Kraken U.S. Privacy Notice - Payward Interactive, Inc., Kraken Securities LLC, Kraken Adviser LLC, Payward Accredited LLC and Kraken Lending LLC d.b.a. Kraken - Last updated 29 April 2026.

The following Kraken Privacy Notice, and GLBA Notice and Disclosure applies to you if you are an individual who resides in the United States and US Territories, and uses the services or websites of Payward Interactive, Inc., Kraken Securities LLC, Kraken Adviser LLC, Payward Accredited LLC and Kraken Lending LLC (d.b.a Kraken). For residents of the United States, the terms in this Privacy Notice take precedence over the terms in Kraken’s Global Privacy Notice available here.

Important information about procedures: To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.

What this means for you: When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents

Introduction

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, related support and services (collectively, “Services”), and to ensure that we can meet their needs when providing these products and services, as well as when providing them with any respective information. When you visit our website, social media pages, or other online properties (collectively “Sites”), we may also collect and use certain information about you.

Your privacy is of utmost importance to us, and it is our policy to safeguard and respect the confidentiality of information and the privacy of individuals. This Privacy Notice explains how Kraken collects, uses, and manages the personal information we receive from you, or via a third party, in connection with our provision of services to you or which we collect from your use of our services and/or our website. The Privacy Notice also informs you of your rights with respect to the processing of your personal information and the choices you can make about what information you share.

The Privacy Notice applies to all products and services offered or provided by Kraken to U.S. clients, potential U.S. clients, individuals U.S. clients transact with, and U.S. users of Kraken’s products and services accessed through our websites, web and mobile applications, white-label, embedded, or API-based partner integrations, products that run on-chain (such as Kraken Verify), as well as U.S. website visitors (including any services, terms, or communications that reference, display, or link to this Privacy Notice), except where a particular product, service, or jurisdiction has a separate privacy notice. The personal information we collect, use, and disclose will vary based on how you interact with Kraken, our products, and our websites. We have done our utmost to make this notice comprehensive and understandable, but appreciate that it is complex, so please reach out by using our contact form if you have questions.

Certain individuals may be provided with additional privacy notices as described below:

• Kraken Clients – When you sign up for an account with us, we may collect and use your information to facilitate the provision of services pursuant to our GLBA Notice, as applicable. Federal law requires us to provide notice to certain customers to explain what personal information we collect, how we disclose it, and how consumers may limit information sharing. These privacy practices are subject to our GLBA Notice, which we strongly suggest you review.

• Notice to California Residents – If you are a resident of California, please see our California Consumer Privacy Notice for additional relevant information.

• You may have other privacy protections under applicable state laws. To the extent these state laws apply, we will comply with them when we disclose information about you. Please see our State Specific Privacy Statement for more information on whether you have additional rights or protections under other state privacy laws.

Key Terms Used Throughout This Notice

The following terms are defined as follows:

“Kraken Account” means a user-accessible account offered via Payward Interactive, Inc..

“We”, “Our”, and “Us” refers to Payward Interactive, Inc., Kraken Securities LLC, Kraken Adviser LLC, Payward Accredited LLC and Kraken Lending LLC d.b.a Kraken.

“Personal information” or “personal data” refers to any information relating to you, as an identified or identifiable natural person, including your name, an identification number, location data, or an online identifier or to one or more factors specific to the physical, economic, cultural, or social identity of you as a natural person.

“User” and “You” refers to our clients, prospective clients, and individuals who visit our Site or use our Services.

"Biometric data" means data generated by automatic measurements of an individual's biological characteristics, such as a facial geometry or other unique biological patterns or characteristics that are used to identify a specific individual.

"Identified or identifiable natural person" means a person who can be readily identified, directly or indirectly.

"DeFi" means decentralised finance systems that run on blockchain technology and use smart contracts to enable peer-to-peer financial activities such as trading, lending, borrowing, earning interest, or providing liquidity.

Categories Of Personal Data Kraken May Collect About You

• Identifiers: identifiers such as a real name, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers;

• Social Sign-In Data: If you create or access your Kraken account using your Google Account or Apple Account via social sign-in, Kraken receives limited information from the provider necessary to authenticate you and operate your account, such as your name, email address (or, if you choose Apple’s “Hide My Email,” a private relay address), a provider-assigned user identifier, and authentication tokens. Kraken does not receive your Google or Apple passwords;

• Customer and Payment Information: signature, physical characteristics or description, age signals (e.g. age band and parent-approval status received from App stores such as Apple or Google, as required by law for individuals in certain U.S. states), identification card number, education, bank account number, credit card number, debit card number, on-chain transactions, and other financial information;

• Third-party payment information: beneficiary details (such as name, bank account number, and routing number) you provide to initiate payments to external bank accounts, and sender details received from banking and payment networks in connection with payments you receive from external bank accounts;

• On-chain interaction and attestation information: meaning information generated when you interact with DeFi products or services or when carrying out other on-chain activities, including through hybrid or self-custodial wallet functionality accessed via Kraken interfaces. This category may include DeFi transaction records, liquidity-provision data, wallet-verification status (e.g., whether a wallet is associated with a Kraken account), wallet addresses used for attestations or other on-chain interactions, and related metadata such as timestamps, transaction hashes, protocol, contract or vault identifiers, schema details, and other technical information recorded on public blockchains;

• Loyalty Programme Information: points balances, tiers or levels, and a randomly generated display name used on leaderboards or in similar interfaces;

• Third-party platform interaction data: identifiers and information we receive from third-party platforms, through which you interact with our services, such as messaging platforms, including the identifiers the platform assigns to you, your username or display name on the platform, profile information you have made available, conversation metadata, and the content of instructions you send to us through the platform;

• Protected Classifications: characteristics of protected classifications under State or federal law, such as race, color, national origin, age, sex, gender, marital status, citizenship status, and military and veteran status;

• Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, securities traded, trade execution data, holding and portfolio information, and other purchasing or consuming histories or tendencies;

• Regulatory and Compliance Data: suitability information for equities trading accounts, investment experience and risk tolerance, and any other information needed to comply with Financial Industry Regulatory Authority (FINRA) and U.S. Securities and Exchange Commission (SEC) regulations;

• Biometric Data;

• Online Activity: internet and other electronic network activity information, including, but not limited to information regarding your interaction with websites, applications, or advertisements;

• Geolocation Data;

• Sensory Information: audio, visual, and similar information;

• Employment Information: professional or employment-related information;

• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, behavior, and attitudes.

Purposes For Processing Personal Data

• To comply with laws and regulations that Kraken may be subject to;

• Performing services, maintaining or servicing accounts including enabling account creation and access via social sign-in with Apple or Google, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, including referral programmes, providing analytics services, or providing similar services;

• To facilitate equities trading services, including brokerage account setup, trade execution, clearing, settlement, and regulatory compliance;

• To facilitate access to DeFi products and services, including hybrid or self-custodial wallet provisioning and authentication that support your use of these services, as well as other on-chain activities accessible through Kraken interfaces;

• To facilitate collateralised borrowing services, including loan origination, collateral management, and interest calculation;

• To facilitate third-party payment services, including processing inbound and outbound payments between Kraken clients and external bank accounts;

• To provide and administer our loyalty programme, including calculating points, determining levels and ranks, and operating leaderboards;

• To enable you to use our services through third-party platforms, such as submitting request for quote (RFQ) instructions via messaging platforms;

• To comply with regulatory obligations under applicable U.S. securities laws, including FINRA and SEC requirements, by verifying customer suitability for trading, monitoring trade activity for suspicious behavior, and ensuring compliance with investor protection regulations;

• Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;

• Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction;

• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;

• Debugging to identify and repair errors that impair existing intended functionality;

• Undertaking internal research for technological development and demonstration; and/or

• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

We may also, 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 products and services. It is our legitimate interest to use your personal information in this way to try to ensure the highest standards when providing you with our products and services and to continue to be a market leader within the cryptocurrency financial service industry.

This may include:

• To tailor specific communications and promotions according to your preferences;

• To provide you with access to the services;

• To serve the functions of the Sites;

• To manage everyday business needs, such as administering and improving the Sites;

• To analyze the performance and functioning of the Sites;

• To analyze how you use the Sites and to perform other market research;

• For internal operations, including troubleshooting, testing, and analytics; and

• To assist us in developing new products and improving our Services.

