Privacy

1. Introduction and Scope

This Privacy Policy explains how PENDENTE Cambeon data controller entity, legal form, and place of registration (“Cambeon”, “we”, “us”, or “our”) collects, uses, shares, and protects personal data when you visit this website and any related digital channels we operate (together, the “Website”), when you contact us, and when you engage with us as a prospective or existing client.

This Policy applies to personal data we process about visitors to the Website, individuals who submit inquiries, and the representatives, beneficial owners, and authorized users of institutional clients. It does not apply to third-party websites or services we do not control.

By using the Website or providing personal data to us, you acknowledge the practices described in this Policy. Where we rely on your consent, we explain that below.

2. Who We Are

Cambeon is the controller responsible for the personal data described in this Policy. PENDENTE identify the Cambeon controlling entity, its legal form, registered address, and, where more than one Cambeon entity is involved, which entity acts as controller for which processing activity and how they relate.

3. Information We Collect

We collect personal data that you provide to us directly, data generated through your use of the Website, and data we receive from third parties. The categories below describe the types of information we may collect; not all of it applies to every individual.

Information you provide. Name, contact details (such as email address, telephone number, and country), your organization and role, and the content of any message, form submission, or request you send us.

Institutional and relationship information. Where you interact with us on behalf of an organization, we may collect details about that organization and your relationship to it, including your position and authority to act.

Commercial inquiries. Information about the products or services you are interested in, the nature of your inquiry, and any preferences you share with us.

4. Identity Verification and Compliance Information

Where you or your organization proceed toward a client relationship, we are subject to legal and regulatory obligations that require us to verify identity and assess risk. For those purposes we may collect additional information, including identification documents, date of birth, nationality, government-issued identifiers, proof of address, beneficial-ownership and corporate-structure information, and the results of identity, sanctions, politically-exposed-person, and adverse-media screening.

PENDENTE confirm the categories of identity-verification, KYC/KYB, and screening data Cambeon actually collects, the identity-verification and screening providers used, and the jurisdictions in which those checks are performed.

5. Financial and Transaction Information

In connection with a client relationship, we may process financial and transaction-related information, such as bank or settlement details, wallet or account identifiers, transaction records, and information necessary to process and reconcile activity. PENDENTE confirm the financial and transaction data categories tied to Cambeon’s actual products (for example OTC digital-asset transactions and fiat-to-crypto activity).

6. Blockchain and Digital-Asset Information

Where our services involve digital assets, we may process public blockchain data associated with transactions, including wallet addresses and on-chain transaction details. Information recorded on a public blockchain is, by the nature of the technology, public, distributed, and generally not capable of being altered or deleted. We do not control public blockchain networks. PENDENTE confirm the scope of on-chain data processing appropriate to Cambeon’s products.

7. Information Collected Automatically

When you use the Website, we and our service providers may automatically collect certain technical information, such as your IP address, device and browser type, operating system, referring pages, the pages you view, and the dates and times of your visits. We collect this information using cookies and similar technologies, as described in Section 14.

PENDENTE confirm the analytics, performance, and session-measurement tools Cambeon actually uses, and the data each one collects. Do not carry over any specific third-party analytics vendor without confirmation.

8. Information From Third Parties

We may receive personal data about you from third parties, including identity-verification and screening providers, sanctions and watchlist data sources, publicly available sources, business partners, and referrals. We may combine this information with data we already hold about you. PENDENTE confirm the third-party sources Cambeon relies on and the data received from each.

9. How and Why We Use Personal Data

We use personal data to:

  • respond to your inquiries and provide information you request;
  • establish, operate, and administer client relationships and provide our services;
  • verify identity and meet our compliance, anti-money-laundering, sanctions, and other legal and regulatory obligations;
  • operate, maintain, secure, and improve the Website and our services;
  • detect, prevent, and investigate fraud, security incidents, and prohibited or unlawful activity;
  • communicate with you about our services and, where permitted, send marketing communications;
  • carry out research and analysis to develop and improve our products and services; and
  • comply with applicable law and enforce our terms and agreements.

Where a data-protection law requires a legal basis for processing, we rely on the basis appropriate to each activity, which may include performance of a contract, compliance with a legal obligation, our legitimate interests, or your consent. PENDENTE confirm the data-protection regimes that apply to Cambeon (for example based on the jurisdictions in which it operates and in which data subjects are located) and the specific legal bases relied on for each processing purpose.

