HODLERS Privacy Policy

Last updated:
16th March, 2023


This Privacy Policy ("Policy" or "Privacy Policy") outlines how BLANK HOLDINGS LTD, with email address hello@hodlers.one (referred to as "HODLERS," "We," "Us," or "Data Controller") collects, uses, and protects personal information furnished by Users when using the Website https://www.hodlers.one (referred to as "the Website" or "the Site") and/or the services offered therein (referred to as "HODLERS Services").

HODLERS respects User privacy and complies with data protection and cybersecurity laws, particularly the General Data Protection Regulation (GDPR). Pursuant to the GDPR, the Data Controller must process Personal Information in accordance with the principles of lawfulness, correctness, transparency, purpose limitation and storage, data minimization, accuracy, integrity and confidentiality. HODLERS abides by these principles.

In this document, "Personal Information" means any information that identifies an individual and any other information associated with persons that Users may have provided to us from time to time in their engagement with us.

By using the Website or the HODLERS Services, Users consent to HODLERS collecting and using their Personal Information pursuant to this Privacy Policy and agree to be bound by its current terms. Please note that this document may be updated or modified by HODLERS at its sole discretion. We recommend that Users read this document carefully, as it contains information about their rights as Users of the Website.

If Users wish to receive more information, make suggestions, or file complaints regarding this Privacy Policy, they can do so by sending an email to hello@hodlers.one.

Information we may collect

HODLERS collects and processes both personal and non-personal information. Personal information includes details that directly or indirectly identify an individual, such as name, date of birth, address, email address, phone number, photo ID, proof of income, credit card details, bank account details, data relating to spouse or children, social security data, etc. Non-personal information is data generated by the devices, applications, tools and protocols used, pages visited, number of clicks, actions taken, duration of sessions, geolocation data that precisely identifies the location, etc. Please note that Personal Information voluntarily provided by the User when interacting with the functions of the Website or requesting to use the services offered on the Website may be processed.

The User's Personal Information will be collected only to the extent necessary for the requested activity, and in accordance with Articles 9 and 10 of the GDPR and other provisions of the GDPR. If there is a legal or contractual obligation to provide Personal Information or if it is a necessary requirement for the conclusion of the contract with the Data Controller, failure to provide such information will result in the Data Controller being unable to establish or continue the relationship with the Data Subject.

It is important to note that the User is directly and exclusively responsible for the origin, collection, processing, communication, or dissemination of Personal Information of third parties that they may share with HODLERS. Visiting and consulting the Website does not involve the collection and processing of the User's Personal Information. However, such information may be collected when the User interacts with the functions of the Website or requests to use the services offered on the Website.

Please note that this Policy may be updated or modified at HODLERS's sole discretion. We encourage Users to visit this section frequently. If you have any questions, comments, or complaints regarding this Privacy Policy, please feel free to contact us at hello@hodlers.one. We recommend that you read this document carefully as it contains information about your rights as a User of the Website.

Purposes and Legal Basis of Personal Information processing

We may collect User data for the following purposes:


  • To fulfil any obligation arising from the pre-contractual or contractual relationship with the Data Subject;
  • To allow the Data Subject to register with the Website, access and be identified, including via external platforms;
  • To respond to Data Subject's requests;
  • To allow the User's use of the services and features on the Website;
  • To provide the User with a secure ecosystem as the collection of data is aimed at avoiding fraud and validating the Purchaser's identity;
  • To conduct research and/or statistical analysis on aggregate or anonymous data, without the possibility of identifying the User, aimed at measuring the functioning of the site, measuring traffic, and assessing the usability and interest of the site;
  • To fulfill any obligation provided for by applicable rules;
  • To ascertain, exercise or defend a right in court or administrative authorities;
  • To exercise legitimate interests (for navigation data and cookies);
  • For marketing purposes, including profiling of the Data Subject (Controller's products and/or services and/or third-party products and/or services);
  • To detect the exact location of the Data Subject.


  • The legal bases of the processing are as follows:


Browsing data and anonymous first-party and statistical cookies: processing is necessary for the legitimate interest of the Data Controller;

  • Personal identification data provided by the User: processing is necessary for the performance of a contract to which the Data Subject is party or for the implementation of pre-contractual measures at the request of the Data Subject;
  • In some cases, processing is necessary to fulfill our legal or regulatory responsibilities, for example, in the case of reporting to authorities, governmental or regulatory bodies.


On the basis of the legitimate interest of the Data Controller, the Website allows interactions with external platforms or social networks whose processing of Personal Information is governed by their respective privacy policies, to which please refer. This information - in the absence of specific consent to the processing for other purposes - is used only to allow the use of the Website and provide the requested information and services.


The processing of Personal Information is carried out through telematic means and recorded in digital format on servers available to the Data Controller, within the limits and time necessary to fulfil the above-mentioned purposes.

