Privacy Policy

Last updated: June 2025

1. Introduction

Unless otherwise defined in this Privacy Policy, all capitalized terms shall have the meaning assigned to them in the Terms and Conditions. In the event of any inconsistency between this Privacy Policy and the Terms and Conditions, the latter shall prevail to the extent permitted by applicable law.

The Website and the Platform are owned and operated by Destrier LLC, (hereinafter “Company”, “we”, “us” and “our”). We are committed to protecting our Users’ (hereinafter “You” or “Users”) personal data by respecting and complying with the applicable data protection and privacy laws. In this Policy, we provide you with transparent information on how we collect and process your personal data when you visit and use the Website, the Platform and their Services. We encourage you to carefully read this Privacy Policy, which we have written in a clear and comprehensible manner to facilitate its understanding.

2. Who we are – Data Controller

The Website and the Platform belong to Destrier LLC, a company registered in US, 1942 Broadway St., Boulder, CO 80302.

Company is the Data Controller within the meaning of the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

You can contact us:

  1. by post, to 1942 Broadway St., Boulder, CO 80302
  2. by telephone, at [number not provided]
  3. by email, using info@destrier.us

3. Email Marketing

If you subscribe to our newsletter, we may occasionally communicate project news, updates, promotions and related information relating to Nickelium or our Company and Services. We shall only do this where you have given us your consent. If you want to opt out of receiving promotional and marketing emails, you can best opt out by clicking “unsubscribe” at the bottom of an email we sent you.

4. Personal Data We Collect

We obtain various types of personal information in several ways, as described under the categories of Personal Information set out below.

Personal Data we collect directly from you

When you access our Platform or use our Services through one of our partners (e.g. your crypto-wallet), we collect a variety of information from you, including (as applicable and in accordance with applicable laws) the following:

  1. Basic User and Contact Information: such as email address.
  2. User Information: This includes your username, password, and data generated by your activity on the Website and the Platform, including but not limited to purchases, redemptions, withdrawals, modifications to your Orders, or any information related to the Orders you place on the Platform.
  3. Transactional Information: This includes information about the transactions made on our Services, including your Wallet’s address and the recipient’s Wallet address, the number of tokens, currency preferences, date, and timestamp.
  4. Additional Information you submit to us: This includes your preferences and other settings, votes, comments, and any other information submitted to our customer support team or when you communicate with Us.

Personal Data we collect automatically or indirectly from you

  1. Technical Data: This includes App, Browser, Network, and Device Information including information about the type of device and operating system you are using, your IP address, login data, browser type and version, time zone setting, operating system and platform, location data etc.
  2. Information from Cookies and Similar Technologies: Please see our Cookie Policy for more information.
  3. Services Usage Information: This includes technical data on your use of our Website and Platform, which helps measure and monitor their performance, detect crashes, and record timestamp data.
  4. Location Information.

Personal Data we collect from our affiliates, partners, service providers

  1. Partners: This includes information from crypto wallet service providers e.g. Metamask, and other partners, which provide us with information needed to provide our Services and for compliance and fraud prevention purposes, such as transactional information to fulfill Orders and transfers of Digital Assets.
  2. Service Providers and Other Vendors: This includes information we collect from vendors that assist us and our Partners with providing and marketing our Services or with user identity verification, anti-fraud, anti-money laundering, and know-your-customer obligations.
  3. Blockchains: This includes transactional information such as IDs, timestamps, and amounts, digital signatures, wallet addresses etc. in connection with our Services.

5. Accuracy of Personal Data

It is important that the personal data we hold about you is accurate and current. If you need to add or change any information, please keep us informed.

6. How We Use Personal Data

We use your personal information for the purposes identified in the table set out below, indicatively.

Processing PurposePersonal Information CategoriesLegal Basis (Where Applicable)
To provide and administer our Platform and Services, fulfill transactions, and process OrdersUser Information, Transactional Information, Services Usage Information, Technical DataThe legal basis for the processing is the performance of the contract (article 6 (1) (b) GDPR) and compliance with legal obligations (article 6 (1) (c) GDPR)
To maintain our Website and Platform, improve our Services, evaluate and improve our service qualityTransactional Information, Technical Data, Services Usage InformationThe legal basis for this processing is the legitimate interest pursued by Company (Article 6 (1) (f) GDPR)
For audit and record-keeping purposesUser Information, Transactional Information, Services Usage InformationThe legal basis for this processing is the legitimate interest pursued by Company (Article 6 (1) (f) GDPR), and Compliance with legal obligations (article 6 (1) (c) GDPR)
To send you marketing communications and advertising in accordance with applicable lawBasic User and Contact Information, Technical Data, Information from Cookies and Similar Technologies, Location InformationIn this case, the legal basis for the processing is the consent (article 6 (1) (a) GDPR)
To comply with applicable laws, regulations, and rules, such as anti-money laundering (“AML”) and know-your-customer (“KYC”) lawsBasic User and Contact Information, Transactional Information, Services Usage Information, Technical Data, Information from Cookies and Similar Technologies, Location InformationThe legal basis for the processing is the legitimate interest pursued by Company (Article 6 (1) (f) GDPR) or Compliance with legal obligations (article 6 (1) (c) GDPR)
To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activityTransactional Information, Services Usage Information, Technical Data, Information from Cookies and Similar Technologies, Location InformationThe legal basis for this processing is the Legitimate interest pursued by Company (Article 6 (1) (f) GDPR or Compliance with legal obligations (article 6 (1) (c) GDPR)
To enforce our Terms and Conditions and other usage policiesTransactional Information, Services Usage Information, Technical Data, Information from Cookies and Similar Technologies, Location InformationThe legal basis for this processing is the performance of the contract (article 6 (1) (b) GDPR) and the legitimate interest pursued by Company (Article 6 (1) (f) GDPR)

