Last updated: 20 June 20, 2026
This Privacy Notice (“Notice”) describes how HashLiquid (“HashLiquid”, “we”, “us”, “our”, “ourselves”) collects and processes your Personal Data (“you”, “your”) through our websites and applications or other services (collectively, together with the Website and the Apps, our “Service”). By using the Services provided by us, you are consenting to the collection, storage, processing, and transfer of your Personal Data as described in this Privacy Notice.
This Privacy Notice applies together with any terms of business and other contractual documents, including but not limited to any agreements we may have with you.
For any questions or concerns, contact us via the contact information below
This Notice covers :
1. Our Relationship with You
2. Collection and Use of Your Personal Data
If you are user or merchant on our P2P Marketplace
Connect Using Third-Party Social Login Platforms
If you are visitor on our website
Marketing and Promotional Communications
Recruitment and Employment
Participation in Our Events
Personal Data collected automatically from you:
Aggregated and Anonymized Data
3. Use of Cookies
4. How We Share Your Data
5. International Transfers of Personal Data
6. Data Security
7. Data Retention
8. What Privacy Rights Do You Have?
Accessing Your Information
Submit Request
9. Children
10. Contact Information
11. Conditions of Use, Notices and Revisions
Our Relationship with You
Your right to privacy and the protection of your personal data is important to us. HashLiquid is committed to the best practices in privacy, and we will only collect data when it’s strictly necessary to provide our services.
By using HashLiquid’s Services, including visiting our website, using our peer-to-peer (P2P) marketplace services, interacting on social media, participating in our surveys or processing your job applications or administering your employment with us. you acknowledge and consent to the collection, use, disclosure outlined in this Privacy Notice.
At HashLiquid, we are committed to protecting your privacy and ensuring transparency in how we handle your personal data. HashLiquid will act as the data controller that determines the "means" and "purposes" of processing your personal data.
The following sections outline how HashLiquid, as the Data Controller, processes your personal data.
Collection and Use of Your Personal Data
“Personal Data” is information that may identify an individual or relates to an identifiable individual. This includes information you provide voluntarily to us, information which is collected or created automatically in the natural course of provision of our services, or otherwise when you contact us. Following best practices in privacy such as data minimisation, we endeavour to collect only the amount of Personal Data that is necessary to provide our services to our users.
As a merchant or user of our P2P services, we’ll ask you to provide us with some additional information about yourself. This information is either required by law to verify your identity and comply with Know Your Customer (“KYC’) obligations, necessary to provide the requested ramp and fiat-related services. Failure in providing the data required implies that HashLiquid will not be able to offer our Services to you.
If you are user or merchant on our P2P Marketplace
Below, we present a table that outlines the Personal Data our Services uses and the purposes for processing that information.
| Category & Types of Personal Data | Purpose of Processing | Purpose of processing & Legal Basis |
| Account information processed includes your name, email address, mobile number, profile photo, username, password, and social login. | To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order. | Our legal basis for this processing is that it is essential for the performance of a contract of which you are a party. |
| Contact Information processed includes your name, email, phone number | We process your contact information to communicate with you on customer support and assistance purposes.
We may also process your information when necessary to request feedback and to contact you about your use of our Services. | Our legal basis for this processing is that it is essential for the performance of a contract of which you are a party. |
“Know Your Customer” (KYC) Details processed includes your full legal name, physical address, date of birth, picture of you, video recording of yourself, your country of residence and copy of your government issued identity documents (such as Passport, National ID, driver’s license), tax and bank information, copy of utility bill and bank statement.
| To manage and verify your identity and perform KYC due diligence checks or travel rule requirements for compliance with applicable Anti-Money Laundering laws or sanctions regulations.
Our verification processes may involve electronic automated verification through comparison of your “selfie” picture against provided information. | Processing is necessary to comply with our legal obligations under applicable laws and regulations, including Anti-Money Laundering laws or sanctions regulations. |
Wallet Information processed includes public wallet address or recipient’s wallet ID.
| To facilitate and execute the payment or transactions processing you request.
| Our legal basis for this processing is that it is essential for the performance of a contract of which you are a party. |
| Chat Information processed includes messages, images, files, documents, and other content that you upload, share, or exchange through the platform with merchants or other users. | To facilitate communication and interaction between merchants and users, as well as between users within the marketplace platform, including enabling the sharing of information, responding to enquiries, and supporting transactions or marketplace activities. | Our legal basis for this processing is that it is essential for the performance of a contract of which you are a party.