Kraken may also use or disclose de-identified information that is not reasonably likely to identify you for commercially legitimate business purposes.

Disclosure of Personal Data

As part of the processing activities described above, Kraken may share your personal data within the Payward group of companies and with carefully selected third parties. We only share personal data for legitimate purposes and when it is lawful to do so, and we require each recipient to protect the confidentiality of your personal data and to comply with applicable privacy and data protection laws. We may share your Personal Data with third parties under the following circumstances:

• Corporate Affiliates: We share personal data with other members of the Payward group of companies, including our parents, subsidiaries, and entities under common ownership or control, for operational and business purposes consistent with this Privacy Notice.

• Service Providers and Business Partners: We share personal data with service providers, specialist advisors, and business partners that need access to perform services on Kraken's behalf, including administrative, financial, commercial, legal, tax, auditing, compliance, insurance, IT, debt-recovery, marketing, analytics, research, blockchain, DeFi, payment card issuance and processing, securities clearing and settlement, and identity verification services. These service providers and business partners are not authorized to use or disclose your personal data except as necessary to perform services on Kraken's behalf or to comply with legal requirements, and have no independent rights to your personal data.

• Independent Partners: In some cases, we share personal data with third parties that use that information for their own purposes, rather than processing it on Kraken's behalf. Examples include our card-issuing partner, partners that enable access to embedded or self-custodial wallets, DeFi products, or other on-chain services, and other Payward group companies when providing their own products or services. In these cases, the partner is responsible for its use of your personal data under its own privacy notice and terms, which you may be asked to accept separately.

• Banking and Payments Partners: We share personal data with banking and payments partners for the purpose of investigating and responding to potential sanctions violations and crime, including fraud and money laundering.

• Telecommunication and Mobile Network Operators: Depending on your jurisdiction, we may share personal data with telecommunication providers and mobile network operators for the purpose of identity verification. No mobile information will be shared with third parties for their marketing or promotional purposes.

• Referral Partners: If you sign up for Kraken using a referral link or code shared by another user, we share limited personal data (such as your first name) with the referring user to operate the referral program.

• Affiliate Program Partners: If you sign up for Kraken through our Affiliate Program, we share limited pseudonymised and aggregated information with the referring affiliate to operate the program and calculate and pay commissions.

• Other Kraken Clients: In connection with your participation in our Ink Points loyalty programme, we may display your rank and score alongside a randomly generated display name on leaderboards or in similar interfaces. The display name is system-generated from random words and is designed so that other clients cannot identify you from it.

• Trustpilot: With your consent, we share your name and email with Trustpilot so that you can leave a review of Kraken without having to create a full Trustpilot account.

• Regulators and Law Enforcement: We share personal data with government, regulatory, and law enforcement authorities where required by applicable law, including in response to court orders, subpoenas, and other legal process. This includes U.S. regulators such as the U.S. Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA), the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) and other authorities administering economic sanctions laws, and anti-money laundering regulators in jurisdictions where Kraken operates.

• Protecting Kraken, Our Users, and Others: We share personal data where we reasonably believe it is necessary to prevent fraud, detect and respond to security threats or illegal activity, enforce our Terms of Service, and protect the rights, property, or safety of Kraken, our users, and others.

• Corporate Transactions: We may share personal data in connection with, or during negotiations of, a prospective merger, acquisition, financing, or sale of all or part of our business or assets.

• Public Blockchain and On-Chain Attestations: On-chain attestations and other data recorded on a public blockchain are publicly accessible and may be accessed by third parties via blockchain explorers and APIs. Kraken does not control or restrict third-party access to this information.

• With Your Consent or at Your Direction: We share personal data with third parties where you have given us your consent or directed us to do so.

We may also share de-identified or aggregated information that cannot reasonably be used to identify you. We maintain and use such information only in de-identified form and will not attempt to re-identify it, except as permitted by law.

Selling Or Sharing Of Personal Information

Kraken does not sell personal data to any third parties for monetary consideration and has not done so in the preceding 12 months. We do not sell personal information. However, we share trading data with our affiliates and service providers to facilitate equities transactions and comply with legal and regulatory obligations. Please note no mobile phone numbers will be shared with third parties for their marketing or promotional purposes.

