Privacy Policy

1. Information We Collect

1.1 Information You Provide

We collect information you directly provide when using our services:

• Account Information: Name, company name, business address, email address, phone number, tax identification number (EIN/TIN)
• Payment Information: Credit card details (processed by Stripe Connect), cryptocurrency wallet addresses, banking information for settlements
• Transaction Data: Container numbers, booking references, bill of lading numbers, terminal fee details, payment amounts and dates
• Customs Information: Import/export documentation, commodity descriptions, harmonized tariff codes, importer of record details
• Identity Verification: Government-issued identification, business licenses, beneficial ownership information (as required by applicable law)
• Communications: Support requests, feedback, and correspondence with our team

1.2 Information Automatically Collected

When you access our platform, we automatically collect:

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages visited, features used, time spent on platform, click patterns
• Location Data: Approximate geographic location based on IP address
• Cookies and Tracking: Session data, analytics information, preference settings

1.3 Information from Third Parties

We receive information from:

• Payment Processors: Circle (USDC payments), Stripe (credit card processing)
• Shipping Lines: Container status, arrival dates, demurrage information
• Terminal Operators: Fee schedules, payment confirmations, gate transaction data
• U.S. Customs and Border Protection: Entry status, exam notifications, release information
• Identity Verification Services: KYC/AML compliance data

2. How We Use Your Information

We use collected information for the following purposes:

2.1 Service Delivery

• Process terminal fee payments via USDC or credit card
• Track container locations and provide arrival notifications
• File customs entries and monitor clearance status
• Facilitate communication with terminals, carriers, and customs authorities
• Generate payment receipts and transaction records

2.2 Compliance and Legal Obligations

• Verify identity and perform KYC/AML checks as required by federal law
• Comply with FinCEN regulations for cryptocurrency transactions
• Maintain records for U.S. Customs broker licensing requirements
• Respond to subpoenas, court orders, or legal process
• Detect and prevent fraud, money laundering, or other illegal activities

2.3 Platform Improvement

• Analyze usage patterns to enhance user experience
• Develop new features and services
• Troubleshoot technical issues and improve security
• Conduct internal research and analytics

2.4 Communication

• Send transaction confirmations and payment receipts
• Provide customer support and respond to inquiries
• Notify you of service updates, maintenance, or policy changes
• Send marketing communications (with your consent, where required)

3. Information Sharing and Disclosure

We share your information only in the following circumstances:

3.1 Service Providers

We share data with third-party vendors who perform services on our behalf:

3.2 Business Partners

• Ocean Terminals: Payment information and container references for fee processing
• Shipping Lines: Container numbers and customer identifiers for tracking services
• U.S. Customs: Entry information, importer details, customs bonds (for brokerage services)

3.3 Legal Requirements

We may disclose your information when required by law or to:

• Comply with legal process (subpoenas, warrants, court orders)
• Respond to government requests or regulatory inquiries
• Enforce our Terms of Service or investigate violations
• Protect the rights, property, or safety of Hontza, our users, or the public
• Detect, prevent, or address fraud, security, or technical issues

3.4 Business Transfers

If Hontza is involved in a merger, acquisition, or asset sale, your information may be transferred. We will provide notice before your information becomes subject to a different privacy policy.

3.5 With Your Consent

We may share information for any other purpose with your explicit consent.

4. Cryptocurrency and Blockchain Transactions

4.1 Public Blockchain Records

When you use USDC for terminal fee payments:

• Transactions are recorded on the Ethereum or Polygon blockchain, which is publicly viewable
• Your wallet address, transaction amount, and timestamp are permanently stored on the blockchain
• Anyone can view these transactions using blockchain explorers (e.g., Etherscan, Polygonscan)
• We cannot delete or modify blockchain records after transactions are confirmed

4.2 Wallet Address Privacy

• We do not publicly associate your wallet address with your personal identity
• However, blockchain analysis techniques may enable third parties to link wallet addresses to identities
• We store your wallet address internally to facilitate payments and maintain transaction records

4.3 Compliance with Virtual Currency Regulations

As a payment facilitator handling cryptocurrency:

