Titanium Chain Services Limited ("we", "us", "our", "Titanium Chain") is committed to protecting and respecting your privacy. This Privacy Notice explains how we process personal data — including collection, use, storage, disclosure, and retention — in compliance with the Data Protection Act of the British Virgin Islands, 2021 ("DPA"). Where applicable, we also ensure compliance with the EU General Data Protection Regulation 2016/679 ("GDPR") for EU/EEA data subjects.
Personal Data We Collect
We may collect and process the following categories of personal data:
- IP address and browser information
- Device identifiers (e.g., cookies, device type)
- Usage data (e.g., pages visited, time spent, referral sources)
- Contact form submissions (name, email, message content)
- Account login details (if using client portal)
- Marketing preferences (if subscribed to newsletters)
- Contact details (name, address, email, phone number)
- Identification information (passport, identity card, driver's license)
- Corporate data (company officers, directors, shareholders)
- Beneficial ownership details
- AML and KYC information
- Financial information (bank account details, transaction data)
- Legal and regulatory documents
- Correspondence and communication records
- Data obtained from third-party service providers
We do not collect sensitive personal data through the website unless explicitly provided in the context of services (e.g., health information in rare compliance scenarios).
Grounds for Processing Personal Data
Titanium Chain only processes personal data where:
- Consent: You have given your express consent for us to process your personal data (e.g., for marketing communications or non-essential cookies). For sensitive personal data, explicit consent is required under both DPA and GDPR. You may withdraw consent at any time without affecting prior processing.
- Performance of Contract: Processing is necessary to perform our contractual obligations or to take steps at your request prior to entering into a contract.
- Legal Obligations: Processing is necessary to comply with applicable legal obligations, such as anti-money laundering, tax reporting, and regulatory filing requirements.
- Vital Interests: Processing is necessary to protect your life or physical safety, or that of another person.
- Administration of Justice: Processing is necessary for the administration or exercise of legal rights and obligations.
- Functions Exercised by Law: Processing is necessary for functions conferred on Titanium Chain by law.
Purposes and Uses of Personal Data
We process personal data for multiple purposes, including but not limited to:
- Providing website functionality (e.g., remembering preferences via essential cookies).
- Enhancing user experience (e.g., session management).
- Security (e.g., monitoring for cyber threats using IP addresses).
- Analytics (e.g., understanding website usage to improve content, with anonymized data where possible).
- Marketing (e.g., sending newsletters only with consent).
- Fraud prevention (e.g., detecting unusual activity).
- Establishing client identity, AML/KYC compliance, due diligence.
- Administering secretarial and corporate support, statutory registers, filing compliance.
- Laws relating to AML, beneficial ownership, sanctions, and data retention.
- Record-keeping, disclosures, reporting to authorities.
- Responding to inquiries, notifications, updates.
- Managing our relationship, billing, record management.
- Ensuring confidentiality, preventing unauthorized access or breaches.
- Analyzing service use, improving offerings, marketing (with consent).
- Supporting dispute resolution or legal actions.
Personal data from the website is not used for automated decision-making that produces legal effects without human intervention.
Disclosure and Data Sharing
We may disclose personal data to:
- Service providers engaged to support our services who process data on our behalf under strict contracts ensuring DPA/GDPR compliance.
- Regulatory or governmental authorities as required by law
- Legal and professional advisers bound by confidentiality
- Third parties in legal proceedings (e.g., courts, insolvency administrators
For website operations, data may be shared with analytics providers (e.g., hosting services), only with appropriate safeguards.
We do not sell personal data. Transfers outside the BVI (e.g., to EU for GDPR compliance) occur only with proof of adequate safeguards (e.g., standard contractual clauses) or your consent, as required by DPA section 7. For EU/EEA data subjects, international transfers comply with GDPR Chapter V, including adequacy decisions or binding corporate rules where applicable.
Cookies and Tracking Technologies
Our website uses cookies and similar technologies:
- Essential cookies: Necessary for site functionality
- Analytics cookies: For usage insights
- Marketing cookies: For personalized ads
You can manage preferences via cookie banners or browser settings. For detailed information, see our Cookie Policy.
Data Security and Retention
We implement appropriate technical and organizational measures to protect personal data from loss, misuse, unauthorized access, alteration, or destruction, considering data sensitivity and potential harm. This includes encryption, access controls, and regular audits. Website data is secured via HTTPS and firewalls.
Personal data is retained only as long as necessary for the purposes outlined, or to comply with legal obligations:
- For our clients: Typically 5-7 years post-relationship end (e.g., for AML records).
- Website data: Session data deleted immediately; other usage data retained for up to 26 months where necessary for analytics or security.
Data is securely destroyed or anonymized when no longer needed.
Data Subject Rights
Under the DPA and GDPR (for EU/EEA subjects), you have rights including:
- Access to your personal data and details of processing.
- Rectification of inaccurate or incomplete data.
- Erasure ("right to be forgotten") where no longer necessary or consent withdrawn.
- Restriction of processing (e.g., during disputes).
- Data portability (in structured format, for contract-based processing).
- Objection to processing (e.g., for marketing; or legitimate interests under GDPR).
- Withdrawal of consent at any time.
- Right to avoid automated decision-making (where applicable).
- Lodge complaints with the BVI Information Commissioner or, for EU subjects, your local supervisory authority (e.g., after exhausting our internal processes).
Requests should be addressed to our Data Protection Officer.
Contact Details
Email: cs@titanium-chain.com
Changes to This Privacy Notice
We reserve the right to update this notice periodically to reflect changes in our practices or legal requirements. The latest version will be posted on our website. Continued use of our website or services constitutes acceptance.