Privacy Statement of Yieldfund
Version: October 2024
Yieldfund is a trade name. The parent company of Yieldfund is Frontpay Capital B.V. For clarity, this privacy statement uses the name ‘Yieldfund,’ which also refers to Frontpay Capital B.V. This statement was originally drafted in Dutch, but versions in other languages may be available. In case of discrepancies, the Dutch version prevails.
Introduction
Yieldfund operates an online platform for financial services. This platform is accessible via our website: yieldfund.com and will be referred to as our “services.”
This is our Privacy Statement, explaining the types of personal data we collect and process through our services. Personal data includes all information that can directly or indirectly identify a person, as defined under the General Data Protection Regulation (GDPR). This statement also outlines our role in processing personal data, how long we retain such data, and your rights as a data subject.
We kindly ask you to read this Privacy Statement carefully. For further questions about the processing of your personal data, please contact us using the details at the end of this statement.
Who is responsible for processing your personal data?
Yieldfund is responsible for processing your personal data, as described in this Privacy Statement, and acts as the ‘data controller’ within the meaning of the GDPR.
For questions about processing your personal data, please contact us using the details provided at the end of this statement.
What personal data is processed, and where does it come from?
Yieldfund may process your personal data if you:
Visit or use our website or services;
Are a (authorized representative) client of ours;
Have a business relationship with Yieldfund;
Work at one of our service providers or other parties we collaborate with.
Special and/or sensitive personal data we process:
Our website and/or services do not intend to collect data about visitors younger than 16 years of age, unless they have parental or guardian consent. However, we cannot verify a visitor’s age. We recommend parents monitor their children’s online activities to prevent the collection of data without parental consent. If you believe we have collected personal data of a minor without consent, please contact us at
info@yieldfund.com, and we will delete the information.
3.1 Information we collect automatically
When you visit our website or use our services, we automatically collect certain information, such as:
Usage data:
including your IP address, the pages you visit, links clicked, and technical information (e.g., browser and system details). See our
Cookie Statementfor more details.
Data about your activities on our website.
3.2 Automated decision-making
Yieldfund makes decisions based on automated processes that may have significant effects on individuals.
These decisions are made by computer programs or systems without human involvement (e.g., a Yieldfund employee). Yieldfund uses the following programs or systems:
Sumsub:
A compliance technology platform specializing in automating identity verification (IDV) and Know Your Customer (KYC) processes.
3.3 Information you provide to us
To use our services, we may request certain information, such as:
Registration details:
Full name, address, date and place of birth, gender, phone number, country, and email address.
Identification details:
A copy of your passport, driver’s license, or ID card, including a selfie for verification purposes.
Financial information:
Your bank account number (if applicable), transaction details, and wallet address.
Other information:
Source of income.
3.4 Information generated by us or received from third parties
To use our services, we may request certain information, such as:
Risk and fraud reports:
Based on your transactions and behavior on our platform.
Third-party data:
We may receive information from external sources such as public databases or blockchain analysis providers.
3.5 Use by third parties
Third parties include:
Marketing partner:
HubSpot;
Cloud service provider:
Rootnet;
Identity verification platform:
Sumsub;
Communication provider:
Bird.com.
Yieldfund may share data with suppliers, audit bodies, government authorities, and companies or individuals hired by Yieldfund to perform specific tasks (including processors).
Data may also be shared with third parties to support the provision of our services.
Yieldfund may provide data to third parties if required by applicable laws, court orders, or other legal obligations or with the data subject’s explicit consent.
For what purposes do we process your personal data?
We process your personal data for the following purposes:
To comply with legal obligations, such as anti-money laundering laws.
To deliver and improve our services.
To prevent fraud and abuse.
To communicate with you about your account and our services.
For marketing purposes, depending on your preferences.
To provide customer service.
For research and development to optimize our services.
Data retention periods
We do not retain your personal data longer than necessary for the purposes for which it was collected unless we are legally obligated to retain it longer.
Retention criteria:
Agreements:
Data is retained for the duration of the agreement.
