💾Privacy & Cookie Policy
Last Updated: October 2025
1. Introduction
This Privacy & Cookie Policy (“Policy”) explains how Sierra Reserve Limited ("Sierra Reserve), a company incorporated in the British Virgin Islands (“BVI”) with a registered office at Rough Point, P.O. Box 4203, Mount Healthy, Tortola, VG1110, British Virgin Islands (“Sierra Reserve”, “we”, “us”, or “our”), collects, uses, stores, shares, and protects personal data when you (“you”, “your”, “user”) use or access our website, platform, mobile applications, products, interface or other services (collectively, the “Services”).
Sierra Reserve is committed to protecting your privacy in accordance with the BVI Data Protection Act, 2021 (“DPA”) and other applicable laws.
By using our Services, you consent to the collection, use, and disclosure of your personal data as described in this Policy.
2. Applicability
This Policy applies to:
All visitors, users, and Authorized Participants of Sierra Reserve’s Services;
Any personal data collected by Sierra Reserve in the course of providing its Services; and
All processing carried out by Sierra Reserve as a “data controller” under the DPA.
3. What Personal Data We Collect
We may collect the following categories of personal data:
(a) Identification Data
For Authorized Participants, the full name, date of birth, nationality, government-issued identification (passport, ID number), entity information and similar details.
(b) Contact Data
For Authorized Participants, email address, residential or business address, and telephone number.
(c) Financial & Transactional Data
For Authorized Participants, transaction records, source of funds, and other financial information relevant to compliance with anti-money laundering (AML) obligations. Additionally, onchain wallet addresses and other information stored on public blockchains may be collected.
(d) Technical & Usage Data
Device identifiers, IP address, browser type, operating system, access times, pages viewed, and user activity logs.
(e) Marketing & Communications Data
Your communication preferences and records of correspondence with us.
We may also collect aggregated or anonymized data for analytical purposes, which does not identify you personally.
4. How We Collect Personal Data
We collect personal data through:
Direct interactions (e.g., Authorized Participant onboarding, inquiries, KYC/AML verification);
Automated technologies such as cookies, server logs, and analytics tools; and
Third parties including identity verification providers, payment processors, and public databases.
5. Lawful Basis for Processing (BVI Data Protection Act)
Under the BVI Data Protection Act, we process personal data only when one or more lawful bases apply, including:
Consent: Where you have given explicit consent;
Contractual necessity: Where processing is required to enter into or perform a contract with you;
Legal obligation: To comply with statutory duties, such as AML/CFT laws or regulatory reporting;
Legitimate interests: For purposes such as security, fraud prevention, analytics, and service improvement, provided such interests are not overridden by your rights; or
Vital interests: In cases where processing is necessary to protect life or safety.
6. How We Use Personal Data
We may use your personal data to:
Provide, maintain, and improve our Services;
Verify your identity and conduct KYC / AML screening;
Manage your account and communicate with you;
Process transactions and prevent fraud;
Comply with BVI legal and regulatory requirements;
Send administrative notifications or updates;
Send marketing or promotional materials (only where you have consented); or
Enforce our legal rights and defend against claims.
7. Disclosure of Personal Data
We may share your personal data with:
Service providers who perform services on our behalf (e.g., IT, analytics, compliance, KYC/AML vendors).
Professional advisers (e.g., lawyers, auditors, accountants, insurers).
Regulatory authorities in the BVI or other jurisdictions, when required by law.
Business partners or affiliates involved in providing the Services.
In connection with corporate transactions, such as mergers or sales, provided data remains protected under this Policy.
We do not sell your personal data. Any sharing of personal data is limited to essential operational functions or legal obligations. We will ensure all third parties protect your data in accordance with the BVI DPA and equivalent standards.
8. International Data Transfers
Your personal data may be transferred to and stored outside the BVI. When we transfer data to another jurisdiction, we ensure that:
The jurisdiction has laws providing equivalent protection; or
We use legally approved transfer mechanisms, such as contractual clauses ensuring adequate data protection safeguards.
9. Data Security
We use appropriate technical and organizational security measures to protect personal data from unauthorized access, disclosure, alteration, or destruction. Access to personal data is limited to employees and service providers who require it for legitimate purposes, and who are bound by confidentiality obligations.
In the event of a data breach or similar incident, Sierra Reserve will notify affected users through official communication channels.
10. Data Retention
We retain personal data only as long as necessary to:
Fulfil the purpose for which it was collected;
Comply with legal or regulatory obligations; or
Resolve disputes and enforce our rights.
Once the retention period expires, we securely delete or anonymize the data.
11. Your Rights Under the BVI Data Protection Act
Subject to applicable law, you have the following rights:
Right of access — to request a copy of personal data we hold about you;
Right to rectification — to correct incomplete or inaccurate data;
Right to erasure — to request deletion of personal data, subject to legal obligations;
Right to restrict processing — to limit how we use your data in certain circumstances;
Right to object — to object to processing on specific grounds, including direct marketing;
Right to data portability — to receive your data in a structured, commonly used format; and
Right to withdraw consent — at any time, without affecting processing already lawfully undertaken.
To exercise your rights, please contact us (see Section 15). We will respond to verified requests within one (1) month unless extended due to complexity or volume.
12. Cookies Policy
12.1 What Are Cookies?
Cookies are small files placed on your device that allow us to recognize your browser and gather information on how you use our website.
12.2 How We Use Cookies
We use cookies to:
Enable essential website functionality (login sessions, security);
Improve performance and usability;
Analyze usage for improvements;
Personalize content and remember preferences;
Deliver relevant advertising (only with consent).
12.3 Managing Cookies
You may:
Adjust browser settings to block or delete cookies.
Opt out of non-essential cookies through our website’s cookie banner or settings panel.
Please note that disabling essential cookies may affect functionality.
13. Children’s Privacy
Our Services are not directed at children under 18. We do not knowingly collect personal data from minors. If you believe a child has provided us data without consent, please contact us immediately.
14. Changes to This Policy
We may amend this Policy at any time. Updates will be posted on our website with a revised “last updated” date. Your continued use of the Services after changes are made constitutes acceptance of the updated Policy.
15. Contact Us
If you have any questions, requests, or complaints regarding this Policy or our data practices, please contact:
Sierra Reserve Limited Rough Point, P.O. Box 4203, Mount Healthy, Tortola, VG1110, British Virgin Islands Email: [email protected]
If you remain dissatisfied, you may contact the Office of the Information Commissioner (BVI) for further assistance.
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