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| Financial Information processed includes bank account information, account number, account holder name, mobile money account, payment QR code. | To facilitate and execute the payment or transactions processing you request.
We record details such as the date, time, the amount, currencies, and digital assets used, payer/beneficiary and wallet details.
We also process this information to prevent and detect fraud and abuse to protect the security of our users, Services and others. We may also use scoring methods to assess and manage credit risks. | Our legal basis for this processing is that it is essential for the performance of a contract of which you are a party.
We also process Personal Data based on the legal basis that it is necessary to fulfill our legitimate interests in preventing fraud and/or abuse and avoiding non-compliance to keep our Services safe and secure. |
| Transaction and Payment Information processed includes Information of historical transaction you made on the public blockchain such as timestamps, amount of transaction, currencies, and virtual assets used, payer/beneficiary and wallet details and transaction amounts. |
Connect Using Third-Party Social Login Platforms
We offer you a seamless connection to our Services through third-party platforms, such as Privy or other Social Login such as Google, Apple or Telegram etc. You can easily access our Services using your existing wallet or login from these platforms. By using or continuing to use your third-party account to log in, you acknowledge that we may receive certain information (such as your wallet address or profile information) from that platform as needed to enable your connection. Please note that these third-party platforms are independent of us, and their processing of your Personal Data is subject to their own privacy notices. We process the Personal Data obtained through social login features (such as your account identifier and basic profile information) on the legal basis of performance of a contract, as this processing is necessary to provide you with access to and use of our Services.
If you are visitor on our website
When you use our website, request customer support, participate in our community forum or campaigns, you may provide your Personal Data. Below, we present a table that outlines the Personal Data that our website uses and the purposes for processing that information.
| Category & Types of personal Data | Purpose of Processing | Purpose of processing & Legal Basis |
| Contact Information processed includes your name, email, country/region that you choose to provide | We use your contact information for responding to and communicating with you regarding your inquiry. | We rely on your consent to process your Personal Data for responding to your inquiry. You may withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. |
| Social Media information processed includes Information you choose to provide during your interaction with us via social media channels such as X, Discord etc. | We use your social media information to interact with you in our community and keep you updated on the latest announcement on social media channels. | We rely on your consent to process your Personal Data for marketing purposes. You may withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. |
Marketing and Promotional Communications
We may use your email address to send you marketing and promotional newsletters, updates, and offers. This processing is based on your consent, which you can withdraw at any time. Please note that withdrawing your consent does not affect the lawfulness of any processing based on consent prior to its withdrawal.
Additionally, you may still receive essential transactional service-related communications, such as those related to your account or necessary administrative messages even if you opt-out from marketing communications.
Recruitment and Employment
If you apply for a position with us or become employed by us, we collect and process your Personal Data for purposes including recruitment, onboarding, employment administration, compliance with legal obligations, and other employment-related activities. Personal Data may be collected directly from you, from third-party recruitment agencies, or from publicly available sources such as LinkedIn.
We process the following categories of Personal Data for recruitment and employment purposes:
Contact Information: We will collect your name, email address, and other relevant contact details to communicate with you about your job application and, where applicable, your employment.
Education and Employment Information: We collect your Curriculum Vitae (CV), resume, LinkedIn profile, academic certificates and transcripts, employment history, and (where relevant) salary and bonus details. We use this information to assess your suitability, process your application, conduct background checks, and manage your employment relationship.
Personal Data collected automatically from you:
In certain circumstances, we may collect personal data automatically from you when you use our Services, in accordance with applicable laws. This may include device type, OS and browser type, login timestamp and usage data, which helps us enhance your experience, provide customer support, improve the performance of our sites and services, and safeguard your account by detecting unauthorized access and preventing fraud.
Location Data. We may collect geo-location data, which includes information about your device's estimated and not precise location. The types of location data we collect vary based on the device you use to access our services. For example, we may collect and use geolocation data that helps us determine your current location (such as your IP address) to comply with applicable local legal and regulatory requirements, enable appropriate service availability based on your location, and support security, fraud prevention, and abuse detection measures..
Device Data. Depending on the device you use, this may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider, mobile carrier, operating system, and system configuration details, language preferences.
Log and Usage Data. When you access or use our services, our servers automatically collect service-related, diagnostic, usage, and performance data, which is recorded in log files. This log data may include your IP address, device information, browser type, settings, and details about your activity within the services (such as timestamps, pages and files viewed, searches performed, and features used). It may also include device event data like system activity, error reports (such as "crash dumps"), and hardware settings.
Our legal basis for processing this data is our legitimate interest in improving our services, ensuring the security of our services, and maintaining a safe environment for our users, including fraud monitoring and prevention.
Aggregated and Anonymized Data
We also use aggregated or anonymized data to improve our Services. This involves analyzing general usage trends, gathering feedback, and conducting research without identifying individual users. For example, we may create overall usage reports for specific regions without containing Personal Data.
We will not use your Personal Data for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest to do so.
Use of Cookies
We use cookies and similar tools to enhance your user experience, provide our services, enhance our marketing efforts and understand how customers use our services so we can make improvements. Depending on applicable laws in the region you are in, the cookie banner on your browser will tell you how to accept or refuse cookies. Please read our cookie notice here.
How We Share Your Data
Information about our customer is an important part of our business and we are not in the business of selling our customer’s Personal Data to others. We may transfer personal data to our service providers or third parties in connection with HashLiquid’s operation of its business, as certain features on HashLiquid rely on various third-party products and services (collectively “Third Party Services”), such as fraud monitoring and KYC identity verification service providers, payment processing, cloud storage, IT and cybersecurity service providers, analytics and improvement of website-related services and features, and performance of maintenance services.
Third-party service providers only must process the Personal Data in accordance with our contractual agreements and only as permitted by applicable data protections laws.
We may also share Personal Data with the following persons or in the following circumstances:
Affiliates: Personal data that we process and collect may be transferred between companies, Services, and employees affiliated with us (collectively, our “Affiliates”) as a normal part of conducting business and offering our Services.
Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, the user consents otherwise). Also, in the unlikely event that HashLiquid or substantially all of its assets are acquired, users' information will be one of the transferred assets.
Legal Authorities: We may be required by law or by Court to disclose certain information which might cover Personal Data or any engagement we may have to relevant regulatory, law enforcement and/or other competent authorities. We will disclose Personal Data to legal authorities to the extent we are obliged to do so according to the law. We may also need to disclose Personal Data in order to enforce or apply our legal rights or to prevent fraud.
Protection of Us and Others: We will share Personal Data outside of HashLiquid if we have a reasonable belief that access, use, preservation, or disclosure of the information is reasonably necessary to comply with any applicable law, regulation, legal process, or enforceable governmental request; to cooperate with law enforcement; to enforce or apply our Terms of Use and other agreements; or to protect the rights, property, or safety of HashLiquid, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction, and with regulatory agencies and law enforcement to comply with lawful requests.
Our services may contain website hyperlinks, content, or references made available by merchants, users, or other third parties that direct you to external websites, decentralized applications, or third-party platforms (collectively, “Third Party Platforms”). These Third Party Platforms may not be related to, operated by, or controlled by us, and their processing of your personal data will be governed by their own privacy notices, terms, and policies.
If you choose to access or interact with any Third Party Platforms, your personal data may be collected, used, or disclosed by those third parties independently of us. This Privacy Notice does not apply to the privacy, security, or data handling practices of any Third Party Platforms or external websites linked through our services. The inclusion of any hyperlink or reference does not imply our endorsement, affiliation, or approval of such Third Party Platforms..
International Transfers of Personal Data
We maintain servers globally, and your information may be processed on servers located outside of your country of residence. Additionally, we may transfer your personal data to our Affiliates, third-party partners, and service providers located outside the European Economic Area (EEA).
In instances where we process your personal data on servers outside your country or transfer it to third countries or international organizations outside the European Economic Area (EEA), we implement appropriate technical, organizational, and contractual safeguards to ensure that your personal data remains protected. This includes, but is not limited to, the use of Standard Contractual Clauses. These measures ensure that any such transfers comply with applicable data protection laws and maintain an adequate level of protection for your personal data as outlined in this Notice.
Data Security
We recognize that information security is a crucial component of data privacy. We are committed to making sure your information is protected in accordance with applicable laws and our data privacy policies. Although no data transmission, including over the Internet or through any website, can be guaranteed to be entirely secure, we employ a range of commercially reasonable physical, technical, and procedural measures to protect personal data from unauthorized access, use, disclosure, alteration, or destruction.
The information you provide to us is stored on secure servers managed by us or our trusted service providers. Access to and use of this information are governed by our internal security policies and standards, or those agreed upon with our service providers, all in alignment with industry best practices.
To further protect your information, it is important that you safeguard your account password. We recommend using a unique password for your account that is not used for other online accounts and ensuring that you sign off when you have finished using our services.
Data Retention
We retain your personal data to support your continued use of our services while ensuring compliance with legal and regulatory obligations. We maintain internal retention policies and schedules on the basis of how information needs to be used. The retention period depends on the purpose of processing, such as fulfilling tax and accounting requirements, complying with anti-money laundering laws, resolving disputes, or meeting other legal obligations.
For example, to comply with regulatory requirements, we must retain your KYC identity verification details for at least 5 years after our business relationship ends. If required by our regulator, this period may be extended to 10 years, even if your verification was incomplete or unsuccessful. If you sign up but do not complete the verification process and choose to close your account, we will still retain your data in accordance with our retention policy and legal obligations. Similarly, other types of personal data may be retained for different periods based on applicable legal or operational requirements.
When we have no ongoing legitimate business or legal requirement to retain your Personal Data, we will either delete or anonymise such information, or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.
What Privacy Rights Do You Have?
Subject to applicable law, as outlined below, you have a number of rights in relation to your privacy and the protection of your Personal Data. These rights may be limited in some situations - for example, where we can demonstrate we have a legal requirement to process your Personal Data.
Right to access: you have the right to obtain a copy of the Personal Data that we hold about you as well as certain information related to its processing.
Right to correct: you can request the rectification of your Personal Data which are inaccurate, and also add to it. You can also change your Personal Data in your account at any time.
Request to erase your personal data: you may request the erasure of your personal data, including where such personal data would no longer be necessary to achieve the purposes for which it was collected. Please note that personal data may still need to be retained for compliance with applicable legal obligations.
Right to object: you can object, for reasons relating to your situation, to the processing of your personal data. For instance, you have the right to object where we rely on legitimate interest or where we process your data for direct marketing purposes.
Right to restrict processing: You have the right, in certain cases, to temporarily restrict the processing of your personal data by us, provided there are valid grounds for doing so. We may continue to process your personal data if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
Right to withdraw your consent: You have the right to withdraw your consent and request us to stop collecting, using or and/or disclosing your personal data for any or all of the purposes listed above at any time. Exercising this right does not affect the lawfulness of the processing based on the consent given before the withdrawal of the latter. Please note that we will respond to such withdrawal request within ten (10) business days;
Right to portability: You can also request us to provide your information in a structured way so you can send it to another service provider.
Accessing Your Information
You are in control. You can access and change some of your personal details in your user account. You can also retrieve your historical transaction records within your user account.
Submit Request
To exercise your rights, you can contact us via email at privacy@ciphernetwork.io.
We will respond as quickly as possible. If we are unable to respond within 30 days, we will inform you in writing of the timeline for our response. If we cannot fulfill your request, we will explain the reasons (unless prohibited by applicable laws).
If you have any questions or concerns about how we collect and process your Personal Data, or if you wish to withdraw your consent for any processing, please contact us. Where we act as a processor, you should contact the data controller, your service provider, to exercise any of your rights.directly to exercise your rights.
Children
We do not knowingly solicit data from or market to children (or minors, as defined in your jurisdiction) under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that Personal Data from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any Personal Data we may have collected from children under age 18, please contact us using the contact information below.
Contact Information
Our support team is available to direct any questions related to your Personal Data. You can contact us at privacy@ciphernetwork.io, and we will ensure your inquiry reaches the appropriate team to address any concerns regarding the collection and processing of your Personal Data.
The following entity is the Data Controller responsible for the collection, use, disclosure and other processing of your Personal Data as described in this Privacy Notice.
Data Controller: METALAYER CORP
Registered Address: Province of Panama, district of Panama, Betania, Vía Ricardo J. Alfaro, PH The Century Tower, office three hundred seventeen (317).
Conditions of Use, Notices and Revisions
If you choose to use our Services, your use and any dispute over privacy is subject to this Privacy Notice and our Terms of Use. If you have any concerns about privacy at HashLiquid, please contact us with a thorough description, and we will try to resolve it. You also have the right to contact your local Data Protection Authority.
We reserve the right to update and revise this Notice at any time. We occasionally review this Privacy Notice to make sure it complies with applicable laws and conforms to changes in our business. If we do revise this Privacy Notice, we will update the “Last Updated” date at the beginning of this Notice so that you can tell if it has changed since your last visit and will do our best to notify you.
Please review this Privacy Notice regularly to ensure that you are aware of its terms. Your continued use of our Services after an amendment to our Privacy Notice constitutes your acceptance to the revised or amended terms.
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