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1. Introduction

Thank you for visiting Shipfinex. By visiting, accessing, or using Shipfinex, you consent to the policies and practices of this Privacy, Data Protection with KYC and Anti-Money Laundering (AMLD5) Policy (the “Privacy, KYC and Anti-Money Laundering Policy” or this “Policy”), so please read them carefully. Your use of the Site is being provided by one or all of the following parties (collectively, as “we”, “our”, or “us”) :

  • FRACTIONAL SHIPPING OWNERSHIP LLC a Saint Vincent and Grenadines entity having registered office at Suite 305, Griffith Corporate Centre, Kingstown, St. Vincent and the Grenadines and Limited Liability Company Number 2728 LLC 2022.

  • SHIPFINEX - FZCO, a free zone company formed in the International Free Zone Authority, having registered office is located at Dubai Silicon Oasis, DDP, Building A2, Dubai, United Arab Emirates and the registration number: DSO-FZCO-22077.

  • SHIPFINEX LLC, a limited liability company formed under the state laws of Wyoming, United States, having its registered office at 1603 Capitol Ave., Suite 310 Cheyenne, Wyoming 82001, United States and Filing Id: 2023-001230608.

Your privacy is of utmost importance to us, and it is our policy to safeguard and respect the confidentiality of information and the privacy of individuals. This Policy applies when Shipfinex is acting as a data controller with respect to the personal data of our users. This Policy describes how we collect, use and share personal data of consumer users across our websites, and services offered to users, and from our partners and other third parties. When using any of our Services you consent to the collection, transfer, storage, disclosure, and use of your personal data as described in this Policy. This Policy does not apply to anonymised data, as it cannot be used to identify you.

This Policy explains what data we collect, how such data is used and stored, as well as how such data may be shared by us. If you do not wish to use your Personal Data (as described below) in ways described in this Policy, you shall not use this Site or any services, software, API (Application program interface), technologies, products and/or functionalities offered by this Website.

Our Privacy Notice is reviewed regularly to ensure that any new obligations and technologies, as well as any changes to our business operations and practices are taken into consideration, as well as that it remains abreast of the changing regulatory environment. Any personal information we hold will be governed by our most recent Privacy Notice. 

Please note that if you are an employee of the Company, a contractor to the Company or a third-party provider, your personal information will be used in connection with your employment contract or your contractual relationship, whichever applies. 

This Privacy Notice applies to the processing activities performed by Shipfinex to the personal information of its clients and its potential clients and website visitors. 

We may amend this Privacy Notice at any time by posting the amended version on this site including the effective date of the amended version. We will announce any material changes to this Privacy Notice on our website. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

2. Definitions 

2.1 As used herein, the following terms are defined as follows: 

2.1.1 “Digital Asset” is a digital representation of value (also referred to as “cryptocurrency,” “virtual currency,” “digital currency,” “crypto token,” “crypto asset,” or “digital commodity”), such as USDC, USDT, bitcoin, or ether, which is based on the cryptographic protocol of a computer network that may be (i) centralized or decentralized, (ii) closed or open-source, and (iii) used as a medium of exchange and/or store of value. 

2.1.2 “Shipfinex Account” means a user-accessible account offered via the Shipfinex platform where Digital Assets are stored by Shipfinex. 

2.1.3 “Shipfinex Platform Services” means Shipfinex branded websites, applications, services, or tools operated by Shipfinex group companies. 

2.1.4 “We,” and “Us” refers to Shipfinex and its shareholders, directors, members, employees, directors, agents, affiliates and officers of its affiliates.

2.1.5 “Personal Information” or “Personal Data” or “your data” means any information which, either alone or in combination with other data, enables you to be directly or indirectly identified, such as your name, email address, username, contact details, identification number, location data, an online identifier such as IP address, device ID or one or more factors specific to the physical, economic, cultural or social identity of you.

3. Your Data Controller 

Our products and services are provided through local operating entities or global entities under the same management details of which are described in this Policy.

The Company you are contracting with is your Data Controller, and is responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with our global privacy standards, this Privacy Notice, as well as any applicable national laws. The Company uses encryption to protect your information and store decryption keys in separate systems. We process and retain your personal information on our servers in multiple data center locations, including ______________ and dynamic servers elsewhere in the world. 

4. How do we protect personal information? 

The Company respects the privacy of any users who access its website, and it is therefore committed to taking all reasonable steps to safeguard any existing or prospective clients, applicants and website visitors. 

The Company keeps any personal data of its clients and its potential clients in accordance with the applicable privacy and data protection laws and regulations. 

