Interim privacy notice — under legal review

1. Who we are

ANKYROS is run by [the legal entity will be named here, with its registered address and registration number], which is the controller of the personal data described in this notice (“we”, “us”).

To contact us about your data, use Help & Support in the app or write to support@ankyros.com.

2. Our service, and our partners

ANKYROS is an app through which you apply for a euro account with its own IBAN, and then use it. The account, its IBAN and the safekeeping of your money are provided by one of our partners; which one depends on your account. Each partner is listed, with what it provides and how it holds your money, in the Partner schedule at the end of this notice. Before a partner’s account opens, you are asked to accept that partner’s own terms.

3. What this notice covers

This notice covers the ANKYROS app at ankyros.com, the Help & Support form and the e-mails we send. It also covers people whose details we receive from someone else: the owners and directors of a business that applies, the people our clients pay, and the people who send money to our clients.

4. What we collect, and where it comes from

When you create an account: your e-mail address and, if you choose one, your password. The password is stored only in hashed form, by our sign-in provider (Supabase).

When you apply, we ask for:

• your home address and phone number, and a proof of address (a document you upload);
• your country and city of birth and your nationalities;
• your tax residence and tax number, a national ID number if you have one, the tax number of any second tax residence and, if you are a US person, your Social Security number (SSN) or ITIN — these numbers are stored encrypted;
• your employment and occupation, where your money comes from, what you will use the account for and how much you expect to move each month;
• whether you are a politically exposed person, whether you are subject to sanctions and whether you act for someone else.

Your identity check. We ask Sumsub, our identity-verification provider, to check your identity on our behalf, and give it an internal reference for you and your e-mail address. On Sumsub’s own page, you photograph your ID document and take a selfie, and Sumsub checks that the selfie is of a real person in front of the camera (a “liveness” check). Sumsub then tells us the result and the details it verified: your name, your date and place of birth, your nationalities, your address, and the type, issuing country and expiry date of your document.

When the result is positive, we keep a copy of the images of your ID document, and of any proof of address or company document the check collected. We copy nothing else: your selfie stays with Sumsub. [Copies of selfies we made before this notice was published are still held; whether and when they are deleted will be stated here.] We do not store your document’s number: when we send your details to the partner that provides your account, we read it from Sumsub and pass it on.

Some applications use our older form instead of Sumsub’s check. On it, an individual types in their identity details and uploads their ID document and a selfie, and we keep what is uploaded. Every business application uses it today (see below); an individual’s application uses it only if it was started when Sumsub’s check was not available.

Files you upload are kept exactly as you made them: a photo still carries anything your phone stored in it, such as where and when it was taken.

If you apply for a business: we collect the company’s details and documents, and the personal details of its owners and directors — names, dates and places of birth, nationalities, addresses, e-mail addresses, phone numbers, ownership and roles, tax numbers (stored encrypted) and an ID document for each of them. If you give us someone else’s details, please show them this notice.

When you use your account: your IBAN and balance; the payments you send and receive; the details of the people you pay (name, IBAN, BIC, bank, country and address); and, for money you receive, the sender’s name and the payment’s details as the partner that holds your account reports them to us.

When you use the app: records of your sign-ins (our sign-in provider keeps your IP address and your browser’s description with each session), your two-factor settings if you set them up, and records of what you did in the app that matter for security and compliance — for example, that you accepted a partner’s terms.

When you write to Help & Support: your name, e-mail address and message, and the IP address it came from — whether or not you have an account. We use the IP address to limit how many messages can be sent in an hour.

5. Why we use your data

• to open and run your account, and to make your payments;
• to check your identity and where your money comes from, and to keep records of those checks (anti-money-laundering checks);
• to send your details to the partner that provides your account, so that it can open and hold it;
• to hold a payment for a check, or to set a risk level on your account, to prevent fraud and financial crime;
• to keep your account and our systems secure;
• to answer your messages.

[The legal basis for each of these uses — including the selfie and liveness check — will be stated here after legal review.]

We do not use your data for advertising, we use no analytics or tracking tools, and we do not sell your data.

6. Decisions made automatically

When your application is complete, it may be approved automatically if nothing in it needs a closer look; otherwise a person on our team reviews it. We never refuse an application automatically: a person on our team makes that decision. If Sumsub asks for a new attempt at your identity check, we ask you to go through the check again.

A payment may be held automatically for a check — for example because of its size or of other recent payments — and a person on our team then reviews it.

[How the law on automated decisions applies will be stated here after legal review.]

7. Who receives your data

Our banking and payment partners: the partner that provides your account receives the details it needs to open and run it — from your application, your identity check and your documents — and the details of your payments and of the people you pay. It uses them under its own terms and privacy notice. What each partner receives, and where it is based, is in its entry in the Partner schedule at the end of this notice.

Our identity-verification provider, Sumsub, which checks your identity on our behalf. We give it an internal reference and your e-mail address; it collects the photos of your ID document and your selfie directly, on its own page. [Sumsub’s company name and country will be stated here.]

Our database and hosting providers:

• Supabase, which runs our database, our sign-in and our file storage: the data we keep about you is stored there. Our Supabase project is hosted in Ireland.
• Vercel, which hosts the app: everything you send to the app and everything it shows you passes through Vercel. Our app’s servers run in Dublin, Ireland.

Our e-mail provider, Resend, which sends our e-mails: your e-mail address and the content of each e-mail we send you — sign-in codes, payment codes (with the amount and the payee’s name), and notices about your application and the security of your account. When you submit an application, Resend also carries an alert with your name, e-mail address and reference to our operations mailbox.