To prevent loss, modification, deletion, unlawful or incorrect use, and unauthorized access or transmission of data, the Data Controller adheres to specific security measures. The Data Controller also undertakes to adopt additional measures required to ensure that Personal Information is treated securely and in compliance with relevant legislation.

To help the controller maintain the accuracy of Personal Information, Users are requested to notify any changes to their Personal Information.

Personal Information will be processed exclusively by the following:


•   Persons authorized by the Data Controller to process Personal Information who have committed themselves to confidentiality or are legally obliged to confidentiality

•   Independent entities operating as separate data controllers or designated as data processors by the Data Controller to perform all processing activities necessary to achieve the purposes outlined in this Policy, such as business partners, consultants, IT companies, service providers, and hosting providers

•   Persons or entities to whom Personal Information must be disclosed by law or order of the authorities.

These entities are required to use appropriate safeguards to protect Personal Information and may only access the Personal Information necessary to perform their assigned tasks. Personal Information will not be disseminated indiscriminately in any way.

Access and Control of Personal Information by Users

Users can access their personal information on our website at any time to verify what information HODLERS has collected about them, correct or update any data, request HODLERS to modify or delete their data, or raise a concern about any misuse of their data.

Compulsory and Optional Nature of Providing Personal Information

The communication of navigation data is mandatory to permit Users to use certain functions of the website. The communication of personal information for purposes such as signing up on our site, utilizing our marketplace, subscribing to our mailing list, placing an order, or requesting information is optional.

Consequences of Refusal to Disclose Personal Information

Users cannot refuse to provide navigation data. However, if Users refuse to disclose personal information for purposes such as signing up on our site, utilizing our marketplace, subscribing to our mailing list, placing an order, or requesting information, HODLERS may not be able to process the User's request in whole or in part.

Information Security for Users

HODLERS takes both online and offline precautions to safeguard Users' personal information submitted through the website. HODLERS will endeavour to protect Users' personal information by using data de-identification and encryption techniques.

Third-Party Website Links

Our website may include links to third-party websites. HODLERS recommends that users review the privacy policies and terms of service of these third-party websites. HODLERS is not responsible for the privacy practices or content of these third-party websites.

Duration of Processing

HODLERS will retain users' personal information for as long as it is necessary to provide the services outlined in this policy and in our terms of service.

User Rights (Art. 15-22 GDPR)

Users have certain rights with regard to their personal information processed by the data controller. These rights include:

·  The right to be informed about the processing of their personal information and to access such data.

·  The right to be informed in case of updates, corrections, deletions, or restrictions of personal information.

·  The right to revoke consent at any time, in which case personal information will be deleted as soon as possible.

·  The right to limit the processing of personal information.

·  The right to object, in whole or in part, to the processing of personal information and to refuse automated decision-making, including profiling, subject to legal obligations regarding the storage of personal information.

·  The right to access personal information.

·  The right to verify and request the rectification of personal information.

·  The right to obtain the limitation of the processing of personal information.

·  The right to obtain the deletion (right to be forgotten), updating, rectification, and integration of personal information without undue delay.

·  The right to transfer personal information to another data controller.

·  The right to lodge a complaint with the supervisory authority for the protection of personal information and/or to take legal action.

These rights may be exercised in accordance with Article 12 of the GDPR, by submitting a specific written request accompanied by a photocopy of your ID sent by registered mail with return receipt to HODLERS' headquarters or by emailing hello@hodlers.one. Before modifying any information, we may need to verify your identity and ask you some questions. HODLERS will provide an appropriate response as soon as possible and within one month of receiving the request.

Use of cookies on the Website

HODLERS uses both technical cookies and profiling cookies on its Website. Additionally, third parties may use cookies over which we have no control. Cookies are small files stored on the hard disk of the User's computer. Technical cookies are necessary for the correct functioning of a Website and to allow the User to navigate. Without cookies, the User may not be able to view the pages correctly or use certain services. Profiling cookies have the task of creating User profiles in order to send advertising messages in line with the preferences expressed by the User during navigation.

By using the Website, you accept the use of cookies in accordance with this Cookie Notice. If you do not accept the use of cookies, please disable them so that cookies cannot be placed on your computer or mobile device. Please note that some functions of the Website might be unavailable after this action.

The data collected through the use of cookies is subject to the HODLERS Privacy Policy.

If you have disabled one or more cookies, we may still use information collected from cookies prior to your disabled preference being set. However, we will stop using the disabled cookie to collect any further information. To remove all known information about you from our systems, please email hello@hodlers.one.

DISCLAIMER: This Privacy Policy may be revised from time to time. Changes to this Privacy Policy will be published on this Website, and the updated version of the policy will be binding from that moment. Users are advised to visit this section regularly. In case of non-acceptance of the changes made to the Privacy Policy, the User must cease using this Website and may request us to delete their Personal Information.