Privacy Policy

Last Updated: September 10, 2025

1. Introduction

This Privacy Policy ("Policy") describes how SFT21 LLC ("Company", "we", "our") collects, uses, shares, and protects your personal information when you use our websites and services within the SFT21 Ecosystem ("Services").

Your privacy is extremely important to us. By using our Services, you agree to the collection and use of information in accordance with this Policy.

2. What Information We Collect

We collect various types of information to provide and improve our Services for you.

• Information You Provide to Us Directly:
  • Account Registration Data: When you create an account, we collect your first and last name, username, email address, and password.
  • Identity Verification (KYC) Data: To activate certain functionalities, we may require you to provide additional information, such as your address, date of birth, and a photograph or scan of a valid identification document (ID card, passport).
  • Contact Information: When you contact us via contact forms or email, we collect your name, email address, and the content of your message.
  • Transaction Data: When you purchase a License Package, we collect information necessary to process payments, although credit card details are handled by our payment processing partners and are not stored by us.
• Information We Collect Automatically:
  • Usage Data: Information on how you use our Services, such as the pages you visit, the time spent on them, and the actions you take.
  • Device Data: Information about the device you use to access the Services, including IP address, browser type, operating system, and unique device identifiers.
  • Cookies: We use cookies and similar tracking technologies to track activity on our Services and store certain information. More details can be found in our Cookie Policy.

3. How We Use Your Information

We use your information for the following purposes:

• To Provide and Maintain the Services: Including creating and managing your account, processing transactions, and providing customer support.
• For Identity Verification (KYC): To comply with legal obligations and prevent fraud.
• To Communicate with You: To send you important notices about your account, transactions, changes to our terms or services, and marketing messages (if you have consented).
• To Improve the Services: We analyze usage data to understand how our users interact with the Services and how we can improve them.
• For Security: To monitor and prevent fraud, abuse, and other harmful activities.

4. How We Share Your Information

We do not sell or rent your personal information to third parties. We may share it only in the following situations:

• With Service Providers: With third parties that perform services on our behalf, such as payment processors, hosting providers, and analytics tools. They have access to your data only to the extent necessary to perform these services and are obligated to protect it.
• For Legal Compliance: We may disclose your information if we believe it is necessary to comply with a law, court order, or other legal process.
• To Protect Our Rights: We may disclose information to protect the rights, property, or safety of the Company, our Users, or the public.

5. How Long We Retain Your Data

We retain your personal data for as long as necessary for the purposes stated in this Policy, unless a longer retention period is required or permitted by law. Data associated with your account is kept as long as your account is active. After account closure, data may be retained in our archives to comply with legal obligations or resolve disputes.

6. Your Privacy Rights (including GDPR)

SFT21 LLC is committed to respecting your privacy rights. If you are a resident of the European Economic Area (EEA), the United Kingdom, or Switzerland, the General Data Protection Regulation (GDPR) provides you with the following rights over your personal data:

• Right to Access: You have the right to request and obtain a copy of the personal data we hold about you.
• Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data.
• Right to Erasure ("Right to be Forgotten"): You have the right to request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected, or under other conditions stipulated by law.
• Right to Restrict Processing: You have the right to request that we temporarily halt the processing of your data in certain situations.
• Right to Data Portability: You have the right to request that we provide your data in a structured, machine-readable format, so you can transfer it to another data controller.
• Right to Object: You have the right to object to the processing of your personal data that is based on our legitimate interests.
• Right to Withdraw Consent: If processing is based on your consent, you have the right to withdraw that consent at any time.

How to Exercise Your Rights?

You can submit a request to exercise any of the above rights by sending an email to our Data Protection Officer at: dpo@sft21.com

Right to Lodge a Complaint

If you believe that the processing of your personal data violates the GDPR, you have the right to lodge a complaint with a data protection supervisory authority in the EU member state of your residence, place of work, or where the alleged infringement occurred.

7. Data Security

We implement reasonable technical and organizational measures to protect your personal data from unauthorized access, use, alteration, or destruction. However, no data transmission over the Internet is 100% secure, and we cannot guarantee absolute security.

8. Children's Privacy

Our Services are not intended for individuals under the age of 16. We do not knowingly collect personal information from children below this age. If we become aware that we have collected data from a child under 16, we will take immediate steps to remove that information.

For individuals between the ages of 16 and 18 (minors), the collection of personal data is permitted only with verifiable consent from a parent or legal guardian. As part of the registration process for minors, we also collect information about the parent/guardian to administer that consent. We consider the parent/guardian providing consent to be responsible for the personal data the minor provides.

9. Changes to This Privacy Policy

We reserve the right to modify this Policy at any time. If we make changes, we will post the updated Policy on this page and update the "Last Updated" date. Your continued use of the Services after the changes are posted will be deemed acceptance of the new Policy.

10. Contact Us

If you have any questions about this Privacy Policy or our practices, please contact us:
SFT21 LLC
Email: privacy@sft21.com