Policy

Privacy Policy

Introduction


Silicon Silk LTD ("we," "us," or "our") is authorized by the UK Financial Conduct Authority (FCA) as an Electronic Money Institution (EMI). We are committed to safeguarding your privacy and ensuring complete transparency regarding how we collect, use, store, and share your personal data through our mobile application Silink (the "App") and related services. By using our App, you consent to the practices described in this Privacy Policy.


1. Information We Collect


We may collect and process the following categories of information:


1.1 Personal Information

  • Identification data and contacts (e.g. name, numbers and expiration dates of civil identification documents, tax);
  • Contact details (e.g. address, phone number, email address);
  • Biographical data (e.g. date of birth, gender, nationality, place of birth, marital status, information on the household, academic qualifications, or data on the profession (name of employer, type of contract, remuneration);
  • Contractual data (e.g. account number, IBAN);
  • Transaction Data (e.g. date, time, description and value of banking operations, as example, deposits, withdrawals, transfers, payments);
  • Credit and solvency data (e.g. bank account details, value of your assets, tax details);
  • Biometric data (e.g. fingerprint);
  • Voice and image recording data (e.g. phone call, video call and photo recordings);


1.2 Financial Information

  • Bank account details and payment card information
  • Transaction data, including payment amounts, dates, and recipient information
  • Wallet addresses and related cryptocurrency transaction data (if applicable), All services related to cryptocurrency and crypto assets will be provided exclusively by licensed third-party institutions.


1.3 Device and Technical Information

  • Device type, operating system, and unique device identifiers
  • IP address and mobile network information
  • App usage data, including feature interactions, error logs, and session durations


1.4 Location Information

  • Precise Location: Collected only with your explicit consent to enable location-based services and compliance checks.
  • Approximate Location: Derived from device settings and used to improve services and for regulatory compliance.


1.5 Sensitive Permissions


We may request access to sensitive device features to deliver specific services. These include:

  • Camera: For identity verification and document uploads
  • Microphone: For in-app voice support or user interaction
  • Location: For geographical verification and localized functionalities


Permissions will only be used for the stated purposes and require your explicit consent.


2. How We Use Your Information


We process your information for the following purposes:


2.1 To Provide Services

  • Create and manage user accounts
  • Facilitate payments, transfers, and financial transactions
  • Verify identity and comply with regulatory obligations


2.2 To Enhance Functionality

  • Analyze usage data to optimize App features and improve performance
  • Personalize user experiences based on preferences and behavior


2.3 To Communicate

  • Send updates, notifications, and transaction confirmations
  • Respond to customer support inquiries and feedback


2.4 To Ensure Compliance

  • Detect and prevent fraud, money laundering, and prohibited activities
  • Meet legal and regulatory obligations, including reporting requirements


3. Data Sharing and Third-Party Services


We do not sell your personal information. However, we may share your data under the following conditions:


3.1 With Service Providers


We collaborate with trusted third parties to deliver services such as:

  • Payment processors and banking partners
  • Cloud storage and IT infrastructure providers
  • Identity verification and fraud prevention services


These providers are contractually obligated to protect your data and use it solely for service delivery.


3.2 With Regulatory Authorities


We may disclose your data to regulatory bodies, such as the FCA or HMRC, when required by law.


3.3 With Third-Party Tools and Analytics


We use third-party analytics tools (e.g., Google Analytics) to monitor App performance and improve services.


These tools may collect data such as usage patterns and device identifiers. Refer to their privacy policies for details:

  • Google Analytics Privacy Policy: https://policies.google.com/privacy
  • Bison Bank Privacy Policy: https://bisonbank.com/privacy-policy/


3.4 During Business Transactions


In the event of a merger, acquisition, or sale, your data may be transferred as part of the business assets.


3.5 With Your Explicit Consent


Your data will only be shared for additional purposes if you have given explicit consent.


4. Cookies Policy


We use cookies and similar technologies to collect information about your interactions with our App. These help us:

  • Enhance functionality and user experience
  • Analyze usage patterns and improve performance
  • Deliver targeted advertisements and promotions


4.1 What are cookies?


Cookies are small text files with relevant information that are downloaded onto the user’s access device (computer, mobile phone/smartphone, or tablet) through the browser when a website is visited by the user.


The use of cookies not only enables the website to recognize the user’s device the next time he/she visits it, but also improves the operation and experience of this website.