We have the necessary and appropriate technical and organizational measures and procedures in place to ensure that your information remains secure at all times. We regularly train and raise awareness for all our employees to the importance of maintaining, safeguarding and respecting your personal information and privacy. We regard breaches of individuals’ privacy very seriously and will impose appropriate disciplinary measures, including dismissal from employment. 

The personal information that you provide us with when applying to open an account, applying for a role within the Company, or when using our website, is classified as registered information, which is protected in several ways. You can access your registered information after logging in to your account by entering your username and the password that you have selected. It is your responsibility to make sure that your password is only known to you and not disclosed to anyone else. Registered information is securely stored in a safe location, and only authorized personnel have access to it via a username and password. All personal information is transferred to the Company over a secure connection, and thus all reasonable measures are taken to prevent unauthorized parties from viewing any such information. Personal information provided to the Company that does not classify as registered information is also kept in a safe environment and accessible by authorized personnel only through username and password.

5. Information we may collect about you 

In order to open an account with us, you must first complete and submit a “create account” form to us by completing the required information. By completing this form, you are requested to disclose personal information in order to enable the Company to assess your application and comply with the relevant laws (including their regulations). 

The information that we collect from you is as follows: 

○ Full name, residential address and contact details (e.g. email address, telephone number, fax etc.); 

○ Date of birth, place of birth, gender, citizenship; 

○ Bank account information, credit card details, including details about your source of funds, assets and liabilities, and such other information as may be asked; 

○ Trading account balances, trading activity, your inquiries and our responses; 

○ Information on whether you hold a prominent public function (PEP) (like politician); 

○ Verification information, which includes information necessary to verify your identity such as a passport, driver’s license or Government-issued identity card); 

○ Other Personal Information or commercial and/or identification information – Whatever information we, in our sole discretion, deem necessary to comply with our legal obligations under various anti-money laundering (AML) obligations, such as under the European Union’s 4th AML Directive and the Bank Secrecy Act (BSA). 

6. Information we collect about you automatically. 

○ Location Information – Information that is automatically collected via analytics systems providers to determine your location, including your IP address and/or domain name and any external page that referred you to us, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform; 

○ Log Information – Information that is generated by your use of Shipfinex platform Services that is automatically collected and stored in our server logs. This may include, but is not limited to, device-specific information, location information, system activity and any internal and external information related to pages that you visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website or App (including date and time; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

7. Information we receive about you from other sources. 

We obtain information about you in a number of ways through your use of our services, including through any of our websites, the account opening process, webinar sign-up forms, event subscribing, news and updates subscribing, and from information provided in the course of on-going support service communications. We also receive information about you from third parties such as your payment providers and through publicly available sources. For example: 

○ The wallets you use to transfer funds to us will provide us with your basic personal information, such as your name and address, as well as your financial information such as your wallet details and source and usage of digital assets deposited or withdrawn from the exchange wallets; 

○ Your business partners may provide us with your name and address, as well as financial information; 

○ Advertising networks, analytics providers and search information providers may provide us with anonymized or de-identified information about you, such as confirming how you found our website; 

○ Credit reference agencies do not provide us with any personal information about you, but may be used to corroborate the information you have provided to us. 

8. Anti-Money Laundering.

To the extent it is required by Shipfinex to establish, maintain and monitor accounts of users on the Shipfinex platform, Shipfines may use services of third-party service providers for the implementation and operation of the AML Policy in order to be in compliance with the United Arab Emirates, State laws of Wyoming, United States and Saint Vincent and Grenadines AML laws applicable to Shipfinex for the data obtained from the users on its platform, including the Bank Secrecy Act and the PATRIOT Act, as described hereinafter.

In this regard, Shipfinex shall use services of third party service providers for : (a) establishing and implementing internal policies, procedures and controls to be reasonably designed to prevent Shipfinex accounts from being used to launder money or finance terrorist activities; (b) independent testing of the activities on the platform, for compliance with Shipfinex AML policies and procedures; (c) designating a person or persons by such third party who shall be responsible for implementing and monitoring the operation and internal controls of Shipfinex AML program; and (d) providing ongoing training to the personnel responsible for monitoring Shipfinex AML relating to the prevention of money-laundering activities. 

9. General Provisions 

Personal Information you provide during the account creation process will be retained for one year, even if your registration is incomplete or abandoned.


10. Lawful basis for processing your personal information 

We will process your personal information on the following bases and for the following purposes: 

Performance of a contract 

We process personal data in order to provide our services and products, as well as information regarding our products and services based on the contractual relationship with our clients (i.e. so as to perform our contractual obligations). In addition, the processing of personal data takes place to enable the completion of our client on-boarding process. 

