1. Introduction

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1.2 The Company respects and values your privacy and the integrity of the information you have provided and/or authorized the Company to collect. The Company will endeavor to follow industry standards to ensure the security and privacy of your personal information when you use the Company Services or access the Company Platform.

1.3 When accessing, registering, downloading, using, clicking or participating in any Services provided on the Company Platform, you are strongly encouraged to carefully read, acknowledge, understand and accept all of the terms and conditions set forth in this Privacy Policy. The Company will not use your information, in any form or fashion, for any other purpose that is not set forth in this Privacy Policy or the Terms, without first notifying you or obtaining your consent.
1.4 This Privacy Policy incorporates certain provisions of the General Data Protection Regulation ("GDPR"), in particular the rules for processing personal information in the European Economic Area ("EEA").

2. Acceptance of the Privacy Policy
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BY ACCESSING, USING OR PARTICIPATING IN THE COMPANY SERVICES, YOU INDICATE AND ACKNOWLEDGE THAT YOU FULLY AND UNCONDITIONALLY AGREE TO THE TERMS OF THIS PRIVACY POLICY.
The Company may not use your Personal Information for any other purpose not covered by this Privacy Policy or the Terms and Conditions without first notifying you or obtaining your consent.

IF YOU DO NOT AGREE, IN PART OR IN WHOLE, TO THIS PRIVACY POLICY, YOU MUST IMMEDIATELY CEASE ACCESSING, USING OR PARTICIPATING IN THE COMPANY SERVICES AND PLATFORM.

3. Personal information collected
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FOR PURPOSES OF THIS PRIVACY POLICY, PERSONAL INFORMATION IS INFORMATION THAT CAN BE USED TO IDENTIFY, DESCRIBE, RELATE OR ASSOCIATE WITH A SPECIFIC INDIVIDUAL. THE FOLLOWING ARE THE TYPES OF INFORMATION THAT THE COMPANY COLLECTS AND STORES WHEN YOU USE THE COMPANY'S SERVICES:
‍3.1 Information provided when registering on the Website

When you first register for Company Services by creating an account on the Company website, you may be required to provide Company with your real name, date of birth, citizenship, home address, e-mail address, telephone number, signature and other information that can be used to identify you.

The Company generally does not collect or process "Sensitive Information" such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data that uniquely identifies specific individuals, or any information relating to health or sexual orientation.

If you use biometric authentication methods to log into your account on the Company's website, you must provide the Company with your fingerprint data, facial recognition data and, more importantly, explicit consent to the processing of your biometric data.

3.2 Information collected by the Company for compliance and anti-money laundering purposes

In order for the Company to comply with domestic and international industry standards, government rules and regulations, in particular Anti-Money Laundering (AML), Know Your Customer (KYC) and Counter Terrorist Financing (CTF) regulations, the Company must collect your Personal Information from your identity documents such as passport, national identification card, driving license, TIN, visa, residence permit, cryptocurrency wallet details, etc.

Other documents the company may use include, but are not limited to, your proof of address, declaration of source of funds, purpose and source of income, etc.

3.3 Information collected by the Company during the use of the Company's Services

(1) Utilization information

When you connect to or use the Company Services, the Company controls and tracks information related to your use of the Company Services, such as your IP address, phone number, the type of device you use to access the Company Platform, cryptocurrency wallet details, device information, operating system and hardware settings, browser type and network operator. This information may be obtained by the Company directly or through third party service providers.  The Company collects such information to provide seamless access to its interface and/or Platform to all users worldwide.

(2) Contact information

You hereby agree that the Company may collect and use Personal Information provided by you on the Company Platform or generated as a result of your use of the Company Services in order to be able to communicate with you through messages, inquiries, emails, phone calls, voicemails, chats, file attachments in connection with your transactions on the Company website or online platforms, or any other information related to your contact with the Company.

