Introduction
iATM Marketplace ("iATM," "Company," "we," "our," or "us") is committed to protecting the privacy, confidentiality, and security of the information entrusted to us by our users, customers, business partners, marketplace participants, lenders, escrow providers, introducing brokers, service providers, and other authorized users of the iATM platform. This Privacy Policy explains how iATM collects, uses, stores, processes, transfers, discloses, and protects information obtained through the iATM Marketplace website, platform, applications, APIs, communications, and related services (collectively, the "Platform").
The Platform has been designed to facilitate commercial transactions, marketplace activity, compliance workflows, escrow-supported settlements, Digital Asset Receipt ("DAR") issuance, transaction verification, documentation management, and other related services. In order to provide these services, iATM may collect and process information relating to individuals, businesses, transactions, compliance activities, and platform usage. By accessing or using the Platform, users acknowledge and agree to the practices described in this Privacy Policy.
Information We Collect
iATM may collect information that identifies, relates to, describes, references, or is reasonably capable of being associated with an individual, business, transaction, or account. The nature of the information collected will depend upon the services utilized, the participant's role within the Platform, applicable legal requirements, and the specific transaction activities being conducted.
Information may be collected directly from users during account registration, onboarding, transaction activity, communications with the Company, compliance reviews, document submissions, and use of Platform functionality. Information may also be obtained from publicly available sources, government registries, identity verification providers, compliance service providers, financial institutions, business databases, regulatory authorities, and other lawful third-party sources.
Personal Information
In order to establish, verify, maintain, and administer user accounts, iATM may collect personal information relating to authorized users, beneficial owners, directors, officers, representatives, brokers, lenders, escrow agents, and other individuals associated with Platform activities. Such information may include legal names, residential addresses, business addresses, telephone numbers, email addresses, dates of birth, citizenship information, government-issued identification details, tax-related information, biometric verification information, photographs, signatures, authentication credentials, and other information reasonably necessary to verify identity, support compliance obligations, and facilitate Platform operations.
Where permitted by applicable law, identity verification procedures may include the collection and processing of photographs, identity documents, facial recognition comparisons, liveness detection technologies, and other verification methods intended to confirm the authenticity of an individual's identity and protect the Platform from fraud, impersonation, and unauthorized activity.
Business Information
For businesses utilizing the Platform, iATM may collect information relating to legal entities, corporate structures, ownership arrangements, management personnel, regulatory registrations, operating licenses, tax registrations, banking relationships, beneficial ownership information, formation documents, corporate governance records, commercial activities, and other information reasonably necessary to support onboarding, transaction facilitation, risk management, and compliance requirements.
Business information may also include operational information relating to products, inventory, logistics, counterparties, transaction histories, financing activities, escrow arrangements, certifications, regulatory filings, and other information submitted through the Platform as part of the user's commercial activities.
Transaction and Marketplace Information
As a transaction infrastructure platform, iATM collects and processes information relating to marketplace participation, commercial transactions, transaction workflows, escrow arrangements, financing activities, settlement processes, and Digital Asset Receipt issuance. Such information may include transaction requests, offers, bids, product listings, product specifications, pricing information, transaction values, shipment information, delivery records, logistics documentation, communications between participants, financing information, escrow records, settlement instructions, transaction approvals, transaction milestones, and transaction outcomes.
The Platform may also record transaction histories, workflow events, audit records, timestamps, participant actions, approval activities, document submissions, and other operational information necessary to support transparency, auditability, compliance, and dispute resolution.
Compliance and Verification Information
To satisfy regulatory obligations, protect marketplace participants, and maintain Platform integrity, iATM may collect and process information necessary to conduct Know Your Customer ("KYC"), Know Your Business ("KYB"), Anti-Money Laundering ("AML"), sanctions screening, Politically Exposed Person ("PEP") screening, fraud prevention, and other compliance-related activities.
Compliance information may include verification results, risk assessments, sanctions screening outcomes, adverse media reviews, beneficial ownership records, source of funds information, source of wealth information, ongoing monitoring records, compliance investigations, enhanced due diligence records, and other information required to evaluate participant eligibility and manage regulatory obligations.
Users acknowledge that compliance reviews may occur both at onboarding and throughout the duration of their relationship with the Platform.
Technical and Usage Information
When users access or interact with the Platform, iATM may automatically collect certain technical and usage information. Such information may include IP addresses, browser types, operating systems, device identifiers, geolocation information, session data, access times, clickstream data, authentication records, log files, network information, application usage statistics, referral sources, and other information relating to Platform performance and security.
This information assists iATM in maintaining system integrity, monitoring performance, improving functionality, detecting suspicious activity, enhancing user experience, preventing unauthorized access, and supporting operational and security objectives.
How We Use Information
iATM uses collected information for a variety of legitimate business, operational, legal, regulatory, and security purposes. These purposes include administering user accounts, facilitating transactions, conducting compliance reviews, supporting escrow processes, managing financing workflows, issuing and maintaining DARs, protecting against fraud, improving Platform functionality, responding to inquiries, providing customer support, conducting audits, enforcing agreements, resolving disputes, complying with legal obligations, and protecting the rights, property, and safety of the Company and its users.
Information may also be used to analyze Platform performance, develop new products and services, conduct internal research, improve operational efficiency, monitor compliance risks, and support business continuity activities.
