Data Privacy Policy

DATA PRIVACY POLICY

Privacy Notice

At Delphi Delta Investment Corporation ("Delphi Delta," "we," "us," or "our"), we prioritize the protection of personal information entrusted to us. As a New York-based financial institution engaged in cryptocurrency trading and investment services, we uphold stringent data safeguards as a fiduciary duty under U.S. federal and state laws.

This Privacy Notice details our personal data handling practices, your rights, and legal protections. It applies to information you provide directly and, per applicable law, data from third-party sources.

"Delphi Delta" includes Delphi Delta Investment Corporation and U.S. affiliates/subsidiaries.

Core privacy principles:

Collect only necessary data for client needs and crypto operations.
Leverage data for superior trading services/products.
Disclose externally only with consent or legal mandate.
Share with authorities (e.g., SEC, CFTC, FinCEN) under proper authority.
Ensure data accuracy/updates.
Implement controls against unauthorized access.

LAWFUL BASIS FOR PROCESSING

Processing complies with Gramm-Leach-Bliley Act (GLBA) Title V, SEC Regulation S-P, CCPA/CPRA (Cal. Civ. Code § 1798.100 et seq.), NY SHIELD Act, and analogs. Bases include:

Contract fulfillment (e.g., trading agreements);
Legal/regulatory obligations (e.g., FinCEN SAR filings under BSA/AML);
Legitimate interests balanced via Privacy Impact Assessments (PIAs);
Explicit consent.

YOUR CONSENT

Processing occurs upon consent, for contracts, or legally required. Consent via onboarding forms/relationship. Disclosures limited to:

Legal mandates/exemptions (e.g., SEC Reg S-P § 248.15);
Justice/public interest/identifier sharing;
Contract necessity;
Vital interests protection;
Authorized purposes.

CHANGE OF PURPOSE

Uses confined to original intent or compatible purposes, with notice where required under CCPA.

TYPES OF INFORMATION COLLECTED

Personal Information (PI)/Personal Data:
"National Identifier" : SSN/ITIN, passport.
"Contact" : Address, phone, email.
"Socio-Demographic" : Occupation, nationality, education, income.
"Financial" : Assets, crypto history, net worth.
"Transactional" : Trades, wallet addresses, transfers.
"Locational" : IP, geodata from platforms.
"Behavioral/Usage" : Platform interactions.
"Technical" : Devices, browsers.
"Communications" : Recorded interactions.
"Social" : Beneficial owners for Identity verification.
"Public" : Records, blockchain explorers.
"Documentary" : ID scans.
Sensitive PI (CCPA "Sensitive Personal Information"): Processed minimally (e.g., SSN portions for verification), racial/ethnic data only if material to crypto risk assessment.

PURPOSES

Administer crypto trading, custody, advisory, compliance (e.g., SEC/CFTC reporting, FinCEN Travel Rule).

COLLECTION METHODS

Directly from you; affiliates; third parties (e.g., Identity verification/AML providers like Chainalysis, credit bureaus, wallets).

DELPHI DELTA WEBSITES AND COOKIES

Cookies/trackers per browser controls. CCPA notice for California residents on sales/sharing.

MARKETING

Consent/legitimate interest-based; opt-out via privacy@delphidelta.com or CCPA mechanisms.

USES

Service delivery, eligibility, needs assessment, claims, credit/Identity verification, marketing (consented), contracts.

DISCLOSURES ("Sales/Sharing" under CCPA)

To service providers (e.g., custodians, fraud detection, auditors). No sales for monetary gain; limited sharing for analytics (opt-out available).

SECURITY (GLBA Safeguards Rule, SEC Reg S-P)

Physical/technical/administrative measures: encryption (AES-256), MFA, firewalls, annual audits, incident response per NIST Cybersecurity Framework.

YOUR RIGHTS (CCPA/CPRA, GLBA, State Laws)

"California" : Know/access, delete, correct, opt-out sales/sharing, limit sensitive use, non-discrimination.
"General" : Access, rectification, erasure, restriction, objection, portability, withdraw consent.
"NY/VA/etc." : Analogous under SHIELD Act, VCDPA.
Submit verifiable requests to DPO; two free CCPA responses/year.

CONTACT:

Data Protection Officer
Delphi Delta Investment Corporation
120 Wall Street, New York, NY 10005
USA
"Email" : privacy@delphidelta.com

NOTICE DELIVERY

Posted on website; provided at onboarding; notified of material changes.

CHANGES

Updated as needed; current: February 2026. Review periodically.