Legal Directory

PRIVACY POLICY

Last Updated: September 2026

Your privacy is important to us. To better protect your privacy, Photon Dance Technology Limited, and our affiliated companies (together, “SYKKA”, “we”, “us”, “our”) developed this Privacy Policy as an extension of our commitment to combine quality services with integrity in dealing with our users.

If you visit or interact with us, or use our website at www.sykka.com (the “Website”), our APIs, our application programming interfaces, or our mobile applications (together, the “Apps”), or if you register to use our products and services, we may collect and process certain personal information about you.

Please read this Privacy Policy carefully. This Privacy Policy is intended to articulate the types of personal data we may collect, what your data may be used for, what the legal bases for those collections and uses are, and how we protect it. This Privacy Policy is not intended to override the terms of any contract that you may have with us or any rights you might have under data protection laws applicable to you.

1. WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT?

Depending on the types and nature of the products and services you use (or continue to use), we may collect different types of personal information from you. This includes:

  1. a.personal particulars (e.g. name, email address, telephone number, country of residence, residential address, nationality, date of birth and/or identity card/passport details, password);
  2. b.identity validation (e.g., photograph, other information requested to verify your information, including copy of valid ID document);
  3. c.voice recordings of our conversations with you;
  4. d.employment details (e.g. occupation, directorships and other positions held, employment history, salary, and/or benefits);
  5. e.blockchain address;
  6. f.biometric data (e.g., facial and/or finger recognition for identity verification, where applicable);
  7. g.Google and/or Apple account information;
  8. h.tax information;
  9. i.banking information (e.g. account numbers and banking transactions);
  10. j.background checks information (e.g. credit history), publicly available and/or criminal history and additional information at the discretion of our compliance team;
  11. k.information you provide to us when you contact our support team to help us answer your queries. We also gather information about any suggestions or complaints you make in order to help address your queries and improve the products and services we offer you;
  12. l.information obtained from mobile device with your consent (e.g. device location and information);
  13. m.your email and marketing preferences including interests and market list assignments, marketing objections, preferred language, Website and Apps data; and
  14. n.your device data and log information through the use of technologies, cookies and web beacons and advertising IDs, including IP addresses, device ID and type, and details about your use of our Website and Apps, browsing history, search queries, browser type, session frequency, geolocation information, wireless and mobile network connection information.

2. HOW DO WE COLLECT PERSONAL INFORMATION?

Your personal information is collected by us directly (for example, when you use our Website and Apps, register for our products or services, enter into our promotional events or competitions, download our applications, or when you interact with us by contacting us for enquiries or providing feedback). You are under no obligation to provide personal information when we seek to directly collect it from you. However, if you do not provide us with certain information marked as mandatory or with an asterisk on the relevant forms, we may not be able to process your submission, provide you with our services or respond to your enquiries.

3. FOR WHAT PURPOSES IS PERSONAL INFORMATION COLLECTED AND USED?

We may use your personal information for our core business purposes, such as:

  1. a.create customer profiles, maintain customer records and to communicate with you (including providing you with updates on changes to products and services), fulfil your requests and respond to your queries or feedback, addressing or investigating any complaints, claims or dispute;
  2. b.send you important notices or personalized messages in relation to your use of our products and services;
  3. c.administer the operation of our Website and Apps, to allow you to use the services and functions of our Website, to conduct website maintenance, to troubleshoot problems, and to continually improve your Website experience;
  4. d.provide you with services and products in accordance with the terms and conditions that govern our relationship with you;
  5. e.to identify and send you marketing materials, news and information which we think will be of interest to you such as our latest promotional offers and upcoming products and services;
  6. f.conducting screening, due diligence checks and verify your identity for the purposes of providing our products or services as may be required under applicable laws, regulations or directives;
  7. g.detect, investigate and prevent fraud and other illegal activities;
  8. h.use your personal information for purposes associated with our legal or regulatory rights and obligations, including financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes and for the purposes of seeking professional advice, including legal advice; and
  9. i.keep internal records, decision making and facilitate internal purposes such as data analysis, and research to improve our products and services, service security and quality, and to maintain opt-in and opt-out lists.

