Privacy Policy
This Privacy Policy describes how DIRE MONEY TRANSMITTER LLC ("Company," "we," "us," or "our"), the operator of the Ashford platform accessible at Ashford.co.com, collects, uses, stores, and discloses personal information from users ("you") of our website and digital asset services. By using Ashford, you acknowledge that you have read and understood this policy.
1. Who We Are and How to Reach Us
DIRE MONEY TRANSMITTER LLC is a limited liability company registered to do business in the United States. We operate as a Money Services Business (MSB) registered with the Financial Crimes Enforcement Network (FinCEN). Our principal place of business is 1201 W Peachtree St NW Ste 2625 #44512, Atlanta, GA 30309. You may contact us regarding privacy matters at support@ashford.co.com or by phone at +1 (770) 282-9628.
2. Information We Collect
The table below summarizes the categories of personal information we collect and the purposes for which each category is used.
| Category of Information | Specific Data Elements | Purpose | Legal Basis |
|---|---|---|---|
| Identity Information | Full legal name, date of birth, government-issued ID number, ID document images | Identity verification (KYC), compliance with USA PATRIOT Act and FinCEN CIP rules | Legal obligation; contract performance |
| Contact Information | Email address, phone number, mailing address, state of residence | Account communication, customer support, regulatory notices | Contract performance; legitimate interest |
| Financial Information | Transaction history, deposit/withdrawal amounts, wallet addresses, asset holdings | Service delivery, transaction processing, AML monitoring, SAR filing where required | Legal obligation; contract performance |
| Device and Usage Data | IP address, browser type, operating system, pages visited, session duration, cookies | Platform security, fraud prevention, analytics, compliance logging | Legitimate interest; consent (for non-essential cookies) |
| Communication Records | Emails, support tickets, phone call records (where applicable) | Customer support, dispute resolution, compliance record-keeping | Legal obligation; legitimate interest |
3. How We Use Your Information
We use the information we collect for the following purposes:
Account administration and service delivery. Processing account registrations, managing your digital asset holdings, executing trades, and maintaining your wallet within the platform.
Regulatory compliance. Fulfilling our obligations under the Bank Secrecy Act (BSA), USA PATRIOT Act, FinCEN regulations, and applicable state money transmission laws. This includes conducting Customer Due Diligence (CDD), filing Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs) where required by law.
Security and fraud prevention. Monitoring account activity for unauthorized access, detecting patterns consistent with financial crime, and maintaining the integrity of the platform.
Customer communications. Responding to inquiries, sending account notifications, and providing information about changes to our services or legal terms.
Legal proceedings. Responding to lawful requests from courts, regulatory agencies, or law enforcement under applicable US law.
4. Disclosure of Your Information
We do not sell your personal information to third parties. We may share your information in the following circumstances:
Service providers. We engage third-party vendors to assist with identity verification, payment processing, cloud infrastructure, and customer support. These vendors are contractually prohibited from using your information for purposes beyond those specified in our agreements.
Legal and regulatory requirements. We disclose information to FinCEN, the IRS, state regulators, law enforcement agencies, and courts when required by applicable US law. This includes filings required under the BSA and the USA PATRIOT Act.
Business transfers. In the event of a merger, acquisition, or sale of substantially all assets, your information may be transferred as part of that transaction, subject to the same privacy protections described here.
Protection of rights. We may disclose information where necessary to protect the rights, property, or safety of DIRE MONEY TRANSMITTER LLC, our users, or the public.
5. Data Retention
We retain personal information for as long as necessary to fulfill the purposes described in this policy, including compliance with our legal obligations. Under the BSA, we are required to retain certain transaction records and customer identification information for a minimum of five years. Identity verification records are retained for at least five years after account closure. Communication records are retained for at least three years. Device and usage logs are retained for up to two years unless a longer retention period is required by law or security investigation.
6. Data Security
We implement administrative, technical, and physical security measures designed to protect your personal information from unauthorized access, alteration, disclosure, or destruction. These measures include encrypted data transmission (TLS), encrypted storage of sensitive credentials, access controls limiting internal data access to authorized personnel, and regular security reviews. No method of transmission over the internet or electronic storage is fully secure. We make reasonable efforts to protect your data but cannot warrant absolute security.
7. California Residents — Your CCPA Rights
If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), gives you specific rights regarding your personal information:
Right to Know. You may request disclosure of the categories and specific pieces of personal information we have collected about you, the purposes of collection, and the categories of third parties with whom we share it.
Right to Delete. You may request deletion of your personal information, subject to exceptions including our legal obligations to retain records under the BSA and other applicable laws.
Right to Correct. You may request correction of inaccurate personal information we hold about you.
Right to Opt Out of Sale or Sharing. We do not sell or share personal information for cross-context behavioral advertising purposes.
Non-Discrimination. We will not discriminate against you for exercising any CCPA rights.
To submit a rights request, contact us at support@ashford.co.com. We will verify your identity before processing any request. We will respond within 45 days as required by the CCPA.
8. Cookies and Tracking Technologies
We use cookies and similar tracking technologies on Ashford.co.com. For detailed information about the cookies we use, the purposes they serve, and your choices, please review our Cookie Policy.
9. Children's Privacy
Ashford does not knowingly collect personal information from individuals under the age of 18. Our platform is intended for adults only. If we become aware that we have collected information from a minor without parental consent, we will take steps to delete it promptly. If you believe a minor has submitted information through our platform, contact us at support@ashford.co.com.
10. Third-Party Links
Our platform may contain links to third-party websites. This Privacy Policy does not apply to third-party sites. We are not responsible for the privacy practices of websites we do not operate. We encourage you to review the privacy policies of any third-party sites you visit.
11. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will update the "Last Updated" date at the top of this document. We encourage you to review this policy periodically. Continued use of Ashford after changes are posted constitutes your acknowledgment of the updated policy.
12. Contact for Privacy Matters
For questions, concerns, or rights requests related to this Privacy Policy, contact DIRE MONEY TRANSMITTER LLC at:
Email: support@ashford.co.com
Phone: +1 (770) 282-9628
Address: 1201 W Peachtree St NW Ste 2625 #44512, Atlanta, GA 30309