(3) Financial information

You hereby agree that, for the purposes set forth in this Privacy Policy, the Company may collect and use information contained in or related to your financial information when you use the Company's Services. This includes, without limitation, your transaction history such as your deposit amount, your withdrawal requests, your wallet address(es) etc.

The Company collects this financial information to track suspicious financial activity in order to protect users from fraud, to resolve legal cases, and for any other purposes specified in this Privacy Policy.

(4) The Company collects users' data on social networks in order to analyze their usage, their activity and interests in them, to identify subscribers and other information determined by the Company independently.

4. Methods of collecting personal information

4.1 Information automatically collected by the Company
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The Company will collect and process Personal Information automatically provided by you in the following cases:
(1) when you register an account, log in by connecting a cryptocurrency wallet, or visit the Company Website;
(2) when you voluntarily complete any user survey or provide feedback to the Company via email or any other electronic channels;
(3) when you use browser cookies or any other relevant software when visiting the Company's Website; and
(4) other situations in which the Company may automatically collect your information as described in this Privacy Policy or the Terms.

4.2 Information collected by third parties
‍The Company collects your Personal Information from third parties where required or permitted under applicable law. Information from third-party sources may include, but is not limited to, publicly available databases, identity verification partners, blockchain data, marketing partners and intermediaries, advertising partners and analytics providers, and data from social media platforms used.

4.3 Anonymized and aggregated data
‍The Company will also collect other information in the form of anonymized and aggregated information, where all information must be combined and then removed from personally identifiable information, making it unsuitable for identifying specific individuals.

The Company may use anonymized or aggregated user information at any time for the purposes set forth in this Privacy Policy, including to better understand user needs and behaviors, conduct business intelligence and marketing initiatives, and identify security threats.

The Company reserves the right to implement innovative technologies as they become available for use in strategic planning and operational processes.

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5. How the Company may use personal information‍

Your Personal Information will be made available to the Company, affiliates of the Company and/or within the Company's group of companies. This includes, but is not limited to, employees and/or any person or third party employed by the Company who is responsible for the use and protection of your Personal Information. The Company may use and process your Personal Information for the following purposes and in the following ways:

5.1 To provide Services to the Company
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The Company uses Personal Information collected or provided to maintain and provide effective Services (including, but not limited to, transaction processing and/or cryptocurrency wallet data), to improve the efficiency of the day-to-day Services, and to verify your identity.

The Company uses IP addresses and unique identifiers stored in your device's cookies to help the Company confirm your identity and activities and to provide the Company Services.
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5.2 To protect Users

The Company uses the information collected to protect the Company Platform, User accounts and archives. The Company also uses IP addresses and cookies to identify suspicious activity and protect against automated abuse such as spam, phishing and distributed denial of service ("DoS") attacks.
‍5.3 To comply with regulatory requirements and meet the Company's legitimate interests

The Company uses information in accordance with the Company's legal obligations, global and local industry standards, government requests and the Company's AML/KYC/CTF procedures.  

In case of an emergency (i.e., to protect the vital interests of users or other natural persons, to achieve a public interest purpose, or to fulfill the reasonable interests of the Company), the Company may use and process your Personal Information without obtaining your consent.

5.4 For measurement, research and development purposes

The Company actively measures and analyzes your information to understand how you use and interact with the Company Services. This analysis is continually performed by the Company's operations teams to continuously improve the Company's Platforms and address user experience issues.  

In addition, Company uses such information to customize, measure and improve the Company Services, the administration, content and layout of the Website, and to develop new services for you.

5.5 For communication purposes

The Company uses your Personal Information collected or received from your communication devices or your email address to communicate directly with you, to provide you with the support you need, and/or to inform you about logins, cryptocurrency wallet, transactions, account security details, and other aspects. All direct communications will be properly retained by the Company or the Company's service providers to verify their accuracy, preserve them as evidence, or use them to fulfill other legal requirements or other obligations under this Privacy Policy and Terms and Conditions.

