Hash Cayman Ltd (“Hash”, “we” “us” or “our”) is committed to responsibly collecting, handling, and protecting the information you provide, or we collect through our operations and website.
This Privacy Policy explains:
The types of personal data we collect
How and why we collect, use, and potentially share your data
Our lawful basis for processing under the Cayman Islands Data Protection Act (2021 Revision) (“DPA”)
Security measures we apply
Our data retention practices
Your rights regarding your data
How to contact us about privacy matters
How to lodge a complaint if needed
Hash acts as the data controller under the DPA. Please ensure that relevant individuals are informed about this Privacy Policy before providing their personal data or having their data processed by us.
Identification documentation (e.g., passport, utility bills, source of wealth)
Contact information (e.g., address, email, phone numbers)
Submitted content such as inquiries, feedback, or other communications
Financial and transactional data, including account numbers and interaction history
Dispute or complaint data
Publicly available or legally sourced information
Compliance-related information for fraud detection or anti-money laundering
Third-party risk or verification data
We may collect:
HOW WE OBTAIN YOUR PERSONAL INFORMATION
We collect data through client onboarding processes, directly from you (via forms, communications), or from authorized representatives.
We may update or verify information using publicly available or trusted third-party sources.
HOW WE WILL USE PERSONAL DATA
Communicating with you
Fulfilling contractual and service obligations
Providing updates or information about our services
Improving our services, content, and website
Displaying website content tailored to your device
Verifying identities per legal requirements
Maintaining website security and fraud prevention
Supporting dispute resolution or regulatory compliance
Purposes include:
To fulfill contractual obligations
To comply with legal/regulatory obligations under the DPA
To serve our legitimate interests that do not override your rights
To protect your or others’ vital interests
In limited public-interest or official duty cases
We only process data when legally permissible under these lawful bases:
INFORMATION ABOUT THE WEBSITE
We may collect anonymized device data such as IP address, operating system, browser type, and browsing actions for system administration and analytics.
This does not identify individuals.
WHO WE MIGHT SHARE YOUR PERSONAL DATA WITH
Service providers (IT, AML tools, system support)
Professional advisors/joint controllers (legal, compliance, accounting)
Financial institutions for payments
Website hosting and security providers
Parties involved in corporate transactions
Regulators, law enforcement, or courts as required by law
Fraud prevention or identity verification agencies
Your authorized representatives
Others you instruct us to share data with
Insurers providing coverage related to our services
We may also share aggregated, anonymized data for analytics or research purposes.
We only share personal data when lawful and necessary. This may include:
RETENTION OF PERSONAL DATA
We retain personal data only as long as necessary for specific purposes or as legally required—typically for a minimum of 5 years post-contract, though longer retention may apply.
Data no longer required is securely deleted, destroyed, or returned.
When shared with third parties, their retention policies apply.
INTERNATIONAL TRANSFERS OF PERSONAL DATA
When transferring data outside the Cayman Islands, we ensure compliance with the DPA by implementing safeguards such as secure agreements.
Transfers may occur for contractual service delivery, legal duties, cloud backups, public interest, or legitimate interests.
If a jurisdiction compels disclosure, we only share data with authorized parties and within permitted scope.
INDIVIDUALS’ RIGHTS
Be informed about data processing
Access your data and its sources
Rectify inaccurate or incomplete personal data
Request erasure, subject to legal exceptions
Object to or restrict processing in some cases
Be informed of decisions based solely on automated processing
You may complain to the Office of the Ombudsman or seek redress in Cayman Islands courts.
Under the DPA, you have the right to:
⦁ MISCELLANEOUS
Please ensure the data you provide is accurate and up to date. Notify us of changes promptly.
We implement security measures including encryption and strict access controls.
This Privacy Policy is governed by the laws of the Cayman Islands, and any disputes fall under its courts’ jurisdiction.
⦁ CONTACT US
For questions, privacy-related requests, or complaints, please contact: