Privacy Policy
Effective Date: May 1, 2026 · EBT CONSULTING LLC
1. Introduction & Data Controller
EBT Consulting LLC ("we," "us," "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains what data we collect, how we use it, and your rights under applicable law, including the California Consumer Privacy Act (CCPA) and other U.S. state privacy laws, as well as GDPR where applicable to EEA residents.
EBT CONSULTING LLC117 173RD St SW, Bothell, WA 98012-9185, United States
Email: ebtconsulting.dev@proton.me
Phone: +1 (425) 318-7042
2. Information We Collect
- Application Data: When you apply for the beta program, we collect your name, email address, Telegram or Discord handle, and self-reported experience level.
- Wallet & Transaction Data: When you use the prototype wallet, we may process public blockchain addresses and transaction metadata to operate the AML screening engine. We never collect your private keys or seed phrase.
- AML Risk Data: Risk score results and screening outcomes associated with queried wallet addresses for compliance and product improvement purposes.
- Technical Data: Device type, OS version, app version, IP address, and usage telemetry for debugging and improvement.
- Communications: Records of your feedback, bug reports, and support communications.
3. Legal Basis & Purpose
We collect and process your data for the following purposes and legal bases:
- Consent: Beta program enrollment and optional marketing communications.
- Contract Performance: Providing prototype access and support.
- Legitimate Interest: Security, fraud prevention, and product improvement.
- Legal Obligation: BSA/AML compliance, FinCEN reporting obligations as a registered MSB, and applicable state regulations.
AML Compliance Note: As a FinCEN-registered Money Services Business, we are legally required to implement and maintain AML/KYC programs under the Bank Secrecy Act. Transaction screening data may be retained for the legally mandated period of five (5) years and may be subject to government reporting obligations.
4. Data Sharing
We do not sell your personal data. We may share data with:
- Third-party AML/compliance data providers who power the risk screening engine, under strict data processing agreements.
- Cloud infrastructure providers hosting our prototype backend, under industry-standard DPAs.
- Regulatory authorities (FinCEN, OFAC, law enforcement) as required by law.
Blockchain transaction data is inherently public and cannot be deleted or modified once on-chain.
5. Data Retention
Beta application data is retained for the duration of the program plus 12 months. AML screening records are retained for 5 years as required by FinCEN regulations. Technical usage data is retained for 90 days.
6. Your Privacy Rights
For all users: You may request access to, correction of, or deletion of your personal data by contacting us. Deletion requests cannot be fulfilled for data we are legally required to retain (e.g., AML records under BSA).
California residents (CCPA): You have the right to know what personal information we collect, to delete it (subject to exceptions), and to opt out of any sale. We do not sell personal information.
EEA/UK residents (GDPR): You have rights of access, rectification, erasure, restriction, portability, and objection. You may lodge a complaint with your local supervisory authority.
To exercise any of these rights, contact: ebtconsulting.dev@proton.me
7. Security
We implement appropriate technical and organizational measures to protect your data, including encryption at rest and in transit, access controls, and regular security reviews. However, no internet transmission is completely secure and we cannot guarantee absolute security.
8. Children's Privacy
The Service is not directed at individuals under 18. We do not knowingly collect data from children. If we become aware we have collected data from a child, we will delete it promptly.
9. Cookies
We use only technically necessary session cookies to operate the website. We do not use advertising or third-party tracking cookies.
10. International Transfers
Your data may be processed in the United States and other countries. For transfers from the EEA, we rely on Standard Contractual Clauses or other GDPR-compliant transfer mechanisms.
11. Changes to this Policy
We may update this Privacy Policy periodically. We will notify active testers of material changes via email. The updated policy will be effective upon posting.
12. Contact Us
EBT CONSULTING LLC — Privacy Inquiries117 173RD St SW, Bothell, WA 98012-9185, United States
Email: ebtconsulting.dev@proton.me
Phone: +1 (425) 318-7042