Privacy Policy

Last updated: June 2026

1. Who we are

Bitcoin Asset Reserve Ltd ("Reserve", "we", "us") is the data controller. We are registered in England and Wales (Company No. 16686955). Our registered office is:

Bitcoin Asset Reserve Ltd
3rd Floor, 1 Ashley Road
Altrincham
Cheshire WA14 2DT
United Kingdom

2. Data we collect

We collect information you provide directly: your name, email address, residential address, date of birth, identity document reference, and source-of-funds description when you apply, plus the details you submit through our inquiry and waitlist forms. We collect limited technical information automatically (IP address, used in hashed form for rate limiting and abuse prevention). As we approach launch we expect to engage identity verification providers and to collect bank details for loan disbursement; this policy will be updated before those processes go live.

3. How we use it

We use your data to: provide our services, verify your identity, assess loan applications, manage your account and collateral, comply with legal and regulatory obligations, prevent fraud, and communicate with you. We do not sell your personal data.

4. Legal basis

We process your data on the basis of: contract performance (to provide our services), legal obligation (KYC/AML, regulatory compliance), and legitimate interests (fraud prevention, service improvement). Where we rely on consent, you may withdraw it at any time.

5. Sharing and processors

We share data with service providers who process it on our behalf: our database hosting provider and our transactional email provider. At launch we may also share data with custodians (for collateral management), identity verification providers, payment institutions, regulators, and professional advisers where necessary. We require third parties to protect your data and use it only for the purposes we specify.

6. International transfers

Some of our service providers store data outside the UK. Where data leaves the UK, we rely on adequacy regulations or standard contractual clauses to protect it.

7. Retention

We retain your data for as long as necessary to provide our services and comply with legal obligations (typically 7 years for financial records). You may request deletion of your data where we have no legal obligation to retain it.

8. Your rights

Under UK GDPR you have the right to: access your data, rectify inaccuracies, erase data (in certain cases), restrict processing, data portability, object to processing, and withdraw consent. You may also lodge a complaint with the ICO. To exercise these rights, contact us at reservebtc.co/contact.

9. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, or destruction.