1.Who we are
SYENU is operated by TIGER AND PARTNERS (PTY) LTD (Registration No. 2021/560984/07). References to “SYENU”, “we”, “us” or “our” mean TIGER AND PARTNERS (PTY) LTD in relation to the Services covered by this Privacy Policy. Privacy questions may be sent to hello@syenu.com.
2.Scope and international users
This Privacy Policy applies to visitors, applicants and customers who use SYENU websites, applications and exchange services. SYENU may accept account applications from non-restricted international jurisdictions where onboarding has been enabled and use of the relevant Service is lawful. Different or supplementary privacy notices may apply when SYENU activates a jurisdiction with mandatory local requirements.
3.Information we collect
SYENU collects only information reasonably required to operate the exchange, verify customers, protect accounts, comply with financial-crime and tax obligations, process transactions and improve the Service. Some information may be sensitive, including identity and biometric/liveness data.
| Category | Examples |
|---|---|
| Account & contact | Name, email, mobile number, username/account identifiers, communication and security preferences. |
| Identity & KYC | Date of birth, nationality, residence, address, identity/passport number, document images, verification results and identity metadata. |
| Biometric / liveness | Selfie images, video/liveness information, facial features/templates where used, face-match results and anti-spoofing/fraud signals. |
| Compliance & risk | Sanctions/PEP/watchlist results, adverse media, AML/CFT risk signals, account purpose, source of funds, source of wealth where required, EDD information, device/fraud signals and compliance notes. |
| Tax | Tax residence(s), TIN/tax reference number or reason for no TIN, self-certification and reportable transaction data. |
| Financial | Bank-account details, account-holder name, payment references, fiat deposit/withdrawal records and related payment information. |
| Trading & blockchain | Orders, executions, balances, wallet addresses, transaction hashes, asset/network information, originator/beneficiary data, counterparty or VASP data, Travel Rule data and wallet-risk signals. |
| Device & technical | IP address, browser/OS, device identifiers/fingerprint, authentication events, security logs, cookies, diagnostics and approximate location derived from IP or device signals. |
| Support & communications | Emails, support tickets, complaints, chat/call records and information you provide to customer support. |
| Public / third-party | Information from Sumsub, sanctions and public databases, banks, payment providers, VASPs, blockchain analytics providers, fraud databases and lawful public sources. |
4.Sumsub and compliance technology
SYENU intends to use Sumsub as a key identity and compliance technology provider. Depending on the flow, Sumsub may process identity documents, liveness/selfie data, facial matching data, device and fraud signals, sanctions/PEP/watchlist results, AML/CFT information, transaction-monitoring data, crypto wallet screening data, VASP attribution data and Travel Rule information. SYENU may also use supplementary or replacement providers where reasonably necessary.
Where SYENU determines the purposes and means of processing, SYENU acts as controller/responsible party as applicable. Providers may act as processors/operators on SYENU’s instructions and may have independent legal obligations for limited processing activities.
5.Why we use personal information
- To create, verify and administer customer accounts.
- To perform KYC, CDD, EDD, AML/CFT, sanctions, PEP and fraud-prevention checks.
- To perform liveness, face matching and identity-fraud controls.
- To process fiat deposits/withdrawals, crypto transfers and spot trades.
- To perform blockchain analytics, transaction monitoring, VASP attribution and Travel Rule compliance.
- To secure accounts, investigate incidents and prevent unauthorised access.
- To meet tax-reporting, recordkeeping, legal, regulatory and law-enforcement obligations.
- To provide support, handle complaints and communicate important service information.
- To operate, test, monitor and improve Platform reliability and user experience.
- To send marketing where permitted and subject to applicable choices.
6.Legal bases / lawful grounds
Depending on jurisdiction, SYENU may process information because it is necessary to perform a contract, comply with law, pursue legitimate interests such as security and fraud prevention, protect vital interests, establish or defend legal claims, or because consent is required for a specific activity. Sensitive or biometric information is processed only where a lawful basis and any additional legal condition are satisfied.
7.KYC, biometric and sensitive information
Identity and biometric/liveness information is used to determine whether an applicant is a real person, whether the face matches the identity document and whether fraud or impersonation indicators are present. This information is protected using access controls, security measures, contractual restrictions and retention limits appropriate to its sensitivity.
8.AML/CFT, sanctions and ongoing monitoring
SYENU may continuously or periodically screen customers, counterparties and activity for sanctions, PEP status, terrorist-financing indicators, fraud, suspicious behaviour and other financial-crime risks. A potential match may be manually reviewed. Compliance decisions may use data from Sumsub, blockchain analytics tools, VASPs, banks, public lists and other lawful sources.
9.Travel Rule and crypto transfer data
Where Travel Rule or similar requirements apply, SYENU may collect, verify, send, receive and retain originator, beneficiary, wallet, transaction and sending/receiving VASP information. This information may be shared with another VASP/CASP or Travel Rule network where legally required or reasonably necessary to process a transfer.
10.Tax residency and reporting
SYENU may collect tax residency and TIN/tax reference information for customers where required. South African reporting obligations may include CARF or other regimes. For international customers, country-specific tax-reporting fields may vary. SYENU may disclose reportable information to SARS or another competent authority where legally required.
11.Geographic and jurisdiction screening
SYENU may process residence, nationality, IP-derived location, device signals and related information to determine eligibility, apply sanctions or jurisdiction restrictions, prevent circumvention and tailor product availability. Users from Restricted Jurisdictions may be denied onboarding or access.
13.Cross-border transfers
Because SYENU uses global technology, compliance, cloud and financial service providers, personal information may be processed outside the customer’s country. SYENU will use contractual, technical, organisational or other safeguards required by applicable law. International processing does not remove a customer’s mandatory local privacy rights.
14.Data security
SYENU uses reasonable administrative, technical and organisational controls designed to protect personal information. No system can guarantee absolute security. Customers must also protect their account credentials, devices, email, mobile number and authentication methods.
15.Retention
SYENU retains personal information for as long as reasonably necessary for the purpose collected and for legal, regulatory, AML/CFT, tax, audit, fraud, dispute and recordkeeping requirements. Some KYC and transaction records may need to be retained after account closure. Retention periods may differ by jurisdiction and data category.
16.Your rights
Depending on applicable law, you may have rights to access, correct, update, object to or restrict certain processing, request deletion where lawful, withdraw consent where processing is consent-based, complain to a data-protection authority, or request portability. Some requests may be limited where SYENU must retain or process information for AML/CFT, sanctions, tax, legal claims or other mandatory obligations.
17.Automated and risk-based decisions
SYENU and its providers may use automated rules, risk signals or scoring to identify verification, fraud, sanctions or transaction risks. Material adverse outcomes may be subject to human review where required by law or appropriate under SYENU policy. Confidential monitoring logic and anti-fraud rules may not be disclosed.
19.Children
SYENU Services are not intended for persons under 18 or a higher local age requirement. We do not knowingly provide trading accounts to underage users.
20.Changes to this Privacy Policy
SYENU may update this Privacy Policy as Services, providers, supported jurisdictions or legal requirements change. Material changes will be communicated where reasonably practicable.
21.Contact and complaints
Privacy enquiries may be sent to hello@syenu.com. You may also have the right to complain to the competent data-protection authority in your jurisdiction, including the Information Regulator in South Africa where applicable.