11. Anti-Money-Laundering, Sanctions, and Regulatory Compliance

As a business operating in the digital-asset and financial sector, we are subject to legal and regulatory obligations that require us to process personal data, including for identity verification, sanctions and watchlist screening, transaction monitoring, record-keeping, and the reporting of suspicious activity to competent authorities. We may be required to process this data, and to retain and disclose it, to meet those obligations, and in some cases we may be prohibited from informing you of a disclosure. PENDENTE confirm the AML/CFT, sanctions, and regulatory framework applicable to Cambeon and the authorities to which it reports; do not carry over any specific regulator or regime without confirmation.

12. How We Share Personal Data

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

  • Affiliates within our corporate group, for the purposes described in this Policy;
  • Service providers and processors that perform functions on our behalf, such as hosting, identity verification, screening, communications, analytics, and professional services, under obligations of confidentiality and data protection;
  • Financial institutions and counterparties where necessary to provide our services;
  • Legal, regulatory, and governmental authorities where required by law, regulation, legal process, or a lawful request, or to protect our rights, safety, or property or those of others;
  • Professional advisers, such as auditors, lawyers, and accountants; and
  • Parties to a corporate transaction, such as a merger, acquisition, financing, or sale of assets, in which case personal data may be transferred as part of that transaction.

We may also share information that has been aggregated or de-identified so that it does not identify you.

PENDENTE confirm the actual categories of recipients with whom Cambeon shares personal data, and, where required, the specific service providers and their roles.

13. International Data Transfers

Cambeon and its service providers may process personal data in countries other than the one in which you are located. Those countries may have data-protection laws that differ from those of your own country. Where we transfer personal data internationally, we take steps to ensure it is protected in a manner consistent with applicable law. PENDENTE confirm where Cambeon and its providers process and store personal data, the countries involved, and the transfer mechanisms and safeguards relied on.

14. Cookies and Similar Technologies

The Website uses cookies and similar technologies to operate the site, remember your preferences, measure usage, and improve your experience. You can manage cookies through your browser settings, and, where required, we will seek your consent for non-essential cookies. PENDENTE confirm the actual cookies and similar technologies used on the Website, their purposes, durations, and providers, and the consent mechanism presented to visitors.

15. Marketing Communications

Where permitted by applicable law, we may send you communications about our services. You can opt out of marketing communications at any time using the unsubscribe mechanism in the relevant message or by contacting us. Opting out of marketing does not affect communications we send you for operational, contractual, or legal reasons.

16. Data Retention

We retain personal data for as long as necessary to fulfill the purposes described in this Policy, including to provide our services, and to meet our legal, regulatory, accounting, and record-keeping obligations, after which we delete or anonymize it. Retention periods differ depending on the type of data and the applicable legal requirement. PENDENTE confirm Cambeon’s actual retention periods, including any minimum retention required by applicable AML and record-keeping rules; do not carry over any specific retention period without confirmation.

17. Security

We maintain technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, and alteration. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security. You are responsible for keeping any credentials you use confidential. PENDENTE confirm the security measures and any certifications Cambeon wishes to reference.

18. Your Privacy Rights

Depending on your location and the applicable law, you may have rights in relation to your personal data, which can include the right to access, correct, delete, or receive a copy of your data, to object to or restrict certain processing, to withdraw consent, and to lodge a complaint with a supervisory authority. To exercise any right available to you, please contact us using the details in Section 23. We may need to verify your identity before responding, and some rights are subject to conditions and exceptions under applicable law, including where we are required to retain data for legal or regulatory reasons.

19. Jurisdiction-Specific Rights

Some data-protection laws grant additional or specific rights to individuals in particular jurisdictions. PENDENTE confirm which jurisdiction-specific privacy regimes apply to Cambeon and set out the corresponding rights and disclosures required by each; do not carry over jurisdiction-specific disclosures written for another company’s regulatory footprint.

The Website may link to or integrate third-party websites and services that we do not control. This Policy does not apply to those third parties, and we are not responsible for their privacy practices. We encourage you to review the privacy notices of any third party before providing your personal data to them.

21. Children’s Privacy

The Website is intended for individuals who are 18 years of age or older. We do not knowingly collect personal data from anyone under that age. If we become aware that we have collected personal data from a person under the applicable age, we will take steps to delete it.

22. Changes to This Policy

We may update this Privacy Policy from time to time. Any updated version becomes effective when published on the Website. Where required by law, we will provide additional notice of material changes. Your continued use of the Website after an update means you acknowledge the revised Policy.

23. Contact and Data-Protection Requests

If you have questions about this Policy or wish to exercise a privacy right, you may contact us at PENDENTE privacy / data-protection contact email or at PENDENTE Cambeon registered address. PENDENTE confirm whether Cambeon has appointed a data protection officer or a representative in any jurisdiction, and provide those contact details if so.

Contact