1. Account Disablement, Account Deletion and Data Retention
HUMB provides Customers with options to temporarily disable or permanently close their account through the applicable account-management features available on the HUMB Platform.
Disabling an account and deleting an account have different consequences. Customers should review the information below carefully before proceeding.
2. Disabling Your HUMB Account
Account disablement is a temporary restriction and does not constitute permanent account closure or deletion of personal data.
When You disable Your HUMB account:
- access to trading and certain account functions may be restricted;
- open positions, open orders, pending transactions or other active services may need to be resolved before disablement can be completed;
- digital assets associated with the account are not deleted as a result of account disablement;
- Your account information, KYC information, transaction history and other applicable records remain stored; and
- HUMB may continue processing Your personal data where necessary for account administration, security, fraud prevention, AML/CFT compliance and other legal or regulatory purposes.
Because the customer relationship has not been permanently terminated solely by disabling the account, applicable post-termination retention periods do not begin merely because an account has been disabled.
Reactivation may require authentication, identity verification, security checks or additional compliance review where appropriate.
3. Permanently Deleting Your HUMB Account
You may request permanent closure of Your HUMB account through the account-management functionality provided by HUMB or through another account-deletion method made available by HUMB.
Account deletion permanently ends access to the relevant HUMB account once the closure process has been completed.
Before an account can be closed, You may be required, where applicable, to:
- close open trading positions;
- cancel open orders;
- complete or resolve pending deposits, withdrawals or transfers;
- withdraw available digital assets;
- end or resolve active trading services or programmes; and
- satisfy outstanding account, contractual, security or compliance requirements.
HUMB may temporarily restrict or delay completion of account closure where this is reasonably necessary to comply with applicable law, regulatory obligations, court or authority requests, AML/CFT requirements, fraud or security investigations, dispute resolution or the establishment, exercise or defence of legal claims.
Where applicable law prevents HUMB from disclosing details relating to a compliance or AML/CFT review, HUMB may be unable to provide certain information regarding such review.
Once all applicable requirements have been satisfied, HUMB will process the account closure and notify You through the registered contact details or another appropriate communication method.
4. What Happens to Your Personal Data After Account Deletion?
Deleting Your HUMB account does not necessarily result in the immediate deletion of every record associated with You.
Following account closure, HUMB will delete or anonymise personal data that is no longer required for the purposes for which it was collected and for which HUMB has no other lawful basis or obligation to retain.
Certain information must continue to be retained where required or permitted under applicable laws and regulatory requirements. This may include, without limitation:
- customer identification and KYC records;
- identity-verification information;
- transaction and trading records;
- deposit and withdrawal records;
- wallet and transaction identifiers;
- AML/CFT monitoring records;
- compliance alerts and investigations;
- fraud-prevention and security records;
- communications relevant to regulatory or legal obligations; and
- records necessary for the establishment, exercise or defence of legal claims.
Under HUMB's AML & KYC Policy, Customer identification and KYC documents, transaction data, and AML alerts and investigation records are retained for a minimum of five (5) years after the end of the customer relationship.
Certain records may be retained for a longer period where required or permitted by applicable law, regulatory requirements, competent authorities, ongoing investigations, dispute resolution or legal proceedings.
After the applicable retention period expires, information that no longer needs to be retained will be securely deleted or anonymised in accordance with HUMB's applicable data-retention procedures.
5. How Retained Information Is Used
Information retained following account closure will only be processed where HUMB has an appropriate legal basis or obligation to do so. Retained information may be used for purposes including:
- compliance with AML/CFT and KYC obligations;
- responding to lawful requests from competent authorities;
- fraud, financial-crime and security prevention;
- regulatory reporting and record keeping;
- audit and compliance requirements;
- resolving disputes; and
- establishing, exercising or defending legal claims.
Access to retained compliance information is restricted to authorised persons on a need-to-know basis and is subject to HUMB's applicable technical, organisational and security measures.
Account deletion does not authorise HUMB to use legally retained information for unrelated purposes.
6. Blockchain Transactions
Certain transactions involving digital assets may be recorded on public or distributed blockchain networks.
Blockchain records may be permanent or technically immutable and may exist independently of HUMB's systems. Where HUMB does not control the relevant blockchain network, HUMB may not be able to alter, remove or delete information that has already been recorded on that blockchain.
Closing or deleting a HUMB account therefore does not result in deletion of transaction information independently recorded on a public blockchain.
Personal data maintained within systems controlled by HUMB will continue to be handled in accordance with this Privacy Policy and applicable data-protection law.
7. Identity and Security Verification
To protect Customers against unauthorised account closure or disclosure of personal information, HUMB may require You to verify Your identity before processing an account-disablement, account-deletion or privacy-related request.
Verification may include, where appropriate:
- password verification;
- email or mobile OTP verification;
- two-factor authentication (2FA);
- identity documentation; or
- other reasonable security or compliance checks.
Additional verification will only be requested where reasonably necessary to protect Your account, confirm Your identity or satisfy HUMB's legal and regulatory obligations.
8. Account Deletion and Your Right to Erasure
Permanent account deletion and the exercise of Your data-protection rights are related but separate processes.
Closing Your HUMB account ends Your access to the account once the closure process has been completed. Your right to request erasure of personal data is governed by applicable data-protection law, including Article 17 of the General Data Protection Regulation ("GDPR"), where applicable.
The right to erasure is not absolute. HUMB may continue to retain and process personal data where processing is necessary or permitted, including for compliance with legal obligations, AML/CFT requirements, regulatory record keeping, security purposes or the establishment, exercise or defence of legal claims.
Where no legal or other lawful basis for continued retention applies, relevant personal data will be deleted or anonymised in accordance with HUMB's retention procedures.
9. Your Data Protection Rights
Subject to applicable law, You may have rights in relation to Your personal data, including the right to:
- request access to Your personal data;
- request correction of inaccurate or incomplete data;
- request erasure of eligible personal data;
- request restriction of processing;
- object to certain processing; and
- request data portability where applicable.
Deleting or disabling Your HUMB account does not prevent You from exercising applicable data-protection rights.
For further information, please refer to the Data Subject Rights section of this Privacy Policy.
10. Important Distinction
Disable Account
Temporarily restricts access to Your HUMB account. Your account and applicable records remain maintained, and the action does not constitute a request to erase Your personal data.
Delete Account
Initiates permanent closure of Your HUMB account. Personal information that HUMB no longer requires will be deleted or anonymised, while information that HUMB is legally required or otherwise permitted to retain will remain protected for the applicable retention period.
11. How to Request Account Deletion
Where available, You can initiate an account-deletion request through:
HUMB App:
Profile / Account → Manage Account → Delete Account
or through any other account-deletion method officially provided by HUMB.
For data-protection enquiries or to exercise Your applicable privacy rights, please contact:
HUMB UAB
J. Jasinskio st. 16B
Vilnius, LT-03163
Lithuania
Email: privacy@humb.io
HUMB may request reasonable identity verification before processing a privacy-related request in order to protect Your personal information from unauthorised access, alteration or deletion.
For additional information regarding how HUMB collects, processes, protects, retains and deletes personal information, please review the other sections of this Privacy Policy and HUMB's AML & KYC Policy.