0.00011783
Last updated April 23, 2025
Thank you for visiting xxi.money (the “Site“). The Site is operated by Twenty One Capital (“Twenty One”, “we,” “our,” or “us”).
This privacy statement (“Privacy Statement”) sets out the basis on which any Personal Information we collect from you (“you”, “your”, or “customer”), or that you provide to us, will be processed by us. By “Personal Information”, we mean any information which, either alone or in combination with other data, enables you to be directly or indirectly identified, for example your name, email address, username, contact details or any unique identifier such as an IP address, device ID or other online identifier.
Please read the following carefully to understand what Personal Information we collect, how it is used and the ways it can be shared by us.
The data controller of your Personal Information is Twenty One Capital, Inc. of 211 East 7th Street, Suite 620 Austin TX 78701-3218.
1. Our Processing of Your Personal information
| Purpose | Personal Information From You | Personal Information From your devices | Legal Basis |
|---|---|---|---|
| Establish and maintain a commercial relationship with you (creation and management of your account with us, including dealing with your request to make account changes) | First name, last name, email address, username, password, country of residence, state/province, time zone | Technical information, including the Internet Protocol (IP) address used to connect your computer or other device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform Information about your visit, including the dates and times you use the Site, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call the contact phone number provided on our Site IP addresses, logs history | You are using us (Performance of a contract) |
| Understand your needs and eligibility for products and services | Contact details | ||
| Deliver our Services to you | Username, email address, Digital Token Wallet addresses, deposit and withdrawals, deposits addresses, balance history, bank statements, bank account numbers, Personal Information posted by you | ||
| Inform you about trading and financing features, inform you on developments and products | Contact details | N/A | |
| Process billing and collection of any fees | Contact details, email address, Digital Token Wallet addresses, deposit and withdrawals, deposits addresses, balance history, bank statements, bank account numbers, Personal Information posted by you | N/A | |
| Administer the website, system administration and detecting usage patterns (including broad demographic information for aggregated use), provide information about developments and new products, including enhancement to the Site, sending you service announcement | Contact details | IP address, traffic routing data, system configuration information, geolocation data, browser type, access requests and times, URL requested and referral URL. | We think we can (Legitimate interest) |
| Detection for troubleshooting purposes | N/A | Technical information, including the Internet Protocol (IP) address used to connect your computer or other device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform Information about your visit, including the dates and times you use the Site, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call the contact phone number provided on our Site | |
| Comply with industry self-regulatory, audit and security requirements | Username, email address, full name and contact details, government ID number (passport or national ID), 2 forms of ID, date of birth, picture signature, skype pseudo and call, bank accounts numbers, proof of residence, utility bill, tax statement, service bill, employment status, employer name and address, certificate of incorporation, business registration, article of association, ownership and control structure, directors, authorized signatories, authorized signature list, board minutes, officer and director list, name of UBO, certificate of good standing. | N/A | |
| Protect the right, property, safety of us, our clients or others | Any of the Personal Information in this table, talking into account necessity and data minimization | N/A | |
| Conduct surveys and get feedback from you | Contact details | N/A | |
| Provide you with news and other matters of general interest to you as a Twenty One customer | Email Address | IP address, other technical information through cookies and other tracking technologies (and plug-ins) | You agree to it (Consent) |
| Meet our legal and regulatory requirements, including managing risk assessments for cryptocurrency transactions, checking your identity for authentication and KYC purposes and against money laundering and terrorist financing or answering your requests | Username, email address, full name and contact details, 2 forms of ID, gender, date of birth, nationality, name of parents, picture, signature, skype pseudo and call, blockchain addresses, wallet addresses, transactional data, bank accounts numbers, proof of residence, utility bill, tax statement, service bill, employment status, employer name and address, certificate of incorporation, business registration, article of association, ownership and control structure, directors, authorized signatories, authorized signature list, board minutes, officer and director list, name of UBO, certificate of goods standing. | Metadata associated with transactions (e.g., patterns of activity that may indicate phishing clusters or address poisoning); Technical information, including the Internet Protocol (IP) address used to connect your computer or other device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform Information about your visit, including the dates and times you use the Site, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call the contact phone number provided on our Site | Compliance with a legal requirement |
When we say that we think we can process your data, it is because we considered we have a legitimate interest (for ourselves or of a third party) to do so; it is in the interest of our organization to conduct and manage our business; this includes conducting analytics to improve and optimize the Site and the Services, protecting our interests and enforcing agreements with others, as well as complying with industry self-regulatory requirements. We might have a legitimate interest to process Personal Information in other contexts. We ensure we balance any potential impact on you and your rights before we process your Personal Information on that basis. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Please also consult the section “Your rights” below.
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us. You can do so by lodging a customer support ticket. We will endeavor to effect those changes within a reasonable timeframe.
We do not rely on consent as a legal basis for processing your Personal Information other than in relation to our use of cookies (please refer to our Cookies Notice), and when we send third party direct marketing communications to you via email. From time to time, we may share your Personal Information with third parties with your consent.
