Privacy Policy

1. Who we are

Verifluence OÜ ("Verifluence", "we", "us") is a company registered in Estonia (registry code 17463448), located at Harju maakond, Saku vald, Saku alevik, Silla tn 11, 75501, Estonia. We operate the Verifluence platform at verifluence.io.

For the purposes of the EU General Data Protection Regulation (GDPR), Verifluence OÜ is the data controller.

Contact: info@verifluence.io

2. What this policy covers

This Privacy Policy explains how we collect, use, store, and share personal data when you visit our website, create an account, or use the Verifluence platform as a streamer or casino operator.

3. Data we collect

3.1 Account data

When you sign up, we collect your name, email address, and account type (streamer or operator). Operators also provide company name, website, and business contact details.

3.2 Identity verification (KYC) data

To comply with anti-fraud and platform integrity requirements, streamers must complete identity verification. This process is handled entirely by our third-party provider, Sumsub (Sum and Substance Ltd). During verification, Sumsub may collect your government-issued ID, selfie or liveness check, date of birth, nationality, and document numbers.

Verifluence does not store your identity documents or biometric data. We only receive a verification status (approved, pending, or rejected) and a verification reference ID from Sumsub. Sumsub processes this data as an independent data controller under their own privacy policy.

3.3 Wallet and payment data

We collect your cryptocurrency wallet address(es) for receiving escrow payouts. On-chain transaction data (transaction hashes, amounts, timestamps) is inherently public on the blockchain and is not considered private data under this policy.

3.4 Platform activity data

We collect data related to your use of the platform, including campaign applications, deal terms, delivery confirmations, dispute records, and communication logs between streamers and operators within the platform.

3.5 Technical and usage data

When you visit our website or use the platform, we automatically collect IP address, browser type and version, device information, pages visited and time spent, and referral source. This data is collected through cookies and similar technologies (see Section 8).

4. How we use your data

We use your personal data to operate and maintain the platform and your account, facilitate campaign matching, deal negotiation, and escrow payouts, verify your identity through Sumsub, resolve disputes between streamers and operators, communicate with you about your account, campaigns, and platform updates, comply with applicable laws and regulations, and prevent fraud, abuse, and platform manipulation.

Legal bases for processing (under GDPR Article 6): contract performance (account operation, escrow, campaigns), legitimate interests (fraud prevention, platform security, analytics), legal obligation (regulatory compliance, record-keeping), and consent (marketing communications, cookies).

5. Who we share data with

5.1 Between platform users

Operators can see a streamer's verified status, public profile, and streaming channel information. Operators never see a streamer's identity documents, personal address, date of birth, or KYC details.

Streamers can see an operator's company name, brand, and campaign details.

5.2 Third-party service providers

We share data with the following categories of providers:

• Sumsub (identity verification) — processes KYC data as an independent controller
• Blockchain networks — wallet addresses and transaction data are recorded on-chain as part of the escrow process
• Hosting and infrastructure providers — for platform operation and data storage
• Email service providers — for transactional and account-related communications
• Analytics providers — for anonymised usage analytics

We do not sell your personal data to third parties.

5.3 Legal and regulatory

We may disclose data when required by law, court order, or regulatory authority, or to protect our legal rights or the safety of our users.

6. International data transfers

Your data is primarily processed within the European Economic Area (EEA). Where data is transferred outside the EEA (for example, to service providers), we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission or adequacy decisions.

7. Data retention

We retain your account data for the duration of your account and for 3 years after account closure for legal and compliance purposes. Verification status and reference IDs are retained for the same period. Platform activity data (campaign records, dispute history) is retained for 5 years for contractual and legal record-keeping. Technical logs are retained for up to 12 months. Sumsub retains identity verification data according to their own retention policy.

You can request earlier deletion subject to our legal obligations (see Section 9).

8. Cookies

We use strictly necessary cookies for platform functionality and session management. We may also use analytics cookies to understand how the platform is used. We do not use advertising or tracking cookies. You can manage your cookie preferences through your browser settings.

9. Your rights

Under the GDPR, you have the right to access the personal data we hold about you, rectify inaccurate or incomplete data, erase your data (subject to legal retention requirements), restrict processing of your data, data portability (receive your data in a structured, machine-readable format), object to processing based on legitimate interests, and withdraw consent at any time where processing is based on consent.

To exercise any of these rights, contact us at info@verifluence.io. We will respond within 30 days.

10. Data security

We implement appropriate technical and organisational measures to protect your data, including encryption in transit (TLS) and at rest, access controls and role-based permissions, regular security assessments, and separation of KYC processing (handled by Sumsub, not stored by Verifluence).

11. Children

The Verifluence platform is not intended for individuals under 18 years of age. We do not knowingly collect data from minors.

12. Changes to this policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or a prominent notice on the platform. Continued use of the platform after changes constitutes acceptance.

13. Complaints

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) at aki.ee, or with the supervisory authority in your country of residence.

14. Contact

Verifluence OÜ Harju maakond, Saku vald, Saku alevik, Silla tn 11, 75501, Estonia Registry code: 17463448 Email: info@verifluence.io