Who we are
Alcyone is the advisory practice of TrustSwap. This website, alcyone.finance, is operated by TrustSwap El Salvador, S.A. de C.V., a company incorporated in the Republic of El Salvador, with registered office at Polígono 8, Oficina 118, Colonia San Benito, San Salvador, El Salvador (referred to in this policy as "TrustSwap", "we" or "us"). Our operations are run from Abu Dhabi, United Arab Emirates, by a team across four continents. TrustSwap is the controller of the personal data described in this policy.
This policy explains what personal data we collect when you visit this website or contact us about our advisory services, why we collect it, how long we keep it, who we share it with and what rights you have. It is written to meet the Personal Data Protection Law of El Salvador, supervised by the Agencia de Ciberseguridad del Estado, and, where they apply to you, the EU and UK General Data Protection Regulations.
Personal data we handle in the course of an advisory engagement is governed by the engagement letter and confidentiality terms agreed with the client, which take precedence over this policy where they differ.
What we collect
When you use the contact form or write to us by email, we collect the information you give us: your name, work email address, company or project, your role, the stage your project is at, and whatever you tell us about what you are trying to get done. You are not required to give us any of it, but we cannot arrange a call without a way to reach you.
When you visit the site, our hosting provider's servers automatically record technical information that every web request carries: your IP address, the date and time of the request, the pages requested, the referring page, and your browser and operating system. These records are used to serve the site, keep it secure and diagnose faults. We do not use them to build a profile of you.
We do not collect special categories of personal data through this site, and we ask you not to send us any. We do not knowingly collect personal data from anyone under eighteen; this site is intended for businesses and the professionals who represent them.
Why we use it and on what basis
We use the information you send us to reply to you, to assess whether we are the right firm for your project, to arrange and prepare for an intro call, and, if we go on to work together, to set up the engagement. The legal basis is that this processing is necessary to take steps at your request before entering into a contract, and, where you write on behalf of a company, our legitimate interest in responding to a business enquiry.
We use the technical records described above to run the site securely and to understand, in aggregate, how it is used. The legal basis is our legitimate interest in operating a working, secure website.
If you agree to receive occasional notes from us, such as a change in the practice, we will send them only with your consent, and every message will carry a way to opt out. We do not send marketing to people who have merely visited the site or filled in the contact form.
We will not use your personal data for automated decision-making that produces legal or similarly significant effects on you.
Cookies and similar technologies
This site does not set advertising or tracking cookies. It may set strictly necessary cookies or use local storage where a feature needs them to work, for example to remember a form you were part-way through. If we add analytics in future, we will update this policy and, where the law requires it, ask for your consent before those cookies are set.
The site loads typefaces from Google Fonts. When your browser requests a font file, Google receives the request, including your IP address, and processes it under Google's own privacy policy. The site does not embed third-party video players, social-media widgets or advertising.
Who we share it with
We share personal data only with providers who help us run the site and handle enquiries, and only to the extent needed for that purpose. At present these are: the form service that delivers contact-form submissions to our inbox; the platform that hosts and serves the website; the email and productivity services our team uses to read and reply to enquiries; and Google, for the fonts described above. Each of these acts under contractual terms that restrict what it may do with the data.
Within the TrustSwap group, the partners and staff who handle advisory enquiries may be employed by affiliated entities in other countries. They have access to your enquiry only for the purposes set out above.
We may disclose personal data where the law requires it, to protect our rights or safety or those of others, or in connection with a merger, acquisition or sale of all or part of the business, in which case the recipient will be bound by this policy in respect of data collected before the transfer.
We do not sell personal data and we do not share it with third parties for their own marketing.
International transfers
TrustSwap is incorporated in El Salvador, operates from Abu Dhabi and has team members on several continents. The providers listed above may store or process data in the United States and the European Union. Where personal data leaves El Salvador, the EU or the UK, we rely on an adequacy decision where one exists, and otherwise on standard contractual clauses or equivalent safeguards approved under the applicable law. You can ask us for details of the safeguards used for your data.
How long we keep it
We keep enquiries for as long as needed to respond and follow up, and then for up to twenty-four months so that we can pick up a conversation that resumes. If an enquiry leads to an engagement, the related records are kept for the life of the engagement and for the period afterwards required by the record-keeping rules that apply to us and our professional obligations, normally six years. Technical server records are kept for a short period, normally no more than ninety days, unless they are needed to investigate a security incident.
Your rights
You have the right to ask us what personal data we hold about you and to receive a copy; to have inaccurate data corrected; to have data erased where we no longer have a lawful reason to keep it; to restrict or object to processing that rests on our legitimate interests; to receive data you gave us in a portable form; and to withdraw any consent you have given, without affecting processing that took place before you withdrew it.
To exercise any of these rights, write to advisory@trustswap.com with "Privacy" in the subject line. We may need to confirm your identity before acting. We aim to respond within one month, and will tell you if we need longer.
If you are unhappy with how we have handled your data, you can complain to the Office of Data Protection of the Abu Dhabi Global Market. If you are in the EU or the UK, you may also complain to your local supervisory authority.
Security
We protect personal data with technical and organisational measures appropriate to the risk, including encrypted connections to the site, access limited to the people who need it, and providers selected for their own security practices. No method of transmission or storage is completely secure, and we cannot guarantee absolute security, but we will notify you and the relevant authority of a breach where the law requires it.
Other websites
This site links to other TrustSwap properties, including Team Finance, the TrustSwap Launchpad, The Crypto App and Panthea, and to third-party sites. Each has its own privacy policy, and this policy does not apply once you leave alcyone.finance.
Changes to this policy
We will post any changes on this page and update the effective date above. If a change materially affects how we use data you have already given us, we will tell you directly where we can.
Contact
TrustSwap El Salvador, S.A. de C.V. is registered at Polígono 8, Oficina 118, Colonia San Benito, San Salvador, El Salvador. Operations, partnerships and product development are run from our Abu Dhabi base, with a globally distributed team supporting all functions remotely. Write to us at advisory@trustswap.com.