Privacy Policy

Last updated: July 2026

RIV-Digital S.r.l. is committed to ensuring the highest level of protection in the processing of its customers’ personal data, in accordance with current data protection laws and regulations. This Privacy Policy describes the policies and practices that RIV Digital, a company incorporated under Italian law, authorized and subject to the supervision of CONSOB (Commissione Nazionale per le Società e la Borsa), with registered office at Via Luigi Dalla Via 3b, 36015, Schio (VI), (“RIV Digital”, “we”, or “us”) has developed and adopted to safeguard personal data and to comply with applicable data protection laws.

Personal data includes all information that RIV Digital collects and processes about you and that can identify you directly or indirectly through our applications (the “App”), including information received from third parties.

Collection of personal data

The personal data that RIV Digital collects or processes about you may include:

(i) Identification data: including name, date of birth, place of birth, nationality, country of residence, country of tax domicile, passport number, residence permit details, tax identification data, passport details, and photos;

(ii) Our interactions with the user: including any recordings of telephone calls between the user and RIV Digital and logs of related information, including phone number, time and date of calls and messages, call duration, routing information, and call types;

(iii) Contact information: including mailing address, telephone number, email address, and mobile number;

(iv) Financial information: including information about your financial situation, details of personal assets, bank account numbers, expenses, income, and credit agency reports provided by competent authorities;

(v) Professional information: including details regarding your employer, your educational and professional background, and your business interests;

(vi) Push notifications: we may send push notifications related to your account. If you wish to opt out of receiving these types of communications, you can contact us.

We will only collect and use personal data necessary for the purposes for which it is intended.

Use of personal data

By providing your personal data, you consent that, where permitted by local legislation or where you have consented to receive such communications from us, we may use the information:

(i) to provide products and services, including executing payments, transactions, and fulfilling instructions or requests;

(ii) to conduct market research and surveys in order to improve our products and services;

(iii) to respond to your requests;

(iv) to improve our level of service;

(v) to improve the content of our communications;

(vi) to provide you with advice, useful information, product news, and updates;

(vii) to inform you about our new products and services;

(viii) for marketing and promotional purposes, conducted with or without the support of third parties appointed by RIV Digital;

(ix) to comply with applicable local or foreign laws, regulations, policies, voluntary codes, directives, judgments, or court orders, as well as any requests from authorities, regulatory bodies (including CONSOB (Commissione Nazionale per le Società e la Borsa) and other competent European supervisory authorities), or law enforcement agencies or bodies;

(x) to comply with “Know Your Customer” (KYC) and anti-money laundering laws and regulations.

(xi) to assert, exercise, or defend legal rights in relation to legal proceedings (including any future legal proceedings) and to seek professional or legal advice regarding such proceedings;

(xii) to prevent, detect, investigate, and prosecute crimes (including, but not limited to, money laundering, terrorism, fraud, and other financial crimes) in any jurisdiction, as well as for identity verification, government sanctions screening, and due diligence checks;

(xiii) for other purposes that may be specified in the App.

Processing principles

In using your personal data, we adhere to the following principles:

RIV Digital will only collect personal data concerning you that is necessary for one or more of our legitimate business purposes or as required by law. Furthermore, RIV Digital will collect personal data only by lawful and fair means and not in an unreasonably intrusive manner.
When RIV Digital collects your personal data, it will take reasonable steps to inform you about what personal data we are collecting and the purposes for which we are collecting it, and will use such information exclusively for the stated primary purposes or related secondary purposes.
RIV Digital will inform you of the organizations (or types of organizations) to which we may normally disclose such personal data and will provide you with contact information should you wish to access your personal data in our possession or need to update your personal data or preferences.

Disclosure of personal information

RIV Digital may use third parties to provide services that may require the disclosure of your personal data to such third parties. If we allow a third party to access your personal data, such access will be permitted solely for purposes consistent with this Privacy Policy, and such third party will be required to protect your personal data in accordance with all applicable data protection laws.

We may disclose personal information to third-party service providers and IT vendors in support of our services or as part of customer support services. Such providers are contractually bound to protect the privacy and security of our customers’ personal information and to comply with the GDPR and the Italian Data Protection Code. We will not disclose personal information to other third parties without obtaining the prior consent of the data subject, except as provided or permitted by law.

In certain circumstances, we may be required to disclose your personal data in response to a court order, subpoena, search warrant, law, or regulation. We intend to cooperate in responding to such requests, taking appropriate measures to ensure that the requester understands the sensitive nature of the personal data they may receive. We also reserve the right to cooperate with law enforcement authorities in investigations and legal proceedings against users who violate our rules or engage in illegal or harmful behavior toward individuals or the personal data for which we are responsible.

Furthermore, if you contact us regarding your experience using our App, we may use the information you provide to submit complaints or reports of adverse events.

