Effective date: 7 September 2026
Version: 3.1
This Privacy Policy (the "
Policy") explains how
AMCH LTD collects, uses, discloses and protects your personal data when you use the websites
https://www.amcapital.app and
https://amch.ltd (together, the "
Marketplace").
We are committed to protecting your privacy and to processing your personal data in strict accordance with the EU General Data Protection Regulation 2016/679 (GDPR), the Cyprus Law providing for the Protection of Natural Persons with regard to the Processing of Personal Data (Law 125(I)/2018) and the Anti-Money Laundering Directives (AMLD).
1. Data Controller informationThe controller of your personal data, determining the purposes and means of its processing, is:
•
Name: AMCH LTD (the "Company", the "Marketplace", "we", "us", "our")
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Registered address: Michalakopoulou, 27, CITY BUSINESS CENTRE, 1075, Nicosia, Cyprus
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Contact email address: info@amch.ltd
If you have any questions about this Policy or about how we process your data in connection with the Marketplace, you may contact our data protection officer at info@amch.ltd.
2. Categories of personal data we collectWe may collect, use, store and transfer various kinds of personal data, which we have grouped as follows:
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Identity Data: first name, last name, date of birth, gender, identity document details (passport, ID card), biometric data (selfies/photographs for facial verification).
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Contact Data: email address, telephone number, registered and actual residential address, postcode.
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Financial & Transaction Data: your transaction history on the Marketplace, cryptocurrency wallet addresses, details of the payment methods you use (we do not store full bank card details; these are processed by PCI-DSS certified gateways).
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Technical Data: IP address, login data, browser type and version, time zone setting and geolocation, browser plug-in types and versions, operating system and other technology on the devices you use to access the Marketplace.
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Usage Data: information about how you use our Marketplace, which pages or offers you visit, page response times, download errors and length of visit.
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Marketing & Communications Data: your preferences in receiving marketing materials from us and your chosen communication preferences.
3. How we collect your dataWe use different methods to collect data from and about you, including:
1.
Direct interactions: you provide us with your Identity and Contact Data by filling in forms on the website, registering an Account or communicating with our Marketplace support team.
2.
Automated technologies: as you interact with our Marketplace, we automatically collect Technical Data and Usage Data through cookies, server logs and similar technologies.
3.
Third parties and publicly available sources: we may receive data about you from third parties (for example, verification results from our KYC/AML providers, analytics data from search engines, or data from public blockchain networks used to verify transactions).
4. Purposes and lawful bases for processingUnder the GDPR, we may only process your personal data where we have a lawful basis for doing so. Set out below are all the ways in which we use your personal data and the lawful bases we rely on:
Purpose / Activity | Type of data | Lawful basis for processing |
Registering you as a Marketplace user and creating an Account | Identity, Contact | Performance of a contract with you |
Carrying out KYC (Know Your Customer) and AML procedures to verify your identity | Identity, Contact | Compliance with a legal obligation |
Processing your transactions and managing settlements on the Marketplace | Identity, Contact, Financial, Transaction | Performance of a contract with you |
Managing our relationship with you (notices of changes to our terms, technical support) | Identity, Contact, Marketing | (a) Performance of a contract (b) Legitimate interest (keeping our records up to date) |
Keeping the Marketplace secure, preventing fraud and cyberattacks | Identity, Contact, Technical, Transaction | (a) Compliance with a legal obligation (b) Legitimate interest (protecting the business and its users) |
Using data analytics to improve Marketplace functionality, our marketing and the user experience | Technical, Usage | Legitimate interest (optimising the platform, growing the business) |
Delivering relevant marketing content | Contact, Marketing, Technical | Consent of the data subject |
5. Automated decision-making and profilingIn order to comply with international AML rules and to keep the Marketplace secure, we may use systems that make automated decisions. For example, our third-party KYC provider may use algorithms to check the authenticity of your documents or to match the face in your selfie against the photograph in your passport.
If an automated decision results in access to the Marketplace being refused, you have the right to contest that decision, to express your point of view and to request human intervention (a manual review) by the Company.
6. Disclosure of your personal dataWe may share your personal data with the following categories of third parties:
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KYC/AML providers and identity verification services: in order to comply with our legal obligations.
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Payment service providers: to enable deposits and withdrawals, payment processing and crypto operations as part of the Marketplace.
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IT service and cloud hosting providers: who ensure the technical stability and security of the Marketplace infrastructure.
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Professional advisers: including lawyers, bankers, auditors and insurers based in Cyprus and the EU.
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Government regulators and law enforcement authorities: authorities of the Republic of Cyprus (for example, MOKAS), tax authorities or other bodies, where required by law.
7. International data transfersOur principal servers and operational offices are located within the European Economic Area (EEA). However, some of our partners may be based outside the EEA.
Whenever we transfer your personal data outside the EEA, we ensure a similar degree of protection is afforded to it by implementing Standard Contractual Clauses (SCCs) approved by the European Commission, or by transferring it to countries with an adequate level of data protection.
8. Data securityWe have put in place appropriate technical and organisational security measures (including encryption of data in transit and at rest, strict access controls on a least-privilege basis, and two-factor authentication) to prevent unauthorised access to your data on the Marketplace. In the event of a personal data breach, we will notify you and the competent supervisory authority (the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus) within 72 hours.
9. Data retention periods
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KYC data and financial transactions: under the laws of the Republic of Cyprus and EU Directives, we are required to retain basic information about Marketplace users (Identity, Contact and Financial Data and transaction records) for
five (5) years after an account is deactivated.
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Account Data: retained for as long as you remain active on the Marketplace.
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Marketing Data: retained until you withdraw your consent.
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Technical Data (server logs): retained for no more than 12 months for audit purposes.
Once these periods expire, your data will be permanently deleted or irreversibly anonymised.
10. Your legal rightsUnder applicable law, you have the following rights:
1.
Right of access: to receive a copy of the personal data we hold about you.
2.
Right to rectification: to request correction of any incomplete or inaccurate data.
3.
Right to erasure ("right to be forgotten"): to ask us to delete your personal data where there is no compelling reason for us to continue processing it (for example, requirements under AML legislation).
4.
Right to object and to restrict processing: to suspend processing or object to it (including direct marketing).
5.
Right to data portability: to receive your data in a machine-readable format.
6.
Right to withdraw consent: at any time, without affecting the lawfulness of processing carried out before the withdrawal.
Exercising your rights: to exercise any of these rights, write to
info@amch.ltd. We respond to all legitimate requests within
one month.
11. Age restrictionsThe Marketplace is strictly not intended for children. Access is permitted solely to persons who have reached the age of
18 years. If we discover that a minor has registered, their account and associated data will be deleted immediately.
12. CookiesThe Marketplace uses cookies to ensure stable operation, security and a personalised user experience. We request your explicit consent to the use of analytics and marketing cookies through a dedicated banner.
13. Changes to this PolicyWe review our Privacy Policy regularly. Any changes will be published on this page. We will notify you of material changes by email or by a prominent notice on the Marketplace.