In view of the above, we must verify your identity in order to accept you as our client and we will use your personal data in order to effectively manage your trading account with us. This may include third parties carrying out credit or identity checks on our behalf. The use of your personal information is necessary for us to know who you are, as we have a legal obligation to comply with “Know Your Customer” and customer due diligence regulatory obligations. 

Compliance with a legal obligation 

There are a number of legal obligations imposed by relevant laws to which we are subject, as well as specific statutory requirements e.g. anti-money laundering laws, financial services laws, corporation laws, privacy laws and tax laws. There are also various supervisory authorities whose laws and regulations apply to us. Such obligations and requirements imposed on us necessitate personal data processing activities for identity verification, payment processing, compliance with court orders, tax laws or other reporting obligations and anti-money laundering controls. 

These obligations apply at various times, including client on-boarding, payments and systemic checks for risk management. 

For the purpose of safeguarding legitimate interests 

We process personal data so as to safeguard the legitimate interests pursued by us or by a third party. A legitimate interest is when we have a business or commercial reason to use your information. Example of such processing activities include the following: 

○ Initiating legal claims and preparing our defense in litigation procedures; 

○ Means and processes we undertake to provide for the Company’s IT and system security, preventing potential crime, asset security and access controls; 

○ Measures for managing the business and for further developing products and services; 

○ Sharing your data within the Shipfinex group of companies for the purpose of updating and/or verifying your personal data in accordance with the relevant anti-money laundering compliance frameworks, and 

○ Risk management. 

To provide you with products and services, or information about our products and services, and to review your ongoing needs. 

Once you successfully open an account with us, or subscribe to information, we must use your personal information to perform our services and comply with our obligations to you. It is also in our legitimate interests to try to ensure that we are providing the best products and services so we may periodically review your needs based on our assessment of your personal information to ensure that you are getting the benefit of the best possible products and services from us. 

To help us improve our products and services, including support services, and develop and market new products and services. 

We may, from time-to-time, use personal information provided by you through your use of the services and/or through client surveys to help us improve our products and services. It is in our legitimate interests to use your personal information in this way to try to ensure the highest standards when providing you with our products and services and to continue to be a market leader within the cryptocurrency financial service industry. 

To investigate or settle enquiries or disputes 

We may need to use personal information collected from you to investigate issues or to settle disputes with you because it is our legitimate interest to ensure that issues and disputes get investigated and resolved in a timely and efficient manner. 

To comply with applicable laws, subpoenas, court orders, other judicial process, or the requirements of any applicable regulatory authorities

We may need to use your personal information to comply with any applicable laws and regulations, subpoenas, court orders or other judicial processes, or requirements of any applicable regulatory authority. We do this not only to comply with our legal obligations but because it may also be in our legitimate interest to do so. 

To send you surveys 

From time to time, we may send you surveys as part of our client feedback process. It is in our legitimate interest to ask for such feedback to try to ensure that we provide our products and services at the highest standard. However, we may from time to time also ask you to participate in other surveys and if you agree to participate in such surveys we rely on your consent to use the personal information we collect as part of such surveys. All responses to any survey we send out whether for client feedback or otherwise will be aggregated and depersonalized before the results are published and shared. 

Data analysis 

Our website pages and emails may contain web beacons or pixel tags or any other similar types of data analysis tools that allow us to track receipt of correspondence and count the number of users that have visited our webpage or opened our correspondence. We may aggregate your personal information with the personal information of our other clients on an anonymous basis (that is, with your personal identifiers removed), so that more rigorous statistical analysis of general patterns may lead us to providing better products and services. 

If your personal information is completely anonymised, we do not require a legal basis as the information will no longer constitute personal information. If your personal information is not in an anonymised form, it is in our legitimate interest to continually evaluate that personal information to ensure that the products and services we provide are relevant to the market. 

Marketing purposes 

We may use your personal information to send you marketing communications by email or other agreed forms (including social media campaigns), to ensure you are always kept up-to-date with our latest products and services. If we send you marketing communications we will do so based on your consent and registered marketing preferences. 

Internal business purposes and record keeping 

We may need to process your personal information for internal business and research purposes as well as for record keeping purposes. Such processing is in our own legitimate interests and is required in order to comply with our legal obligations. This may include any communications that we have with you in relation to the products and services we provide to you and our relationship with you. We will also keep records to ensure that you comply with your contractual obligations pursuant to the agreement (‘Terms of Service”) governing our relationship with you. 

