Privacy Policy

1. Who We Are and What This Notice Covers

Incyt Trading LLC, a Wyoming limited liability company with its principal place of business in Travis County, Texas ("Incyt," "we," "us"), is responsible for the personal information described in this Notice.

This Notice applies to personal information we collect through our websites, the Incyt Compute Prime platform and APIs, onboarding, and our business dealings. It covers:

  • Client personnel: employees, officers, Authorized Users, and beneficial owners of our institutional clients.

  • Prospects and counterparties: representatives of prospective clients, compute providers, lenders, custodians, and other business partners.

  • Website visitors: anyone who visits our websites or contacts us.

The Services are offered only to businesses. We do not offer them to individuals for personal, family, or household purposes.

This Notice does not cover data our clients run on compute capacity arranged through the Services. Incyt has no access to that data, and the client and its compute provider are responsible for it. It also does not cover our own employees and job applicants, who receive a separate notice.

2. Information We Collect

We collect the categories below. We do not intentionally collect sensitive personal information except government identifiers and related data needed for identity verification, as noted below.

  • Identifiers and contact details: name, job title, employer, business email, phone, and business address. Collected from you, your employer, and public sources.

  • Identity verification data: date of birth, nationality, government ID images and numbers, proof of address, selfie or liveness checks, and beneficial-ownership information. Collected from you, your employer, and identity-verification vendors.

  • Compliance screening results: sanctions, politically-exposed-person, and adverse-media results, and risk ratings. Collected from screening vendors and public sources.

  • Account and credential data: username, Authorized User role and permissions, multi-factor settings, and API key metadata. Collected from you and your employer.

  • Transaction and instruction data: orders, quotes, confirmations, approvals, and the individual who gave or approved them. Collected through your use of the Services.

  • Wallet and on-chain data: wallet addresses, transaction hashes, and on-chain activity linked to your organization. Collected from you, public blockchains, and blockchain-analytics vendors.

  • Communications: emails, chat messages, recorded calls, meeting notes, and support requests. Collected from you.

  • Device and usage data: IP address, approximate location, browser and device type, pages viewed, log data, and session timestamps. Collected automatically through our websites and platform.

  • Marketing and event data: event registrations, newsletter subscriptions, and email engagement. Collected from you and event partners.

If you give us information about someone else, such as a colleague or beneficial owner, you confirm you are authorized to do so and have told them about this Notice where required.

3. How We Use Information

We use personal information for the purposes below. Where EU or UK law applies, the legal basis for each purpose is shown in parentheses.

  • Providing the Services: onboarding clients, operating accounts, arranging and settling transactions, reporting, and support. (Contract; legitimate interests)

  • Compliance: identity verification, sanctions and export-control screening, anti-money-laundering monitoring, recordkeeping, and responding to regulators and lawful requests. (Legal obligation; legitimate interests)

  • Security and fraud prevention: authenticating users, detecting unauthorized access, and protecting client assets and our systems. (Legitimate interests)

  • Risk and credit: assessing counterparties, financing eligibility, and collateral. (Contract; legitimate interests)

  • Improving the Services: analytics, debugging, and product development, using aggregated or de-identified data where practical. (Legitimate interests)

  • Communications and marketing: sending service notices, and, where permitted, business updates and event invitations. (Contract; legitimate interests; consent where required)

  • Legal rights: enforcing our agreements, handling disputes, and protecting our rights and the rights of others. (Legitimate interests)

  • Corporate transactions: due diligence in a financing, merger, acquisition, or sale of assets. (Legitimate interests)

We do not use personal information to make decisions based solely on automated processing that produce legal or similarly significant effects on individuals.

4. How We Share Information

We do not sell personal information, and we do not share it for cross-context behavioral advertising. We share it only with the categories of recipients below.

  • Service providers that process information on our behalf under contract, including hosting, identity verification, compliance screening, blockchain analytics, communications, and analytics providers.

  • Custodians, compute providers, lenders, and other counterparties where needed to onboard you, arrange or settle a transaction, or meet their own compliance obligations.

  • Professional advisers such as lawyers, auditors, and insurers, under confidentiality obligations.

  • Financing sources and investors in confidential diligence, limited to what is reasonably necessary.