Data Retention

We retain personal data as necessary to fulfil the purposes for which it was collected, to comply with our legal and regulatory obligations, and to establish, exercise, or defend legal claims. When personal data is no longer necessary for the purposes for which it may lawfully be processed, we will remove any details that will identify you, or we will securely destroy the relevant records. For legal and regulatory reasons we may need to maintain records for a significant period of time after you cease being our client, for example, when we need to retain information to help manage a dispute or legal claim. Additionally, we are subject to certain laws and regulations including anti-money laundering laws and U.S. securities and investment advisory laws which may require us to retain the following for a period (e.g., 5 years or longer) after our business relationship with you has ended:

• A copy of the records we used in order to comply with our client due diligence obligations;

• Supporting evidence and records of transactions with you, and your relationship with us;

• Records and communications relating to the services we provide to you.

If you have opted out of receiving marketing communications, we will keep your information on our suppression list to ensure that you do not receive these messages.

You may unlink social sign-in in your Google or Apple settings. If you revoke access, you may need to add another sign-in method (for example, create a Kraken password) to continue accessing your account. Revoking access does not automatically delete information we already maintain about your Kraken account.

We may keep your personal data for longer than 5 years if we cannot delete it for legal, regulatory, or technical reasons.

Kraken retains on-chain interaction and attestation information for operational, security and integrity purposes. Off-chain data generated through these interactions is stored only as long as necessary to prevent fraud, spam and abuse, ensure platform integrity, and support the services you use. On-chain data recorded on a public blockchain is immutable and cannot be modified or deleted by Kraken.

Biometrics Policy

By using Kraken’s services, accepting our privacy notice, and/or accepting our terms of service, you give your written consent to the collection, processing, usage, and storage of your Biometric Data.

You release in favor of Kraken any claims related to collection, processing, usage, and storage your Biometric Data. This includes any past or prior claims as well as any claims that may arise in the future related to your use of Kraken’s services

Biometric Data Collection

Kraken collects, uses, stores, and processes Biometric Data to verify or confirm your identity, both when you initially open or verify your Kraken account and at any point thereafter as deemed necessary by Kraken or required by law or regulation. Full details relating to this are contained in Kraken’s Biometrics Policy.

Children's Personal Information And Online Privacy (COPPA)

The Children's Online Privacy Protection Act (COPPA) is intended to provide parents increased control over what information is collected from their children online and how such information is used. The law applies to websites and services directed to, and which knowingly collect information from, children under the age of 13.

Our products and services are not directed to persons under the age of 18, hereinafter “Children” or “Child,” and we do not knowingly collect personal information from Children. If we learn that we have inadvertently gathered personal information from a Child, we will take legally permissible measures to remove that information from our records. Kraken will require the user to close his or her account and will not allow the use of our products and services.

If you are a parent or guardian of a Child, and you become aware that a Child has provided personal information to us, please reach out by using our contact form and you may request to exercise your applicable access, rectification, cancellation, and/or objection rights. If you are under the age of 18, please do not provide any personal information through the Sites or Services.

For additional information on COPPA protections refer to the Federal Trade Commission's website.

GLBA Notice And Disclosure

What Does Kraken Do With Your Personal Information?

Financial companies choose how they disclose your personal information. Federal law gives consumers the right to limit some but not all disclosures. Federal law also requires us to tell you how we collect, disclose, and protect your personal information. Please read this notice carefully to understand what we do.

All financial companies need to disclose customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can disclose their customers’ personal information; the reasons Kraken chooses to disclose, and whether you can limit this disclosure.

Kraken takes the security of personal data incredibly seriously. Please see here for further detail about our information security practices, and here for general security information.

The types of personal information we collect and disclose depend on the product or service you have with us. This information can include:

• Social Security number and income

• Account balances and payment history

• Transaction history and account transactions

• Government-issued ID information

• Tax information

Kraken collects your personal information, for example, when you:

• Interact with support, Kraken website or we communicate with you;

• Apply for or use any Kraken product or service;

• Open an account;

• Make deposits or withdrawals from your account;

• Give us your income information;

• Provide employment information or your employment history;

• Give us your contact information;

• Show your government-issued ID or your driver's license.