Legal Notifications 

Often the law requires us to advise you of certain changes to products or services or laws. We may need to inform you of changes to the terms or the features of our products or services. We need to process your personal information to send you these legal notifications. You will continue to receive this information from us even if you choose not to receive direct marketing information from us.

11. Disclosure of your personal information 

The Company will not disclose any of its clients’ confidential information to a third party, except: (a) to the extent that it is required to do so pursuant to any applicable laws, rules or regulations; (b) if there is a duty to disclose; (c) if our legitimate business interests require disclosure; (d) in line with our Terms of Service; (e) at your request or with your consent or to those described in this Privacy Notice. The Company will endeavor to make such disclosures on a “need-to-know” basis, unless otherwise instructed by a regulatory authority. Under such circumstances, the Company will notify the third party regarding the confidential nature of any such information. 

As part of using your personal information for the purposes set out above, the Company may disclose your personal information to the following: 

○ Any members of the Company, which means that any of our affiliates and subsidiaries may receive such information; 

○ Any of our service providers and business partners, for business purposes, such as specialist advisors who have been contracted to provide us with administrative, financial, legal, tax, compliance, insurance, IT, debt-recovery, analytics, research or other services; 

If the Company discloses your personal information to service providers and business partners, in order to perform the services requested by clients, such providers and partners may store your personal information within their own systems in order to comply with their legal and other obligations. We require that service providers and business partners who process personal information to acknowledge the confidentiality of this information, undertake to respect any client’s right to privacy and comply with all relevant privacy and data protection laws and this Privacy Notice.

12. Where we store your personal data 

Our operations are supported by a network of computers, servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and our third-party service providers and business partners store and process your personal data in ______________ and elsewhere in the world. 

13. Privacy Shield 

Under Privacy, we are responsible for the processing of personal information we receive, collect, use, retain and subsequently transfer to a third party service provider or business partner acting for or on our behalf. We may not be liable for ensuring that the third parties we engage also support our Privacy commitments. Shipfinex commits to cooperate and comply with the advice of the regulatory authorities to whom you may raise a concern about our processing of your personal information pursuant to Privacy. This is provided at no cost to you.

14. Disclosures for National Security or Law Enforcement 

Under certain circumstances, we may be required to disclose your personal information in response to valid requests by public authorities, including to meet national security or law enforcement requirements. 

15. Transfers of personal information outside of India

We and our other group companies have offices in the United Arab Emirates, the State of Wyoming, United States and Saint Vincent and Grenadines. To facilitate our operations we may transfer, store and process your personal information within these countries or to other Company subsidiaries, service providers and business partners (i.e Data Processors) who are engaged on our behalf. To the extent that we transfer your personal information outside these countries, we will ensure that the transfer is lawful and that Data Processors in third countries are obliged to comply with the GDPR General Data Protection Act 2016. If transfers of personal information are processed in the US, we may in some cases rely on applicable standard contractual clauses, binding corporate rules. 

16. Transfers of Personal Information outside of your country 

By using our products and services, you consent to your Personal Data being transferred to other countries, including countries that have differing levels of privacy and data protection laws than your country. In all such transfers, we will protect your personal information as described in this Privacy Notice, and ensure that appropriate information sharing contractual agreements are in place. 

17. Privacy when using digital assets and blockchains 

Your funding of USDT, bitcoin, XRP, ether, and other Digital Assets, may be recorded on a public blockchain. Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to deanonymization and the unintentional revelation of private financial information, especially when blockchain data is combined with other data. 

Because blockchains are decentralized or third-party networks which are not controlled or operated by Shipfinex or its affiliates, we are not able to erase, modify, or alter personal data from such networks. 

18. Data Retention 

Safeguarding the privacy of your personal information is of utmost importance to us, whether you interact with us personally, by phone, by email, over the internet or any other electronic medium. We will hold personal information, for as long as we have a business relationship with you, in secure computer storage facilities, and we take the necessary measures to protect the personal information we hold from misuse, loss, unauthorized access, modification or disclosure. 

When we consider that personal information is no longer necessary for the purpose for which it was collected, we will remove any details that will identify you or we will securely destroy the records. However, we may need to maintain records for a significant period of time (after you cease being our client). For example, we are subject to certain anti-money laundering laws which require us to retain the following, for a period of 7 years after our business relationship with you has ended. 

○ A copy of the records we used in order to comply with our client due diligence obligations; ○ Supporting evidence and records of transactions with you and your relationship with us.

Also, the personal information we hold in the form of a recorded information, by telephone, electronically or otherwise, will be held in line with local regulatory requirements (i.e. 7 years after our business relationship with you has ended or longer if you have legitimate interests (such as handling a dispute with you)). If you have opted out of receiving marketing communications we will hold your details on our suppression list so that we know you do not want to receive these communications. 

