Website Privacy Notice
Applies to: custodyagents.com and enterprise.custodyagents.com Effective Date: 1 September 2026 Last Updated: 1 September 2026 Data Controller: Custody Agents S.L. Address: Avenida Diagonal, 449, 4a planta, 08036, Barcelona, Spain Contact: privacy@custodyagents.com
Scope
This notice covers our public websites: custodyagents.com and enterprise.custodyagents.com.
It does not cover the Sentinel Platform. If you hold a Sentinel account, the processing of your account and governance assessment data is governed by the separate Sentinel Privacy Policy at https://sentinel.custodyagents.com/privacy
We publish two notices because the two surfaces process different data through different providers. This notice describes only what happens when you browse our websites.
1. What we collect
1.1 Information you give us
- Contact forms, playbook downloads, newsletter and partnership enquiries: name, professional email address, firm name, role, and any message you write. Where offered, an optional assets-under-management range.
- Governance readiness assessment: your answers are processed to produce a score. Answers are handled without identifying you unless you choose to continue to a follow-up form and provide contact details.
1.2 Information collected automatically
- IP address, browser type and version, operating system, device identifiers, screen resolution.
- Pages viewed, features used, time on page, referring source.
1.3 What we never collect
We do not collect private keys, seed phrases, wallet addresses, or any credential capable of moving assets. Custody Agents S.L. is non-custodial: we never hold, control, or have access to any customer funds or keys. Do not submit such material through any form on this website.
2. Cookies and analytics
2.1 Strictly necessary cookies
Required for the site to function. Set without consent, as permitted under ePrivacy Directive Art. 5(3).
2.2 Microsoft Clarity, analytics and session recording
With your consent only, we load Microsoft Clarity (Microsoft Corporation) on custodyagents.com. Clarity is a behavioural analytics tool that records:
- Session recordings: a reconstruction of your visit, including mouse movement, scrolling, clicks, and page navigation.
- Heatmaps: aggregated maps of where visitors click and how far they scroll.
- Technical data: IP address, browser, operating system, device type, referring URL.
Input masking. We configure Clarity with masking applied to all form fields. Text you type into forms is not captured in the recording. Masking is a configuration control, not an absolute guarantee, and you should not enter sensitive information into any field on this site beyond what the form asks for.
Cookies set: _clck and _clsk.
Purpose and legal basis: to understand how visitors use the site and improve it. Consent, GDPR Art. 6(1)(a) and ePrivacy Art. 5(3).
Withdrawing consent: use "Cookie Settings" in the site footer. On withdrawal we stop Clarity, clear its cookies, and reload the page. Withdrawal does not affect processing carried out before withdrawal.
International transfers: Microsoft Clarity is operated by Microsoft Corporation (United States). Transfers rely on the EU-US Data Privacy Framework, under which Microsoft is certified, and on the Standard Contractual Clauses incorporated in the Microsoft Products and Services Data Protection Addendum.
Retention: Microsoft retains Clarity data for up to 30 days from collection. See Microsoft's privacy statement: https://privacy.microsoft.com/privacystatement
Your choice not to be recorded. If you would rather not be recorded, decline analytics cookies in the banner. The site works fully without them.
2.3 enterprise.custodyagents.com
The Enterprise site uses strictly necessary cookies only. No analytics, no session recording, no advertising or tracking cookies.
2.4 Cookie consent
Visitors from the EU, UK, and Brazil see a consent banner on first visit and may accept or reject non-essential cookies. Your choice is stored for 12 months and can be changed at any time via "Cookie Settings" in the footer.
3. Why we process your data
| Purpose | Legal basis |
|---|---|
| Responding to enquiries and delivering requested materials | Contract, or steps prior to contract, Art. 6(1)(b) |
| Newsletter and marketing communications | Consent, Art. 6(1)(a) |
| Analytics and session recording | Consent, Art. 6(1)(a) |
| Site security, abuse prevention, and integrity | Legitimate interests, Art. 6(1)(f) |
| Retention of records required by law | Legal obligation, Art. 6(1)(c) |
4. Who we share it with
We do not sell personal information.
| Provider | Role | Purpose |
|---|---|---|
| HubSpot, Inc. | Processor | Contact forms, enquiry management, newsletter. Processed within the EU under Standard Contractual Clauses. |
| Microsoft Corporation (Clarity) | Processor | Analytics and session recording, custodyagents.com only, with consent. |
| Microsoft Ireland Operations Limited (Azure) | Processor | Website hosting and backend functions, EU regions. |
We may also disclose personal data where required by law, legal process, or a lawful government request, or to establish, exercise, or defend legal claims.
5. How long we keep it
| Data | Retention |
|---|---|
| Enquiry and contact records | 24 months from last contact |
| Newsletter subscription data | Until you unsubscribe |
| Assessment responses (without contact details) | 12 months |
| Microsoft Clarity recordings and heatmaps | Up to 30 days, held by Microsoft |
| Server and security logs | 12 months |
6. Your rights
Under GDPR and UK GDPR you may request access to your personal data, rectification, erasure, restriction of processing, portability, and you may object to processing based on legitimate interests. Where processing is based on consent, you may withdraw it at any time.
Exercise any of these by writing to privacy@custodyagents.com.
If you are in Brazil, the rights set out in LGPD Art. 18 apply and may be exercised through the same address. If you are in Argentina, the rights set out in Ley 25.326 Arts. 14 to 17 apply.
Complaints. You may lodge a complaint with your national supervisory authority:
- Spain: Agencia Española de Protección de Datos (AEPD), https://www.aepd.es/
- United Kingdom: Information Commissioner's Office (ICO), https://ico.org.uk/
- Brazil: Autoridade Nacional de Proteção de Dados (ANPD), https://www.gov.br/anpd/pt-br
- Argentina: Agencia de Acceso a la Información Pública (AAIP), https://www.argentina.gob.ar/aaip
7. Data Protection Officer
Custody Agents S.L. has not formally appointed a Data Protection Officer. The company qualifies for the small-scale processing relief under GDPR Art. 37(1) and ANPD Resolução CD/ANPD nº 02/2022, which permit publication of a data protection contact channel in place of a formal appointment. That channel is privacy@custodyagents.com.
8. Children
These websites are not directed at anyone under 18 and we do not knowingly collect personal data from children. If you believe a child has provided us with personal data, write to privacy@custodyagents.com and we will delete it.
9. Regulatory status
Custody Agents S.L. provides governance, security, and compliance software. It does not provide digital asset custody, brokerage, exchange, or value transmission services, and is not a licensed CASP under MiCA, nor regulated by the Banco Central do Brasil under Lei 14.478/2022.
10. Changes
We may update this notice. Material changes will be posted here with a new "Last Updated" date and, where required, notified by banner on the site.
11. Contact
Custody Agents S.L. CIF B24890931 Avenida Diagonal, 449, 4a planta, 08036, Barcelona, Spain
Data protection: privacy@custodyagents.com Legal, compliance, and security: compliance@custodyagents.com
END OF WEBSITE PRIVACY NOTICE