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

7. Change of Purpose

We will only use your personal data in accordance with the purposes described in this Privacy Policy and as provided for under applicable law for the purposes for which we collected it. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact Us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

8. If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (i.e. to provide the Services to you).

9. How We Share and Recipients of Personal Data

In the regular course of business, we may share your personal information for the business and commercial purposes mentioned above with the following parties:

  1. Affiliates: Other companies within our group of companies as reasonably necessary for the purposes set out in this Policy.
  2. Third-Party Service Providers: Vendors who may need access to personal data to provide services on our behalf.
  3. Authorized Employees: Employees who have access to personal data only when necessary to perform their duties.
  4. Public or Independent Authorities: Entities such as the Public Prosecutor’s Office, Cybercrime Division, Data Protection Authority (DPA), etc.
  5. Third-Party Partners Setting Cookies: Some cookies are placed by third-party service providers.

We may also share your personal information with the following parties in specific contexts:

  • Blockchain-based Services: When you engage in blockchain-based services, some information may be recorded publicly on a distributed ledger.
  • Law Enforcement and Regulatory Authorities on various jurisdictions: Including tax authorities, fraud prevention agencies, debt collection agencies, self-regulatory organizations, and other relevant bodies.
  • Corporate Transactions: In the context of a corporate transaction or restructuring, such as a merger, acquisition, or sale.

10. Retention of Personal Data

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, as well as for any compatible purposes. Additionally, we retain data to comply with applicable laws, regulations, and requests from law enforcement or other governmental authorities.

Account Deletion. If you request account deletion, we will erase all associated information unless:

  1. Retention is required to comply with legal obligations or to maintain evidence of compliance;
  2. A dispute or claim is pending, in which case relevant information is retained until resolution;
  3. Retention is necessary for legitimate business interests, such as fraud prevention and Website security.

11. Protection of your Personal Data

We implement commercially reasonable physical, technical, and organizational safeguards to enhance the security of our systems and ensure the confidentiality, integrity, availability, and resilience of personal data, in compliance with applicable data protection laws.

12. International Transfers

In order to support our business, your personal information may be transferred worldwide. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy.

13. Your Rights Regarding Personal Data

13.1. Right to Access

You have the right to request information about the personal data we process about you.

13.2. Right to Rectification

You have the right to request the correction of any inaccurate or incomplete personal data we hold about you.

13.3. Right to Erasure (Right to Be Forgotten)

You can request the deletion of your personal data when certain conditions apply.

13.4. Right to Restriction of Processing

You can request a limitation on the processing of your personal data under certain conditions.

13.5. Right to Object

You can object to the processing of your personal data at any time, based on your particular situation.

13.6. Right to Withdraw Consent

If you have given consent for us to process your personal data, you have the right to withdraw that consent at any time.

13.7. Right to Data Portability

If we process your data based on consent or contract, you can request the transfer of your personal data to you or a third party in a machine-readable format.

You can exercise these rights by contacting us via email at info@destrier.us.

14. Automated Processes of your personal data

Certain usages of the Platform involve automated processing of your data for various reasons, mostly in order for us to comply with our legal obligations.

15. Third-party applications

We may collect information via third-party applications (“Applications”) that Users download and operate on their devices.

16. For Customers Residing in California

This Section provides information to California residents whose personal information is processed pursuant to the California Consumer Privacy Act.

17. Cookies and Do Not Track (DNT)

We use analytics systems and providers that process personal information about your online activities over time and across third-party websites or online services.

19. Changes to this Privacy Policy

We may, at our discretion, modify, update, or change this Privacy Policy at any time.

20. Contact Us

If you have any questions or concerns about this Privacy Policy and/or how we process personal information, please contact us via e-mail at info@destrier.us.