  • Regulators, law enforcement, and courts where required by law or legal process, or where we believe disclosure is needed to prevent harm, fraud, or sanctions violations.

  • Successors in a merger, acquisition, financing, or sale of assets, subject to this Notice.

  • Others with your direction or consent.

Counterparties and custodians that receive information to perform their own services act under their own privacy notices. We will provide a current list of the categories of providers we use on request.

5. Blockchain Data

Transactions broadcast to public blockchains are permanently recorded and visible to anyone. Once a wallet address is linked to you or your organization, that link may reveal your on-chain activity.

We cannot delete, edit, or hide data recorded on a public blockchain, including in response to a privacy request. We can delete the off-chain records that link an address to you, subject to our retention obligations in Section 7.

6. Cookies and Similar Technologies

We use cookies, local storage, and similar technologies on our websites and platform for three purposes:

  • Essential: keeping you signed in, security, and remembering settings. These cannot be turned off.

  • Analytics: understanding how our websites are used so we can improve them.

  • Marketing: measuring campaign performance.

You can control non-essential cookies through our cookie banner and your browser settings. Where the law requires consent, we ask for it before setting non-essential cookies. We honor Global Privacy Control signals as an opt-out where required by law.

7. Retention

We keep personal information only as long as needed for the purposes in this Notice, then delete or de-identify it.

  • Identity verification and compliance screening records: 5 years after the client relationship ends, or longer if required by law.

  • Transaction, instruction, and communication records: 5 to 7 years after the transaction or relationship ends.

  • Account and credential data: the life of the account plus 1 year.

  • Prospect and marketing data: 2 years after last meaningful contact, or until you opt out.

  • Website logs and analytics: 13 months.

We may keep information longer where needed for a legal hold, dispute, investigation, or regulatory request.

8. Security

We use administrative, technical, and physical safeguards suited to the sensitivity of the data, including encryption in transit and at rest, role-based access, multi-factor authentication, and logging.

No system is completely secure. If we confirm a security incident affecting your personal information, we will notify you and regulators as required by law.

9. International Transfers

We are based in the United States and process information here and in other countries where we or our service providers operate. Those countries may not have data-protection laws equivalent to yours.

Where EU, UK, or Swiss law applies, we transfer personal information outside those regions using an approved mechanism, such as the European Commission's Standard Contractual Clauses and the UK addendum, or a provider's certification under an applicable data privacy framework. You may request a copy of the relevant safeguards.

10. Your Privacy Rights

Depending on where you live, you may have the right to:

  • know what personal information we hold about you and get a copy;

  • correct inaccurate information;

  • delete information;

  • receive information in a portable format;

  • object to or restrict certain processing;

  • opt out of sale, targeted advertising, or profiling (we do none of these);

  • withdraw consent where processing is based on consent; and

  • appeal our decision on your request, and complain to a data-protection authority.

Some U.S. state privacy laws do not apply to information about individuals acting in a business or employment capacity. We will honor requests where the law requires it and consider other requests in good faith.

How to make a request. Email privacy@incyt.xyz. We will verify your identity before acting, and may ask your employer to confirm requests about business accounts. An authorized agent may submit a request with proof of authority. We respond within the time the law requires, generally 45 days in the U.S. and one month in the EU and UK, and will tell you if we need more time.

Limits. We may decline or limit a request where we must keep information for legal, compliance, or security reasons, where it would affect others' rights, or where on-chain data cannot be changed (Section 5). We will not discriminate against you for exercising your rights.

Appeals. If we deny your request, you may appeal by replying to our decision with "Appeal" in the subject line. We will respond within the time the law requires.

11. Other Terms

Marketing. You can unsubscribe from marketing emails using the link in any message. You will still receive service and legal notices.

Children. The Services are for businesses and are not directed to anyone under 18. We do not knowingly collect information from children.

Third-party sites. Our websites may link to sites we do not control. Their privacy practices are their own.

Changes. We may update this Notice. We will post the updated version with a new effective date, and notify clients of material changes by email or through the platform before they take effect.

Contact. Incyt Trading LLC, Travis County, Texas. Email: operations@incyt.xyz.