GLBA Privacy Notice

This Gramm-Leach-Bliley Act (GLBA) Privacy Notice (“Privacy Notice”) describes how Paxos Trust Company, LLC (“PTC”, “we,” “us,” and “our”) collects and shares the nonpublic personal information of U.S. Consumers. This Privacy Notice applies only to your use of financial products and services provided by PTC, and does not apply to any other product or service that you may obtain from our affiliates or subsidiaries.

FACTS – WHAT DOES PTC DO WITH YOUR PERSONAL INFORMATION?

Why? 

Financial companies choose how they share your personal information. Federal law gives  consumers the right to limit some but not all sharing. Federal law also requires us to tell you  how we collect, share, and protect your personal information. Please read this notice carefully to understand what PTC does.

What? 

The types of personal information we collect and share depends on the product or service you have with us. This information can include: 

■ Social Security Number, government identification number, and other identity verification information

■ Assets, account balances, transaction history, and wire transfer information

When you are no longer our customer, we continue to share your information as described in this notice.

How? 

All financial companies need to share customers’ personal information to run their everyday  business. In the section below, we list the reasons financial companies can share their  customers’ personal information; the reasons PTC chooses to share; and whether you can limit this sharing.

 

Reasons we can share your personal information 

Does PTC share? 

Can you limit this sharing?

For our everyday business purposes— 

such as to process your transactions, maintain  your account(s), respond to court orders and legal investigations, or report to credit bureaus

Yes

No

For our marketing purposes— 

to offer our products and services to you

Yes

No

  For joint marketing with other financial companies

No

We don’t share

For our affiliates’ everyday business purposes— information about your transactions and experiences

Yes

No

For our affiliates’ everyday business purposes— information about your creditworthiness

No

We don’t share

For our affiliates to market to you

Yes

No

For nonaffiliates to market to you

No

We don’t share

 

Questions? 

Email us at [email protected]

 

Who we are

Who is providing this notice? 

Paxos Trust Company, LLC

What we do

How does PTC protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include technical, physical, and administrative safeguards designed to protect the confidentiality, integrity, and availability of your personal information.

How does PTC collect my personal information?

We collect your personal information, for example, when you 

■ create an account with us or take advantage of our services through one of our partnerships

■ conduct transactions on our platform including partner applications that we provide services for 

■ provide us your information directly 

We also collect your personal information from others such as our affiliates, our partners, and our service providers such as those we use for identity verification.

Why can’t I limit all sharing? 

Federal law gives you the right to limit only: 

■ sharing for affiliates’ everyday business purpose

■ affiliates from using your information to market to you—information about your creditworthiness

■ sharing for nonaffiliates to market to you  

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

What happens when I limit sharing for an account I hold jointly with someone else?

Your choices will apply to everyone on your account.

Definitions

Affiliates 

Companies related by common ownership or control. They can be financial and nonfinancial companies. 

Paxos Technology Solutions, Paxos Global Pte. Ltd., and our related companies with Paxos in their name.

Nonaffiliates 

Companies not related by common ownership or control. They can be financial and nonfinancial companies. 

PTC does not share with nonaffiliates so they can market to you.

Joint marketing 

A formal agreement between nonaffiliated financial companies that together market financial products or services to you. 

PTC does not jointly market. 

Other important information

Vermont residents: We will not share information we collect about you with affiliated or nonaffiliated third parties, except as permitted by Vermont law, such as to process your transactions or to maintain your account, or as authorized by you.

California residents: In accordance with California law, we will not share information we collect about you with nonaffiliates, unless the law permits it. For example, we may share information with your consent or to process your transactions or maintain your account. We will limit sharing among our affiliated companies to the extent required by California law.

Nevada residents: Nevada law requires us to disclose that you may request to be placed on the Federal Do Not Call List by phone by calling 1-888-382-1222 (TTY 1-866-290-4236) from the phone number you want to put on the registry. When you sign up with the Federal Do Not Call List, you are automatically placed on Nevada’s Do Not Call List. You can confirm that your number is on the Federal Do Not Call List by going to donotcall.gov/confirm/conf.aspx. To obtain further information, contact the Bureau of Consumer Protection, Office of the Nevada Attorney General at 555 E. Washington Ave., Suite 3900, Las Vegas, NV 89101; phone 1-702-486-3132; or email [email protected].

Privacy Questions, Comments or Feedback?

