The purpose of this Privacy Policy (the “Policy”) is to describe how Independent Well USA Corp., doing business as Bitcoin Well ("Independent Well," the “Company," "we," "us," or "our") collects, uses, discloses, and protects personal information obtained through its operations in the United States, including through the Platform (as defined in our Terms of Service). This Policy supports Independent Well USA Corp.'s obligations under applicable U.S. federal and state privacy and consumer protection laws, including the Gramm-Leach-Bliley Act (GLBA), and the Federal Trade Commission Act (FTC Act).
In the Policy, information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identified or identifiable individual is personal information (“Personal Information”).
This Policy supplements and should be read with Independent Well USA Corp.’s Terms of Service.
Independent Well USA Corp. is committed to protecting your privacy, handling your Personal Information with care, maintaining transparency in its data practices and ensuring that Personal Information is collected and handled lawfully, fairly, and securely. This Policy provides users with a clear understanding of:
Independent Well USA Corp. does not sell Personal Information for monetary consideration. We do not share Personal Information for cross-context behavioral advertising, and we do not use Personal Information to provide targeted advertising. We do not knowingly use or disclose Sensitive Personal Information for purposes other than providing the services, verifying identity, preventing fraud, protecting security, complying with legal and regulatory obligations, or other purposes permitted by applicable law.
We collect Sensitive Personal Information only as reasonably necessary to provide the services, verify identity, prevent fraud and other unlawful activity, and comply with applicable legal and regulatory obligations, including obligations under the Bank Secrecy Act and related anti-money laundering requirements.
This Privacy Policy applies to individuals located in the United States who use the products and services of Independent Well USA Corp. It governs the collection, use, disclosure, and protection of Personal Information obtained through the Company's operations, digital platforms, communication channels, and customer interactions.
This Policy applies to all Personal Information collected directly from clients, prospective clients, business partners, and other individuals who engage with the Company. It also applies to information received indirectly through authorized third-party service providers that support the Company's operations.
Independent Well USA Corp. operates as a Money Services Business (MSB) registered with the Financial Crimes Enforcement Network (FinCEN) under registration number 31000308454032. As a registered MSB, the Company is subject to the Bank Secrecy Act (BSA), the Anti-Money Laundering Act of 2020, and related Financial Crimes Enforcement Network (FinCEN) regulations. These laws require the Company to collect, verify, and retain certain identifying information to meet its regulatory obligations.
This Policy applies only to information collected and controlled by Independent Well USA Corp. Information collected or processed by third-party service providers acting independently under their own privacy policies is outside the scope of this Policy.
Children's Privacy. Consistent with the Terms of Service, our products and services are available only to individuals who are at least eighteen (18) years of age and capable of entering into a binding contract. We do not knowingly collect Personal Information from individuals under 18, and if we learn that we have done so, we will take steps to delete that information.
Independent Well USA Corp. collects Personal Information that is necessary to establish and maintain business relationships, comply with regulatory obligations, and deliver secure financial services. The categories of information collected depend on the nature of the user's interactions with the Company and the products or services requested.
The Company may collect Personal Information that users provide directly through account creation, identity verification, transaction requests, or other communications. This information may include:
2.1.1 Biometric Information and Consent
Before we collect any biometric information described above, we obtain your separate written consent, presented to you before the camera opens and distinct from this Policy, describing what we collect, why, who receives it, and how long we keep it. Sumsub processes this information on our behalf, as described in Section 4.2. We do not sell, lease, trade, or otherwise profit from biometric information. Consistent with our publicly available biometric data retention and destruction schedule, facial-geometry scans and other biometric identifiers are destroyed when the initial purpose for their collection (identity verification) has been satisfied, or within 5 years of your last interaction with us, whichever occurs first, except that records we are independently required by law to retain – including a copy of your identification document – are kept for five years to meet Bank Secrecy Act recordkeeping requirements, as described in Section 5.
When users interact with the Company's websites or digital applications, limited technical and usage data may be automatically collected. This information helps maintain platform security, monitor for suspicious activity, and ensure reliable service delivery. It may include:
Device identifiers, browser type, operating system, and access times;
Internet Protocol (IP) address and general location derived from network routing information; and
Logs of user activity within Company-controlled systems, including date, time, and session details.