The cookies used by the Entities on their websites do not collect personal information that could identify the user. They only process and keep general information, namely the form or place of origin of the users’ access and the way that they use the websites, among other aspects.


The cookies only keep demographic data and information related to the users’ preferences.


The users may, at any time, through their browser, decide to be notified of the reception of cookies, and may block their entry into their system. However, it should be highlighted that rejection of the use of cookies on the websites could result in precluding access to some of their areas and not permitting the entire browsing experience on the websites.


4.2 What are cookies used for?


Cookies are used to help determine the usefulness, interest and number of uses of websites, enabling faster and more efficient browsing, and eliminating the need to repeatedly enter the same information.


4.3 What type of cookies do we use?


Each cookie used has a function and an expiry date. Regarding function, the cookies used may be:

  • Essential cookies – Some cookies are essential to access specific areas of the Entities’ websites. These enable browsing website and using their applications, such as access to secure areas of the websites through login. Without these cookies, the services requiring them cannot be made available.
  • Functional cookies – These cookies enable remembering the user’s preferences relative to browsing on the website. Accordingly, the users do not need to reset and personalize it each time they visit it.
  • Analytical cookies – These cookies are used to analyze the way that the Entities websites are used, enabling the highlighting of articles or services that could be of interest to the users, the monitoring of the websites performance, and knowledge of which are the most popular pages, what is the most effective method of links between pages or to determine the reason why some pages are receiving error messages. These cookies are used for purposes of creation and statistical analysis only, and never collect information of personal nature. This means that we can provide a high-quality experience by personalizing its offer and rapidly identify and correct any problems that may arise.


Regarding expiry date, the cookies used may be:

  • Permanent cookies – These are stored on the user’s access devices (computer, mobile phone/smartphone, or tablet), at browser level, and are used whenever the user returns to the Entities websites. They are used to direct the browsing according to the user’s interests, enabling us to provide a more personalized service.
  • Session cookies – These are temporary cookies available until the session is closed. Next time the users access their browser, these cookies will no longer be stored. The information obtained by these cookies enables managing the sessions, identifying problems and providing a better browsing experience.


4.4 Blocking the use of cookies


All browsers enable the user to accept, refuse or delete cookies. This can be done by selecting the appropriate definitions in the browser. Users are thus allowed to partially or completely deactivate the cookies used on Entities’ websites at any given time. For further information, see the instructions and manuals of the actual browser.


Nevertheless, we inform that by deactivating the cookies on their websites they might not function properly.


5. Data Retention


We retain your data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, and resolve disputes.


5.1 Retention Periods


  • Personal and financial data: Retained for a minimum of six years to comply with anti-money laundering (AML) regulations.
  • Device and technical data: Retained for up to three years to improve services and ensure compatibility.
  • Communication records: Retained for two years to respond to inquiries and resolve issues.


5.2 Deletion of Data


Upon meeting legal and regulatory requirements, we will securely delete or anonymize your data. You may request data deletion through our support team, subject to applicable legal obligations.


6. Security Measures


We implement robust security measures to protect your data from unauthorized access, alteration, disclosure, or destruction.


6.1 Data Protection Methods


  • Encryption: Sensitive data is encrypted in transit and at rest.
  • Access Controls: Role-based access restrictions ensure only authorized personnel can access your data.
  • Monitoring: Routine security audits and monitoring for potential vulnerabilities.


6.2 Incident Response


In the event of a data breach, we will notify affected users and regulatory authorities as required by law.


7. Sensitive Permissions and Transparency


We are committed to transparency regarding sensitive permissions:

  • Location Data: Used for geographical compliance and enhanced user experiences.
  • Camera Access: Used solely for document verification purposes.
  • Microphone Access: Enabled for specific features such as voice-based support.

All sensitive permissions are subject to your explicit consent and can be managed through your device settings.


8. Updates to This Privacy Policy


We may update this Privacy Policy to reflect changes in our practices, technologies, or legal requirements. Changes will be communicated through the "Effective Date" and significant updates may be sent via the App or email.


9. Contact Us


For privacy-related inquiries or to exercise your rights, please contact us:

Silicon Silk LTD

  • Email: contact@siliconsilk.com
  • Address: 128 City Road, London, UK


10. Governing Law


This Privacy Policy is governed by the laws of England and Wales. Any disputes will be subject to the exclusive jurisdiction of the courts of England and Wales.

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