Privacy Policy

1. Who we are

Olbra Finance LLC, a limited liability company incorporated in the State of Wyoming, USA (“Olbra”, “we”, “our”), is the data controller for the personal data processed through this onboarding platform.

Eurodollar ApS (Copenhagen, Denmark; CVR 39 72 94 82) acts as joint controller and processor for the issuance of E-Money Tokens under its Danish EMI license, under the Cooperation Agreement between us.

Nanolabs sp. z o.o. sp. k. (Łódź, Poland), Olbra’s Polish operational subsidiary, performs day-to-day KYC review, customer support, and operational handling of your personal data under Schedule 2 of the Cooperation Agreement.

Contact for privacy matters, including all requests addressed to the Data Protection Officer: [email protected]. A dedicated DPO mailbox will be published once a DPO has been formally appointed; until then this address is the sole point of contact for privacy and data-protection requests.

2. What data we collect and why

We collect the following categories of personal data, processed for the purposes of onboarding, identity verification, and ongoing AML / CTF monitoring:

Identification data — full name, date of birth, nationality, residential address, contact details.
Identity document images — passport, national ID, or residence permit (front and back).
Selfie image — used to confirm the person presenting the identity document.
Employment and income data — status, occupation, employer, income range.
Source of funds information.
Politically exposed person (PEP) and sanctions screening data.
Intended use of E-Money Tokens, expected counterparties, expected transaction geographies.
Blockchain wallet address and on-chain transaction history relating to it.
Communications you exchange with our team.

3. Legal bases

We process your personal data on the following GDPR legal bases:

Article 6(1)(b) — performance of the contract that governs your onboarding.
Article 6(1)(c) — compliance with AML / CTF legal obligations under MiCA, AMLD6, and applicable Polish and Danish law.
Article 6(1)(f) — our legitimate interest in fraud prevention and protection of platform integrity.

4. Who receives your data

We share personal data with the following categories of recipients, each bound by written processing terms:

Eurodollar ApS — Copenhagen, Denmark (EEA). Joint controller / processor for E-Money Token issuance and regulatory reporting under its Danish EMI license.
Nanolabs sp. z o.o. sp. k. — Łódź, Poland (EEA). Operational sub-processor performing day-to-day KYC review and customer support.
Resend, Inc. — United States. Transactional email delivery; transfer protected by Standard Contractual Clauses (SCCs) and accompanying supplementary measures.
Hetzner Online GmbH — Germany (EEA). Hosting provider for the onboarding application, customer database, and identity-document storage.
Competent regulators on lawful request — including Finanstilsynet (Denmark), UODO (Poland), and EU / national tax authorities.

We do not sell personal data and do not share it for advertising purposes.

5. International transfers

Olbra Finance LLC is incorporated in Wyoming, USA. Where personal data is transferred from the EEA to the United States in connection with our role as controller, or to Resend as our email processor, transfers are made under Standard Contractual Clauses (SCCs) and supplementary measures appropriate to the categories of data.

Transfers within the EEA — to Eurodollar ApS in Denmark, to Nanolabs in Poland, and to Hetzner’s German data centres — are made without additional transfer safeguards beyond those required by the GDPR.

6. How long we keep your data

We retain personal data for as long as required by law, and no longer than necessary for the purposes for which it was collected:

KYC records (identity documents, selfies, source-of-funds evidence, PEP / sanctions screening results) — five years following the end of our customer relationship, per Article 40 of AMLD6 and the Polish AML Act.
Accounting records — five years from the end of the financial year, per the Polish Accounting Act and applicable US federal recordkeeping rules.
Audit logs (staff actions, status transitions, access logs to KYC data) — five years, for AML and regulatory-audit purposes.
Communications (support emails and ticket history) — two years from the last interaction, extended to five years where the communication is relevant to an AML investigation.
Session cookies — cleared on logout; otherwise rolling 30-day expiry with sliding renewal on activity.

Account data is deleted on your request, subject to the AML retention obligations above and to any ongoing legal or regulatory hold.

7. Your rights

You have the right to access, rectify, and request erasure of your personal data (the erasure right is subject to the AML retention overrides in section 6), to restrict or object to processing, to data portability, and — where applicable — to withdraw consent.

You have the right to lodge a complaint with a supervisory authority. EU residents habitually resident in Poland may complain to UODO (the Polish data-protection authority); residents of other EU member states may complain to the supervisory authority of their own state, or to Datatilsynet (Denmark) given Eurodollar ApS’s role.

8. Security

We protect personal data with encrypted transport (TLS 1.3), encrypted storage of identity documents, role-based access for staff, and audit logging of all KYC-related staff actions.

9. Cookies

We use strictly necessary cookies only, for session management and CSRF protection. We do not use analytics or advertising cookies. The cookie name we set is session, with attributes SameSite=Lax, Secure, and HttpOnly.

10. Changes to this policy

We will notify you by email of material changes to this policy at least 30 days before they take effect.

11. Contact

For any privacy request, contact [email protected]. Olbra Finance LLC is registered in the State of Wyoming, USA; the Wyoming Secretary of State File ID will be provided from the company register on request.