appropriate safeguards and the means to obtain their copy.

g. The period for which your personal data will be stored, or if that is not possible, the criteria used to determine that period;

h. Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obligated to provide the personal data and of the possible consequences of failure to provide such data;

i. The existence of automated decision-making, including profiling and meaningful information about the logic involved.

j. Where we intend to further process your personal data for a purpose other than that for which the personal information was collected for, we must apprise you, prior to such further processing, with information on those other purposes and with any other relevant information.

12.2.Right of access: This is your right to see what personal data is held about you by us. Particularly you have the right to:

a. Receive confirmation as to whether or not your personal data is being processed;

b. Access your personal data which we are processing along with the purposes of processing; the categories of personal data being processed; the recipients or categories of recipients to whom the personal data has been or will be disclosed; the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; where the personal data is not collected from you, any available information as to their source;

c. Where your personal data is transferred to a third country or to an international organization, you have the right to be informed of the appropriate safeguards relating to the transfer;

d. A copy of your personal data being processed; and

e. Any further copies requested by you, upon paying a reasonable fee.

1.3.Right to rectification: This is your right to have your personal data corrected, rectified or amended, if what is held by us or a third party onboarded by us is incorrect/ inaccurate in some way.

12.3.Right to erasure: This is your right under certain circumstances to ask for your personal data to be deleted. This would apply if your personal data is no longer required for the purposes it was collected for, or your consent for the processing of that personal data has been expressly withdrawn, or where your personal data has been unlawfully processed. Once deleted all your personal data will be removed from our systems and will not be recoverable.

12.4.Right to restrict processing: This is your right to ask for a temporary halt or pause in processing your personal data, such as in the case where a dispute or legal case must be concluded, or the data is being corrected.

12.5.Right to data portability: This is your right to ask for your personal data supplied directly to us, which we have processed pursuant to your consent, under a contract, or by automated means, to be provided to you in a structured, commonly used, and machine-readable or electronic format.

12.6.Right to object: This is your right to object to the further processing of your personal data which is inconsistent with the primary purpose for which it was collected.

12.7.Rights in relation to automated decision making and profiling: This is your right not to be subject to a decision based solely on automated processing.

12.8.Right to lodge a complaint with the supervisory authority: You have the right to lodge a complaint with the supervisory authority of the member state in which you are habitually resident, or with the supervisory authority of the member state in which you work or in which your rights under the GDPR have been infringed if you believe such infringement has taken place.

12.9.Right to contest automated decisions: You may contest any automated decision by us, which has been made about you and where this has a legal or similar significant effect and ask for it to be reconsidered.

12.10.If you wish to exercise any of the rights set out above or any other laws concerning your personal information (in so far as same is applicable), please contact us at in the first instance, so that we may resolve your query, feedback or complaint amicably. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This security measure is to ensure that your personal information is not disclosed to any person who has no right to receive it.

12.11.Automated decisions: You may contest any automated decision by us, which has been made about you and where this has a legal or similar significant effect and ask for it to be reconsidered.

12.12.We aim to respond to all legitimate requests without undue delay and within two (2) calendar months of receipt of any request from you. Occasionally it may take us longer than two (2) calendar months, if your request is particularly complex, or if you have made duplicated or numerous requests. In this case, we will notify you of receipt of such request(s) and keep you updated as to the status of progress concerning such request(s).

12.13.Please note that if you do not allow us to collect or process the required personal information or withdraw the consent to process the same for the required purposes, you may not be able to access or use the services for which your information was sought.


13.1.Your personal information is contained behind secured networks and is only accessible by a limited number of individuals who have special access rights to such systems and are required to keep the information confidential. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

13.2. No Guarantee

13.2.1.Please note that no transmission of information over the Internet or any method of electronic storage can be guaranteed to be absolutely 100% secure. However, our best endeavours will be made to secure data and the ability to access your personal data.

13.2.2.Without prejudice to our efforts on protection of your data, nothing contained in this Policy constitutes a warranty or guarantee of security of the facilities, and you agree to transmit personal data at your own risk.

13.2.3.Please note, that we do not guarantee that your personal data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

13.2.4.If you do receive any suspicious communication of any kind or request, do not provide your information and report it to us by contacting our offices immediately at

13.2.5.Since we cannot guarantee against any loss, misuse, unauthorised acquisition, or alteration of your personal data, you acknowledge and agree that you play a vital role in protecting your own personal data, including the adoption of sufficient safety measures such as your choosing of an appropriate password (where applicable) of sufficient length and complexity and to not reveal this password to any third-parties.

