Privacy Policy

Last updated: 31 March 2026 · Calisken Technologies

1 Scope

This Privacy Policy applies to personal data we process when you interact with dPass Invest properties, including the public marketing site (for example pages such as the home page, terms, privacy, and maintenance or status pages), contact or access-request forms, and any other application or endpoint we operate under the dPass Invest brand on the same website or origin as this policy, unless a different privacy notice is expressly presented to you.

It also applies to personal data processed in connection with dPass Invest software, APIs, or services we offer you, as described in any product-specific notice we provide.

dPass Invest is a distinct product. If you use other Calisken websites, apps, or services, the privacy policy published on each property applies to that product. Where we use shared infrastructure (for example, corporate web hosting or a group support address), we treat data according to the product you were using when the data was collected, unless we notify you otherwise.

2 Data controller

The data controller responsible for personal data described in this policy is:

3 Data we collect

Depending on how you interact with us, we may process the categories below. Not all categories apply to every user at every stage (for example, before accounts exist we may collect only technical data).

We do not require you to provide special categories of personal data (“sensitive” data under GDPR) for basic website use. If we ever request such data, we will explain why and rely on an appropriate legal basis.

4 Purposes & legal bases

Where the GDPR or UK GDPR applies, we rely on the following legal bases, as appropriate:

• Contract (Art. 6(1)(b)) — to provide services you request, manage your account, and perform our agreement with you.
• Legitimate interests (Art. 6(1)(f)) — to secure our systems, prevent abuse, improve our products, analyse aggregated usage, and communicate service-related messages, balancing your rights and freedoms.
• Legal obligation (Art. 6(1)(c)) — to comply with law, regulation, court orders, or regulatory requests.
• Consent (Art. 6(1)(a)) — where required for non-essential cookies or similar technologies, marketing emails, or other processing we specifically present as optional. When you use our cookie banner, your choice is stored in the dpass_consent cookie. You may withdraw consent at any time (see Section 5).

We use personal data to operate, secure, and improve dPass Invest properties; respond to enquiries; comply with law; enforce our Terms of Service; and, where applicable, to deliver trading or investment-related features described in supplemental terms.

5 Cookies & consent

dPass Invest uses a cookie consent banner in line with the GDPR and the ePrivacy Directive (and equivalent UK rules). When you first visit our site, we ask for your consent before treating optional categories as accepted. You can Accept all, Reject non-essential, or open Cookie settings for details.

Cookies we use

What we do not use

On the public marketing site, we do not use advertising cookies, tracking pixels, third-party analytics cookies, browser fingerprinting, or cross-site tracking for ads. No data is shared with ad networks for that purpose.

Managing your consent

You can withdraw or change your cookie consent using Cookie settings on the banner when it is shown, or by clearing cookies for this site in your browser. After you remove dpass_consent, the consent banner will appear again on your next visit. You can also open our Privacy Policy from the banner for full details.

6 Sharing & processors

We may share personal data with:

• Service providers who host our infrastructure, send email, provide analytics, customer support tools, or security services, bound by contractual confidentiality and processing terms.
• Professional advisers (lawyers, auditors) where necessary.
• Authorities when required by law or to protect rights, safety, and integrity.
• Corporate transactions in connection with a merger, acquisition, or asset sale, subject to appropriate safeguards.

We do not sell your personal information for monetary or other valuable consideration in the sense used by the CCPA/CPRA and similar US state laws, and we do not “sell” personal data under the GDPR/UK GDPR where that term requires a sale. We do not use third-party advertising or analytics cookies on the public dPass Invest marketing site; if we introduce measurement tools that could constitute “sharing” for cross-context behavioural advertising under US law, we will describe them in Section 5 and honour any opt-out or consent rights that apply.

Payment or brokerage partners (e.g. if we integrate with third parties in the future) will process data under their own privacy notices for their roles.

7 International transfers

Calisken may process data in the United Kingdom, the European Economic Area, the United States, or other countries where we or our providers operate. If we transfer personal data from the EEA, UK, or Switzerland to countries not deemed adequate by the relevant authority, we will use appropriate safeguards such as the EU Standard Contractual Clauses, the UK International Data Transfer Agreement, or other lawful mechanisms.

8 Retention

We retain personal data only as long as necessary for the purposes above, including satisfying legal, accounting, and reporting requirements. Typical criteria include: the duration of your relationship with us, statutory limitation periods, and regulatory retention rules for financial services where they apply. Technical logs may be kept for shorter rolling periods. When data is no longer needed, we delete or anonymise it.

9 Security

We implement technical and organisational measures designed to protect personal data against unauthorised access, alteration, disclosure, or destruction. No method of transmission over the Internet is completely secure; we encourage strong passwords, device security, and caution with phishing.

10 Your rights (EEA, UK, and similar jurisdictions)

Subject to applicable law, you may have the right to: access your personal data; rectify inaccuracies; erase data in certain cases; restrict processing; data portability; object to processing based on legitimate interests or direct marketing; and withdraw consent where processing is consent-based.

You may also lodge a complaint with a supervisory authority in your country of residence. To exercise rights, contact us at info@calisken.ai. We may need to verify your identity before responding.

11 California (US) residents

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), as amended, including to know categories and specific pieces of personal information collected, to delete personal information subject to exceptions, to correct inaccuracies, to opt out of “sale” or “sharing” for cross-context behavioural advertising (we do not sell personal information in the conventional sense; we describe cookie-based activities in Section 5), and not to receive discriminatory treatment for exercising rights.

California residents may designate an authorised agent; we may require proof of authorisation. To submit a request, email info@calisken.ai with “California Privacy Rights” in the subject line.

12 Marketing

Where permitted, we may send product updates or marketing about dPass Invest. You can opt out of marketing emails using the unsubscribe link or by contacting us. We may still send transactional or legal notices.

13 Children

dPass Invest services are not directed at individuals under 18 (or the higher age required locally for entering into contracts or using investment services). We do not knowingly collect personal data from children. If you believe we have done so, contact us and we will delete it.

14 Automated decision-making

We do not use solely automated decision-making that produces legal or similarly significant effects regarding you, unless we implement such a feature in the future with appropriate notice and, where required, consent or other lawful basis.

15 Third-party sites

Our properties may link to third-party websites, brokers, exchanges, or educational resources. Their privacy practices are governed by their own policies. We encourage you to read them before providing personal data.

16 Changes

We may update this Privacy Policy to reflect changes in our practices, technology, or legal requirements. When we do, we will revise the Last updated date at the top. For changes that materially affect how we use personal data, we will provide any additional notice or obtain any consent required by applicable law before the changes take effect. Where the law allows reliance on continued use, continued use of the dPass Invest properties covered by this policy after the revised date may constitute notice of the update; this does not override any right you have to withdraw consent or object where the law requires a different process.

17 Contact & complaints

For privacy questions or requests: