Privacy Policy

1. About This Policy

This Privacy Policy describes how DIRE MONEY TRANSMITTER LLC ("Company," "we," "us," or "our"), operator of the Vaultora platform accessible at vaultora.co.com, collects, uses, stores, and discloses personal information when you use our services or visit our website.

We are a registered Money Services Business (MSB) under the supervision of the Financial Crimes Enforcement Network (FinCEN). Our data practices are shaped by that regulatory context. Identity verification is not optional on our platform. Federal law under the Bank Secrecy Act (BSA) and the USA PATRIOT Act requires us to know who our customers are.

By accessing or using our platform, you acknowledge that you have read this policy. If you do not agree with the practices described here, do not use our services.

2. Information We Collect

We collect different types of information depending on how you interact with us.

2.1 Identity and Verification Information

To comply with federal KYC (Know Your Customer) requirements, we collect full legal name, date of birth, government-issued identification documents (such as a driver's license or passport), a selfie or liveness image for identity confirmation, Social Security Number or Tax Identification Number where required, and for business accounts: entity formation documents, beneficial ownership information, and authorized signer details.

2.2 Contact and Account Information

We collect email address, phone number, mailing address, and account login credentials. We do not store raw passwords. Passwords are hashed using industry-standard cryptographic methods.

2.3 Transaction Data

Every transaction conducted through our platform is recorded. This includes transaction type, amount, asset, timestamp, wallet addresses involved, and any associated fees. This data is retained as required by federal law.

2.4 Technical and Usage Data

When you use our website or platform, we may collect IP address, browser type, operating system, device identifiers, pages visited, session duration, and referring URLs. This information is used for security purposes, fraud detection, and improving platform functionality.

2.5 Communications

If you contact us by email, phone, or through our contact form, we retain a record of that communication and any information you provide within it.

3. How We Use Your Information

We use the information we collect for the following purposes:

Regulatory Compliance: Verifying identity as required under the BSA, USA PATRIOT Act, and applicable FinCEN regulations. Filing Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) as required by law. Maintaining records for the periods specified by applicable regulation.

Account Management: Creating and maintaining your account, processing transactions, communicating about your account status, and verifying your eligibility to use our services in your state of residence.

Security and Fraud Prevention: Monitoring transactions for patterns associated with money laundering, fraud, and other financial crimes. Protecting the platform from unauthorized access.

Platform Operation: Providing the exchange and wallet services you have requested. Processing fees and maintaining transaction records. Sending service-related communications.

Legal Obligations: Responding to lawful requests from government authorities, courts, or law enforcement. Exercising or defending our legal rights.

4. Legal Basis for Processing

Our processing of personal data is grounded in several legal bases under applicable US law:

Legal Obligation: A substantial portion of the data we collect and retain is required by federal law. The BSA, 31 U.S.C. § 5311 et seq., and associated FinCEN regulations at 31 C.F.R. Chapter X mandate collection and retention of identity information and transaction records. We have no discretion to waive these requirements.

Contract Performance: We process your information to perform our obligations under the Terms of Use you agree to when creating an account and using our services.

Legitimate Interests: We process certain technical and usage data to maintain platform security, prevent fraud, improve our services, and detect unauthorized activity. These interests do not override your rights where applicable law requires otherwise.

Consent: Where we rely on your consent for any processing activity, you may withdraw that consent at any time by contacting us. Withdrawal of consent does not affect the lawfulness of processing that occurred before withdrawal.

5. Sharing Your Information

We do not sell your personal information to third parties. We share your information only in the following circumstances:

Government Authorities and Regulators: We disclose information to FinCEN, the IRS, and other federal and state regulators as required by law. This includes mandatory reporting obligations under the BSA. We may also disclose information in response to lawful subpoenas, court orders, or law enforcement requests.

Identity Verification Partners: We use regulated third-party identity verification services to process KYC documents. These providers are contractually bound to use your information only for the purpose of identity verification on our behalf.

Service Providers: We work with technology vendors for platform infrastructure, data storage, and security. These vendors process data on our behalf under data processing agreements and are not permitted to use your data for their own purposes.

Business Transfers: If DIRE MONEY TRANSMITTER LLC is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. You will be notified of such a change through our website or by direct communication.

With Your Consent: We will share your information with other parties if you have explicitly authorized that sharing.

6. Data Retention

Federal regulations under the BSA require us to retain records related to customer identity and transactions for a minimum of five years from the date of the transaction or the closure of the account, whichever is later. We comply with this requirement and do not delete records during the mandatory retention period.

Technical and usage data that is not subject to mandatory retention periods is retained only as long as reasonably necessary for the purposes described in this policy, after which it is deleted or rendered non-identifiable.

Communications you send to us are retained for as long as they are relevant to an active account relationship or open matter, and for a reasonable period thereafter.

7. Your Rights

Depending on your state of residence, you may have certain rights regarding your personal information. We recognize and respect the following rights where they apply under applicable law:

Access: You may request a copy of the personal information we hold about you.

Correction: You may request that we correct inaccurate information.

Deletion: You may request deletion of personal information we hold, subject to our legal obligations. We cannot delete information that federal law requires us to retain.

Restriction: In certain circumstances you may request that we limit how we use your data.

Portability: Where technically feasible and legally applicable, you may request your data in a structured, machine-readable format.

To exercise any of these rights, contact us at support@vaultora.co.com. We will respond within the timeframe required by applicable law and will verify your identity before processing any request.

8. California Residents (CCPA)

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), grants you specific rights regarding your personal information.

Under the CCPA, you have the right to know what categories of personal information we collect and why, to access specific pieces of personal information we have collected about you, to request deletion of your personal information (subject to exceptions including our BSA retention obligations), to opt out of the sale or sharing of your personal information (note: we do not sell personal information), to correct inaccurate personal information, and to non-discrimination for exercising your CCPA rights.

Categories of personal information collected include identifiers (name, email, IP address), government ID documents (collected for legal compliance), financial information (transaction records), and internet activity data (usage and technical information).

To submit a CCPA request, contact us at support@vaultora.co.com with the subject line "CCPA Request." We will verify your identity and respond within 45 days, with a possible extension of an additional 45 days where reasonably necessary.

9. Security Practices

We implement technical and organizational measures designed to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit using TLS, encrypted storage for sensitive identity documents, access controls limiting which personnel can access personal data, session management controls, and monitoring for unauthorized access attempts.

No method of electronic transmission or storage is entirely free from risk. While we work to protect your information using commercially reasonable means, we cannot provide a warranty of absolute security.

In the event of a data breach that affects your personal information and triggers notification obligations under applicable state law, we will notify you in accordance with the timeframes and methods required by that law.

10. Children's Privacy

Our platform is not directed at individuals under the age of 18. We do not knowingly collect personal information from anyone under 18. Identity verification conducted during account creation is designed to confirm that users meet this age requirement.

If you believe that we have inadvertently collected information from a minor, contact us immediately at support@vaultora.co.com and we will take appropriate steps to delete that information, subject to any conflicting legal obligations.

11. Contact and Updates

Questions about this Privacy Policy or our data practices should be directed to:

DIRE MONEY TRANSMITTER LLC
Operating as Vaultora
8395 International Dr, Orlando, FL 32819
Email: support@vaultora.co.com
Phone: +1 (407) 903-9055

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or applicable law. The "Last Updated" date at the top of this document indicates when the most recent revision was made. We encourage you to review this policy periodically.