Privacy Policy

1. Who We Are (Data Controllers & Processors)

POLAR TENSOR CORP. (Panama): Data controller for investment and trading data.

POLAR MSB INC. (Montana, USA): Data controller for payment processing, KYC/AML checks, and US compliance.

POLAR TENSOR LAB LIMITED (Hong Kong): Data processor for platform hosting, software development, and technical maintenance.

2. Information We Collect

We collect:

• Identity Data: Name, DOB, nationality, ID documents, proof of address, tax IDs
• Compliance Data: Sanctions checks, PEP screenings, blockchain analytics, source of funds
• Financial Data: Deposits, withdrawals, wallet addresses, balances, fees, ledger entries
• Technical Data: IP address, device identifiers, browser info, activity logs, cookies
• Communication Data: Support tickets, emails, chat logs, submitted documents

3. How We Use Your Data

To provide services (operate account, enable transactions, process payments, provide trading), comply with legal obligations (AML/KYC, sanctions, fraud prevention, reporting), improve the platform (optimize models, analyze usage, troubleshooting), protect the business (detect security incidents, respond to regulators, enforce terms), and communicate (account notifications, system updates, security alerts).

4. Legal Basis for Processing (GDPR Compliance)

For EU and EEA users (accessing via reverse solicitation), data is processed under the following legal bases:

• Contractual Necessity: To fulfill our contractual obligations (e.g., trading, payments)
• Legitimate Interest: Fraud prevention, system optimization, security
• Legal Obligation: AML, sanctions checks, regulatory compliance
• Consent: For certain optional functions (e.g., cookies)

5. Data Sharing

We may share data with affiliates, third-party service providers (KYC verification, blockchain analytics, custodians, payment processors, cloud hosting, legal consultants, security auditors), legal & regulatory authorities (AML/CTF compliance, subpoenas, sanctions enforcement), and as part of business operations (reorganization, merger, acquisition).

6. International Data Transfers

Data may be transferred to Panama, United States, Hong Kong, European Union, and global cloud hosting locations. Transfers comply with GDPR adequacy principles, Standard Contractual Clauses (SCCs), and local laws.

7. Data Retention

We retain data only as long as necessary for regulatory compliance, contractual obligations, legal defense, AML monitoring, and tax/audit requirements.

In most cases:

• KYC records: 5-10 years
• Transaction records: 5-7 years
• Support communication: 2-5 years
• General account data: until closure, then archived per law

8. Data Security

We implement encryption in transit and at rest, multi-factor authentication, firewalls and intrusion detection, segregated access control, secure data centers, and ongoing security audits. However, no system is fully secure. The Client accepts risk of cyberattacks and data breaches.

9. Client Rights (GDPR Applicable)

Clients may request access, correction, deletion (where legally allowed), restriction of processing, data portability, objection to processing, and withdrawal of consent. Requests may be denied for AML/CTF obligations, fraud prevention, legal compliance, or contractual requirements.

10. Cookies & Tracking

We may use session cookies, authentication cookies, analytics cookies, and performance cookies. Third-party analytics tools may process anonymized or pseudonymized data.

You can adjust your browser settings to refuse cookies or alert you when cookies are being used. However, disabling cookies may limit certain features of the Platform.

11. Children's Privacy

The Platform is not intended for minors under 18. We do not knowingly collect data from minors.

12. Third-Party Links

The Platform may contain links to external websites. We are not responsible for third-party privacy practices.

13. Reverse Solicitation Notice

The Platform does not solicit EU clients, market to US residents, or conduct targeted advertising in restricted jurisdictions. Any EU or US user who accesses the Platform does so voluntarily and independently. GDPR applies solely due to cross-border data flow.

14. Dispute Resolution

This Policy is governed by the laws of Panama. Disputes shall be resolved by binding arbitration in Panama City, in English.

15. Changes to This Policy

We may update this Policy periodically. Continued use of the Platform constitutes acceptance of the updated Policy.

16. Contact Information

For privacy requests: POLAR TENSOR CORP., Compliance Department, compliance@polar-tensor.com, Republic of Panama.