Cookies - data files placed on your device that often include an anonymous unique identifier; and
Web beacons, tags, and pixels - electronic files used to record browsing behavior.
The Company does not use cookies or tracking technologies for third party advertising purposes and does not engage in cross-context behavioral advertising.
2.2.1 Cookies, Do Not Track Signals, and Global Privacy Control
Our websites may use cookies and similar technologies to support platform security, session management, and basic analytics, as described in Section 2.2 above. Some web browsers offer a “Do Not Track” (DNT) signal; because there is no common industry standard for how businesses should respond to DNT signals, we do not currently respond to them. We do honor the Global Privacy Control (GPC) signal, where it is sent by your browser or device, as a valid consumer request to opt out of the sale or sharing of your Personal Information under applicable law.
The Company may obtain additional information from verified third-party sources to meet its due diligence and regulatory requirements. These sources may include:
Once we associate third-party information with your account or otherwise process it as personal information, we handle it in accordance with this Policy.
Independent Well USA Corp. uses Personal Information to operate its business, deliver services, and meet legal and regulatory requirements. All use of information is consistent with applicable federal and state privacy and consumer-protection laws.
Personal Information may be used to:
Independent Well USA Corp. does not use Personal Information for third-party marketing, profiling, or targeted advertising. The Company does not sell or share mobile numbers or related contact information with third parties or affiliates for marketing or promotional purposes. Text message opt in data and consent information is used only to provide the services you request and is not shared with any marketing or sales third party.
We may disclose mobile telephone numbers and related information to service providers that help us deliver communications, customer support, account security, identity verification, fraud prevention, or the services, and to government authorities or other parties when required or permitted by law. SMS opt-in and consent information is used only to provide communications and services requested or authorized by you, maintain records of your consent, and comply with applicable law.
Independent Well USA Corp. shares Personal Information only when necessary to conduct lawful business activities, meet regulatory requirements, or legal obligations. We do not sell your Personal Information for monetary consideration. We do not share Personal Information for cross-context behavioral advertising, and we do not use Personal Information to provide targeted advertising. We do not knowingly use or disclose Sensitive Personal Information for purposes other than providing the services, verifying identity, preventing fraud, protecting security, complying with legal and regulatory obligations, or other purposes permitted by applicable law. In all cases, we share the minimum information reasonably necessary, and where applicable, require service providers contractually to protect it and use it only for the purposes we specify.
Personal Information may be shared in the following circumstances:
Independent Well USA Corp. takes reasonable steps to ensure that any third party receiving Personal Information provides safeguards consistent with applicable privacy and data protection laws.
Independent Well USA Corp. uses Plaid Inc. ("Plaid") to securely collect and share information from users' financial institutions. When you choose to link a financial account, Plaid accesses and transmits the relevant account data to Independent Well USA Corp. to support account verification and authorized transactions.
By connecting a financial account, you consent to Plaid's access, use, and transmission of your information as described in the Plaid End User Privacy Policy, available at https://plaid.com/legal/#end-user-privacy-policy.
4.2 Identity Verification (Sumsub)
We use Sumsub (Sum and Substance Ltd.) to verify your identity. Sumsub receives your name, date of birth, address, identification number, images of your identification document, and photographs or video of your face, and processes this information on our behalf and under our instructions. We obtain your separate written consent before collecting biometric information for identity verification, as described in Section 2.1.1 above. Sumsub's public privacy notice is available at https://sumsub.com/privacy-notice/.
4.3 BitGo
Digital asset trading, settlement, and custody services accessible through the Platform are provided by BitGo, Inc. (“BitGo”). To open and operate your BitGo account, we share your identity and contact information, your identity-verification results, your linked bank account details, your wallet address, and your transaction instructions with BitGo. BitGo is an independent financial institution, not our affiliate, and uses this information for its own account opening, anti-money laundering and sanctions compliance, trade execution, settlement, custody, recordkeeping, and regulatory reporting, as described in the BitGo Privacy Policy (https://www.bitgo.com/privacy). We share this information with BitGo before you accept the BitGo Customer Agreements, so that BitGo can open your account.
