Revision date: 1 January 2026
The OBOLUS website is located at https://oboluslaw.com/ (hereinafter — the “Website”). The Website is used to promote legal support in the field of digital assets, provided under the OBOLUS brand and managed by Ventos Arqueáveis Unipessoal Lda (NIPC 519153529) (hereinafter — the “Firm”, the “Company” or the “Operator”), as well as to receive preliminary requests from business clients.
Information provided by the user is used to contact the user, provide technical support, assess a legal request in the field of digital assets and prepare a possible proposal for cooperation.
This Privacy Policy (hereinafter — the “Policy” or the “Agreement”) applies to all users of the Website.
The Policy defines the purposes of collection, storage and processing of personal data, protection measures and rules for transferring personal data to third parties.
The Policy applies to any information that Ventos Arqueáveis Unipessoal Lda / OBOLUS may receive about the user when the user uses the Website, contacts the Firm using the contact details specified at https://oboluslaw.com/, and enters into or performs agreements between the Firm and the user.
By using the Website in any way, the user confirms that they have read this Policy, understood its content and unconditionally accept its terms.
Privacy Policy - this document addressed to an unlimited circle of persons.
The Parties to the Policy are Ventos Arqueáveis Unipessoal Lda, operating under the OBOLUS brand, and the User.
OBOLUS is the brand under which Ventos Arqueáveis Unipessoal Lda operates the Website https://oboluslaw.com/ and coordinates legal support in the field of digital assets for business clients.
Website Owner — the person who independently determines the procedure for use of the Website and publication of information. The Website Owner is Ventos Arqueáveis Unipessoal Lda, which operates the OBOLUS Website.
Operator — Ventos Arqueáveis Unipessoal Lda, operating under the OBOLUS brand, which organises and carries out the processing of personal data and determines the purposes, categories of data and actions performed with them.
Website — a collection of web pages, software, databases, textual, graphic and other information located at https://oboluslaw.com/.
Services — the activities of OBOLUS in providing or coordinating legal support in the field of digital assets, including licensing and regulatory matters, disputes and asset recovery, tax and structuring, derivatives and structured products, compliance, AML/KYC, the Travel Rule, banking and onboarding, as well as related matters for business clients.
User — any visitor to the Website https://oboluslaw.com/. By accepting the Policy, the user confirms that they have reached the age of majority and have authority to act on their own behalf or on behalf of third parties.
User Data / personal data - any information, including cookies, voluntarily and knowingly provided by the user when using the Website or necessary for the operation of the Website, performance of agreements and communication with the user.
Processing of personal data - any action or set of actions performed with personal data, including collection, recording, systematisation, accumulation, storage, clarification, retrieval, use, transfer, anonymisation, blocking, deletion and destruction.
Dissemination of personal data - actions aimed at disclosing personal data to an indefinite circle of persons.
Provision of personal data - actions aimed at disclosing personal data to a specific person or circle of persons.
Blocking of personal data - temporary cessation of the processing of personal data, except where processing is necessary to clarify the data.
Use of personal data — actions of the Operator with personal data for making decisions or performing other actions affecting the rights and obligations of the data subject or other persons.
Destruction of personal data - actions as a result of which it becomes impossible to restore the content of personal data in the information system and/or as a result of which physical media are destroyed.
Anonymisation of personal data — actions as a result of which it becomes impossible, without additional information, to determine the data’s association with a specific data subject.
Cookie - data automatically transmitted to the Operator when the Website is used by software installed on the user’s device, including browser data, operating-system data, web-page request data, IP address and activity data.
Software - programs and services used to collect data on the Website, including analytics systems and form-processing systems.
Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state, to a foreign authority, foreign individual or foreign legal entity.
Device - a personal computer, tablet, smartphone or other device that allows use of the Website.
User electronic signature — information in electronic form attached to the information being signed and used to confirm the user’s actions on the Website. Clicking an active button, checking a checkbox or performing a similar action may be regarded as confirmation of the corresponding user action if permitted by applicable law.
2.1. The User represents and warrants to OBOLUS that, as of the date of acceptance of this Policy and throughout its term, the User:
acts in accordance with applicable law;
has sufficient command of the language of the Policy to understand its meaning and consequences;
agrees with the content of the Policy and undertakes to comply with its requirements;
has all authority necessary to accept and perform the Policy;
has provided complete, valid and accurate personal data;
meets the requirements established by the Policy;
consents to the processing of personal data in accordance with applicable law;
agrees to compensate OBOLUS for losses arising from breach of the user’s warranties or obligations;
confirms that the information provided by the user is true, complete and up to date;
confirms that all actions within the user’s account or using the user’s contact details are performed by the user personally or by an authorised person.
2.2. The User clearly and unequivocally understands the meaning of the warranties assumed and accepts that their breach, challenge or improper performance may be regarded as an abuse of rights to the extent permitted by applicable law.
2.3. The Parties confirm that OBOLUS’s decision to enter into relations with the user is based on the warranties contained in this Policy and in other correspondence between the Parties.
