Effective Date: January 1, 2025 | Last Updated: 2025
1. Introduction
Dana Express LLC ("Company," "we," "us," or "our"), operating also as EBT Consulting LLC, is committed to protecting the privacy and security of personal information collected in the course of providing cryptocurrency wallet and digital asset services.
This Privacy Policy describes how we collect, use, disclose, and safeguard personal information obtained from customers, prospective customers, and visitors to our website at de-llc.it.com ("Site").
By using our Site or services, you agree to the collection and use of information in accordance with this policy.
2. Information We Collect
2.1 Identity Information (Required for Services)
As a regulated Money Services Business, we are legally required to collect and verify identity information before providing services. This includes:
- Full legal name
- Date of birth
- Government-issued identification (e.g., driver's license, passport)
- Social Security Number or Tax Identification Number (where applicable)
- Physical address and proof of address
2.2 Contact Information
- Email address
- Phone number
- Mailing address
2.3 Transaction Information
- Transaction history, amounts, and counterparty wallet addresses
- Source of funds information (where required by regulation)
2.4 Website Usage Data
- IP address, browser type, and device information
- Pages visited and time spent on the Site
- Referring URLs
3. How We Use Your Information
We use collected information for the following purposes:
- Service Delivery: To provide cryptocurrency wallet and money transmission services
- Identity Verification (KYC): To verify your identity as required by applicable law
- AML Compliance: To screen transactions and detect suspicious activity as required by the Bank Secrecy Act
- Legal Reporting: To file required reports with FinCEN (SAR, CTR) and other regulators
- Customer Support: To respond to inquiries and provide assistance
- Legal Obligations: To comply with applicable laws, regulations, and court orders
- Fraud Prevention: To detect and prevent fraudulent, illegal, or unauthorized activity
4. Information Sharing and Disclosure
We do not sell, trade, or rent your personal information to third parties. We may share information in the following circumstances:
- Legal Requirements: We are required by law to share information with FinCEN, law enforcement, and other governmental authorities in connection with our BSA obligations, including SAR filings.
- OFAC Compliance: We screen against OFAC sanctions lists and may report as required.
- Regulators: We may share information with state and federal regulators in connection with examinations or investigations.
- Service Providers: We may use third-party service providers (e.g., identity verification vendors) who process data on our behalf under contractual confidentiality obligations.
- Legal Process: In response to valid subpoenas, court orders, or other legal process.
Note on SAR Confidentiality: Federal law prohibits us from disclosing to customers that a Suspicious Activity Report has been filed. If required to file a SAR, we will not notify the subject of such a filing.
5. BSA Recordkeeping Requirements
As a registered MSB under the Bank Secrecy Act, we are required to retain certain records for minimum periods set by federal regulation. Customer identification records must be retained for at least 5 years from the date of account closure. Transaction records must be retained for at least 5 years from the date of the transaction. We may retain records longer where required by law or regulatory guidance.
6. Data Security
We implement appropriate technical and organizational measures to protect personal information against unauthorized access, disclosure, alteration, and destruction. These measures include access controls, encryption of sensitive data in transit, and regular review of our security practices.
No method of transmission over the internet is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.
7. Your Rights
Subject to applicable law, you may have the right to:
- Access the personal information we hold about you
- Request correction of inaccurate information
- Request deletion of information (subject to our legal retention obligations)
Certain rights may be limited or unavailable where we are required to retain information under the Bank Secrecy Act or other applicable law. To exercise your rights, contact us at support@de-llc.it.com.
8. Cookies and Tracking
Our website may use essential cookies to enable basic website functionality. We do not use advertising cookies or track users across third-party websites. You may configure your browser to refuse cookies, though this may affect certain website functionality.
9. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be posted on this page with an updated effective date. Continued use of our services after a policy update constitutes acceptance of the revised policy.