4. WHAT IS OUR LEGAL BASIS FOR USING YOUR PERSONAL INFORMATION?

We will only process your personal information where we have a legal basis to do so. We are required to establish a legal basis in order to use your personal information for the purposes set out above. We will make sure that we only use your personal information for the purposes set out above where we are satisfied that:

  1. a.our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to fulfil obligations under the contract signed between you and us);
  2. b.you have provided your consent;
  3. c.it is necessary to comply with a legal obligation; or
  4. d.our use of your personal information is necessary to support the “legitimate interests” that we have as a business (for example, to improve our products and services, to provide help or support in connection with our Website and Apps, to ensure that they operate efficiently and securely, and to carry out analytic across our datasets), provided it is always carried out in a way that is proportionate, and that respects your data privacy rights.

5. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

Your personal information may be shared with companies within our group to assist us in providing our products and services to you. We may also disclose your personal information to the following third parties for the purposes described below:

  • •Service providers and partners we engage in order to provide our products and services to you, such as payment processing companies, custodians, acquirers, bank partners, payment system operators to process your transactions.
  • •In response to a valid legal request from government, regulatory authorities, law enforcement agencies and courts.
  • •Professional advisors, such as law firms, to enforce or apply any contract with you or including subpoenas, court orders, legal process, and our auditors in connection with our audit requirements.
  • •Service providers and partners we engage in carrying out due diligence identity verification, transaction monitoring, fraud-screening and for the purposes of detecting, preventing or otherwise addressing fraud, security or technical issues, protecting against harm to the rights, property or safety of our users or the public, or as necessary to serve our legitimate business interests.
  • •In order to improve our business services, we may share your personal information, as well as non-personally identifiable information, with our advertising and analytic providers and with related service providers.
  • •We may share your personal data with any subsidiaries, joint ventures, or other companies under common control. If another company acquires our company, business, or our assets, that company will possess the personal data collected by us and will assume the rights and obligations regarding your personal data as described in this Privacy Policy. However, the acquiring company may need to obtain fresh consent if the purpose of processing changes.

Our Website and Apps may, from time to time, contain links to and from the websites of our partners and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we have no control over how they may use your personal data. You should check the privacy policies of third party websites before you submit any personal data to them.

6. WHAT COUNTRIES WILL YOUR PERSONAL INFORMATION BE SENT TO?

Your information, including personal data, may be transferred to and maintained on places located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. Please note that we may transfer the data, including personal data, outside your jurisdiction and process it there. Your consent to this Privacy Policy and your submission of such information represent your agreement and consent to that transfer. Information you provide to us may also be stored on our and/or third-party cloud servers.

When we do so, we will use appropriate safeguards, where necessary, to ensure an adequate level of protection for any personal data that is transferred (e.g. standard contractual clauses where no mandatory governmental rules are imposed, conduct DPIAs for high-risk processing activities, including transfers to countries without an adequacy decision, to ensure your data is protected.) We will always take steps to ensure that any international transfer of information is carefully managed to protect your rights and interests and is undertaken in accordance with the applicable rules governing such transfers.

You have the right to ask us for more information about the safeguards we have put in place (please see the “How to contact us” section below if you would like further information).

7. HOW CAN WE KEEP YOUR PERSONAL INFORMATION SECURE?

We make every effort to protect us and you (including your data and personal information that we hold) from unauthorized access, alteration, disclosure or destruction. We have implemented technical and organizational security measures to safeguard your personal information and data.

We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake. We monitor the services provided to clients for quality purposes, which may involve processing personal data stored on the relevant client file.

We have policies and procedures in place to monitor the quality of our services and manage risks in relation to client engagements.

