Privacy policy

Last updated: 8 October 2026

Money loves silence. Holders is built so that we don't hold your money and don't need most of your data. This policy explains what personal data we do process, why, and the rights you have under UK data protection law.

1. Who we are

Holders is operated by [Company name] Ltd, a company registered in England and Wales under company number [00000000], with its registered office at [Registered office address] (“Holders”, “we”, “us”). We are the controller of the personal data described in this policy.

For any privacy question or request, email support@holders.io with “Privacy” in the subject line.

2. Your self-custody account

Your Holders account is a smart contract on a public blockchain, controlled by a key that is created and stored on your device. We never receive your key or your recovery phrase, and we cannot access, move or recover your funds.

Balances and transactions at a blockchain address are public by design and visible to anyone. We do not publish any link between your address and your identity, but we cannot change or delete information recorded on a public blockchain.

3. The data we collect

• Identity and contact data: name, date of birth, address, email address, phone number and identity documents, when you order a card or use bank transfers.
• Account data: your public account address, the cards linked to it and your app settings.
• Transaction data: card payments, bank transfers and cheques you make through Holders.
• Device and technical data: device type, operating system, app version, IP address and security logs.
• Communications: messages you send to us and, for Holders Platinum members, communications with your private banker made through Holders.

We do not collect special category data, and we do not knowingly collect data from anyone under 18.

4. Why we use it and our lawful basis

• To provide Holders (your account, cards, cheques, bank transfers and, for Platinum members, private banker services). Lawful basis: performance of our contract with you.
• To verify your identity and prevent fraud and financial crime. Lawful basis: legal obligation, and our legitimate interest in keeping Holders secure.
• To support you and send you service messages. Lawful basis: performance of our contract with you.
• To keep the app and website secure and working. Lawful basis: our legitimate interests.
• To send you news about Holders, only if you ask us to. Lawful basis: consent, which you can withdraw at any time.

We do not sell your data, use it for advertising profiles, or track you across other apps and websites.

5. Who we share it with

We share personal data only where needed to provide Holders, and only with:

• our card issuing and payment partners, to issue and run your card;
• identity verification and fraud prevention providers;
• banking and conversion partners, to process transfers to and from bank accounts;
• if you are a Holders Platinum member, your private banker, limited to what you choose to share;
• hosting, communications and support providers working on our instructions;
• other companies in the Whales Corp group that help us run Holders;
• authorities, courts or regulators where the law requires it.

6. International transfers

Some of our partners process data outside the UK. When they do, we protect your data with a UK adequacy regulation, the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses.

7. How long we keep it

We keep identity and transaction records for as long as you use Holders and for up to 5 years after our relationship ends, or longer where the law requires it. We keep other data only as long as we need it for the purposes above. Data on a public blockchain cannot be deleted.

8. Your rights

Under the UK GDPR and the Data Protection Act 2018 you have the right to:

• access the personal data we hold about you;
• have inaccurate data corrected;
• have your data erased, where we have no reason to keep it;
• restrict or object to how we use your data;
• receive your data in a portable format;
• withdraw consent at any time, where we rely on it.

To use any of these rights, email support@holders.io. We will reply within one month.

9. Cookies

This website does not use advertising or tracking cookies. It loads fonts from Google Fonts, which receives your IP address when the page loads.

10. Complaints

If you are unhappy with how we handle your data, please contact us first. You can also complain to the Information Commissioner's Office (ICO) at ico.org.uk/make-a-complaint or by phone on 0303 123 1113.

11. Changes to this policy

We will post any changes on this page and update the date above. If a change materially affects you, we will tell you in the app.