We also collect your personal information from third parties, such as credit bureaus, affiliates, your social account providers Apple or Google if you use our social sign-in feature, or other companies that provide services to Kraken (e.g. KYC service providers).

Federal law gives you the right to restrict the sharing of your personal information in the following specific situations:

• Sharing your creditworthiness information with our affiliates for their everyday business purposes.
• Allowing our affiliates to use your personal information for marketing purposes.
• Sharing your personal information with non-affiliated companies for their marketing purposes.

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law

To limit our sharing or ask questions about this GLBA Notice, please submit a request to us by:

• Using our contact form;

• By phone, at (888) 871- 2573

California Consumer Privacy Notice

This California Privacy Notice (“California Notice”) is for California residents, and describes how Kraken collects, uses, and discloses your personal information. The information on this notice provides details on how we respond to and implement processes to uphold California State laws.

Any terms defined in the California Consumer Privacy Act (as amended by the California Privacy Rights Act of 2020) (“CCPA”) have the same meaning when used in this California Notice. The CCPA does not apply to personal information we collect as part of our current or former client relationship with you pursuant to other privacy laws such as the federal Gramm-Leach-Bliley and Fair Credit Reporting Acts, and the California Financial Information Privacy Act. For more information about what information is exempt from disclosure, see the section titled ‘Exemptions’ below.

Definitions

“Personal information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. This information may also be referred to in this California Notice as “personal data.”

“Shine the Light” and “Eraser” Laws: Residents of the State of California may request a list of all third parties to which we have disclosed certain personal information during the preceding year for those third parties’ direct marketing purposes.

“Customers” are defined as individuals who access or use our services.

Sources Of Personal Information

We gather various types of personal information from our customers from a range of sources, such as:

• information you give us when you sign up for, or otherwise use, our Services;

• information we receive from our affiliates and third parties;

• Information that is in the public domain;

• information we collect automatically through cookies and similar technologies (see our Cookie Policy for more information on this type of information).

Purpose For Collection And Disclosure Of Personal Information

We’ve collected and disclosed the below categories of personal information to create, develop, operate, deliver, and improve our services; to communicate with you; to comply with applicable laws and regulations; to ensure the safety, security and integrity of our Services; and for business and commercial purposes. Kraken does not collect, use, or disclose sensitive personal information for purposes other than those specified in this Notice, to provide the Services, or as permitted under applicable law. Kraken does not sell personal information. For more information about how Kraken may use your personal information, please refer to other potentially applicable notices, such as the Global Privacy Notice.

Collection And Disclosure Of Personal Information

In the past 12 months, we’ve collected the below categories of personal information, and disclosed the specific types of personal information below with the following categories of third parties:

Collection and Disclosure of Sensitive Personal Information

In the past 12 months, we’ve collected and disclosed the following categories of sensitive personal information, with the following categories of third parties:

Selling or Sharing of Personal Information

In the past 12 months, we may have shared identifiers with third party analytics providers, advertising partners, and ad networks for analytics and advertising purposes. For referral programme administration, including commission calculation and payment, we may have shared limited pseudonymised referral performance information with referrers. Kraken does not sell your personal information.

Rights

As a California resident, you may have the rights listed below in relation to personal information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

Right to Know

You have a right to request the following information about our collection, use and disclosure of your personal information over the prior 12 months, and ask that we provide you with a copy of the following:

• Categories of personal information we have collected, sold, or shared about you;

• Specific pieces of personal information we collected about you;

• Categories of sources from which we collect personal information;

• The business or commercial purpose for collecting, selling, or sharing the personal information;

• Categories of third parties with whom we disclose that personal information;

• Categories of personal information disclosed about you for a business purpose;

• Categories of personal information that each recipient received.

Twice within a twelve month period, you have the right to request the personal information we have collected, used, disclosed, and sold about you during the past 12 months.

Right to Correct

You have a right to request that we correct inaccurate personal information maintained about you.

Right to Delete

You have a right to request that we delete personal information, subject to certain exceptions.

