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Privacy Policy


The following are the terms and conditions governing your (hereinafter "Publisher") relationship with Horka Network (hereinafter "Horka Network") and the use of any website associated with Horka Network's services (hereinafter "Site"). Publisher agrees to use the Site and any additional services offered by Horka Network only in accordance with these Terms and Conditions. Horka Network reserves the right to make changes to the Site and these Terms and Conditions at any time. Publisher's continued use of the Site after any such modification and notification thereof (which may be provided by e-mail to the email address provided in the course of Publisher's registration with Horka Network) shall constitute Publisher's consent to such modification.

1. Introduction

This Privacy Policy explains how Horka Network uses client's Personal Data (defined below). Horka Network provides access and utility through our platform via software, API (application program interface), technologies, products, and/or functionalities ("Service"). In the course of providing the Service, to abide by the laws in the jurisdictions that Horka Network operates and to improve services, Horka Network needs to collect and maintain personal information about the client. As a rule, Horka Network never discloses any personal information about our customers to any non-affiliated third parties, except as described below.
Horka Network may update this Privacy Policy at any time by posting the amended version on this site, including the effective date of the amended version. Horka Network communicates any material changes to this Privacy Policy via email.


2. Personal Data

As used herein, "Personal Data" means any information relating to an identified or identifiable natural person, such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, economic, cultural, or social identity of you as a natural person.

3. Collection of Personal Data

Horka Network collects, processes, and stores Personal Data collected from you via your use of the Service or where you have given consent. This Personal Data may include contact details, copies of identification documentation provided by you or derived from publicly accessible databases, government identification numbers, as well as information relating to devices or internet service (such as an IP address and a MAC number). Horka Network collects information provided during the onboarding process, which may be a completed, incomplete, or abandoned process.

Horka Network collects, uses, stores, and transfers Personal Data, which may include the following:
Operating within the European Economic Area ("EEA").
Horka Network collects, stores, and processes personal information in accordance with the Best Practices of Data Collection in the EU, in addition to GDPR [General Data Protection Regulation - (EU) REGULATION 679/2016].
Types of clients are defined in APPENDIX A.


4. Collection and Storing of Data Outside the EU

As outlined above, Horka Network may collect Personal Data from customers located in the EEA. To facilitate the services Horka Network provides to customers located in the EEA, Horka Network requests explicit consent for the transfer of Personal Data from the EEA to outside of the area. If you are an individual located in the EEA and decline to consent to such transfer, you will no longer be able to use Horka Network services.


5. Personal Data Usage

Horka Network uses Personal Data to communicate with you and to administer, deliver, improve, and personalize the Service. Horka Network might also generate generic data out of any Personal Data collected and use it for company purposes. Horka Network may also use such data to communicate with you in relation to other products or services offered by Horka Network and/or its partners. Horka Network does not share Personal Data with third parties (other than partners in connection with their services) except where you have given consent and as further detailed below.

6. Horka Network may share Client Personal Data with third parties

Horka Network may share Client Personal Data with third parties in the following circumstances:

  • If Horka Network deems that sharing is necessary to enforce the Terms of Service.

  • To comply with government agencies, including regulators, law enforcement, and/or justice departments.

  • To third parties who provide services to Horka Network (such as administration or technical services).

  • In connection with the sale or transfer of our business or any part thereof. Additionally, Horka Network has implemented international standards to prevent money laundering, terrorist financing, and circumvent trade and economic sanctions. Horka Network will implement final rules and regulations when effective, which will likely require us to undertake due diligence on our customers. This may include the use of third-party data and service providers, which we will cross-reference with your personal information.


7. Storage of Personal Data

The data that Horka Network collects from the client may be transferred to, and stored at, a destination outside of the EU. It may also be processed by staff operating outside of the EU who work for Horka Network or for one of our suppliers. By submitting client personal data, you agree to this transfer, storing, or processing, except for customers located in the EEA, as detailed above. All information you provide to us is stored on Horka Network's and/or third-party cloud servers.

8. Access and Correction of Personal Data

By entering these Terms and Conditions, the client warrants and represents that:

  • You have the right to obtain a copy of Personal Data upon request and ascertain whether the information Horka Network holds about you is accurate and up-to-date.

  • If any of the Personal Data is inaccurate, you may request to update the information. You may also request to delete Personal Data, with the exception that Horka Network may refuse your deletion request in certain circumstances, such as compliance with the law or legal purposes. For data access, correction, or deletion requests, please contact Horka Network. In response to a data access, correction, or deletion request, Horka Network will verify the requesting party's identity to ensure that he or she is legally entitled to make such a request. While Horka Network aims to respond to these requests free of charge, we reserve the right to charge you a reasonable fee should the request be repetitive or onerous.


9. Marketing

Horka Network may communicate company news, promotions, and information relating to our products and services. Horka Network may share Personal Data with third parties to help with marketing and promotional projects or send marketing communications. By using our services, you accept this Privacy Policy and agree to receive such marketing communications. Customers can opt-out of these marketing communications at any moment. If you do not want to receive these communications, please send an email to [email address]. For product-related communications, such as policy/terms updates and operational notifications, you will not be able to opt out of receiving such information.

10. Information Security

Horka Network endeavors to protect clients from unauthorized access, alteration, disclosure, or destruction of Personal Data that we collect and store. We take various measures to ensure information security, including encryption of communications with SSL, required two-factor authentication for all sessions, periodic review of our Personal Data collection, storage, and processing practices, and restricted access to client's Personal Data on a need-to-know basis for our employees and vendors who are subject to strict contractual confidentiality obligations.


11. Contacting Horka Network about Privacy Concerns

If you have any questions about this Privacy Policy or the use of Personal Data, please contact us by sending an email to the following address: [email protected] with the subject "PRIVACY REQUEST."

12. Changes to the Privacy Policy

Any changes made to Horka Network's Privacy Policy in the future will be posted on our website, and when appropriate, we will notify you by email.



Definition of Clients

  1. Individual clients:

  • Email address

  • Mobile phone number

  • Full legal name (including former name and names in the local language)

  • Nationality

  • Passport number or any government-issued ID number

  • Date of birth ("DOB")

  • Proof of identity (e.g., passport, driver's license, or government-issued ID)

  • Residential address

  • Proof of residency

  • Additional Personal Data or documentation at the discretion of our Compliance Team


Corporate clients:

  • Corporate legal name (including the legal name in local language)

  • Incorporation/registration Information

  • Full legal name of all beneficial owners, directors, and legal representatives

  • Address (principal place of business and/or other physical locations)

  • Proof of legal existence

  • Description of the business

  • Percentage of ownership for Individual/corporate owners

  • Contact information of owners, principals, and executive management (as applicable)

  • Proof of identity (e.g., passport, driver’s license, or government-issued ID) for significant individual beneficial owner of the institutional customer entity

  • Personal Data for each entity’s significant beneficial owner of the institutional customer entity (see the “Individual Customer” section above for details on what Personal Data we collect for individuals)

  • Source of wealth

  • Amount of bitcoin or other digital assets projected to be injected

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