Aggregated Data. We may also aggregate personal and other data captured by us so that the data is no longer capable of identifying an individual. Aggregated data may cover patterns of usage or information and data that you provide to us, and we reserve the right to use this aggregated information for the purposes of improving and enhancing our Services, generating insights, for use in marketing to other users and current and potential partners and otherwise for the purposes of our business. Provided that such aggregated data does not directly or indirectly identify you as an individual, this data is not considered to be Personal Information and is not covered by this Privacy Statement.
2. Security and Confidentiality.
Twenty One is committed to protecting your privacy. Internally, only people with a business need to know Personal Information, or whose duties reasonably require access to it, are granted access to customers’ Personal Information. Such individuals will only process your Personal Information on our instructions and are subject to a duty of confidentiality. We audit our personal compliance regularly.
The Site’s systems and data are reviewed periodically to ensure that you are getting a quality service and that leading security features are in place. We have put in place procedures to deal with any actual or suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Twenty One takes all reasonable endeavors to protect and safeguard Personal Information. Unfortunately, the transmission of information via the Internet is not completely secure. While we do our utmost to protect your Personal Information, we cannot guarantee the security of your data transmitted to us over email or through the Site; any transmission is at your own risk. Once we have received your Personal Information, we will use strict procedures and security features to try to prevent unauthorized access, but there are protective measures you should take, as well. Do not share your Personal Information with others unless you clearly understand the purpose of their request for it and you know with whom you are dealing. Do not keep sensitive Personal Information in your e-mail inbox or on Webmail. If you are asked to assign passwords to connect you to your Personal Information, you should use a secure password and always use two-factor authentication (2FA), where available. You should change your password regularly.
3. What and with whom we share your Personal Information
As necessary, we will share your Personal Information with:
a) Any member of our group, which means our direct or indirect subsidiaries, our ultimate holding company and any other subsidiary of that holding company, including their respective shareholders, directors, officers, affiliates, employees, contractors, agents, partners, insurers, and attorneys or representatives.
b) Our service providers, to the extent necessary to supply the Services to you
c) Selected third parties, including analytics and search engine providers that assist us in the improvement and optimization of the Services.
d) Authorities and law enforcement agencies worldwide either when ordered to do so or on a voluntary basis if this appears reasonable and necessary to us.
We also disclose your Personal Information to third parties:
a) If Twenty One or substantially all of its assets are acquired by a third party, in which case Personal Information held by it about its customers will be one of the transferred assets.
b) If we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or in order to enforce any agreements; or to protect the rights, property, or safety of us, our clients, or others, including to defend ourselves from legal claims.
Twenty One reserves the right to share current and historical bids, asks, and market prices; opening and closing range prices; high–low prices; trade prices; estimated and actual trade volumes; settlement prices; and other aggregate data and information related to the digital tokens purchased or redeemed on the Site.
4. Data Retention
We have data retention and deletion policies designed to retain Personal Information for no longer than necessary for the purposes set out herein or as otherwise required to meet legal or business needs. Because of those retention requirements, we might not be able to honor erasure requests.
5. Your rights
All Customers. You may access and verify your Personal Information held by Twenty One, where consent is the legal basis for processing of your Personal Information and subject to any legal or contractual restrictions, withdraw your consent, in each case, by submitting a written request to info@xxi.money. Our electronic marketing communications also contain opt-out mechanism and options to update your contact information or change your preferences at any time. We will do our best to honor your request promptly. For cookies, this is done by setting up the cookies’ preferences.
No fee usually required.
You will not have to pay a fee to access your Personal Information or to exercise any of your other rights. We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
6. Changes to this Privacy Statement
Any changes we make to our Privacy Statement in the future will be posted on this page and, where material, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Statement.
7. Contact
Questions, comments and requests regarding this Privacy Statement should be addressed by email to info@xxi.money.
Appendix – List of Third-Party Service Providers with whom Personal Information may be shared (1):
| Party Name and Jurisdiction | Purpose | Data Disclosed |
|---|---|---|
| Cloud providers | For storage purposes. | User names, corporate documentation, dates of birth, identifying documentation, correspondence, transactional activity and analysis, financial information. |
| Cloudflare, Inc. (US). Cloudflare’s privacy policy is available at https://www.cloudflare.com/privacypolicy/ | To provide DNS management, security, and content delivery network (CDN) services, enhancing website performance and accessibility. We also utilize its geolocation identification services to manage access to certain parts of our platforms of xxi.money and app.xxi.money | IP addresses, traffic routing data, system configuration information, and other information about traffic to and from our websites, devices, applications, and/or networks. |
| Legal Counsel | As part of attorney-client relationships, legal counselling and litigations | Any relevant account information, as the case may be. |
[^1]: This list does not include banks to which personal information is transferred for payment purposes in accordance with international banking practice.