Right to Opt out of Selling or Sharing

You have the right to direct a business that sells or shares personal information about you to third parties to stop doing so. Kraken does not sell personal information.

Right to Non-Discrimination

We will not discriminate against you for exercising any of these rights

Right to Portability

You have the right to receive this information in a format, where feasible, that is portable, usable, and allows you to transmit the personal information without impediment.

Other Rights That May Be Available in Some Circumstances

Right against automated decision making

A prohibition against a business making decisions about a consumer based solely on automated processing.

Private right of action

The right for a consumer to seek civil damages from a business for violations of a statute.

Other California Privacy Rights

The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

Exemptions

Please note that certain types of personal information collected or maintained by a covered business are exempt from the CCPA. For example, a covered business has limited obligations, or in some cases, no obligations, under the CCPA with regard to the following types of personal information:

• Personal information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act (Public Law 106-102) and implementing regulations, or pursuant to the California Financial Information Privacy Act (Division 1.4 commencing with Section 4050 of the California Financial Code)

• Medical information governed by the Confidentiality of Medical Information Act or protected health information that is collected by a covered entity or business associate pursuant to the Health Insurance Portability and Accountability Act of 1996.

Please note that the description of the CCPA set forth in this California Notice is a summary of only certain aspects of the CCPA and is not and should not be considered a complete description of the CCPA. In addition to what is described above, the CCPA includes other exemptions that apply to particular types of personal information and particular businesses, as well as additional situations where a covered business is not required to honor a consumer’s request to delete the consumer’s personal information.

Other State Privacy Rights

Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with certain rights, which may include some or all of the following depending on your location:

• Confirm whether we process their personal information.

• Access and delete certain personal information.

• Correct inaccuracies in their personal information, taking into account the information's nature processing purpose (excluding Iowa and Utah).

• Data portability.

• Opt-out of personal data processing for:

  • targeted advertising (excluding Iowa);

  • sales; or

  • profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).

• Either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary by state, please reach out by using our contact form if you have any questions.

Exercising Rights

To exercise your rights described above, please submit a request to us by:

Using our contact form;

By phone, at (888) 871- 2573

Only you or an agent who is authorized to act on your behalf (and registered with the California Secretary of State, if you are a California resident) may make a Request.

• You may only make two Requests within a 12-month period.

• Each Request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

• We will make every effort to verify your identity using your email address, but we may request additional information. If an authorized representative is making the request on your behalf, we require documentation showing that the representative has such authority. Describe your Request with sufficient detail that allows us to properly evaluate and respond to it.

• We will not respond to your request or provide you with personal information if we are unable to verify your identity, or to verify the authority for the person making the request as your agent.

• We will use personal information provided in a verifiable consumer Request to verify your identity or authority to make the Request, and not for any other purpose.

To appeal a decision regarding a consumer rights request, please use the same contact details as above.

Verified Request

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may require you to provide any of the following information: your name, date of birth, the last four digits of your Social Security number, the email and physical addresses associated with your Kraken account, one or more recent transactions, and the last four digits of one or more of the cards associated with your account.

If you have never had an account with us and you request access to or deletion of your personal information, there is likely no reasonable method by which we can verify your identity to the level of certainty required. The reason for this is that Kraken does not maintain information about non-account holders in a way that is linked to named actual persons (and historically has not linked IP addresses, device identifiers or other information collected by automated means to named actual persons).

In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

For questions or concerns about our privacy notices and practices, please contact us as described in the Exercising Rights section above.

Response Timing And Format

We will respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Kraken will not charge a fee to process or respond to your verifiable consumer request, but reserves the right to request a fee if the request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Changes To The Privacy Notice

You may request a copy of this Privacy Notice from us using the contact details set out above. Where changes to this Privacy Notice will have a fundamental impact on the nature of our processing of your personal data or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise any rights you may have under applicable law (e.g., to object to the processing).

We reserve the right to make changes to our Privacy Notice at any time consistent with applicable local laws. Such changes, as long as they do not have a fundamental impact on the nature of our processing of your personal data or, otherwise, have a substantial impact on you, will be posted on this page. We encourage you to review the web site and the Privacy Notice periodically for any updates or changes.