13.2.6.Furthermore, we cannot ensure and do not warrant the security or confidentiality of data transmitted to us, or sent and received from us by Internet or wireless connection, including: email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us

13.2.7.Please note that should your personal data be breached, and the security of your rights be at high risk, we shall in a timely manner communicate to you the nature of the breach which has taken place, the likely consequences of such a breach and shall describe thoroughly the measures we have implemented to address the breach and to mitigate any and all adverse effects to you and your rights. In the event of a breach occurring, please reach out to us at for further information and for further advice on how to mitigate the potential adverse effects of such a breach.


14.1.The Website uses cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to make websites work, or function more efficiently, as well as to provide information to the owners of the websites. Cookies are typically stored on your computer’s hard drive or your browser.

14.2.Information collected from cookies is used by us to evaluate the effectiveness of our Website and Platform, analyze trends, and administer the Website and the Platform. The information collected from cookies allows us to determine such things as which parts of the Website and the Platform are most visited and difficulties our users may experience in accessing the Website and the Platform. With this knowledge, we can improve the quality of your experience on the Website and the Platform by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties.

14.3.Information collected through cookies may also include:

● Strictly necessary cookies. These are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log into secure areas of the Website.

Analytical/performance cookies. They allow us to recognize and count the number of visitors/users and to see how visitors/users move around the Platform when they are using it. This helps us to improve the way the Website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognize you when you return to the Website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

14.3.1.Computer or mobile device information, such as device ID, browsing information such as name and version, IP address, internet connectivity data, operator and carried data, login data, browser type and version, device type category and model, time zone setting and location data, operating system and platform, other information stored on or available regarding the device you allow us access to when you visit our Website and Platform.

14.3.2.Platform usage information, such as:

a. Page views

b. Button clicks

c. Input form changes (without the values being tracked)

d. Information about how our services are performing when you use them, e.g. error messages you receive, performance of the site information, other diagnosis data.

14.4.By continuing to browse the Website, you are agreeing to our use of cookies. Where required under applicable laws, your consent to non-essential cookies will be requested and these cookies will not be placed without your consent. You can revoke your consent at any time.

14.5.Most of the cookies are only used for one session and afterwards they are deleted from your hard drive at the end of the browser session. Other permanently stored cookies remain on your computer and allow us to recognize you when you visit the Website again.

14.6.A cookie cannot read data off your hard drive or read cookie files created by other websites. Cookies set by the website operator are called "first party cookies''. Cookies set by parties other than the website operator are called "third party cookies". The parties that set third party cookies can recognize your computer both when it visits the website and when it visits certain other websites and/or mobile apps.

14.7.We use third party service providers, to assist us in better understanding the use of our Platform. Our service providers will place cookies on the hard drive of your computer (or use similar technologies) and will receive information on how our users navigate the Platform. This information is aggregated to provide statistical data about our users’ browsing actions and patterns, and does not personally identify individuals.

14.8.The Platform uses Google Analytics, a web analytics service provided by Google, Inc. (‘Google’). Google Analytics uses cookies (text files placed on your computer) to help the website operators analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States.

14.9.Google will use this information for the purpose of evaluating your use of the Platform, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.

14.10.Google will not associate your IP address with any other data held by Google. By using this Website and Platform, you consent to the processing of data about you by Google in the manner and for the purposes set out above. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: and “How Google uses data when you use our partners’ sites or apps” located at .

14.11.The Platform also uses the “Google Tag Manager” service. The Tag Manager is a tool for the management of so-called tags, which are used for tracking in online marketing, e.g. it allows for the counting of downloads of documents made available on the Platform. The Tag Manager itself does not process any personal data, since it is purely for the administration of other services – e.g. Google Analytics etc. For more information about the Tag Manager, please visit the Google Analytics Tag Manager privacy policy at

14.12.We utilize third-party email marketing services, such as Mailchimp, to send newsletters and promotional emails to you. Mailchimp may collect and process personal data for the purpose of email delivery, tracking, and analysis. This may include the use of cookies, web beacons, and similar technologies to gather information about email opens, clicks, and other interactions with our emails.

