Privacy Policy

Last Updated: June 6, 2025

1. Introduction

This Privacy Policy describes how GoldenBasis, Inc. ("Polar," "we," "us," or "our") collects, uses, shares, and protects your personal information when you use the Polar app and related services (the "Services").

Polar is a financial technology company that helps users manage self-custody cryptocurrency wallets and connects them with third-party partners for financial services like onramping/offramping and US virtual bank accounts. We are not a bank, money services business (MSB), or money transmitter. All regulated financial services are provided through our licensed and regulated partners.

By using our Services, you agree to the collection and use of information in accordance with this Privacy Policy.

Age Requirement: Our Services are intended for users who are 18 years of age or older. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from someone under 18, we will delete that information promptly.

2. Information We Collect

2.1 Personal Information You Provide

Account Registration and KYC Information:

Communication Data:

2.2 Automatically Collected Information

Device and Technical Data:

App Analytics:

2.3 Information from Third Parties

We may receive information about you from our service providers and partners, including for identity verification, compliance, and regulatory purposes.

2.4 Blockchain Transaction Data

When you use our Services to interact with the Base blockchain network, transaction information is permanently recorded on the blockchain and becomes publicly viewable. This includes wallet addresses, transaction amounts, timestamps, and any other data included in blockchain transactions. Due to the nature of blockchain technology, this information cannot be modified or deleted once recorded.

2.5 Derived Information

We may derive additional information or draw inferences based on the data we collect, such as risk assessments, usage patterns, and eligibility determinations for our Services.

3. How We Use Your Information

We use your personal information for the following purposes:

3.1 Core Service Delivery

3.2 Legal and Regulatory Compliance

3.3 Security and Fraud Prevention

3.4 Customer Support and Communication

3.5 Product Improvement and Analytics

3.6 Automated Decision-Making

4. How We Share Your Information

4.1 Service Providers and Partners

Financial Services Partners:

Service Infrastructure:

4.2 Legal and Regulatory Disclosures

4.3 With Your Consent

We may share your information with third parties when you explicitly consent to such sharing.

5. International Data Transfers

Primary Data Processing: All personal data is processed and stored in the United States on cloud infrastructure.

Cross-Border Considerations: If you are accessing our Services from outside the United States, your information will be transferred to, stored, and processed in the United States. By using our Services, you consent to this transfer.

Future International Expansion: As we expand our services internationally, we may process data in additional jurisdictions and will update this Privacy Policy accordingly.

6. Data Retention

Account Data: We retain your account and transaction data for as long as your account remains active and thereafter as needed for our business operations and legal obligations.

KYC/AML Data: Identity verification data is retained in accordance with applicable financial regulations, even after account closure.

Communication Records: Customer support communications are retained to provide ongoing support and improve our services.

Analytics Data: App usage and analytics data may be retained for product improvement purposes.

7. Your Privacy Rights

7.1 Corrections

You may request corrections to inaccurate personal information by contacting us.

The availability of these rights may vary based on your location and applicable law.

7.2 Additional Rights for European Users

If you are located in the European Economic Area (EEA) or United Kingdom (UK), you have additional rights including:

7.3 California Residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect and how it's used, and the right to request deletion of your information.

8. Automated Decision-Making

We may use automated systems to make decisions about your account, including fraud detection, identity verification, and eligibility assessments. These decisions are made through our partners' systems to protect you and comply with legal requirements. If you believe an automated decision has negatively affected you, you may contact us to request a review.

9. Security Measures

We implement appropriate technical and organizational security measures to protect your personal information, including:

10. Third-Party Links and Services

Our Services may contain links to third-party websites or services. This Privacy Policy does not apply to such third-party services, and we encourage you to review their privacy policies.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated policy in our app and updating the "Last Updated" date above.

12. Contact Information

If you have questions about this Privacy Policy or our data practices, please contact us at:

GoldenBasis, Inc.
Email: [email protected]