5.6 Ensuring compliance with the Terms and Conditions and other documents and standards of the Company

PERSONAL INFORMATION IS ALSO USED TO CONTINUOUSLY AND ACTIVELY ENFORCE COMPLIANCE WITH THE TERMS AND CONDITIONS AND OTHER COMPANY DOCUMENTS AND STANDARDS AMONG COMPANY USERS.  

ACTIVITIES IN THIS REGARD INCLUDE, INTER ALIA, VERIFICATION, INVESTIGATION AND PREVENTION OF ANY POTENTIALLY PROHIBITED OR ILLEGAL ACTIVITIES THAT MAY VIOLATE THE PREVIOUS PROVISIONS, AS WELL AS DISCLOSURE OF RELEVANT INFORMATION TO THIRD PARTIES.  IN THIS REGARD, THE COMPANY RESERVES THE RIGHT TO SUSPEND OR TERMINATE ANY COMPANY SERVICES TO ANY USERS FOUND TO BE ENGAGING IN ACTIVITIES THAT VIOLATE THE COMPANY'S TERMS AND CONDITIONS.

5.7 For marketing and advertising

Company will share your personal information with marketing partners for targeting, modeling and/or identification analytics, and marketing and advertising purposes.
5.8 For returns

Company shares personal information collected from you, including but not limited to your identification and transaction information, with your referrer for the purpose of receiving discounts and other benefits.
5.9 For other purposes

THE COMPANY WILL NOT USE YOUR PERSONAL INFORMATION FOR PURPOSES OTHER THAN THOSE CONTEMPLATED BY THIS PRIVACY POLICY WITHOUT YOUR PRIOR CONSENT.

IF THE COMPANY NEEDS TO PROCESS OR USE YOUR PERSONAL INFORMATION FOR OTHER PURPOSES, THE COMPANY MUST NOTIFY YOU AND SEEK YOUR CONSENT TO USE SUCH INFORMATION.

6. Storage of personal information

6.1. The Company takes great care to implement and maintain the security of its Services and the security of your Personal Information.

The Company has procedures and policies that incorporate industry best practices to ensure the integrity of your personal information and prevent unauthorized use.   
6.2. THE SECURITY OF YOUR PERSONAL INFORMATION CANNOT BE FULLY GUARANTEED, AND WHILE THE COMPANY TAKES REASONABLE STEPS TO PROTECT YOUR PERSONAL INFORMATION, IT CANNOT BE HELD RESPONSIBLE FOR ACTIONS TAKEN BY THOSE WHO GAIN UNAUTHORIZED ACCESS TO OR MISUSE YOUR INFORMATION AND SERVICES.

THEREFORE, IT IS RECOMMENDED THAT YOU TAKE YOUR OWN PRECAUTIONS TO PROTECT YOUR PERSONAL INFORMATION, ESPECIALLY CREDENTIALS SUCH AS USERNAME AND PASSWORD.  
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YOU AGREE THAT THE COMPANY SHALL NOT BE LIABLE FOR INFORMATION LEAKS OR OTHER LOSSES NOT CAUSED BY THE INTENT OR GROSS NEGLIGENCE OF THE COMPANY, INCLUDING BUT NOT LIMITED TO HACKER ATTACKS, POWER OUTAGES OR UNAVOIDABLE TECHNICAL FAILURES.

7. Preserving personal information

In accordance with applicable laws and regulatory requirements, the Company is required to retain certain information, including users' personal information, user profiles, identity verification materials, information related to AML/KYC/CTF procedures, cryptocurrency wallet and transaction data, account information, account agreements and other agreements between the Company and third parties, account statements and other records.

Such records are generally retained as required by law for the minimum period of time necessary to accomplish the purpose for which they were collected and no longer than permitted by the Company's retention policy.  