KYB, KYC and Ongoing Compliance Monitoring
As part of its commitment to marketplace integrity and regulatory compliance, iATM may conduct identity verification, business verification, sanctions screening, AML reviews, PEP screening, adverse media reviews, beneficial ownership verification, and other due diligence activities. Such reviews may be performed prior to onboarding, during transaction activity, periodically throughout the customer relationship, or whenever risk-based monitoring procedures require additional review.
Users acknowledge and agree that iATM may request additional information, conduct enhanced due diligence procedures, suspend transactions, restrict access, delay approvals, or terminate accounts where compliance concerns arise or where required by applicable law, regulation, sanctions programs, or internal risk-management procedures.
Digital Asset Receipts (DARs), Blockchain Records and Tokenized Assets
The Platform may create, issue, maintain, store, reference, or otherwise process Digital Asset Receipts ("DARs") and related transaction records. DARs are intended to provide transparency, auditability, verification, and structured transaction recordkeeping relating to transactions conducted through the Platform.
Certain DAR-related information may be linked to blockchain networks, distributed ledger systems, smart contracts, digital identifiers, transaction hashes, wallet addresses, or other digital infrastructure. Users acknowledge that information recorded on public blockchain networks may become publicly accessible, immutable, and permanently recorded. iATM does not control third-party blockchain networks and cannot guarantee the modification, deletion, correction, or removal of information recorded on such networks.
The existence of a DAR, tokenized transaction record, or blockchain reference does not independently create ownership rights, legal title, security interests, or contractual rights unless expressly provided by separate legal agreements governing the transaction.
Disclosure and Sharing of Information
iATM may disclose information to third parties where reasonably necessary to provide services, facilitate transactions, satisfy legal obligations, manage risk, or operate the Platform. Such disclosures may include sharing information with identity verification providers, compliance providers, sanctions-screening providers, escrow agents, financial institutions, lenders, logistics providers, technology vendors, cloud service providers, payment providers, legal counsel, auditors, consultants, regulators, law enforcement agencies, courts, and other authorized parties.
Information may also be disclosed in connection with mergers, acquisitions, corporate restructurings, financing transactions, asset sales, business transfers, insolvency proceedings, or similar corporate events.
iATM does not sell personal information for advertising purposes.
International Transfers of Information
The Platform may operate across multiple jurisdictions and may utilize service providers, infrastructure providers, compliance providers, escrow agents, financial institutions, and business partners located in various countries. As a result, information may be transferred to, stored in, processed in, or accessed from jurisdictions outside the user's country of residence.
By utilizing the Platform, users acknowledge and consent to the international transfer of information where permitted by applicable law.
Data Retention
iATM retains information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, satisfy regulatory requirements, support audits and investigations, resolve disputes, enforce contractual rights, protect Platform integrity, and maintain business records.
Retention periods may vary depending upon the nature of the information, the participant's relationship with the Platform, applicable legal requirements, regulatory obligations, and operational needs. Certain records may be retained for extended periods where required by law, compliance obligations, audit requirements, or risk-management considerations.
Information Security
iATM maintains administrative, technical, organizational, and physical safeguards designed to protect information from unauthorized access, disclosure, misuse, alteration, destruction, or loss. Security measures may include encryption, access controls, authentication procedures, network monitoring, vulnerability management, incident response protocols, vendor assessments, audit logging, and security training programs.
While iATM employs reasonable safeguards designed to protect information, no security measure or transmission method can guarantee absolute security. Users acknowledge that they provide information and utilize the Platform at their own risk.
User Rights and Data Requests
Subject to applicable law, users may have certain rights regarding their information, including the right to request access to information, correct inaccurate information, request deletion of information, restrict certain processing activities, object to certain processing activities, and request portability of information.
Certain requests may be limited or denied where retention or processing is necessary to comply with legal obligations, regulatory requirements, contractual commitments, fraud prevention measures, dispute-resolution requirements, security obligations, or other legitimate business interests.
Cookies and Similar Technologies
iATM may utilize cookies, session technologies, web beacons, analytics tools, and similar technologies to support Platform functionality, security, authentication, performance monitoring, user preferences, and operational analytics. These technologies assist in maintaining secure user sessions, improving Platform performance, understanding user interactions, and enhancing overall user experience.
Users may modify browser settings to manage cookie preferences; however, certain Platform functionality may be impaired if cookies are disabled.
Children's Privacy
The Platform is intended exclusively for individuals who are at least eighteen (18) years of age and legally capable of entering into binding agreements. iATM does not knowingly collect information from children. If iATM becomes aware that information relating to a child has been collected, reasonable steps may be taken to remove such information in accordance with applicable law.
Regulatory Compliance and Legal Disclosures
iATM may collect, process, retain, disclose, monitor, review, and report information where necessary to comply with applicable laws, regulations, sanctions programs, court orders, regulatory requests, government investigations, financial crime prevention obligations, anti-money laundering requirements, counter-terrorist financing obligations, tax reporting requirements, and other legal obligations.
The Company reserves the right to cooperate with law enforcement agencies, regulatory authorities, courts, governmental entities, and other authorized parties where required or permitted by law.
Changes to this Privacy Policy
iATM reserves the right to amend, modify, update, or replace this Privacy Policy at any time. Updated versions may be published through the Platform, website, user notifications, email communications, or other reasonable means. Continued access to or use of the Platform following publication of an updated Privacy Policy constitutes acceptance of the revised Privacy Policy.
Questions relating to this Privacy Policy, privacy practices, data protection matters, or compliance concerns may be directed to iATM through the contact information published on the Platform and official Company communications.