[The provider of our e-mail mailboxes will be named here]: the e-mails you send us, our replies to your messages (which quote what you wrote), and the alert about a new application.

Public authorities, such as courts or the police, when the law requires us to give them data.

8. Transfers outside the European Economic Area

Our database and our app’s servers are in Ireland. Some of your data is processed outside the European Economic Area (EEA):

• a partner based outside the EEA receives there the data its entry in the Partner schedule lists;
• Vercel’s network may first receive your connection at a location near you — outside the EEA if you are;
• Supabase, Vercel and Resend are companies based in the United States; they, and the companies they work with, may handle data from outside the EEA. Where Resend sends our e-mails from is not confirmed yet;
• Where Sumsub processes your data is not confirmed yet.

[The safeguards for each transfer, and how you can get a copy of them, will be stated here after legal review.]

9. How long we keep your data

We have not yet set how long we keep each kind of data [the periods will be stated here after legal review]. Today, nothing is deleted because of its age: we keep your data while your account exists — including an application you never finished, and an account whose e-mail address was never confirmed.

If your account is deleted, these are kept:

• a record that the account was deleted, with your name and e-mail address;
• the messages you sent to Help & Support;
• the records our partners sent us about your payments;
• the copies of identity documents in our storage — those made after your identity check, and the documents you sent in answer to a partner’s request — until they are removed in a separate clean-up;
• e-mails in our mailboxes: the alert about your application, and our correspondence with you;
• a copy of your record that a member of our team downloaded to their computer, if one was made;
• technical records that refer to you by an internal reference: our error log, and Sumsub’s notifications about your check;
• what Sumsub and our partners hold, under their own rules, and the logs that Supabase, Vercel and Resend keep, under theirs.

You cannot delete your account in the app. Our team can delete it, but not while you have an account at one of our partners, money in your account or a payment in progress.

10. Your rights, and how to use them today

You can ask us for a copy of your data, ask us to correct or delete it, ask us to restrict or stop using it, or ask for it in a form you can take elsewhere, and you can withdraw any consent you have given. [Which of these rights applies to each use of your data, and its limits, will be stated here after legal review.]

To use them, write to us through Help & Support in the app or at support@ankyros.com. We may need to confirm who you are before we answer.

What you can already do in the app:

• see your name, customer reference, e-mail address, phone number, address and account details (Settings, then Profile);
• see your payments, and download an account statement as a PDF;
• see, add and delete the people you pay;
• change your answers while your application is a draft, or after we have asked you for more information;
• change your password.

What needs a request to us: a full copy of your data; a correction after you have submitted your application (your profile cannot be edited in the app); deleting your account.

11. Cookies and storage on your device

Browsing the site sets no cookies. We use only the cookies that sign you in. When you ask us to e-mail you a sign-up or sign-in code, one is set (its name ends with “-auth-token-code-verifier”) so that the link in that e-mail can complete your sign-in. Once you are signed in, another holds your session (its name starts with “sb-” and ends with “-auth-token”, and it may be split into parts ending “.0”, “.1” and so on). The page’s scripts cannot read them, and each expires 24 hours after it was last set — the session’s each time it is refreshed.

If you set a quick-unlock PIN, your device stores it in hashed form, together with your name so that we can greet you. Your device also remembers whether you closed two of our reminders. We use no analytics, advertising or tracking cookies.

12. How we protect your data

Connections to the app are encrypted (HTTPS). Tax and ID numbers are stored encrypted. Documents are kept in private storage. In our admin console, staff open a document through a link that expires after 60 seconds, or download an applicant’s record — the uploaded documents and the tax and ID numbers, decrypted — as a file to their computer; every opening, every reveal of a tax or ID number and every download is recorded. You can add an authenticator app to your sign-in.

13. Age

You must be 18 or over to open an account.

14. Complaints

If you are unhappy with how we handle your data, please tell us first, through Help & Support or at support@ankyros.com. You can also complain to a data-protection authority, in particular in the country where you live or work. [Our lead data-protection authority will be named here.]

15. Changes to this notice

This notice is interim. When it changes, the new version will be published on this page with its date.

16. Partner schedule

The partners that can provide your account, one entry each; each entry describes the partner’s live service. Before your account opens, the app tells you which partner will provide it and asks you to accept that partner’s own terms.

Bridge

• What it provides: It opens your account, gives you its IBAN and holds your money; the euro transfers you receive and send go through it.
• How it holds your money: Your money is held as EURC, not as a deposit with a bank. EURC is a euro stablecoin; Bridge keeps it for you in a wallet on the Solana blockchain. Money you receive at your IBAN is converted into EURC in that wallet, and a payment you send leaves it as a euro transfer (SEPA). The wallet’s movements are recorded on a public ledger under the wallet’s address, not under your name, and cannot be deleted from it. [What this means for the protection of your money will be set out here.]
• Its terms: Before your account at Bridge opens, you accept Bridge’s own terms and privacy notice, on Bridge’s page or in the app. [The links to them will be given here.]
• What we send it: Your name, e-mail address, phone number, date and place of birth, nationalities and address; your tax numbers; your document’s type, number and images; your proof of address; your answers about your employment, where your money comes from, what the account is for, how much you expect to move each month and whether you act for someone else; and the details of your payments and of the people you pay. For a business, also the company’s details and documents, and its owners’ and directors’ details and ID documents.
• Where it is based: In the United States.
• Its own privacy notice: Bridge uses your data under its own terms and privacy notice. It works with its own partners, among them the bank named in your account details. [Bridge’s partners will be named here.]