Privacy Policy.

1 Introduction & Sovereign Jurisdiction

This Privacy Policy explains how Emto Max Holdings Ltd (Anguilla) handles information in connection with EM : Beyond Reach at emtome.io and on the EM platform.

EM is hosted in Anguilla, including infrastructure at the Rock Farm and Blowing Point micro-DCs. These facilities are outside the 5/9/14-Eyes surveillance alliances. We design the service so that personal identity and communications data do not need to leave this sovereign perimeter.

2 Zero KYC & Zero PII

EM does not carry out KYC and does not require your name, email address, phone number, government ID, or other personal identifying information (PII) to register. Activation uses a three-word activation token and a 12-word seed phrase.

There is no key escrow. We do not hold a copy of your private keys or seed phrase, and cannot recover them if you lose them. Do not share your activation token or seed phrase with anyone.

3 Zero Tracking & Zero Logging

The EM platform does not use third-party trackers, external APIs, Google Analytics, or other analytics services. There is no IP logging. It does not rely on US CDNs for the closed-loop service.

The public website may receive the minimum technical information required to deliver a page, but EM does not build advertising profiles or use tracking pixels. See our Cookie Policy for the single strictly necessary session cookie used by the site.

4 Closed-Loop Platform & Infrastructure Isolation

EM uses the Matrix protocol for end-to-end encrypted communications. Federation is disabled, so the service does not connect to public Matrix homeservers. EM does not use push relays and is designed without third-party communications dependencies.

Messages and supported calls use end-to-end encryption. EM does not inspect message content or intentionally create a readable copy of it. Security protections cannot remove risks from a compromised device, a user’s actions, or a recipient’s device.

5 Payment Privacy & Financial Data

The subscription costs £1,200 per year. Payment is Monero-only via NOWPayments. A Lightning fallback may be offered where stated during onboarding. EM does not accept fiat currency for the subscription.

There are no refunds and no chargebacks. NOWPayments may process information required to confirm a payment under its own terms and privacy practices. EM does not ask for financial identity information as part of KYC.

6 Data Retention & Automated Cryptographic Shredding

The account lifecycle is fixed:

• Days 1–365: full access while the subscription is active.
• Days 336–365: the renewal window.
• Day 366: an unpaid account enters Restricted Mode.
• Day 373: an automated process cryptographically shreds the account records and metadata.

After cryptographic shredding, the account cannot be restored. The deletion process is described in our Data Retention & Shredding Policy.

7 Communications & Support Channels

Use @setup:chat.emtome.io for onboarding, device setup, and activation. Use @support:chat.emtome.io for general support. EM does not provide web portals or email support for these channels.

8 Legal Governance & Jurisdiction

This Privacy Policy is governed by the laws of Anguilla. The courts of Anguilla have exclusive jurisdiction over disputes relating to this Policy or the handling of information by EM.