Privacy Notice


The purpose of this notice is to provide you with information on our use of your personal data in accordance with the Data Protection Law (as Revised) of the Republic of Panama (the “DPL“). In this document, “we”, “us” and “our” refers to Union Protocol Labs, Inc. (together the “Company“) and its affiliates and/or delegates. This Privacy Notice describes our information handling practices when you access our services, services, which include our content on the website located at,, or any other Company website.

  1. Acceptance of this Privacy Notice
    By accessing and using our Website, you signify acceptance to the terms of this Privacy Notice.
    If you do not agree with or you are not comfortable with any aspect of this Privacy Notice, you should immediately discontinue access or use of our Services.
  2. Data
    By virtue of accessing a Company Website and your associated interactions with us (including any subscription (whether past, present of future), including the recording of electronic communications or phone calls where applicable) or by virtue of you otherwise providing us with personal information, you will provide us with certain personal information which constitutes personal data within the meaning of the DPL (“Data“). We may also obtain Data from other public sources. Data includes, without limitation, the following information relating to you and/or any individuals connected with you: name, residential address, email address, contact details, corporate contact information, signature, nationality, place of birth, date of birth, tax identification, credit history, correspondence records, passport number, bank account details, source of funds details and details relating to your investment activity.
  3. Who this Affects
    If you are a natural person, this will affect you directly. If you are a corporate body (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) that provides us with Data on individuals connected to you for any reason in relation to your interactions with us, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.
  4. How We May Use Your Personal Data
    The Company, as the data controller, may collect, store and use Data for lawful purposes, including, in particular:
    • where this is necessary for the performance of our rights and obligations under the Subscription Agreement and/or the constitutional and operational documents of the Company;
    • where this is necessary for compliance with a legal and regulatory obligation to which the Company is subject (such as compliance with anti-money laundering and FATCA/CRS requirements); and/or
    • where this is necessary for the purposes of our legitimate interests and such interests are not overridden by your interests, fundamental rights or freedoms.

    Should we wish to use Data for other specific purposes (including, if applicable, any purpose that requires your consent), we will contact you.

  5. Why We May Transfer Your Personal Data
    In certain circumstances we and/or our authorised affiliates or delegates may be legally obliged to share Data and other information with respect to your interactions with the Company with the relevant regulatory authorities. They, in turn, may exchange this information with foreign authorities, including tax authorities.

    We anticipate disclosing Data to the following parties who provide services to the Company and their respective affiliates (which may include certain entities located outside the Republic of Panama or the European Economic Area), who will process your personal data on our behalf:

    •; and
    • CipherTrace, Inc.;
  6. Changes to the Privacy Notice
    We may revise and update this Privacy Notice from time to time in our sole discretion. All changes are effective immediately when we post them.

    Your continued use of the Website following the posting of a revised Privacy Notice means that You accept and agree to the Changes. You are expected to check this page frequently so you are aware of any changes, as they are binding on You.

  7. Information we Collect Automatically
    To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with the Website or use the Services. This information helps us address customer support issues, improve the performance of our Website and applications, and satisfies our regulatory obligations. Information collected automatically includes:

    *Online Identifiers. This includes, but is not limited to, geo location / tracking details, browser fingerprint, operating system, browser name and version, and / or personal IP addresses.

    *Usage Data: Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies. Please read our Cookie Policy for more information.

    For example, we may automatically receive and record the following information on our server logs:

    • How you came to and use the Services;
    • Device type and unique device identification numbers;
    • Device event information (such as crashed, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL);
    • How your device interacts with our Website and Services, including pages accessed and links clicked;
    • Broad geographic location (ex. country or city location); and
    • Other technical date collected through cookies, pixel tags and other similar technologies that uniquely identify your browser.

    We may also use identifiers to recognize you when you access our Website via an external link, such as a link appearing on a third-party website.

  8. Information we collect from third-parties
    We may obtain information from third party sources as required or permitted by applicable law. We may analyze public blockchain data to ensure parties accessing our Website are not engaged in illegal or prohibited activity under our Terms of Use, and to analyze transaction trends for research purposes.
  9. Data Aggregation
    Union may anonymize or aggregate date we collect for any business purpose, including to better understand user needs and behaviors.
  10. The Data Protection Measures We Take
    Any transfer of Data by us or our duly authorised affiliates and/or delegates outside of the Republic of Panama shall be in accordance with the requirements of the DPL.

    We and our duly authorised affiliates and/or delegates shall apply appropriate technical and organisational information security measures designed to protect against unauthorised or unlawful processing of Data, and against accidental loss or destruction of, or damage to, Data.

    We shall notify you of any Data breach that is reasonably likely to result in a risk to the interests, fundamental rights or freedoms of either you or those data subjects to whom the relevant Data relates.

Getting In Touch
Should you have any queries or wish to discuss your data protection rights with us, please contact our compliance team at .