Legal obligations:
Data is retained as long as legally required.
Legitimate interests:
Data is retained as long as necessary to protect such interests.
If Yieldfund has asked for and received your (explicit) consent to process your personal data, Yieldfund will retain it until you withdraw that (explicit) consent or it is deemed to have expired without your renewed (explicit) consent.
Legal retention periods:
Tax purposes:
7 years after the relevant calendar year (Art. 52, Dutch General Tax Act).
Anti-Money Laundering and Terrorist Financing Act (Wwft):
5 years after the business relationship ends (Art. 33).
Wwft reporting requirements:
5 years after notification to the FIU (Art. 34).
Your rights
Under the GDPR, you have certain rights regarding your personal data, including the right to access, correct, delete, and restrict processing. You can exercise these rights at any time by contacting us.
Changes
Yieldfund reserves the right to amend this privacy statement. We recommend reviewing this statement regularly for updates.
Right to lodge a complaint
Yieldfund handles personal data with care and aims for continuous improvement. If you have tips or complaints about our handling of personal data, please contact Yieldfund’s Data Protection Officer. You may also file a complaint with the Dutch Data Protection Authority.
Security
Yieldfund has implemented appropriate technical and organizational measures to protect personal data against loss or unlawful use. If data is processed by third parties on behalf of Yieldfund, a data processing agreement ensures that data is handled securely and adequately.
International data transfer:
Personal data may be transferred outside the European Economic Area (EEA) to countries deemed to provide an adequate level of data protection under GDPR. This includes Canada (commercial organizations), Japan, Switzerland, and New Zealand. For transfers outside these countries, standard contractual clauses will apply.
Contact information
For questions, comments, or complaints about this Privacy Statement or the processing of your personal data, please contact us at:
Yieldfund Data Protection Officer
Email:
info@yieldfund.comPost: Hanzeweg 5, 7418 AW, Deventer, Attn: Yieldfund Data Protection Officer
Part 2 · Yieldfund Wallet app
Privacy in the Yieldfund Wallet
This statement covers the Yieldfund Wallet app. Do you also use our website or the investor portal? Our general privacy policy above applies to those.
●Last updated: 03-08-2026
In short
The app works without an account. You create no profile, you upload no documents, and you do not have to tell us anything.
Your keys stay on your phone. We have no access to them and cannot reach your funds.
There is no tracking or advertising software in the app.
What you do share: your IP address with the blockchain network the app connects to, and a notification code if you turn notifications on.
Blockchain transactions are public and permanent. No one can undo that, including us.
Who we are
The Yieldfund Wallet is issued by
frontpay capital B.V.
, trading as Yieldfund, registered with the Dutch Chamber of Commerce under number 84040823.
Hanzeweg 5, 7418 AW Deventer, the Netherlands
Privacy questions:
info@yieldfund.comThe starting point: we ask for nothing
The app does not ask for your name, your email address or an identity document. There is no registration and no login. You open the app, create a wallet, and that wallet is yours.
That is a deliberate choice. The less we know about you, the less can go wrong.
The app supports USDC only. You can use it to receive and send USDC, check your balance and look back through your transaction history. That is all the app does.
What stays on your phone
The following data sits on your own device and never reaches us:
your private key and recovery phrase
your wallet address
your settings and the app lock
We cannot access any of it. That has a consequence for you as well: if you lose both your device and your recovery phrase, we cannot restore your wallet. So keep that phrase safe, on paper or in a password manager, and share it with no one.
What is shared
A wallet app cannot work without an internet connection. Here is exactly what becomes visible in the process, and to whom.
4.1 Connection to the blockchain network
To display your balance and transactions, and to send a transaction, the app connects to a node on the blockchain network through Alchemy.
During that connection, your IP address and the wallet address you are querying are visible to the party operating that node. This is technically unavoidable: without that query there is no balance to display. We do not use this data to build profiles or to track your behaviour.
4.2 Amounts in euros
The app shows amounts in euros. To do so it retrieves a current exchange rate from exchangerate-api. Your IP address is visible to that service as well. No information about you or your balance is sent along.
