KYC/KYB Privacy Notice

1. Introduction

1.1. This KYC/KYB Privacy Notice explains how Grant Fund LLC processes personal data and business data for know-your-customer, know-your-business, sanctions, export-control, UBO, AML, fraud-prevention, payment-risk, abuse-prevention, and compliance purposes.

1.2. This Notice supplements the Privacy Policy, Terms and Conditions, Data Processing Addendum, and other applicable legal documents.

2. Why KYC/KYB processing may be required

2.1. Grant Fund may perform KYC/KYB and related compliance screening to comply with legal obligations, manage sanctions and export-control risks, prevent fraud and abuse, protect the Service, manage payment and chargeback risks, protect Grant Fund's legitimate interests, and determine whether to provide, restrict, suspend, terminate, refund, export, or support the Service.

2.2. KYC/KYB may be applied at registration, Passport creation, subscription, refund request, export request, support request, success-fee service request, payment processing, suspicious activity review, or any other point Grant Fund considers appropriate.

3. Data categories

3.1. Identity data: names, dates of birth where required, nationality where required, identification details where required, professional roles, business contact details, and identity-verification status.

3.2. Business data: legal entity name, registration number, VAT or other tax identification number, registered address, operating address, corporate structure, business activities, sector, jurisdictions, websites, public profiles, and company registry information.

3.3. Ownership and control data: shareholders, beneficial owners, directors, officers, authorised representatives, control structure, group structure, UBO percentages, source of control, and related corporate records.

3.4. Compliance data: sanctions screening results, restricted-party results, PEP indicators, adverse media indicators, export-control indicators, restricted-sector indicators, high-risk jurisdiction indicators, AML/KYC/KYB risk indicators, fraud indicators, chargeback indicators, abuse indicators, payment-risk data, and internal compliance decisions.

3.5. Source-of-funds and payment-risk data: billing details, payment method metadata, transaction identifiers, invoices, refund history, chargeback history, bank or payment provider records, source-of-funds information where required, and fraud-prevention signals.

3.6. Public-source data: company registries, sanctions lists, restricted-party lists, PEP lists, adverse media, government records, public websites, official portals, public grant records, and other publicly available information.

4. Purposes

4.1. To verify identity, authority, ownership, control, and business legitimacy.

4.2. To screen against sanctions lists, restricted-party lists, PEP lists, adverse media, export-control indicators, fraud indicators, abuse indicators, high-risk jurisdictions, high-risk sectors, and other compliance sources.

4.3. To assess whether Grant Fund may lawfully provide the Service, process payments, issue refunds, provide exports, provide support, or enter into additional services.

4.4. To detect and prevent sanctions evasion, AML risk, export-control violations, payment fraud, chargeback abuse, account abuse, scraping, fake accounts, identity misrepresentation, and other misuse.

4.5. To comply with legal, regulatory, payment, tax, accounting, audit, sanctions, export-control, court, law-enforcement, and public-authority obligations.

4.6. To establish, exercise, or defend legal claims and enforce the Terms.

5. Legal bases

5.1. Legal obligation: where KYC/KYB, sanctions, export-control, tax, payment, AML, regulatory, or similar processing is required by law.

5.2. Legitimate interests: where processing is necessary to prevent fraud, manage legal and reputational risk, protect the Service, ensure compliance, prevent abuse, protect payment integrity, and enforce contractual rights, provided those interests are not overridden by the rights and freedoms of individuals.

5.3. Contract performance: where processing is necessary to provide, restrict, suspend, terminate, refund, export, or support the Service under the Terms.

5.4. Consent: where a specific verification step legally requires consent.

6. Recipients

6.1. KYC/KYB data may be disclosed to Grant Fund personnel, contractors, advisors, counsel, auditors, payment providers, tax providers, KYC/KYB providers, sanctions-screening providers, fraud-prevention providers, hosting providers, security providers, banks, card networks, regulators, courts, law-enforcement bodies, public authorities, and other recipients where necessary or permitted.

6.2. Some providers may act as independent controllers for certain compliance, payment, fraud-prevention, or verification activities.

7. International transfers

7.1. KYC/KYB providers, payment providers, sanctions-screening providers, fraud-prevention providers, or support providers may process data outside the EEA.

7.2. International transfers will rely on adequacy decisions, Standard Contractual Clauses, transfer-impact assessments, supplementary measures, derogations, or other lawful mechanisms where required.

8. Retention

8.1. KYC/KYB and compliance data may be retained for as long as required or permitted for legal, regulatory, sanctions, export-control, tax, accounting, audit, payment, anti-fraud, security, dispute, chargeback, or legal-defence purposes.

8.2. Retention may continue after Account closure where necessary to evidence compliance decisions, prevent repeat abuse, respond to regulators, defend claims, or comply with law.

9. Consequences of not providing data

9.1. If a User does not provide requested KYC/KYB or compliance data, Grant Fund may refuse registration, restrict features, suspend access, terminate the Account, withhold exports, refuse refunds, refuse additional services, or decline to process payments where legally or operationally necessary.

10. Rights

10.1. Individuals may have rights of access, rectification, erasure, restriction, objection, portability, withdrawal of consent, and complaint to a supervisory authority, subject to applicable law.

10.2. Some rights may be limited where necessary for legal obligations, sanctions compliance, AML/KYC/KYB obligations, fraud prevention, security, confidentiality, legal defence, audit, or public-interest reasons.

11. Contact

11.1. Questions about KYC/KYB processing may be sent to privacy@grant.fund.