Privacy Policy

1. Information We Collect

We collect information in the following ways:

Information you provide: Name, email address, phone number, date of birth, government-issued ID documents (for KYC), and bank/payment account details for withdrawals.

Automatically collected: IP address, browser type and version, device identifiers, operating system, pages visited, time spent, and referring URLs.

From identity verification: Document images (front and back of ID), selfie/liveness photos, and proof of address documents when required for higher KYC levels.

From transactions: Transaction details, communication between parties, dispute evidence files, and financial records required for regulatory compliance.

2. How We Use Your Information

We use your information to:

• Create and manage your account
• Verify your identity and comply with AML/KYC regulations
• Process transactions and hold funds in escrow
• Resolve disputes and provide customer support
• Detect and prevent fraud, money laundering, and security threats
• Send transactional emails (receipts, alerts, dispute updates)
• Comply with legal obligations and respond to lawful requests
• Improve platform performance and user experience

We do not use your data for advertising purposes or sell it to third parties.

3. Sharing & Disclosure

We do not sell personal data. We may share data with:

• Identity verification providers (Onfido, Jumio, or similar) for KYC processing
• Payment processors to facilitate deposits and withdrawals
• Cloud infrastructure providers (AWS, Cloudflare) for hosting and security
• Email delivery services to send transactional notifications
• Law enforcement or regulators when legally required to disclose

All third-party processors are bound by data processing agreements and GDPR-compliant data handling obligations.

4. Data Retention

We retain personal data for as long as your account is active. After account closure, we retain data for a minimum of 5–7 years as required by financial regulations (AML, FCA). Identity documents are deleted as soon as verification is complete and no longer legally required.

You may request deletion of non-legally-required data at any time by contacting [email protected].

5. Security Measures

We implement multiple layers of security including:

• AES-256 encryption for all data at rest
• TLS 1.3 for all data in transit
• Access controls and role-based permissions for internal staff
• Regular third-party security audits and penetration testing
• SOC 2 Type II and ISO 27001 certified infrastructure

6. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access the personal data we hold about you
• Correct inaccurate or incomplete information
• Delete data not required for legal or regulatory purposes
• Export your data in a portable format
• Object to certain types of processing
• Withdraw consent where processing is consent-based

To exercise any right, email [email protected]. We respond within 30 days. GDPR users may also lodge a complaint with their national Data Protection Authority.

7. Cookies

We use the following types of cookies:

• Essential cookies: Required for login sessions, security tokens, and platform functionality. Cannot be disabled.
• Analytics cookies: Used to understand how users interact with our platform (anonymised). Can be disabled in your browser.

We do not use advertising or tracking cookies. We do not share cookie data with advertisers.

8. Children's Privacy

Flux Escrow is not intended for users under 18 years of age. We do not knowingly collect personal data from children. If we become aware that a user is under 18, we will immediately close their account and delete associated data. Please contact us if you believe a minor has created an account.

9. Contact Our Privacy Team

For any privacy-related enquiries, requests, or complaints:

Data Protection Officer
Flux Escrow Ltd
14 Finsbury Square, London EC2A 1HP, UK
Email: [email protected]