Privacy Policy

Last updated: 17 September 2026 · Effective for the website and application platform at alphamonnaies.io

Alpha Monnaies is operated by VirtuVault Technologies EOOD, a company incorporated in Bulgaria (UIC 207524160) with its registered office at 49A Bulgaria Blvd, fl. 1, Triaditsa, Sofia 1404, Bulgaria, and operating offices in Switzerland and the United Arab Emirates (in this Policy, "Alpha Monnaies", "we", "us", "our"). VirtuVault Technologies EOOD acts as the introducing Programme Partner for regulated payment services provided by Equals Money Europe S.A. For the personal data we collect through this website and application form, VirtuVault Technologies EOOD is the data controller.

We are committed to protecting your privacy and complying with the EU General Data Protection Regulation (GDPR) and the Bulgarian Personal Data Protection Act (Закон за защита на личните данни). Where relevant to our offices and to visitors from those regions, we also have regard to the Swiss Federal Act on Data Protection (FADP) and the UAE Personal Data Protection Law (PDPL).

1. Scope & who this covers

This Policy explains how VirtuVault Technologies EOOD handles personal data for two groups of people:

• Website visitors — anyone browsing alphamonnaies.io or contacting us by email.
• Applicants — individuals and business representatives who complete our online application to open an account, including company directors, beneficial owners, and authorised signatories whose details are provided as part of a business application.

Once we submit your application to Equals Money Europe S.A. ("Equals Money"), Equals Money carries out the regulated identity (KYC), business (KYB), and anti-money-laundering checks, provides the account, and issues any card. In doing so Equals Money acts as an independent data controller under its own privacy notice; this Policy explains what we do and how your data reaches Equals Money. The ongoing operation of a live account is additionally governed by the client agreement and the Equals Money terms you accept during onboarding.

2. Personal data we collect

2.1 From website visitors

If you only browse the site or email us, we collect a deliberately minimal set of personal data:

For website browsing we do not run advertising trackers and we do not build behavioural profiles.

2.2 From applicants

When you complete the application form, and to prepare and check your application, we collect the following additional categories. Some fields depend on whether you apply as an individual or a business:

The regulated identity-document, selfie/biometric, and formal KYC/KYB verification data is collected and processed by Equals Money directly through its verification flow — see section 6. We do not ask you to upload identity documents to the Alpha Monnaies form.

3. How we collect it

• Directly from you — when you submit the access-request form, complete the application form, verify your email, or send us an email.
• Automatically — when you visit or apply, our hosting provider's server logs and our application record technical, device, and connection data as part of standard, secure operations and fraud prevention.
• Derived by us — we generate risk indicators from the data you provide and the signals above.
• From Equals Money — during and after onboarding we receive status updates on your application (for example whether identity verification is complete, whether more information is needed, and whether the account is approved or active).

4. Purposes & legal bases

We use your personal data only for these purposes:

• To respond to your access request and enquiries, and to contact you about onboarding. Legal basis: steps taken at your request prior to entering into a contract (GDPR Art. 6(1)(b)) and our legitimate interest in developing client relationships (GDPR Art. 6(1)(f)).
• To take your application, prepare it, and pass it to Equals Money so an account can be opened. Legal basis: steps taken at your request prior to, and performance of, a contract (GDPR Art. 6(1)(b)).
• To verify your email address and confirm we are dealing with the real applicant. Legal basis: legitimate interest in preventing impersonation and fraud (GDPR Art. 6(1)(f)).
• To detect and prevent fraud, money laundering, and abuse, including the device, connection, and risk signals described in section 5. Legal basis: legitimate interest (GDPR Art. 6(1)(f)) and compliance with legal obligations, including anti-money-laundering and counter-terrorist-financing law (GDPR Art. 6(1)(c)).
• To meet regulatory and record-keeping obligations that apply to us and to Equals Money as a regulated payment institution. Legal basis: legal obligation (GDPR Art. 6(1)(c)).
• To send you product updates you have asked for. Legal basis: your consent (GDPR Art. 6(1)(a)), which you may withdraw at any time.
• To secure the website and prevent abuse. Legal basis: legitimate interest (GDPR Art. 6(1)(f)) and legal obligation (GDPR Art. 6(1)(c)).

Where we rely on legitimate interest, we have balanced that interest against your rights and freedoms. We will not use your personal data for any other purpose without your prior consent or another lawful basis.

5. Fraud checks & automated risk assessment

To protect the platform and meet our anti-fraud and anti-money-laundering obligations, our application system automatically examines the device and connection signals described in section 2.2 and derives risk indicators — for example where the location you state does not match the location of your connection, or where a disposable email address is used. These indicators are used to prioritise and inform a human review of your application; they do not, by themselves, produce a final decision about you. The regulated approve/decline decision is made by Equals Money as part of its KYC/KYB process.

We do not carry out solely-automated decision-making that produces legal or similarly significant effects on you within the meaning of GDPR Art. 22 on the basis of these indicators alone. If you would like to understand how a risk indicator affected the handling of your application, contact privacy@alphamonnaies.io.