We collect personal data as part of our client engagement and acceptance procedures. As part of those procedures we carry out searches using publicly available sources (such as internet searches and sanctions lists) to identify politically exposed persons (PEPs), their family members (FMs) and known close associates (KCAs) and heightened risk individuals (as High Net-Worth) and organizations and check that there are no issues that would prevent us from a particular client (eg. sanctions).

In particular:

  1. a.we regularly review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems;
  2. b.we use encrypted password protection where appropriate; and
  3. c.we restrict access to personal information only to those employees and contractors who need access to the relevant personal information in order for them to process it for us and who are subject to strict contractual confidentiality obligations.
  4. d.we provide our personnel with relevant training and continually updating our security practices in light of new risks and developments in technology.

We work hard to protect your personal information, however, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee the absolute security of your data.

8. HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION?

We will retain your personal information for as long as is reasonably necessary for the purposes listed in section “For what purposes are personal information collected and used?”. When we no longer need to use your personal data, we will remove it from our systems and records and/or take steps to anonymize it so that you can no longer be identified from it. In some circumstances, we may retain your personal information for longer periods of time. Such circumstances may include but are not limited to where we are required to do so to meet legal, regulatory, tax or accounting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

9. CHILDREN’S PRIVACY

The Website and Apps are not intended for or directed at children. By children we mean users under the age of 16 or in the case of a country where the minimum age for processing personal information differs, such different age.

We do not knowingly collect any information from children. If we obtain actual knowledge that we have collected personal information from a child, we will immediately delete it (unless we are legally obligated to retain such information). Please contact us if you believe that we inadvertently collected information from any child.

10. WHAT ARE YOUR OTHER RIGHTS?

Subject to applicable laws and regulations, you may have a number of rights in relation to your personal information. For example, under GDPR, you may request access to your data, rectification of any mistakes in our records, erasure of records where no longer required, restriction on the processing of your data, objection to the processing of your data, data portability and various information in relation to any automated decision making and profiling or the basis for international transfers. You also have the right to lodge a complaint with your national supervisory authority.

  1. a.Access: you can ask us to provide details of what personal information (if any) we process about you, what we use it for, who we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it for, how you can make a complaint, where we got your data from, you can also ask us to provide a copy of it;
  2. b.Rectification: you can ask us to rectify inaccurate personal information;
  3. c.Erasure: you can ask us to erase your personal information in certain circumstances (for example if it is no longer needed for the purposes for which it was collected or you have withdrawn your consent if the data processing was based on consent) absent an overriding legitimate interest;
  4. d.Restriction: you can ask us to restrict (i.e. keep but not use) your personal information in certain circumstances (for example where its accuracy is contested or where it ceases to be useful for the purposes we are using it for);
  5. e.Portability: in certain circumstances you can ask us to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it 'ported' directly to another data controller;
  6. f.Objection: you can object to any processing of your personal information which has our 'legitimate interests' as its lawful basis if you believe your fundamental rights and freedoms outweigh our legitimate interests;
  7. g.Automated Decision Making: you can ask for certain automated decisions to be reconsidered by us using human intervention；
  8. h.Withdrawal of Consent: if you have consented to our processing of your personal information, you have the right to withdraw your consent at any time. This includes cases where you wish to opt out from marketing messages you receive from us; and
  9. i.Lodging a Complaint: you have a right to lodge a complaint with your national data protection supervisory authority at any time if you believe that we have not complied with applicable data protection laws. Please click here for a list of national data protection authorities in the EEA countries. We would, however, appreciate the chance to deal with your concerns before your approach the data protection authorities, so please contact us in the first instance.

Please contact us as set out in the section headed “How to contact us?” if you do wish to exercise these rights.

11. COOKIES

To make our Websites and Apps work properly, SYKKA, similar to many other major operators, sometimes use small data files called cookies or other tracking technology to track information about your use of our website and services. We may use third party service providers to collect this information on our behalf.

11.1 What are cookies

Cookie is a small text file that a website saves on your computer or mobile device when you visit the website. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don't have to keep re-entering them whenever you come back to the website or browse from one page to another.

11.2 How we use cookies and tracking

We use the following cookies/tracking mechanisms:

  1. a.Session cookies. Session cookies are temporary cookies that remain in the cookie file of your browser until you leave the website. We use session cookies to allow you to carry information across pages of our site and avoid having to re-submit the same information. The cookies will be deleted after your web browser has been closed.
  2. b.Persistent cookies. Persistent cookies remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie). We use persistent cookies:
  • •to help us recognize you as a unique visitor when you return to our website and to monitor your use of our website;
  • •to allow us to link you to any of our Partners of Affiliates should you come to our website through a paid advert or banner on a website of an Affiliate or Partner.
  • •the cookies will be deleted based on their own expiration period after your web browser has been closed.
  1. c.Web Beacons. Some of our web pages may contain web beacons which allow us to count users who have visited these pages. Web beacons collect only limited information including a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. These beacons do not carry any personally identifiable information and are used to track the effectiveness of a particular marketing campaign.

11.3 How to control cookies

You can control and/or delete cookies as you wish – for details, see about cookies.org. You can delete all cookies that are already on your computer or other channels, and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit the website and some services and functionalities may not work. For non-essential Cookies and tracking technologies (such as Cookies used for analytics or marketing purposes), we will seek your explicit consent when you first visit the website, and provide you with convenient options for managing your consent.

11.4 Opt-in and Opt-out for Non-Essential Cookies

We are committed to providing you with clear control over how cookies are used. For non-essential cookies and tracking technologies (such as cookies used for analytics or marketing purposes), we require your explicit opt-in consent before they are placed.

11.5 How to Manage Your Cookie Preferences

  1. a.Via the Consent Banner: When you first visit our website, a cookie consent banner will appear, allowing you to choose whether to accept or decline non-essential cookies.
  2. b.Via Browser Settings: You can adjust your browser settings at any time to reject all or specific cookies. Please note that this action might affect your experience with certain features on our website.
  3. c.Via a Privacy Dashboard: We may provide a privacy dashboard that allows for more granular management of your cookie preferences and data settings.

11.6 Withdrawing Your Consent

If you have previously consented to the use of non-essential cookies, you can withdraw your consent at any time through any of the methods mentioned above (e.g., by revisiting the consent banner, adjusting browser settings, or via a privacy dashboard).

11.7 Important Note on Consent

Simply continuing to use our website or scrolling does not constitute consent for non-essential cookies. We will only load and use these cookies after you have made an explicit choice to opt-in.

12. HOW TO CONTACT US?

If you have questions or concerns about this Privacy Policy or a specific request related to your personal information, please contact us at dpo@sykka.com.

If you wish to make an inquiry regarding how we process your personal information, please contact us at dpo@sykka.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.

13. POLICY UPDATES.

We reserve the right to make changes to this Privacy Policy at any time by posting a revised version to our Website and Apps and updating the “Last Updated” date at the top of this Privacy Policy. To the extent permitted by applicable law, your continued use of our services after such notice or posting constitutes your consent to our revisions of this Privacy Policy. If you disagree with any of our changes, you may deactivate your account with us at any time.

14. LIABILITY.

TO THE EXTENT PERMISSIBLE UNDER APPLICABLE LAWS AND GDPR REGULATIONS, WE ARE NOT LIABLE TO YOU IN RESPECT OF ANY CLAIMS, LOSSES, DAMAGES, EXPENSES (INCLUDING REASONABLE LEGAL FEES) ARISING OUT OF OR IN CONNECTION WITH THE USE AND/OR DISCLOSURE OR DISSEMINATION OF THE USER DATA IN ACCORDANCE WITH THIS PRIVACY POLICY AND ANY CONSENTS THAT YOU MAY HAVE OTHERWISE PROVIDED TO US.