Privacy Policy - iTRY Limited
Last updated: 25 March 2025
This Privacy Policy explains how iTRY Limited (“iTRY”, “we”, “us” or “our”) collects, uses, stores, shares, and protects personal data when you:
Use iTRY services, through mint.brix.money (the “Application”) as a mint/redeem user (“Mint/Redeem User”);
Use iTRY services as a secondary market participant (“Holding user”)
otherwise interact with the iTRY, including contacting us.
We are committed to protecting your privacy and complying with applicable data protection laws, including:
the British Virgin Islands Data Protection Act, 2021 (“BVI DPA”)
By accessing or using our services, you acknowledge that you have read and understood this Privacy Policy.
If you have any questions about this Privacy Policy, please contact us at admin@itry.com and we will do our best to assist you.
1. Who We Are
Data Controller
iTRY Limited Craigmuir Chambers, PO Box 71 Road Town, Tortola VG1110, British Virgin Islands
Corporate Registration Number: 2190088 Email: admin@itry.network
iTRY Limited acts as the data controller in respect of personal data processed under this Privacy Policy.
2. Personal Data We Collect
We collect only the personal data that is necessary for legitimate business purposes and lawful operation of our services.
We may use your personal information to:
perform customer due diligence and ongoing monitoring in accordance with applicable laws;
operate iTRY related services;
communicate with you in connection with the services you use;
manage accounts, records, and internal administration;
support audit, compliance and risk management;
comply with applicable laws, regulations, and requests from competent authorities.
2.1 Information collected by using our services
If you accept our User Policy to use our services and to subscribe to our products, you will be required to upload information for KYC (Know-Your-Customer) purposes. This is required by regulators as part of the client’s onboarding process. Personal information such as names, addresses, email addresses, telephone numbers, date of birth and other personal details including your financial status will be collected for evaluation purposes. Such information is collected from users who voluntarily input such information.
Provision of this data is voluntary; however, iTRY Limited takes compliance and AML very seriously. Our services (such as minting and redeeming iTRY) require these checks and cannot be provided without it.
We use third-party blockchain analytics tools, including Chainalysis, to monitor secondary market transactions involving our tokens for purposes of fraud prevention, sanctions compliance, and regulatory obligations. Where these tools flag transactions or wallets as potentially high-risk, we record the relevant information — including the wallet address, risk flag, and any compliance-related decisions — in an internal log. This data is processed solely to comply with our legal obligations and for our legitimate interests in maintaining the integrity of our platform. The underlying intelligence provided by third-party tools remains the property of the third-party provider, while the logs and decisions we generate are processed and stored by us in accordance with applicable data protection laws.
Depending on your interaction with iTRY services, particularly if you are a mint / redeem user, you may voluntarily provide:
Communications and support correspondence
Any other information you choose to submit to us
2.2 Mint/Redeem Application Data
The mint/redeem application is operated by a third-party service provider. The provider does not process personal data on behalf of iTRY Limited. However, certain information may be shared with us from time to time to support audit or operational purposes. We process any such shared data in accordance with this Privacy Policy and applicable data protection laws.
2.3 Blockchain and Accounting Data
We do not control or store personal data recorded directly on public blockchains. However, we may process blockchain transaction data off-chain for legitimate business purposes such as accounting, audit, financial reporting, compliance, and record-keeping.
Where such data constitutes personal data under applicable law, it is processed in accordance with our legal obligations and legitimate interests, and is subject to appropriate technical and organisational safeguards.
2.4 Data You Provide Voluntarily
Depending on your interaction with us, you may voluntarily provide:
Email address
Communications and support correspondence
Any other information you choose to submit to us
Provision of this data is voluntary.
2.4 Marketing
We do not operate a marketing program. If we ever use your contact details to send you information about updates or developments related to iTRY Limited, we will do so only where permitted by law and where you have not objected.
3. How We Collect Personal Data
We collect personal data through:
Directly provided information – data you submit when using our services or contacting us.
KYC/KYB/AML checks – currently performed by an associated group entity; we maintain logs of negative risk hits and compliance decisions. May perform checks directly in the future.
Third-party transaction monitoring – using tools like Chainalysis to flag high-risk wallets; only outputs and decisions are stored internally.
Third-party service providers providing infrastructure support.
Blockchain and accounting data – off-chain processing for audit, accounting, and compliance purposes.
For a full list of the types of personal data we collect, see Section 2.
4. Purposes of Processing
We may process personal data for the following purposes:
4.1 Legal, Security and Compliance
complying with legal and regulatory obligations;
preventing fraud, abuse or security incidents;
investigating complaints, disputes or technical issues;
exercising or defending legal rights.
We may process “sensitive” or “special” categories of personal data (for example, data relating to criminal checks or sanctions status) only where required for AML/CFT, sanctions or regulatory compliance, and only as permitted by applicable data protection laws.
4.2 Services
maintaining service functionality and performance;
managing our whitelisted wallets database;
5. Legal Bases for Processing
Under the BVI DPA and GDPR, we rely on the following legal bases:
5.1 Consent
Where you voluntarily submit information, you consent to its processing. You may withdraw consent at any time by contacting admin@iTRY.network.
5.2 Legitimate Interests
We process data where necessary for our legitimate interests, including:
operating and improving our services;
communicating with users who have shown interest in iTRY;
ensuring platform security and integrity.
5.3 Legal Obligations
We may process or retain personal data where required by applicable law or regulatory authorities.
6. Data Sharing and Transfers
We do not sell personal data.
We may share personal data with:
service providers supporting infrastructure, analytics, or blockchain functionality;
professional advisers (legal, compliance, tax);
regulators or law enforcement where required by law; and
affiliated entities within our corporate group for operational purposes.
All third-party processors are subject to confidentiality and data protection obligations consistent with the BVI DPA.
International Transfers
Where personal data is transferred outside the British Virgin Islands, we ensure appropriate safeguards are in place in accordance with applicable data protection laws.
In the event of a merger, reorganisation, or transfer of assets, personal data may be transferred to the relevant successor entity, subject to applicable safeguards.
7. Data Retention
We retain your personal information only for as long as necessary for the purposes described in this Privacy Policy and as required by law.
7.1 KYC/CDD/ Compliance related data
In particular, we may retain AML/KYC-related records for a minimum period required by applicable regulations (at least five (5) years after the end of the business relationship or a given transaction), or longer where legally required or in connection with investigations or legal proceedings. After the retention period expires, personal information is deleted or anonymised in a secure manner.
7.2 Accounting Data
Off-chain blockchain transaction data and related accounting records are retained for as long as necessary to meet legal, regulatory, and internal audit requirements, typically for up to 7 years. All such data is stored securely and processed in accordance with applicable data protection laws.
7.3 All other data
Data pertaining to use of services and contact data: up to 36 months
You may request deletion at any time, subject to legal obligations.
8. Your Rights
Under the BVI DPA, you have the right to:
access your personal data;
rectify inaccurate or incomplete data;
request deletion of your data;
withdraw consent at any time;
object to or restrict processing;
request data portability; and
lodge a complaint with a supervisory authority.
To exercise any of these rights, please contact us at admin@iTRY.network.
9. Security Measures
We are committed to protecting the security of your personal information. We use appropriate technical and organisational measures, which may include:
encryption of data in transit and at rest;
access controls and least-privilege principles;
secure infrastructure and monitoring;
periodic review of security practices.
10. Contact Us
For questions regarding this Privacy Policy or our data practices, please contact:
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Any changes will be effective upon publication, and the “Last updated” date will reflect the most recent revision.
Last updated