Thank you for visiting soya-coin.com (the “Site”) and or using our mobile application (“App”). The Site and the App are owned and operated by SoyCycle LTD (together “SoyaCoin”, “we,” “our,”, “us” or “Company”). As part of our daily business operations, we collect personal information from our clients and prospective clients in order to provide them with our products and Services and ensure that we can meet their needs when providing these products and Services, as well as when providing them with any respective information.

This privacy policy (“Privacy Policy”) together with our Terms and Conditions (which can be found at – https://soya-coin.com/terms ) (“Terms and Conditions”) sets out the basis on which any Personal Information we collect from you (“you”, “your”, “user” or “customer”), or that you provide to us, will be processed by us. By “Personal Information”, we mean any information which, either alone or in combination with other data, enables you to be directly or indirectly identified, for example your name, email address, username, identification document, contact details or any unique identifier such as an IP address, device ID or other online identifier.

Please read the following carefully to understand what data we collect, how that data is used and the ways it can be shared by us. 

The data controller of your Personal Information is SoyCycle LTD, a company registered in the United Kingdom under company number 12512223 with registered office is at Suite 2A Blackthorn House, St. Pauls Square, Birmingham, B3 1RL, United Kingdom.


By accessing and using our Services, you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. This document may supplement or clarify our privacy practices or may provide you with additional information about how we process your data. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.


We may modify this Privacy Policy from time to time which will be indicated by changing the date at the bottom of this document. If we make any material changes, we will notify you by email (sent to the email address specified in your account), by means of a notice on our Services prior to the change becoming effective, or as otherwise required by law.


In order to use our Services and open an account with us, you must first complete and submit a “create account” form to us by completing the required information. By completing this form, you are requested to disclose personal information in order to enable the Company to assess your application and comply with the relevant laws (including their regulations).

The Personal Information most often collected and maintained in a customer file includes:

  • Full name, residential address and contact details (e.g. email address, telephone number, fax etc.);
  • Date of birth, place of birth, gender, citizenship;
  • Bank account information, credit card details, including details about your source of funds, assets and liabilities, and OFAC information;
  • Trading account balances, trading activity, your inquiries and our responses;
  • Information on whether you hold a prominent public function (PEP);
  • Verification information, which includes information necessary to verify your identity such as a passport, driver’s license or Government-issued identity card);
  • Other Personal Information or commercial and/or identification information – Whatever information we, in our sole discretion, deem necessary to comply with our legal obligations under various anti-money laundering (AML) obligations, such as relevant legislation.

We also collect some information about you which may be considered to be Personal Information when combined with other information about you, such as:  

  • Internet protocol (IP) address used to connect your computer or other device to the Internet;
  • browser type and version;
  •  time zone setting;
  • location information when using our Services;
  •  browser plug-in types and versions;
  • operating system and/or platform;
  • dates and time you use the Site length of visits to certain pages;
  •  page interaction information (such as scrolling, clicks, and mouse-overs);
  • methods used to browse away from the page; and, 
  • any phone number used to call the contact phone number provided on our Site.

We do not collect any special categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

All the information about is collected when you are:

  • registering for a SoyaCoin account;
  • using our Platform, Site or App;
  • acquiring SOY Tokens;
  • using the Support Centre on the Site; or
  • corresponding with us by phone, e-mail or otherwise.


We will process your personal information on the following bases and for the following purposes:

Performance of a contract

We process personal data in order to provide our Services, as well as information regarding our products and services based on the contractual relationship with our clients (i.e. so as to perform our contractual obligations). 

Compliance with a legal obligation and AML requirements

The processing of personal data takes place to enable the completion of our client on-boarding process. In view of the above, we must verify your identity in order to accept you as our client and we will use your personal data in order to effectively manage your account with us. This may include third parties carrying out credit or identity checks on our behalf. The use of your personal information is necessary for us to know who you are, as we have a legal obligation to comply with “Know Your Customer” and customer due diligence regulatory obligations.

Also, there are a number of legal obligations imposed by relevant laws to which we are subject, as well as specific statutory requirements e.g. anti-money laundering laws. There are also various supervisory authorities whose laws and regulations apply to us. Such obligations and requirements imposed on us necessary personal data processing activities for identity verification, payment processing, compliance with court orders, tax laws or other reporting obligations and anti-money laundering controls. These obligations apply at various times, including client on-boarding, payments and systemic checks for risk management.

For the purpose of safeguarding legitimate interests

We process personal data so as to safeguard the legitimate interests pursued by us or by a third party. A legitimate interest is when we have a business or commercial reason to use your information. Example of such processing activities include the following:

  • Initiating legal claims and preparing our defense in litigation procedures;
  • Means and processes we undertake to provide for the Company’s IT and system security, preventing potential crime, asset security and access controls;
  • Measures for managing the business and for further developing products and services;
  • Sharing your data within the third-party companies for the purpose of updating and/or verifying your personal data in accordance with the relevant anti-money laundering compliance frameworks, and
  • Risk management.

To provide you with products and services, or information about our products and services, and to review your ongoing needs.

Once you successfully open an account with us, or subscribe to information, we must use your personal information to perform our Services and comply with our obligations to you. It is also in our legitimate interests to try to ensure that we are providing the best Services so we may periodically review your needs based on our assessment of your personal information to ensure that you are getting the benefit of the best possible products and services from us.

To help us improve our products and services, including support services, and develop and market new products and services.

We may, from time-to-time, use personal information provided by you through your use of the Services and/or through client surveys to help us improve our Services. It is in our legitimate interests to use your personal information in this way to try to ensure the highest standards when providing you with our Services.

To investigate or settle enquiries or disputes

We may need to use personal information collected from you to investigate issues or to settle disputes with you because it is our legitimate interest to ensure that issues and disputes get investigated and resolved in a timely and efficient manner.

To comply with applicable laws, court orders, other judicial or administrative processes or the requirements of any applicable regulatory authorities

We may need to use your personal information to comply with any applicable laws and regulations, subpoenas, court orders or other judicial processes, or requirements of any applicable regulatory authority. We do this not only to comply with our legal obligations but because it may also be in our legitimate interest to do so.

To send you surveys

From time to time, we may send you surveys as part of our client feedback process. It is in our legitimate interest to ask for such feedback to try to ensure that we provide our products and services at the highest standard. However, we may from time to time also ask you to participate in other surveys and if you agree to participate in such surveys, we rely on your consent to use the personal information we collect as part of such surveys. All responses to any survey we send out whether for client feedback or otherwise will be aggregated and depersonalized before the results are published and shared.

Data analysis

Our website pages and emails may contain web beacons or pixel tags or any other similar types of data analysis tools that allow us to track receipt of correspondence and count the number of users that have visited our webpage or opened our correspondence. We may aggregate your personal information with the personal information of our other clients on an anonymous basis (that is, with your personal identifiers removed), so that more rigorous statistical analysis of general patterns may lead us to providing better products and services.

Marketing purposes

We may use your personal information to send you marketing communications by email or other agreed forms (including social media campaigns), to ensure you are always kept up to date with our latest Services. If we send you marketing communications, we will do so based on your consent and registered marketing preferences.

Internal business purposes and record keeping

We may need to process your personal information for internal business and research purposes as well as for record keeping purposes. Such processing is in our own legitimate interests and is required in order to comply with our legal obligations. This may include any communications that we have with you in relation to the products and services we provide to you and our relationship with you. We will also keep records to ensure that you comply with your contractual obligations pursuant to the Terms and Conditions governing our relationship with you.

Legal Notifications

Often the law requires us to advise you of certain changes to products or services or laws. We may need to inform you of changes to the terms or the features of our products or services. We need to process your personal information to send you these legal notifications. You will continue to receive this information from us even if you choose not to receive direct marketing information from us.

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.


The Company respects the privacy of any users who access its website, and it is therefore committed to taking all reasonable steps to safeguard any existing or prospective clients, applicants and website visitors. We are committed to protecting your privacy. Internally, only people with a business need to know Personal Information, or whose duties reasonably require access to it, are granted access to customers’ Personal Information. Such individuals will only process your Personal Information on our instructions and are subject to a duty of confidentiality.

The Company keeps any personal data of its clients and its potential clients in accordance with the applicable privacy and data protection laws and regulations. We have the necessary and appropriate technical and organizational measures and procedures in place to ensure that your information remains secure at all times. 

We regularly train and raise awareness for all our employees to the importance of maintaining, safeguarding and respecting your personal information and privacy. We regard breaches of individuals’ privacy very seriously and will impose appropriate disciplinary measures, including dismissal from employment. We have also appointed a Group Data Protection Officer, to ensure that our Company manages and processes your personal information in compliance with the applicable privacy and data protection laws and regulations, and in accordance with this Privacy Notice. The Site’s systems and data are reviewed periodically to ensure that you are getting a quality service and that leading security features are in place. We have put in place procedures to deal with any actual or suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Your Personal Information (documents, registering documents, transactions will and all data we collect as defined in this document) will be stored in the Google Cloud platform, which operates a series of data centers around the world and may be transferred worldwide. However, as almost every transaction is made on public blockchain (BTC, ETH, etc.), this data will be stored and shown on the public blockchain.

Your Personal Information may be processed and stored in a foreign country or countries as we are storing them on Google Cloud Services. Under those circumstances, the governments, courts, law enforcement, or regulatory agencies of that country or those countries may be able to obtain access to your Personal Information through foreign laws. You need to be aware that the privacy standards of those countries may be lower than those of the jurisdiction in which you reside.

Unfortunately, the transmission of information via the Internet is not completely secure. While we do our utmost to protect your Personal Information, we cannot guarantee the security of your data transmitted to us over email or through the Site; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access.


The Company will not disclose any of its clients’ confidential information to a third party, except on the following situations, in which you agree that we have the right to share your Personal Information:

  • to the extent that it is required to do so pursuant to any applicable laws, rules or regulations;
  • any members of the Company, which means that any of our affiliates and subsidiaries may receive such information;
  • applications on our platform that analyze the user’s behavior;
  • any of our service providers and business partners, for business purposes, such as specialist advisors who have been contracted to provide us with administrative, financial, legal, tax, compliance, insurance, IT, debt-recovery, analytics, research or other services;
  • to promote the adequate KYC analysis and AML screening accordingly to the applicable regulations;
  • Selected third parties, including analytics and search engine providers that assist us in the improvement and optimization of the Services;
  • if there is a duty to disclose;
  • if our legitimate business interests require disclosure;
  • in line with our Terms and Conditions;
  • at your request or with your consent or to those described in this Privacy Policy. 

If the Company discloses your personal information to service providers and business partners, in order to perform the services requested by clients, such providers and partners may store your personal information within their own systems in order to comply with their legal and other obligations. We require that service providers and business partners who process personal information to acknowledge the confidentiality of this information, undertake to respect any client’s right to privacy and comply with all relevant privacy and data protection laws and this Privacy Policy.

All users may access and verify their Personal Information held by us by submitting a written request to [email protected], and demand, if needed to rectify any inaccurate Personal Information that we may hold about you; have your Personal Information erased in certain circumstances, (i.e. when the Personal Information it is no longer necessary for us to process your Personal Information and to fulfill our processing purposes); restrict the processing of your Personal Information where, for example, the information is inaccurate or it is no longer necessary for us to process such information or where you have exercised your right to object to our processing; and have your data ported to a new service provider if you no longer wish to use the Services. You may exercise these rights by contacting us.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information   is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

This Privacy Policy and the use of your Personal Information only applies to the information you provide. You are cautioned that if you disclose Personal Information or personally sensitive data through use of the Internet, such as through chat rooms, communities, bulletin boards, or other public online forums, this information may be collected and used by other persons or companies over which the Company has no control. It is your own responsibility to review the privacy statements, policies, terms, and conditions of any person or company to whom you choose to link or with whom you choose to contract. We are not responsible for the privacy statements, policies, terms, conditions, or other content of any Site not owned or managed by us.


When you use our Services, we may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, “Cookies”) on your computer or other devices used when engaging with us. We use Cookies to (i) help us recognize you as a customer, collect information about your use of our products and services, to better customize our services and content for you, and to collect information about your computer or other access devices to ensure our compliance with our BSA and AML obligations. 


Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy.



If you have any concerns about how we handle your Personal Information, please contact us in the first instance. We will do our best to resolve your concern. Questions, comments and requests regarding this Privacy Policy should be addressed to [email protected].