Finally, only with the user’s prior consent, RIV Digital may transfer personal data to third parties, including the transfer of data from one country to another, and this may involve transfers to a country where the legislation provides a different level of protection than that of the user’s country of residence. In such cases, we will take appropriate measures to ensure adequate data protection under applicable data protection laws, such as the General Data Protection Regulation (EU 2016/679) (“GDPR”) and the Personal Data Protection Code (Legislative Decree no. 196/2003, as amended by Legislative Decree no. 101/2018). However, we will take steps to ensure that your personal data is processed securely and in compliance with this Privacy Policy, the GDPR, and the Italian Data Protection Code.

Monitoring

To the extent permitted by law, we may record and monitor your communications with us to ensure compliance with our legal and regulatory obligations and our internal policies. This may include the recording of telephone conversations.

Your rights

Subject to applicable law, the user may have the right to assert data subject rights in relation to their personal data processed by RIV Digital. The rights that the user may assert as a data subject may include:

Right of access. The user has the right to obtain confirmation from us as to whether or not personal data concerning them is being processed and, if so, to request copies of their personal data from us free of charge. Please note that we may charge a reasonable fee based on administrative costs for any additional copies requested or refuse any additional request that is reasonably deemed excessively repetitive.
Right to rectification. You have the right to obtain from RIV Digital, without undue delay, the rectification of inaccurate personal data concerning you.
Right to erasure. Subject to compliance with applicable mandatory retention periods, the user has the right to request RIV Digital to erase personal data concerning them if (a) the personal data is no longer necessary for RIV Digital’s business activities (including the offering of financial services or products to the user), (b) the user withdraws their consent to the processing of their personal data, or (c) there is no other legal basis for the processing.
Right to restriction of processing. The user has the right to obtain from RIV Digital the restriction of processing where one of the following conditions applies: (i) the user contests the accuracy of their personal data (in which case, the restriction will last for a period enabling RIV Digital to verify the accuracy of said data); (ii) the processing is unlawful; (iii) the user objects to the processing as being in violation of the purposes agreed upon with RIV Digital (in which case, the restriction will last for a period enabling RIV Digital to verify the agreed purposes of the processing and whether RIV Digital is violating said purposes). The user may request RIV Digital to continue storing their personal data even after the purposes of the processing have been achieved, if such data is necessary for the establishment, exercise, or defense of legal claims. Subject to the provisions of this clause 4, we may still proceed with the processing of your personal data without your consent if the processing is: (i) limited to the storage of personal data; (ii) necessary to initiate, defend, or assert rights in legal proceedings, or is related to legal proceedings; (iii) necessary to protect the rights of third parties in accordance with applicable law; or (iv) necessary to protect the public interest.
Right to data portability. The user has the right to: (i) obtain their personal data in a machine-readable format, where the processing is based on the user’s consent or is necessary for the performance of a contractual obligation; (ii) request the transfer of their personal data to another service provider, where this is technically feasible.
Right to object to processing. The user has the right to object, on grounds relating to their particular situation, at any time to the processing of personal data concerning them. RIV Digital will no longer process such personal data, except in cases where it is necessary for business operations. Any withdrawal of consent in the future will not affect the lawfulness of the processing of personal data carried out before such withdrawal nor any subsequent processing related to RIV Digital’s business operations. This right can be exercised when your personal data is processed for direct marketing purposes, for conducting statistical surveys, or if the processing violates your personal data rights under applicable law.

Security

The security and confidentiality of your personal data are important to us, and RIV Digital has invested significant resources to ensure the custody and confidentiality of your personal data. Regardless of where your personal information is transferred or stored, we take all reasonably necessary measures to ensure that personal data is stored securely. When we use external service providers acting as data processors, we require them to adhere to the same standards as RIV Digital.

Storage of personal data

Your personal data is stored on the company’s own cloud services provided by Amazon Web Services. We take reasonable steps to protect the personal data in our possession from misuse, interference, and loss, as well as from unauthorized access, modification, or disclosure. We will retain personal data only for as long as necessary to fulfill the purposes for which it was collected or as required by law.

Updates to this Privacy Policy

We will use personal data only in the ways described in the Privacy Policy in effect at the time the information was collected. However, we reserve the right to change the terms of this Privacy Policy at any time (for example, following changes to data protection laws) by posting revisions on this website. We will take appropriate and reasonable steps to obtain your consent, if required, following such changes.

Contact Us

If you have any questions or concerns about our Privacy Policy or to exercise your rights, please contact our Data Protection Officer at dpo@riv-digital.it.

Home

Our team

Transparency

Conflicts of Interest Management Policy

Whistleblowing

RIV-Digital S.r.l.
Sede legale: Via Luigi Dalla Via 3 B, 36015, Schio
Registro delle Imprese di Vicenza – REA VI-414981
Codice Fiscale/P. IVA: 05421350280
Capitale sociale: € 300.000,00 interamente versato
LEI: 815600DCB0E8882D2314

RIV-Digital S.r.l. — Authorized by CONSOB as a crypto-asset service provider (Resolution no. 24030 of June 10, 2026).

Activity subject to the supervision of CONSOB (Italian Companies and Exchange Commission), Via G. B. Martini 3, 00198 Rome – www.consob.it.