6. Equals Money & identity/AML checks

Regulated payment services, accounts, and cards are provided by Equals Money Europe S.A., a Regulated Payment Institution supervised by the National Bank of Belgium (registration No. 0849.185.510, Avenue Louise 231, 1050 Bruxelles, Belgium). When you apply, we pass your application details to Equals Money so it can carry out identity verification (KYC), business verification (KYB), sanctions and anti-money-laundering screening, and open and operate your account.

For those regulated activities, Equals Money is a separate, independent data controller and processes your personal data — including any identity documents, selfie/biometric checks, and verification results collected through its own verification flow — under its own privacy notice and lawful bases. We are not able to change how Equals Money processes data for its regulated purposes. Please read the Equals Money privacy notice for the detail of that processing, the safeguards it applies, and how to exercise your rights against Equals Money; it is provided to you during onboarding and available from Equals Money on request.

7. Disclosure to third parties & processors

We do not sell personal data and we do not share it with third parties for their own marketing. Apart from the disclosure to Equals Money described in section 6, we share personal data only with trusted service providers (processors) acting on our documented instructions under Art. 28 GDPR:

We may also disclose personal data where required by law, court order, or a valid request from a competent authority, or where necessary to establish, exercise, or defend legal claims, or to protect the rights, property, or safety of Alpha Monnaies, our clients, or the public.

8. International transfers

Because some of our processors operate global infrastructure, your personal data may be processed outside the European Economic Area, including in the United States. Where it is, we rely on an adequacy decision where one exists, on the European Commission's Standard Contractual Clauses, or on the EU–US Data Privacy Framework where the recipient is certified, together with appropriate supplementary measures. You may request a copy of the relevant safeguard by emailing privacy@alphamonnaies.io.

9. Retention

• Access-request email addresses — kept until onboarding or for up to 24 months from last contact, or until you ask us to delete them, whichever is earlier.
• Email correspondence — kept for up to 24 months unless a longer retention is required for legal or accounting purposes.
• Server logs — kept for up to 90 days for security and abuse prevention, then deleted or anonymised.
• Applications that do not proceed — application details and the associated device, connection, and risk data are kept for up to 12 months, then deleted, unless we are required to keep them longer to meet an anti-money-laundering or other legal obligation.
• Applications that proceed to an account — records relating to the customer relationship and to anti-money-laundering compliance are retained for the period required by applicable law, which is typically five years after the end of the relationship (and longer where a competent authority requires it). Equals Money applies its own retention periods to the data it holds as controller.

10. Your rights

Under the GDPR and Bulgarian data-protection law you have the right to:

• Access — obtain confirmation of, and a copy of, the personal data we hold about you.
• Rectification — have inaccurate or incomplete data corrected.
• Erasure — have your data deleted ("right to be forgotten"), subject to legal retention requirements.
• Restriction or objection — restrict or object to certain processing, including processing based on legitimate interest.
• Portability — receive your data in a structured, commonly used, machine-readable format.
• Withdraw consent — at any time, without affecting the lawfulness of processing before withdrawal.
• Lodge a complaint — with a supervisory authority (see below).

To exercise any of these rights, email privacy@alphamonnaies.io. We will respond within one month as required by GDPR Art. 12(3), extendable by two further months for complex requests, and may need to verify your identity first.

Some of these rights are limited where we must keep or process data to comply with a legal obligation — in particular, we cannot erase records we are required to retain under anti-money-laundering law. For the data Equals Money holds as an independent controller, you should exercise your rights directly against Equals Money using the contact details in its privacy notice; we will help direct your request where we can.

11. Security measures

We follow OWASP best practice and apply technical and organisational measures appropriate to the risk (GDPR Art. 32), including: HSTS-enforced HTTPS across the whole site, a strict Content Security Policy, X-Frame-Options: DENY against clickjacking, MIME-sniff blocking, no third-party tracking, least-privilege access to data, and incident-response procedures. See our Security Policy for detail.

12. Cookies & tracking

The Alpha Monnaies website does not set advertising or analytics cookies. We use localStorage only to remember two of your preferences — your chosen theme (light/dark) and language — both of which stay on your device and are never sent to us. Full detail is in our Cookie Policy.

13. Children

The Alpha Monnaies website and platform are intended for businesses and adults. We do not knowingly collect personal data from children under 18. If you believe we have inadvertently done so, contact privacy@alphamonnaies.io and we will delete it.

14. Changes to this Policy

We may update this Policy to reflect changes in law or our practices. We will revise the "Last updated" date and, for material changes, notify subscribers by email. The current version is always at alphamonnaies.io/privacy.html.

15. Contact & complaints

For any privacy question, request, or complaint, contact our data-protection contact:
VirtuVault Technologies EOOD — Privacy
49A Bulgaria Blvd, fl. 1, Triaditsa, Sofia 1404, Bulgaria
Email: privacy@alphamonnaies.io

If you are not satisfied with our response, you may complain to the Bulgarian Commission for Personal Data Protection (Комисия за защита на личните данни) at cpdp.bg, or to the supervisory authority in your country of residence. Visitors in Switzerland may contact the FDPIC; visitors in the UAE may contact the UAE Data Office.