• We maintain transaction records for at least 5 years as required by FinCEN
• We may report certain transactions to the Financial Crimes Enforcement Network
• We perform enhanced due diligence for high-value or suspicious transactions
• We comply with all applicable anti-money laundering (AML) and counter-terrorism financing (CTF) laws

5. Data Security

We implement industry-standard security measures to protect your information:

5.1 Technical Safeguards

• Encryption: All data transmitted over the internet uses TLS 1.3 encryption
• Data at Rest: Sensitive data is encrypted using AES-256 encryption
• Access Controls: Role-based access restrictions and multi-factor authentication
• Network Security: Firewall protection, intrusion detection systems, regular security audits
• Payment Security: PCI DSS compliance for credit card processing; private keys stored in hardware security modules (HSMs) for cryptocurrency transactions

5.2 Organizational Safeguards

• Background checks for employees with access to sensitive data
• Confidentiality agreements with all staff and contractors
• Regular security training and awareness programs
• Incident response plan for data breaches

5.3 Limitations

While we strive to protect your information, no security system is impenetrable. We cannot guarantee the absolute security of data transmitted over the internet. You use our services at your own risk.

6. Data Retention

We retain your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law.

6.1 Retention Periods

• Account Information: Duration of account plus 7 years (standard business practice)
• Transaction Records: 7 years (IRS and customs recordkeeping requirements)
• Payment Data: 5 years (FinCEN requirements for money service businesses)
• Customs Documents: 5 years from entry date (CBP regulations, 19 CFR 163.4)
• Identity Verification: 5 years after relationship ends (AML requirements)
• Usage Data: 2 years for analytics purposes

6.2 Deletion Requests

You may request deletion of your personal information, subject to legal retention requirements. We will comply with deletion requests within 30 days unless retention is required for:

• Compliance with federal or state law
• Completion of pending transactions
• Resolution of disputes or enforcement of agreements
• Detection and prevention of fraud or security incidents

7. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

7.1 General Rights

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information (subject to legal exceptions)
• Data Portability: Receive your data in a structured, machine-readable format
• Objection: Object to processing of your information for certain purposes
• Restriction: Request restriction of processing under certain circumstances

7.2 State-Specific Rights

California Residents (CCPA/CPRA):

• Right to know what personal information is collected, used, shared, or sold
• Right to delete personal information (with exceptions)
• Right to opt-out of the sale of personal information (we do not sell personal information)
• Right to non-discrimination for exercising privacy rights
• Right to correct inaccurate personal information
• Right to limit use and disclosure of sensitive personal information

Nevada Residents: You have the right to opt-out of the sale of personal information. We do not sell personal information.

7.3 Exercising Your Rights

To exercise any of these rights, contact us at:

• Email: privacy@hontza-global.com
• Mail: Hontza Global LLC, Attn: Privacy Officer, [Nevada Address]

We will respond to verified requests within 30-45 days. We may request additional information to verify your identity before processing your request.

8. International Data Transfers

Hontza Global LLC is based in Nevada, United States. Your information may be transferred to, stored, and processed in the United States or other countries where our service providers operate.

8.1 European Economic Area (EEA) Users

If you are located in the EEA, please note:

• Data transfers to the U.S. are based on Standard Contractual Clauses or other approved mechanisms
• You have rights under the General Data Protection Regulation (GDPR)
• You may lodge a complaint with your local data protection authority

8.2 Data Processing Basis

We process your personal information based on the following legal grounds:

• Contract Performance: Processing necessary to provide our services
• Legal Obligation: Compliance with customs, financial, and regulatory requirements
• Legitimate Interests: Fraud prevention, platform improvement, analytics
• Consent: Marketing communications and optional data processing

9. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at privacy@hontza-global.com. We will delete such information promptly.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements. We will notify you of material changes by:

• Posting the updated policy on our website with a new "Last Updated" date
• Sending an email notification to your registered email address
• Displaying a prominent notice on the platform

Your continued use of our services after the effective date constitutes acceptance of the updated Privacy Policy.

11. Contact Information

For questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact:

We will respond to all privacy inquiries within 30 days.