If you wish to exercise any of your rights, or have questions concerning this Privacy Notice, please contact:

Email: [email protected]

This Gramm-Leach-Bliley Act (GLBA) Privacy Notice (“Privacy Notice”) describes how Paxos Trust Company, LLC (“PTC”, “we,” “us,” and “our”) collects and shares the nonpublic personal information of U.S. Consumers. This Privacy Notice applies only to your use of financial products and services provided by PTC, and does not apply to any other product or service that you may obtain from our affiliates or subsidiaries.

FACTS - WHAT DOES PTC DO WITH YOUR PERSONAL INFORMATION?

Why? 

Financial companies choose how they share your personal information. Federal law gives  consumers the right to limit some but not all sharing. Federal law also requires us to tell you  how we collect, share, and protect your personal information. Please read this notice carefully to understand what PTC does.

What? 

The types of personal information we collect and share depends on the product or service you have with us. This information can include: 

Social Security Number, government identification number, and other identity verification information

Assets, account balances, transaction history, and wire transfer information

When you are no longer our customer, we continue to share your information as described in this notice.

How? 

All financial companies need to share customers’ personal information to run their everyday  business. In the section below, we list the reasons financial companies can share their  customers’ personal information; the reasons PTC chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information 

Does PTC share? 

Can you limit this sharing?

For our everyday business purposes— 

such as to process your transactions, maintain  your account(s), respond to court orders and legal investigations, or report to credit bureaus

Yes

No

For our marketing purposes— 

to offer our products and services to you

Yes

No

  For joint marketing with other financial companies

No

We don’t share

For our affiliates’ everyday business purposes— information about your transactions and experiences

Yes

No

For our affiliates’ everyday business purposes— information about your creditworthiness

No

We don’t share

For our affiliates to market to you

Yes

No

For nonaffiliates to market to you

No

We don’t share

Questions? 

Email us at [email protected]

Who we are

Who is providing this notice? 

Paxos Trust Company, LLC

What we do

How does PTC protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include technical, physical, and administrative safeguards designed to protect the confidentiality, integrity, and availability of your personal information.

How does PTC collect my personal information?

We collect your personal information, for example, when you 

create an account with us or take advantage of our services through one of our partnerships

conduct transactions on our platform including partner applications that we provide services for 

provide us your information directly 

We also collect your personal information from others such as our affiliates, our partners, and our service providers such as those we use for identity verification.

Why can’t I limit all sharing? 

Federal law gives you the right to limit only: 

sharing for affiliates’ everyday business purpose

affiliates from using your information to market to you—information about your creditworthiness

sharing for nonaffiliates to market to you  

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

What happens when I limit sharing for an account I hold jointly with someone else?

Your choices will apply to everyone on your account.

Definitions

Affiliates 

Companies related by common ownership or control. They can be financial and nonfinancial companies. 

Paxos Technology Solutions, Paxos Global Pte. Ltd., and our related companies with Paxos in their name.

Nonaffiliates 

Companies not related by common ownership or control. They can be financial and nonfinancial companies. 

PTC does not share with nonaffiliates so they can market to you.

Joint marketing 

A formal agreement between nonaffiliated financial companies that together market financial products or services to you. 

PTC does not jointly market. 

Other important information

Vermont residents: We will not share information we collect about you with affiliated or nonaffiliated third parties, except as permitted by Vermont law, such as to process your transactions or to maintain your account, or as authorized by you.

California residents: In accordance with California law, we will not share information we collect about you with nonaffiliates, unless the law permits it. For example, we may share information with your consent or to process your transactions or maintain your account. We will limit sharing among our affiliated companies to the extent required by California law.

Nevada residents: Nevada law requires us to disclose that you may request to be placed on the Federal Do Not Call List by phone by calling 1-888-382-1222 (TTY 1-866-290-4236) from the phone number you want to put on the registry. When you sign up with the Federal Do Not Call List, you are automatically placed on Nevada’s Do Not Call List. You can confirm that your number is on the Federal Do Not Call List by going to donotcall.gov/confirm/conf.aspx. To obtain further information, contact the Bureau of Consumer Protection, Office of the Nevada Attorney General at 555 E. Washington Ave., Suite 3900, Las Vegas, NV 89101; phone 1-702-486-3132; or email [email protected].

Privacy Questions, Comments or Feedback?

If you wish to exercise any of your rights, or have questions concerning this Privacy Notice, please contact:

Email: [email protected]