1. Who we are
Treasury B.V. Legal form: B.V. Country of establishment: The Netherlands. Contact email: contact@treasury-btc.com. Website: www.treasury-btc.com
Treasury is a euro-denominated Bitcoin treasury company. We do not operate a consumer business and we do not hold a customer database. The personal data we process is limited, and we intend to keep it that way.
2. What personal data we collect
We only collect personal data that you voluntarily provide to us, attending our events, applying for a role with us, or dealing with us in a business capacity. We collect this across four channels. Separately, and only if you agree to it, we collect limited analytics data about how this website is used, which is set out in section 2.5.
2.1 Events
Name, email address, organization and role
Any dietary or accessibility requirements you tell us about, used only for that event and deleted afterwards
Photographs and video footage taken at in-person events
This data is collected when you register for, or attend, an event hosted by Treasury or at which Treasury hosts a session.
2.2 Investor relations and shareholder communications
Name, contact details, organization and role
Where you are or become a shareholder, details of your holding and the information required to verify your identity
This data is collected directly from you, from your advisers or intermediaries, and where applicable through the arrangements under which shares are held.
2.3 Recruitment and job applications
If you apply for a role with us, or send us your details speculatively, we collect:
Your CV and any covering letter or portfolio you send us
Your name, contact details, work history, education and qualifications
Notes and assessments made during the recruitment process, including interview notes
References, where you have agreed to us taking them
Information from your public professional profiles, such as LinkedIn, where relevant to the role
Where a recruiter introduces you, the information they pass to us
How we handle it. Applications are only seen only by the people involved in that recruitment. We do not share your application outside Treasury without your agreement, other than with a recruiter already acting for you in that process.
How long we keep it. If we do not offer you a role, we delete your CV and everything else connected to your application within four weeks of the end of the recruitment process.
If we would like to keep your details on file in case a suitable role comes up later, we will ask you. If you agree, we keep your application for a maximum of one year from the date you give that consent, and then delete it. You can withdraw that consent and ask us to delete your details at any time, and we will do so.
If you send us a speculative application and there is no live role, the same four-week rule applies unless you ask us to keep your details on file.
If we offer you a role and you accept, the information from your application becomes part of your personnel file and is kept in accordance with our obligations as an employer.
2.4 Business and counterparty contacts
Business contact details for individuals at counterparties, service providers, advisers and partner organizations
Where required by law, identity and ownership information gathered as part of onboarding a counterparty or provider
We do not buy, scrape or harvest contact lists.
2.5 Website analytics
Our website uses Google Analytics 4 to understand how visitors find and use the site, such as which pages are read, how long for, and the general region a visit comes from. We use it to improve the site. We do not use it to identify you personally, and we do not use it for advertising.
Analytics only runs if you agree to it. When you first visit, a banner asks for your choice. Until you accept, analytics runs in a restricted mode that stores no cookies and sends no identifiers. If you decline, it stays in that mode.
The cookies involved are:
CookieScriptConsent, set by our consent manager to remember the choice you made. This cookie is strictly necessary and is set whichever choice you make, including declining.
_ga and _ga_3YL5JBC996, set by Google Analytics only after you accept, to tell one visitor's session apart from another. Google's default expiry for these is two years.
You can change or withdraw your choice at any time using the "Cookie settings" control shown on this site, or by clearing this site's cookies in your browser. Withdrawing consent stops any further analytics cookies being set.
3. How we use your personal data
We use your personal data for the following purposes:
To communicate with you about events you have registered for
To send updates and investor communications where you have asked to receive them
To respond to enquiries you send us
To administer our relationship with investors and shareholders, and to meet our obligations to them
To assess your suitability for a role you have applied for, and to run a fair recruitment process
To manage our relationships with counterparties, providers, advisers and partners
To promote Treasury and future events using photographs or video from past events, on our website and social media channels
To meet our legal and regulatory obligations, including anti-money laundering requirements
To keep our systems and information secure
We do not use your data for automated decision-making that produces legal or similarly significant effects on you. We do not use automated screening to reject job applications. Where we tailor communications to your stated interests, this is done manually, not through automated profiling within the meaning of Article 22 GDPR.
4. Legal basis for processing
We process your personal data based on:
Your consent (Article 6(1)(a) GDPR), for: newsletter and marketing sign-ups, non-essential cookies, and keeping your job application on file beyond the standard four weeks.
Performance of a contract, or steps taken at your request before entering into one (Article 6(1)(b) GDPR), for: administering your event registration, managing our relationship with investors and shareholders, and processing your job application.
