halco Nonprofit Suite Customer Privacy Policy
Effective Date: July 10, 2025
Halco is a product of AltC Studios, Inc. ("AltC Studios," "we," "our," or "us"). This Privacy Policy describes how we collect, use, disclose, and safeguard data related to nonprofit Organizations that use the Halco platform.
1. Scope
This Policy applies to information AltC Studios processes about (a) the Organization itself, (b) its Authorized Signatories and other administrators, and (c) the Bitcoin transactions carried out through Halco.
2. Definitions
“Organization” – the nonprofit entity that has executed a Sales Contract or otherwise enrolled in Halco.
“Authorized Signatory” – an individual designated by the Organization with legal power to bind the Organization and approve transactions.
“Halco+ User” – an individual user account created under the Organization’s profile with permissions set by an Authorized Signatory.
“Personal Information” – data that identifies or relates to an identified or identifiable person.
“Service” – the Halco software, websites, mobile applications, APIs, dashboards, and related support provided by AltC Studios.
3. Information We Collect
We collect the following categories of Personal Information:
Organization Data — legal name, physical address, Employer Identification Number (EIN), incorporation date and state, and mission statement. We use this data for account setup and regulatory filings.
Authorized Signatory Data — full name, title, date of birth, Social Security number, residential address, email address, and phone number. We collect this data to perform Know‑Your‑Customer (KYC) and anti‑money‑laundering (AML) checks, verify authority over the Organization’s wallets, and secure the Organization’s funds.
Admin Data — names, titles, email addresses, and phone numbers of additional Halco+ Users. We use this data for identity verification, role assignment, and customer support.
Transaction Data — wallet addresses, transaction IDs (TXIDs), timestamps, transaction amounts, and BTC ↔ USD exchange rates. We process this data for reporting, fee calculation, and compliance purposes.
Compliance Data — OFAC screening results and AML/KYC notes. We retain this data to meet legal obligations and to protect the integrity of the platform.
4. Legal Bases for Processing
Contract performance – providing and maintaining the Service.
Legal obligations – fulfilling AML, OFAC, IRS, and state charitable‑record‑keeping requirements.
Legitimate interests – safeguarding the Service, preventing fraud, and improving functionality.
5. How We Use Information
Create and maintain Organization and user accounts.
Conduct KYC/AML screening on Authorized Signatories.
Generate donation receipts, exportable reports, and audit trails.
Detect and prevent fraud, money‑laundering, and sanctions violations.
Improve and personalize platform features and user experience.
Provide customer and technical support.
6. Sharing & Disclosure
We disclose information only to:
Service Providers (cloud hosting, KYC vendors, analytics) under written confidentiality obligations.
Regulators, auditors, or law‑enforcement when required by law, subpoena, or court order.
Prospective donors only with the Organization’s consent (e.g., displaying a public wallet address or QR code).
We do not sell or rent Personal Information.
7. International Transfers
We and our service providers operate globally. Where data is transferred outside your jurisdiction, we rely on Standard Contractual Clauses or equivalent safeguards to protect it.
8. Data Retention
We retain Organizational, Authorized Signatory, and Transaction data for at least seven (7) years after the end of the relevant relationship to comply with IRS, AML, and audit requirements, or longer if required by law.
9. Security
We employ encryption in transit and at rest, network segmentation, SOC‑2‑compliant infrastructure, multi‑factor authentication, and principle‑of‑least‑privilege access controls. AltC Studios never stores secret recovery phrases.
10. Organizational Rights
An Authorized Signatory may, subject to applicable law, request access to or correction of Organizational Data, export transaction histories, or request deletion where legally permissible. Requests should be sent to the contact details below.
11. Children’s Information
Halco is not directed to children under 13, and we do not knowingly process children’s data.
12. Changes to This Policy
We may update this Policy from time to time. Material changes will be communicated to the Organization’s primary Authorized Signatory at least 30 days before they take effect, unless a shorter period is required by law.
13. Contact
Email: privacy@altcstudios.com
Mail: AltC Studios, Inc., 123 Market St., Wilmington, DE 19801, USA