2.4. Other arrangements between the Parties concerning warranties apply to the extent that they do not contradict this Policy.
2.5. The User undertakes to take all necessary measures to ensure the accuracy of the information provided to OBOLUS.
2.6. The User expresses consent to the Policy by using the Website, submitting a form, checking the relevant checkbox or performing another action provided for by the functionality of the Website.
2.7. By checking a checkbox or submitting a form, the User confirms that the action is specific, conscious, purposeful and unambiguous, and that the Policy has been read in full.
2.8. The legal bases for processing personal data are applicable legislation on personal data and information, the User’s consent, an agreement with the User, the Operator’s legitimate interests and other grounds permitted by applicable law.
2.8.1. General personal data, such as name, e-mail, age, sex and Telegram ID, may be processed on the basis of an agreement, consent, the Operator’s legitimate interest and other permissible grounds. Special categories of personal data are processed on the basis of separate informed consent, unless otherwise permitted by law.
2.8.2. Personal data are processed for the following purposes:
providing access to the Firm’s legal support in the field of digital assets, including licensing and regulatory matters, disputes and asset recovery, tax and structuring, derivatives and structured products, compliance, AML/KYC, the Travel Rule, banking and onboarding, as well as related matters for business clients;
communication with the user, consulting and responding to requests;
compliance with localisation requirements, notification of competent authorities and other requirements of applicable law, if such requirements apply.
2.9. For marketing mailings and other purposes unrelated to performance of an agreement or legal requirements, the Operator processes personal data on the basis of the user’s freely given consent.
2.10. If required by applicable law, the Operator notifies the competent authority of personal data and of cross-border data transfer in the prescribed manner.
3.1. The processing of users’ personal data, including ensuring the security of processing and protecting users’ rights, is governed by this Policy.
3.2. Any user who uses the Website or its functionality agrees to the terms of the Policy and undertakes to comply with them. If the user does not agree with any term, the user must stop using the Website. Consent is expressed by providing data and/or checking a checkbox when performing actions on the Website.
3.3. Nothing in the Policy shall be construed as establishing any relationship between the user and OBOLUS other than those expressly provided for by the Policy.
3.4. The Policy is governed by applicable law.
3.5. Disputes under the Policy are subject to resolution in accordance with applicable law by the competent court determined in accordance with applicable law, unless mandatory rules require otherwise.
3.6. The invalidity of an individual provision does not affect the validity of the remaining provisions.
3.7. OBOLUS’s failure to take action in connection with a breach of the Policy does not constitute a waiver of the right to protect its interests later.
3.8. OBOLUS may amend the Policy without special notice to users. A new version enters into force after publication at https://oboluslaw.com/privacy, unless otherwise specified in the new version. Continued use of the Website means acceptance of the new version.
3.9. Rights of the data subject
3.9.1. The User, as a data subject, has the right to:
obtain confirmation that the Operator processes the User’s personal data;
receive information on the legal bases, purposes, methods and retention periods of processing;
receive information about the Operator and persons having access to the data, including processors;
obtain a list of the personal data being processed and the source from which they were obtained;
receive information on cross-border data transfer;
require clarification, blocking or destruction of data if they are incomplete, outdated, inaccurate, obtained unlawfully or no longer needed for the stated purpose;
appeal the actions or inaction of the Operator to a competent authority or court.
3.9.2. To exercise their rights, the user may send a written or electronic request to the Operator using the contact details specified in the Policy. The Operator responds within the time limits established by applicable law, or within a reasonable period if no specific period is established. The user is responsible for the accuracy of the personal data provided.
3.10. OBOLUS is not responsible for data that the user provides to third-party resources accessed from the Website.
3.11. OBOLUS is not responsible for possible loss of or damage to data resulting from the user’s breach of the Policy or unauthorised access to the Website by third parties.
3.12. The User is independently responsible to third parties for actions performed when using the Website and for compliance with applicable law.
3.13. Request procedure: the user sends a request to info@oboluslaw.com or to the Operator’s postal address; the request must contain information enabling identification of the applicant; the Operator considers the request and responds in a form corresponding to the request, where possible.
4.1. Personal data are processed for performance of the user agreement and/or other agreements with the user, to ensure operation of the Website and to provide the functionality available through it.
4.2. The purposes of processing apply to the following categories of data subjects: Website visitors and persons who have an agreement with OBOLUS. In particular:
4.3. With respect to the data specified above, the following actions are performed: collection, recording, systematisation, accumulation, storage, clarification, retrieval, use, transfer, anonymisation, blocking, deletion and destruction, both by automated means and without automation.
4.4. Personal data are processed for the following tasks:
providing the user with legal services in the field of digital assets;
identification of the user in the performance of an agreement or other agreements;
ensuring the functionality of the Website and presenting informational and advertising materials;
performance of the Operator’s obligations;
conducting marketing, statistical and other research based on anonymised data;
displaying informational materials using anonymised analytical data;
the Firm’s business purposes, including monitoring Website effectiveness, security and fraud prevention;
technical support for users;
sending automated electronic messages.