We may keep your data for longer than 7 years if we cannot delete it for legal, regulatory or technical reasons. 

19. Cookies 

When you use our products and services, we may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, “Cookies”) on your computer or other devices used when engaging with us. We use Cookies to (i) help us recognize you as a customer, collect information about your use of our products and services, to better customize our services and content for you, and to collect information about your computer or other access devices to ensure our compliance with our AML obligations. 

20. Your rights regarding your personal information 

The rights that are available to you in relation to the personal information we hold about you are outlined below. 

Information Access 

If you ask us, we will confirm whether we are processing your personal information and, if so, what information we process and, if requested, provide you with a copy of that information within 30 days from the date of your request. 


It is important to us that your personal information is up to date. We will take all reasonable steps to make sure that your personal information remains accurate, complete and up-to-date. If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have disclosed your personal information to others, we will let them know about the rectification where possible. If you ask us, if possible and lawful to do so, we will also inform you with whom we have shared your personal information so that you can contact them directly. 

You may inform us at any time that your personal details have changed by emailing us at ___________________________ The Company will change your personal information in accordance with your instructions. To proceed with such requests, in some cases we may need supporting documents from you as proof i.e. personal information that we are required to keep for regulatory or other legal purposes. 


You can ask us to delete or remove your personal information in certain circumstances such as if we no longer need it, provided that we have no legal obligation to retain that data. Such requests will be subject to the contract that you have with us, and to any retention limits we are required to comply with in accordance with applicable laws and regulations. If we have disclosed your personal information to others, we will let them know about the erasure request where possible. If you ask us, if possible and lawful to do so, we will also inform you with whom we have shared your personal information so that you can contact them directly. 

Processing restrictions 

You can ask us to block or suppress the processing of your personal information in certain circumstances such as if you contest the accuracy of that personal information or object to us processing it. It will not stop us from storing your personal information. We will inform you before we decide not to agree with any requested restriction. If we have disclosed your personal information to others, we will let them know about the restriction of processing if possible. If you ask us, if possible and lawful to do so, we will also inform you with whom we have shared your personal information so that you can contact them directly. 

Data portability 

In certain circumstances you might have the right to obtain personal information you have provided us with (in a structured, commonly used and machine readable format) and to re-use it elsewhere or ask us to transfer this to a third party of your choice.


You can ask us to stop processing your personal information, and we will do so, if we are: 

○ Relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing; 

○ Processing your personal information for direct marketing; or 

○ Processing your personal information for research unless we reasonably believe such processing is necessary or prudent for the performance of a task carried out in the public interest (such as by a regulatory or enforcement agency). 

21. Automated decision-making and profiling 

If we have made a decision about you based solely on an automated process (e.g. through automatic profiling) that affects your ability to access our products and services or has another significant effect on you, you can request not to be subject to such a decision unless we can demonstrate to you that such decision is necessary for entering into, or the performance of, a contract between you and us. Even if a decision is necessary for entering into or performing a contract, you may contest the decision and require human intervention. We may not be able to offer our products or services to you, if we agree to such a request (i.e. end our relationship with you).

22. Changes to this Privacy Notice 

Our Privacy Notice is reviewed regularly to ensure that any new obligations and technologies, as well as any changes to our business operations and practices are taken into consideration, as well as that it remains abreast of the changing regulatory environment. Any personal information we hold will be governed by our most recent Privacy Notice. 

If we decide to change our Privacy Notice, we will post those changes to this Privacy Notice and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

23. Our products and services are not available to children 

Our products and services are not directed to persons under the age of 18, hereinafter “Children”, “Child” and we do not knowingly collect personal information from Children. If we learn that we have inadvertently gathered personal information from a Child, we will take legally permissible measures to remove that information from our records. The Company will require the user to close his or her account and will not allow the use of our products and services. If you are a parent or guardian of a Child, and you become aware that a Child has provided personal information to us, please contact us at ___________________________ and you may request to exercise your applicable access, rectification, cancellation, and/or objection rights. 

24. Data Security

  • We have implemented measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration and disclosure. The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

  • Steps taken to ensure data security:

i. All the user information can only be accessed by authorized users; and

ii. Users need to authenticate themselves with a username-password combination.

  • Unfortunately, the transmission of information via public networks such as the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted through the Services. Any transmission of personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Services.

25. If you have a complaint 

Any questions, complaints, comments and requests regarding this Privacy Notice are welcome and should be addressed to ___________________________.

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