Compliance with a legal obligation (Article 6(1)(c) GDPR), for: anti-money laundering and identity verification requirements, and our accounting, tax and corporate record-keeping obligations.
Our legitimate interest (Article 6(1)(f) GDPR), for: essential event administration and communication, managing business contacts, photographs and video at events as described in Section 5, keeping our systems secure, and promoting Treasury and its activities.
You may withdraw your consent at any time. This will not affect the lawfulness of any processing carried out before you withdrew it. Where we rely on legitimate interests, you may object at any time.
5. Photo & video consent
At our in-person events, and where we host a session or record a Treasury Forum conversation, photographs and video may be taken for use in our communications, on our website, and on our social media channels. We rely on our legitimate interest (Article 6(1)(f) GDPR) for this, as promoting Treasury and the events we host is part of our activities, and we apply the safeguards below to limit the impact on attendees.
Attendees are informed of this at event registration and on arrival. If you do not wish to be photographed or filmed, please let our team know upon arrival at the event, and we will make reasonable efforts to exclude you from published material. You may also object to this processing at any time, or request that a specific photo or video be taken down, by contacting us at contact@treasury-btc.com.
Where you are a speaker or panellist in a recorded session that we intend to publish, we ask for your agreement separately, since the recording is the purpose rather than an incidental part of the event.
6. Third-party services
We use trusted third-party services to process personal data on our behalf, you can ask us for more information by contacting us at contact@treasury-btc.com. We also share personal data with our professional advisers, including legal, audit, tax and corporate finance advisers, where they need it to advise us, and with regulators, authorities or other third parties where we are required to disclose it by law.
These service providers process personal data only in accordance with our instructions and applicable data protection laws, under a written agreement.
The third-party providers that process personal data through this website are Google, for Google Analytics, and CookieScript, for recording your cookie choice. Google Analytics data is processed by Google Ireland Limited for visitors in the European Economic Area, and by Google LLC in the United States.
7. International data transfers
Some of our third-party providers may be based outside the European Economic Area (EEA), including in the United States. Where this is the case, we rely on recognized safeguards, such as the EU-US Data Privacy Framework (where the provider is certified under it) or Standard Contractual Clauses approved by the European Commission, to protect your personal data in accordance with GDPR requirements.
Where a provider stores data within the EU, no international transfer takes place for the data collected through that provider.
You can ask us for more information about the safeguards applied to a specific transfer by contacting us at contact@treasury-btc.com.
8. Data retention
We do not store personal data longer than necessary.
Newsletter and marketing data is stored until you unsubscribe. We keep a record of your unsubscribe so that we do not add you again
Event-related data is stored only as long as required for event communication and follow-up
Photos and video are retained for as long as they remain relevant for marketing purposes, unless a takedown request is received
Job applications from unsuccessful candidates are deleted within four weeks of the end of the recruitment process, or after one year where you have consented to us keeping your details on file
Personnel records are retained for the periods required of us as an employer
Investor and shareholder records are retained for the periods required by law, including anti-money laundering and accounting requirements
Counterparty onboarding records are retained for the period required by anti-money laundering law
Accounting and corporate records are retained for seven years
Analytics data is held by Google for the retention period configured on our Google Analytics property, after which Google deletes it. Analytics cookies expire on the timescales set out in section 2.5, or sooner if you clear them or withdraw consent.
You may request deletion of your data at any time. Where we are legally required to keep information we cannot delete it on request, and we will explain that to you if it applies.
9. Your rights under the GDPR
You have the right to:
Access your personal data
Rectify inaccurate personal data
Request deletion of your personal data
Restrict the processing of your personal data in certain circumstances
Receive the personal data you provided to us in a structured, commonly used, machine-readable format, and to have it transmitted to another controller, where technically feasible (data portability)
Withdraw your consent at any time
Object to the processing of your personal data
Lodge a complaint with a supervisory authority (in the Netherlands: the Autoriteit Persoonsgegevens)
To exercise these rights, please contact us via the email address below. We aim to respond within one month, as required by the GDPR. You do not need to use any particular wording, and there is no charge.
10. Data security
We take appropriate technical and organizational measures to protect your personal data against loss, misuse, unauthorised access, or disclosure. These include restricting access to those who need it, multi-factor authentication on our systems, encryption of devices, and written agreements with the providers who process data on our behalf. We review these measures regularly.
11. Changes to this policy
We may update this Privacy Policy from time to time. The most recent version will always be available on our website, and the date at the top shows when it was last changed.
12. Contact
If you have any questions about this Privacy Policy or how we handle your personal data, please contact us at: contact@treasury-btc.com