4.5. Access to personal data is provided only to OBOLUS employees and engaged persons who need such data to perform their duties. Such persons are obliged to maintain confidentiality.
4.6. The Operator may transfer data to third parties: cloud and hosting providers; CRM, analytics and service providers; payment systems; government authorities, if required by law; local consultants, forensic specialists, compliance consultants and contractors, if this is necessary for legal support in the field of digital assets. The list and scope of data transferred are determined by a processing instruction, agreement or law. If a cross-border transfer requires notification, permission or other formalities, the Operator fulfils them in the prescribed manner.
4.7. The Company takes the necessary organisational and technical measures to protect data from unlawful or accidental access, destruction, alteration, blocking, copying, dissemination and other unlawful actions.
4.8. Personal data are processed lawfully and fairly, within specific, predetermined and lawful purposes. Storage is limited to the periods necessary for the purposes of processing, unless otherwise required by law.
4.9. The Operator must provide the subject with information about their data, take protection measures and stop processing at the subject’s request, unless otherwise required by law.
4.10. Localisation and cross-border data transfer: when collecting data, the Operator takes into account applicable legal requirements for localisation and storage of data; cross-border transfer is carried out in the cases and manner permitted by law, using organisational, contractual and technical protection measures. The User is notified that Telegram, WhatsApp and other messengers may process messages and identifiers on their own infrastructure.
4.11. The Operator takes measures to identify, investigate and mitigate the consequences of personal-data security incidents and, if required by law, notifies the competent authority and/or affected data subjects.
4.12. The Operator may keep records of operations performed with personal data, indicating the date, basis and person who performed the operation, and store such information for the periods established by internal rules and law.
5.1. In accordance with applicable personal-data legislation, by visiting the Website or submitting a form, the user gives OBOLUS consent to the processing of personal data and confirms that the user acts freely, of their own will and in their own interest.
5.2. Consent may be provided for performance of the user agreement, the Public Offer and other agreements, as well as for actions giving rise to legal consequences. Consent covers name, e-mail address, analytical and technical information, IP address, cookies, information about actions on the Website, user messages and requests, as well as any other information available to OBOLUS in connection with use of the Website and services.
5.3. Consent remains valid until expiry of the retention periods for the relevant information or documents determined by applicable law, but no longer than required for the purposes of processing, unless another period is established by law or agreement.
5.4. After expiry of the processing period, personal data are destroyed within the period established by applicable law or the Operator’s internal rules.
5.5. The User may withdraw consent at any time by sending a notice to info@oboluslaw.com or in another manner provided for by the Policy. The Operator ceases processing and destroys the data within the period established by law, unless further processing or storage is required by law or on accounting, tax, judicial or contractual grounds. Withdrawal of consent may make it impossible to use part of the Website or services.
5.6. After withdrawal of consent, OBOLUS may continue processing and storing data if the retention periods under applicable law have not expired.
5.7. Consent is provided for all operations with personal data necessary or desirable to achieve the stated purposes, including systematisation, accumulation, storage, clarification, use, transfer, anonymisation, blocking and destruction.
5.8. Personal data are processed by OBOLUS by methods including storage, recording on electronic media and creation of databases and lists.
5.9. OBOLUS ensures the security of personal data during processing, including by applying reasonable technical and organisational measures.
5.10. The User confirms that, where necessary to achieve the stated purposes, OBOLUS may disclose information about the user to authorised persons, consultants, contractors and representatives to the extent necessary.
5.11. The User confirms that this consent applies, with necessary changes, to third parties to whom personal data are transferred in accordance with the Policy.
The pre-trial dispute-resolution procedure is mandatory if it is permitted or required by applicable law. The period for responding to a claim is 10 business days from receipt, unless another period is established by law.
6.2. A claim sent by the user to info@oboluslaw.com is subject to consideration.
6.3. The Parties may at any time formalise their relationship by signing paper documents, including this Policy.
6.4. The User undertakes to perform the necessary actions to comply with this Policy.
6.5. Documents and information sent by e-mail to info@oboluslaw.com may have evidentiary value and legal force to the extent permitted by applicable law.
6.6. If contacted by a supervisory authority, the user must record information about the person, the basis of the request, the scope of documents and the deadlines for their provision and immediately notify OBOLUS before taking independent action if the request is related to use of the Website or services.
6.7. Upon receiving a request from a supervisory authority or authorised person, the user must provide OBOLUS with the documents necessary for a response as soon as possible and no later than 3 days from receipt of the request, where applicable.
6.8. If the circumstances specified above arise, the user performs the necessary actions, including obtaining documents from third parties, notaries, state and local authorities, if required.
6.9. The User understands that OBOLUS’s conclusions, opinions and recommendations are based on the Firm’s commercial experience, practice, discretion and knowledge and may differ from the opinions of third parties, authorities, specialists, counterparties and the user’s partners.
6.10. Documents and information transmitted through the Website, e-mail, messengers or social networks may have evidentiary value and legal force to the extent permitted by applicable law.
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