Privacy Policy

Privacy Policy

We protect your privacy while maintaining transparency and regulatory cooperation as required.

Last updated: September 23, 2025

1. Information We Collect

We collect information necessary to operate our cryptocurrency distribution platform and meet regulatory requirements:

  • Personal Information: Name, email address, and identity verification documents as required for compliance
  • Platform Activity: Usage patterns, transaction history, governance participation, and tier advancement metrics
  • Technical Information: Device identifiers, IP addresses, browser information, and security event logs
  • Communication Records: Customer support interactions, governance discussions, and platform notifications
  • Financial Data: Cryptocurrency wallet addresses and transaction records for platform operations

2. How We Use Your Information

We process your information for the following purposes:

  • Operating our cryptocurrency distribution platform and related services
  • Verifying user identity and maintaining regulatory compliance obligations
  • Processing community governance participation and tier-based benefits
  • Detecting, preventing, and investigating fraudulent activities and security threats
  • Communicating platform updates, governance matters, and service-related information
  • Improving platform functionality, user experience, and service delivery
  • Maintaining records as required by applicable financial and data retention regulations

3. Information Sharing and Disclosure

We may share your personal information in the following circumstances:

  • Implementation Partners: Limited operational data sharing with partners like VDV for service delivery and compliance
  • Regulatory Authorities: Information disclosure as required by applicable laws, regulations, or regulatory investigations
  • Service Providers: Third-party vendors who provide technical infrastructure, security, or operational support under confidentiality agreements
  • Legal Obligations: Disclosure pursuant to legal process, court orders, subpoenas, or law enforcement requests
  • Business Transfers: Information transfer in connection with mergers, acquisitions, or asset sales
  • Safety and Security: Disclosure necessary to protect the safety of users, prevent fraud, or enforce our terms of service

We do not sell personal information to third parties for commercial marketing purposes.

4. Data Security Measures

We implement comprehensive security measures to protect your information:

  • End-to-end encryption for sensitive data transmission and storage
  • Multi-factor authentication requirements and role-based access controls
  • Regular security assessments, penetration testing, and vulnerability monitoring
  • Employee security training and confidentiality agreements
  • Secure infrastructure hosting with reputable cloud service providers
  • Incident response procedures for potential security breaches

While we employ industry-standard security practices, no electronic transmission or storage method provides absolute security. We cannot guarantee complete protection against all potential security threats.

5. Data Retention Practices

We retain personal information for periods necessary to fulfill operational and legal obligations:

  • Account Information: Retained during active account status plus applicable regulatory retention periods
  • Transaction Records: Maintained as required by financial service regulations and audit requirements
  • Communication Records: Business communications typically retained for 3-5 years
  • Security Logs: Technical logs maintained for security monitoring and incident investigation
  • Governance Records: Community participation records maintained for platform integrity
  • Analytics Data: Aggregated and anonymized usage data may be retained indefinitely for platform improvement

Specific retention periods may vary based on regulatory requirements in applicable jurisdictions.

6. Your Privacy Rights

Subject to applicable law and regulatory requirements, you may have the following rights regarding your personal information:

  • Access Rights: Request access to personal information we maintain about you
  • Correction Rights: Request correction of inaccurate or incomplete personal information
  • Deletion Rights: Request deletion of personal information (subject to regulatory retention requirements)
  • Data Portability: Receive personal information in a structured, commonly-used format
  • Processing Objection: Object to certain types of data processing activities
  • Marketing Communications: Opt-out of non-essential marketing communications

To exercise privacy rights or submit privacy-related inquiries, contact us at support@gambino.gold. We will respond within reasonable timeframes as required by applicable law.

Note: Certain data retention may be required by regulatory obligations and cannot be deleted upon request. We will explain any limitations when responding to your requests.

7. International Data Processing

Our platform operates through infrastructure located primarily in the United States. Personal information may be processed and stored in the United States and other countries where our service providers maintain operations.

When transferring personal information internationally, we implement appropriate safeguards including contractual protections and security measures. By using our platform, you acknowledge that your information may be processed outside your country of residence.

For users in the European Union or other regions with specific data transfer requirements, we work to ensure transfers comply with applicable legal frameworks.

8. Third-Party Services and Links

Our platform may integrate with or link to third-party services, including:

  • Cryptocurrency wallet providers and blockchain networks
  • Identity verification and compliance service providers
  • Analytics and platform monitoring services
  • Communication and customer support tools

These third-party services operate under their own privacy policies. We encourage you to review the privacy practices of any third-party services you interact with through our platform.

9. Children's Privacy

Our platform is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information promptly.

Parents or guardians who believe we may have collected information from a child under 18 should contact us immediately at support@gambino.gold.

10. Privacy Policy Updates

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or service offerings. Material changes will be communicated through platform notifications and the updated policy will be posted here.

Your continued use of our platform after policy updates constitutes acceptance of the revised privacy practices. We encourage periodic review of this policy to stay informed about how we protect your information.

11. Contact Information

For privacy-related questions, requests, or concerns, contact us at:

Email: support@gambino.gold

For time-sensitive privacy matters or requests requiring immediate attention, please clearly indicate "PRIVACY REQUEST" in your subject line.

12. Additional Disclosures

California Residents: California residents may have additional rights under the California Consumer Privacy Act (CCPA). For information about CCPA rights and how to exercise them, contact us using the information provided above.

European Union Residents: EU residents may have rights under the General Data Protection Regulation (GDPR). For information about GDPR rights and our data protection officer contact information, please reach out using the contact details provided.

Cookies and Tracking: For information about cookies, analytics, and tracking technologies, please review our Cookie Policy.