4.3 Notifications
If you turn notifications on, we receive a push token through Apple. That is a unique code for your installation of the app. Nothing more: no name is attached to it and no email address. We use it only to send you a notification, for example when a payout arrives. We use Firebase to deliver those notifications.
If you turn notifications off again in your phone settings, or delete the app, we delete the token.
Legal basis:
your consent. You can withdraw it at any time.
4.4 Apple
When you download the app, Apple processes data about that download. If you choose to share crash data with developers, we receive anonymised crash reports through App Store Connect. We cannot identify you from those. Apple’s own privacy policy applies to what Apple does with your data.
4.5 What is not in the app
No analytics. No tracking pixels. No advertising identifiers. No access to your contacts, photos, camera or location. No sale of data to anyone.
The blockchain is public and permanent
This is the most important limitation in this statement, so we will put it plainly.
Every transaction to or from your wallet address is recorded on a public blockchain network. Anyone in the world can look those transactions up, including amounts and timestamps. So anyone who knows your wallet address can see what comes in and goes out.
That data does not sit on our servers and belongs to no one. It cannot be changed or erased by anyone — not by us, and not even if you ask us to delete your data.
Your right to erasure and rectification therefore applies to the data in our own records, but not to what is already on the blockchain. Please bear that in mind when deciding who to share your wallet address with.
How this relates to your investment
The app itself does not know who you are. But the wallet address on which you receive your interest is one you give us through the investor portal.
In our records, that address is therefore linked to you as an investor. We need this to pay your interest to the correct address and to demonstrate that this happened correctly and on time. Our general privacy policy applies to those records.
In other words: in the app you are anonymous, in our records you are not. That distinction matters too much to be vague about.
What we cannot do
Because the wallet is non-custodial, there are things we cannot do. Not even if you ask us to.
We cannot restore your wallet without your recovery phrase.
We cannot reverse or stop a transaction.
We cannot freeze or move your balance.
We cannot see what you do with your wallet beyond our own payouts.
Please note
Precisely because we cannot intervene, your recovery phrase is a target for fraudsters. Yieldfund will never ask you for your recovery phrase or your private key. Not by email, not by phone, not through a chat, and not when someone tells you it is urgent. If you receive such a request, report it to
info@yieldfund.comstraight away.
Who we share data with
Party
Purpose
Location
Alchemy
Connection to the blockchain network
EU / US
exchangerate-api.com
Exchange rate for display in euros
EU / US
Apple / Google
App distribution and notification delivery
EU / US
Firebase
Sending notifications
EU / US
Where a party processes personal data on our behalf, we enter into a data processing agreement. Where a party processes data outside the European Economic Area, this takes place on the basis of an adequacy decision by the European Commission or on the basis of Standard Contractual Clauses.
We also disclose data where the law requires it, for example to a regulator or a law enforcement agency.
How long we keep data
Data
Retention period
Push token
Until you turn off notifications or delete the app
Crash reports
12 months (Apple’s default)
Payout records and wallet addresses
7 years, see the general privacy policy
Data on the blockchain falls outside these periods. See section 5.
Security
The app connects over encrypted connections only. Your keys are stored in your device’s secure storage. The app and the environment around it are tested periodically by an external party.
On your side: enable a screen lock on your phone, keep your operating system up to date, store your recovery phrase offline, and always check the first and last characters of the receiving address before you send.
Your rights
You can ask us for access to the data we hold about you, for correction or erasure of it, for restriction of processing, and for transfer of your data. You can object to processing and withdraw consent you have given.
For the app this comes down to your push token in practice, because we hold nothing else. If your question concerns your investment or your payouts, our general privacy policy applies.
If you disagree with how we handle your data, please tell us first. You also always have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at
autoriteitpersoonsgegevens.nl.
Age
The Yieldfund Wallet is not intended for people under 18. We do not target minors and do not knowingly collect data from minors.
Changes
We update this statement when the app changes or when the applicable rules require it. The date at the top shows when that last happened. We announce significant changes inside the app.
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