> For the complete documentation index, see [llms.txt](https://pleasing.gitbook.io/docs/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://pleasing.gitbook.io/docs/legal/privacy-policy.md). # Privacy Policy **Entity:** Pleasing International Limited (“**Pleasing Market**”, “**we**”, “**us**”, “**our**”)\ **Scope:** Websites, apps, dashboards, APIs, support channels, and tokenization/redemption services (collectively, the “**Services**”). By accessing or using the Services, you **consent** to this Privacy Policy and represent that you have authority to provide personal data of any related individuals (“**Relevant Persons**”). We may update this Policy by posting a revised version on our site/app; continued use signifies acceptance. *** ### 1. Introduction This Privacy Policy explains how we **collect**, **use**, **disclose**, **transfer**, and **secure** personal data when you interact with Pleasing Market's Services and products (including PGOLD and related portals). If you do not agree, please discontinue use. *** ### 2. Personal Data We Collect We collect personal data from you and Relevant Persons during onboarding, ongoing use, and compliance processes. **Individual users (illustrative):** * Identity: full legal name (incl. former/alias), DOB, place of birth, nationality, gender * Government ID: type/number (e.g., passport), copies as required by law * Contact: residential address, phone, email * Financial/Source Data: source of funds/wealth, activity levels, purpose of account, bank details * Blockchain Data: wallet addresses, transaction hashes * Usage Data: device/telemetry, logs, cookies, analytics **Corporate users (illustrative):** * Entity: legal & trading names, jurisdiction, registration/incorporation details * Representatives: directors, officers, UBOs/controlling persons, authorized signatories (incl. IDs) * Business & Financial: nature of business, asset information, expected activity * Contact & Operations: emails/phones, billing, integration details **Other sources:** * KYC/KYB vendors, sanctions/PEP screening providers, blockchain analytics * Public/company registries, risk databases, credit/reference agencies * Event sign-ups, surveys, support communications, referral programs We may request **additional documentation** as required by compliance and risk policies. *** ### 3. How We Use Personal Data We process personal data to: * **Provide & improve Services:** account creation, onboarding, tokenization, redemption, support, feature delivery * **Compliance:** KYC/KYB, AML/CTF, sanctions/PEP checks, PoR-related attestations, fraud monitoring, audit logs * **Risk & Operations:** transaction monitoring, security, incident response, product analytics, billing/collections * **Communications:** service notices (e.g., policy updates, security alerts), event/program information * **Marketing (with consent or legitimate interest, where allowed):** product updates, newsletters, offers * **Legal & Governance:** dispute handling, regulatory reporting, enforcing terms, corporate transactions * **Purpose disclosed at collection:** any additional purpose we notify and/or for which we obtain consent *** ### 4. Sharing Your Personal Data We may share data with: * **Service providers/processors:** hosting, cloud, KYC/KYB, sanctions & blockchain analytics, email/SMS, payments, storage, support * **Affiliates:** entities under common control for compliant processing * **Professional advisors:** legal, tax, audit, insurance * **Regulators/law enforcement:** where required by law, court order, or lawful request * **Transaction counterparties:** in mergers, acquisitions, financing, or asset transfers (subject to confidentiality) * **Aggregated/Anonymized** outputs for analytics and transparency that do not identify you We do **not** sell personal data. *** ### 5. International Data Transfers Your data may be processed in countries outside your jurisdiction (e.g., Hong Kong SAR, \[add locations of key vendors]). We implement appropriate **transfer safeguards** (e.g., SCCs/IDTA, vendor due diligence, contractual protections) and require comparable security from our processors. *** ### 6. Data Storage & Security We use technical and organizational measures to protect data, including **encryption in transit**, access controls, network segmentation, monitoring, and least-privilege administration. No system is 100% secure; please safeguard your credentials and private keys. *** ### 7. Data Retention We retain data **only as long as necessary** for the purposes described and to meet legal, tax, accounting, AML/CTF, and regulatory requirements (which may require retention for **5–10+ years**, depending on jurisdiction). We then delete or anonymize data. *** ### 8. Legal Bases (GDPR/UK GDPR) Where GDPR/UK GDPR applies, we rely on: * **Contract necessity** (to provide Services) * **Legal obligations** (e.g., AML/CTF, sanctions, tax) * **Legitimate interests** (security, fraud prevention, product improvement, business operations), balanced against your rights * **Consent** (marketing, certain cookies/analytics, where required). You may withdraw consent at any time. *** ### 9. Your Rights Depending on your location, you may have rights to **access**, **rectify**, **erase**, **restrict**, **object**, **port**, and **withdraw consent**. You may also have the right to lodge a complaint with your supervisory authority. We will verify identity before fulfilling requests and may deny/limit requests as permitted by law (e.g., where retention is legally required). Requests: **** (subject: “DATA REQUEST”). *** ### 10. Marketing Communications With your **opt-in** (or where permitted by law), we may send marketing about products, features, events, and ecosystem updates. You can **unsubscribe** via the link in each message or by emailing ****.\ **Transactional/Service** notices (e.g., KYC, receipts, security) will continue where permitted. *** ### 11. Cookies & Similar Technologies We use cookies and similar technologies for authentication, preferences, analytics, fraud prevention, and performance. * Manage cookies via your browser or our **Cookie Preferences** center. * Some features may not function without certain cookies. * We currently do **not** respond to “Do Not Track” signals. See our **Cookie Policy** for details. *** ### 12. Links to Third-Party Sites/Protocols Our Services may link to third-party sites, wallets, dApps, or protocols. We do not control these and are **not responsible** for their privacy practices. Review their policies before use. *** ### 13. Children’s Privacy Our Services are **not** intended for individuals under **18**. We do not knowingly collect data from minors. If you believe a minor has provided data, contact **** and we will take appropriate action. *** ### 14. User Interactions You are solely responsible for interactions with other users/protocols. We may (but are not obligated to) monitor disputes for abuse, fraud, or security. *** ### 15. Contact Us **Email (privacy & general support):** To withdraw consent, update data, or exercise rights, email **** with subject **“DATA REQUEST.”** We may charge a reasonable fee where requests are excessive or repetitive, as permitted by law. *** ### 16. Language If this Policy is translated, the **English version controls** in case of conflict.