This document explains the personal information Pinnacle Reclaim Group Ltd ("PRG", "we", "us") collects through the lambo-diablo-1.bond website and the case intake process, the lawful bases on which we use it, and your rights in relation to it. It is written in deliberately plain English because we want every reader to be able to read it without legal training.
1. Who we are
Pinnacle Reclaim Group Ltd is a private company limited by shares, incorporated in England and Wales (Companies House No. 14628097). Our registered office is 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom. For all data protection enquiries, the responsible point of contact is the firm's data protection lead, reachable at [email protected].
2. What we collect, and why
We collect only what we need to do the work you have asked us to do. Specifically:
- Contact details — name, email, phone — supplied through the contact form or directly to us during intake. We use these to contact you about your enquiry and, if you become a client, to administer your case.
- Case information — including financial records, communications with the platform, identity documents and any other evidence you submit. We use this only to investigate and pursue your matter.
- Technical information — including IP address, browser type, pages viewed. Collected in standard server logs and retained for 30 days for security and diagnostic purposes only.
- Cookies — we use first-party cookies only, and only for session integrity and consent recording. We do not use advertising or cross-site tracking cookies. See our cookie policy for detail.
3. Lawful bases
We rely on the following lawful bases under the UK GDPR:
- Contract performance — processing client case data is necessary to deliver the services in your engagement letter.
- Legitimate interests — responding to enquiries, securing our infrastructure, maintaining business records.
- Legal obligation — AML record keeping, financial regulatory cooperation, statutory disclosure where required.
- Consent — where you specifically opt in to a particular use of your data (for example, agreeing to be referenced as a closed-case testimonial).
4. How long we keep it
Enquiries that do not result in an engagement are deleted within 6 months. Active client files are retained for the duration of the engagement and for 6 years thereafter, as required by professional record-keeping rules. AML records are held for 5 years from the close of the matter. After those periods, files are securely destroyed.
5. Who we share with
We share information only with the parties strictly necessary to do the work, and never with marketers or data brokers. Specifically:
- Counterparties in the recovery process — issuing banks, acquirers, exchange compliance desks, regulators — on your written instruction.
- Specialist subcontractors — blockchain analytics providers and counsel — under binding confidentiality and data-processing agreements, and only with named individual approval on a per-matter basis.
- UK authorities — where required by law, including under SAR obligations.
6. International transfers
All primary case storage is in the United Kingdom. Where a specific case requires evidence to be transmitted abroad — for example to an overseas regulator or exchange — we use either UK-adequacy-decision jurisdictions or appropriate safeguards under the UK GDPR Article 46.
7. Your rights
You have the right to access the personal data we hold about you, ask us to correct or delete it, restrict or object to its processing, and obtain it in a portable format. To exercise any of these rights, write to [email protected]. We respond to verified requests within 30 days. If you are dissatisfied with our response, you may complain to the Information Commissioner's Office (ico.org.uk).
8. Security
Our case folder environment is UK-hosted, encrypted at rest and in transit, and subject to annual third-party penetration testing. Access is role-based and audited. Personal devices used by staff are full-disk-encrypted, screen-locked and remotely revocable.
9. Changes to this policy
We review this policy at least annually. Material changes are signalled at the top of the document and, for current clients, communicated by email before they take effect.
If anything in this document is unclear, write to us. We will explain it without jargon.