4.4 Heritage IRA
If you open an individual retirement account (an “IRA”), we share your identity and contact information, your identity-verification results, your BitGo account details, and your IRA elections with Heritage IRA Inc. (“Heritage IRA”). Heritage IRA is an independent financial institution, not our affiliate, and uses this information to open, administer, and report on your IRA, as described in the Heritage IRA Privacy Policy (https://heritageira.com/privacy-policy-2/). BitGo acts as a qualified custodian for assets held in your Heritage IRA account.
4.5 Information We Receive From BitGo and Heritage IRA
BitGo and Heritage IRA share information with us about your accounts, including account status, verification outcomes, balances, transaction confirmations, and tax information. We use this information to operate the Platform, provide customer support, and meet our compliance oversight obligations.
Independent Well USA Corp. retains Personal Information for as long as necessary to meet operational needs, fulfill legal and regulatory obligations, and maintain accurate business and financial records. The Company follows the recordkeeping standards established under the Bank Secrecy Act (BSA) and the Anti-Money Laundering (AML) Act of 2020. Records created to verify your identity, including copies of identification documents, are generally retained for at least five years after the account relationship ends, consistent with Bank Secrecy Act recordkeeping rules. Biometric information is retained only as described in Section 2.1.1.
Records may be retained for longer periods when required by law, to support investigations, audits, or regulatory reviews, or when necessary to protect the Company's legal interests. When Personal Information is no longer required for these purposes, it is securely deleted, anonymized, or otherwise disposed of in accordance with the Company's Data Retention & Disposal Policy.
Independent Well USA Corp. maintains administrative, technical, and physical safeguards to protect Personal Information against unauthorized access, use, disclosure, or destruction. These safeguards include, but are not limited to:
Independent Well USA Corp. respects the privacy and rights of individuals whose information it collects and maintains. In accordance with applicable U.S. federal and state privacy laws, users may have certain rights related to the Personal Information collected by the Company.
Subject to verification and applicable law, users may have the right to:
6.1 How to Submit a Request
To submit a privacy request, contact us at: privacy@bitcoinwell.com we will respond within 45 days of receiving a verifiable request, extendable once by an additional 45 days where permitted by law.
Please describe your request with sufficient detail for us to understand, evaluate, and respond to it. We may request information to verify your identity and authority to make the request. We will not require you to create an account solely to submit a privacy request.
6.2 California “Shine the Light” Notice
California Civil Code Section 1798.83 (the “Shine the Light” law) permits California residents to request information about our disclosure, if any, of personal information to third parties for those third parties' own direct marketing purposes. Independent Well USA Corp. does not disclose personal information to third parties for their direct marketing purposes.
6.3 Nevada Privacy Rights
Under Nevada Revised Statutes Chapter 603A (NRS 603A.340), Nevada residents may submit a verified request directing us not to sell certain covered information. Independent Well USA Corp. does not sell covered information as defined under Nevada law. Nevada residents may submit a request or question about this notice to privacy@bitcoinwell.com.
We may update or modify this Policy from time to time, for example to reflect changes in our practices, clarify our policies, introduce or remove features, address technology changes, or ensure compliance with legal requirements or guidance. If we make material changes, we will notify you by appropriate means, such as by posting a notice on our website or in-app, sending an email notification to the address associated with your account, or otherwise providing notice as required by law. We will also update the “Effective Date” date at the top of this Policy.
We encourage you to review this Policy periodically to stay informed about our data practices. Your continued use of the Platform after any changes to this Policy signifies your acknowledgement of the updated terms, to the extent permitted by law. If you do not agree with any update, you should discontinue use of the Platform and may request that we delete your personal Information, subject to the limitations described in this Policy.
Where a change requires consent under applicable law, we will seek consent before applying the relevant change. We will not apply changes to this Policy retroactively without your consent where consent is required by law.
Governing law and dispute resolution are addressed in our Terms of Service (see, in particular, Section 14, Dispute Resolution and Mandatory Arbitration, and Section 16, Governing Law). Nothing in this Policy limits any rights or remedies you may have, or the jurisdiction of any supervisory authority or regulator, under the mandatory privacy, consumer-protection or data-protection laws of your jurisdiction.
Independent Well USA Corp. will respond to verified privacy-related requests and other inquiries regarding this Privacy Policy.
Independent Well USA Corp.
Attn: Privacy
Unit 203, 10138 82 Ave
Edmonton, Alberta T6E 1Z4 Canada
Email: privacy@bitcoinwell.com