Legal
Privacy Policy
Last updated: 2026.
1. Introduction
Ultimo ("we", "us", or "our") is committed to protecting your personal information. This Privacy Policy explains what data we collect, how we use it, who we share it with, and the rights you have over it. By using the Platform you consent to the practices described in this policy. This policy applies to all users of the Ultimo platform and associated services.
2. Information We Collect
We collect information you provide directly — such as your name, email address, government-issued identification documents, date of birth, and financial information required for KYC/AML compliance. We also collect information automatically when you use the Platform, including your IP address, browser type, device identifiers, pages visited, time spent on the Platform, and transaction data. We may also receive information about you from third-party identity verification providers, fraud prevention services, and blockchain analytics tools.
3. How We Use Your Information
We use your information to: provide, maintain, and improve the Platform; verify your identity and comply with our legal obligations; process your transactions; detect and prevent fraud, money laundering, and other illegal activity; communicate with you about your account, updates, and promotional offers (where you have opted in); analyse usage patterns to improve user experience; and comply with applicable law and regulatory requirements. We do not sell your personal information to third parties.
4. Legal Basis for Processing
We process your personal data on the following legal bases: performance of a contract (to provide the Platform services); compliance with a legal obligation (including KYC/AML requirements); our legitimate interests (including fraud prevention, security, and product improvement); and your consent (for marketing communications, where applicable). Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
5. Data Sharing & Disclosure
We may share your information with: service providers who assist us in operating the Platform (subject to confidentiality obligations); identity verification and fraud prevention partners; regulators, law enforcement, and government authorities where required by law; and successor entities in connection with a merger, acquisition, or sale of assets. We require all third parties to respect the security of your personal data and to treat it in accordance with applicable law.
6. Data Retention
We retain your personal data for as long as necessary to provide the Platform services and to comply with our legal obligations. KYC/AML records are typically retained for a minimum of five years following the end of your relationship with us, or such longer period as may be required by law. After the applicable retention period, your data will be securely deleted or anonymised.
7. Data Security
We implement appropriate technical and organisational security measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction. These measures include encryption of data in transit and at rest, access controls, and regular security assessments. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.
8. Your Rights
Depending on your jurisdiction, you may have the right to: access the personal data we hold about you; correct inaccurate or incomplete data; request deletion of your data (subject to our legal obligations); object to or restrict certain processing activities; data portability; and withdraw consent where processing is based on consent. To exercise any of these rights, please contact us through the support channels on the Platform.
9. Cookies & Tracking
We use cookies and similar tracking technologies to enhance your experience on the Platform, analyse usage, and deliver relevant content. You can control cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the Platform. We do not use cookies to track you across third-party websites for advertising purposes.
10. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by posting a notice on the Platform or by email. Your continued use of the Platform after changes are effective constitutes acceptance of the updated policy. We encourage you to review this policy periodically.
Disclaimer
DRAFT v1.0 — PENDING LEGAL REVIEW. This document is a working draft provided for transparency. Final, legally binding policies will be published following review by BVI counsel.