14.13.By subscribing to our newsletters or providing your name and email address to us, you consent to the collection and processing of your personal data by Mailchimp in accordance with their respective privacy policies. We encourage you to review the privacy policies of these third-party services to understand how they handle your data, which can be found at

14.14.Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. Our service providers will place cookies on the hard drive of your computer and will receive information that we select that will educate us on such things as how visitors navigate around our Platform, what products are browsed, and general information. Our service providers analyze such information and provide us with aggregate reports. The information and analysis provided by our service providers will be used to assist us in better understanding our visitors/users’ interests in our Website and the Platform and how to better serve those interests, as well as help ensure secure use of the Website and the Platform for all users. The information collected by our service providers may be linked to and combined with information that we collect about you while you are using the Platform. Our service provider(s) is/are contractually restricted from using information they receive from our Website other than to assist us.

14.15.We treat information collected by cookies as non-personal information. However, to the extent that IP addresses or similar identifiers are considered personal data by applicable data protection laws, we also treat these identifiers as personal data. If we combine non-personal information with personal data, the combined information will be treated as personal data for as long as it remains combined.

14.16.You can control the setting of cookies on your device using your browser’s settings. We cannot delete cookies set on our Website that are managed by other parties (for instance Google, etc.). If you want to avoid using cookies altogether, you can disable or delete cookies in your browser’s settings. You can also block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, disabling, deleting or blocking cookies might make it impossible for you to access or use certain features of the Website. Your use of the Website with a browser that is configured to accept cookies constitutes acceptance of our and third-party cookies.


Some web browsers may transmit “do-not-track” (DNT) signals to the Websites. Currently, we do not respond to DNT signals. If an industry standard on responding to such signals is established and accepted, we may reassess how to respond to DNT signals.


16.1.We keep your personal data to enable your continued use of the Platform, for as long as it is required in order to fulfill the purposes as specified in clause 6 of this Policy, and as may be required by law such as for tax and accounting purposes, compliance with anti-money laundering laws, or to resolve disputes and/or legal claims or as otherwise communicated to you.

While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your personal data are described below.

16.1.1.Personal Identifiable Data collected to comply with our legal obligations under financial or anti-money laundering laws may be retained after account closure for as long as is required under such laws.

16.1.2.Contact Information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis and until you (a) unsubscribe, or we (b) delete your account. Thereafter we will add your details to an unsubscribed list to ensure we do not inadvertently market to you.

16.1.3.Content that you post on our Platform such as support desk comments, photographs, videos, blog posts, and other content may be kept after you close your account for audit and crime prevention purposes.

16.1.4.Recording of voice calls with you may be kept for a period of up to six years, for audit/ compliance purposes and to resolve disputes and/or legal claims.

16.1.5.Information collected via cookies, web page counters and other analytics tools is kept for a period of up to one year from the date of the collection of the cookie of the relevant cookie.

16.1.6.Employment information, such as your name, employment history, curriculum vitae, salary, etc. is kept for a period of one year from the date of submission of such information.

16.2.Aggregated de-identified data, which cannot identify a device/ browser/ individual and are used for purposes of reporting and analysis, are maintained for as long as commercially necessary.

16.3.Personal data whose retention period has expired or whose purpose of processing has been served, are deleted, destroyed, blocked or anonymized.


You may contact us by email to the following email address: We use the data that you provide in an email to us, which you may give voluntarily, only to answer your questions or to reply to your email in the best possible manner.


If you are a data subject whose data we process, you may also have the right to lodge a complaint with a data protection regulator in one or more of the European Union member states.


19.1.If you are based in the UK, EU or the EEA region, then you have the right to make a complaint at any time to a supervisory or regulatory authority, in particular within the UK, or a member state in the EU or EEA where you are habitually resident, where we may be based (if applicable), or where an alleged infringement of any data protection law has taken place. However, we would appreciate the opportunity to address your concerns before you approach any such authority. Please contact us in the first instance so that we may try to resolve your complaint swiftly and satisfactorily. Please contact us via email at


20.1.In the case of abuse or breach of security, we are not responsible for any breach of security or for any actions of any third parties which receive the information illegally.

20.2.If you choose to restrict the collection or use of your confidential and personal information, please exit our Website and the Platform.


Please contact us with questions, comments, or concerns regarding our Policy as well as with any requests at