HOWEVER, EVEN AFTER YOU DEACTIVATE YOUR ACCOUNT, THE COMPANY MAY RETAIN COPIES OF INFORMATION ABOUT YOU AND ANY TRANSACTIONS OR SERVICES IN WHICH YOU MAY HAVE PARTICIPATED FOR A PERIOD OF TIME CONSISTENT WITH APPLICABLE LAW, APPLICABLE STATUTES OF LIMITATIONS, OR IF WE BELIEVE IT IS REASONABLY NECESSARY TO COMPLY WITH APPLICABLE LAWS, REGULATIONS, LEGAL PROCESS, OR GOVERNMENTAL REQUESTS TO DETECT OR PREVENT FRAUD, RECOVER PAYMENTS DUE, RESOLVE DISPUTES, AND PROVIDE YOU WITH INFORMATION ABOUT YOUR ACCOUNT.

8. Cookies

8.1 The Company uses cookies and other web analytics technologies or techniques to collect, store and track certain information related to your access to and actions on the Services, including when you visit the Company's website.  
8.2 The term "cookie" as used herein means a small piece of information that the Website assigns to your device while you are browsing the Website.  Cookies are useful and can be used for a variety of purposes, including enabling efficient navigation between pages, automatically activating certain features, remembering your preferences and making interactions between you and the Services faster, easier and smoother.  
8.3 The following types of cookies are used on the Company's Website:
(1) Strictly necessary cookies  

These cookies are necessary to allow you to log in, navigate the website and use its features, or to provide the service you have requested. The Company does not need your consent to use these cookies.
(2) Functional cookies

These cookies allow the Website to remember choices you make (such as your username, language or region of residence) and provide enhanced, more personalized features. The information these cookies collect remains anonymous and they cannot track your activity on other sites.
(3) Performance-related cookies  

These files collect information about how you use the website, such as which pages you visit most often, record difficulties you may encounter when using the website, such as error messages. All information collected by these cookies is aggregated and therefore anonymous. It is only used to improve the performance of the Website.
(4) Targeted cookies or advertising cookies

These cookies are used to deliver advertisements targeted specifically to you and your interests. They are also used to limit the number of times an advertisement is displayed and to determine the effectiveness of an advertising campaign. These cookies remember that you have visited a website and this information is shared with other organizations, such as advertisers. It is possible that targeting or advertising cookies will be linked to website functionality provided by other organizations.
8.4 You can delete these cookies by following the instructions in your device settings. However, if you choose to disable cookies, some features of the Company Services may not function properly and your online experience may be limited.

9. Sharing personal information

The Company does not rent, sell or disclose your Personal Information to third parties, except to those who need access to the information to perform their tasks and duties and to share it with third parties who have a legitimate purpose for accessing it. The Company may share, transfer, disclose or provide access to your Personal Information to the following third parties for the purposes described below:
9.1 To third parties for the purpose of administering or processing the Transaction or Services that you have authorized or requested, or in the context of facilitating the performance of the Transaction;
9.2 Confirm your identity in accordance with applicable laws and regulatory requirements and utilize the services of third parties to perform such verifications. The personal information you provide to us during the account opening process is shared with these services at account opening and on an ongoing basis thereafter;
9.3 As required by applicable laws and regulations to perform or assist in the performance of certain functions such as, but not limited to, invoice processing, surveillance, reconciliation, execution, record retention requirements and document distribution;
9.4 With the financial institutions we partner with to process payments you have authorized;
9.5 Analysis based on anonymous information about the user or his behavior with affiliated companies of the Company for the purpose of exploitation and improvement of products and services;
9.6 Disclose or share information that the Company collects with a purchaser of our business;
9.7 Disclose or share information that the Company collects when you close your account(s), when you have an insufficient balance, or in excessive cases when you have insufficient funds in your account(s);
9.8 For certain promotions and special offers where the nature of the promotion or special offer requires the Company to collect and share your personal information with a third party in order to deliver the goods or services.  If you decide to purchase a product or service offered by a third party as part of a promotion or special offer, any personal information you share with such third party will no longer be subject to this Privacy Policy;
9.9 To third parties who provide services such as, but not limited to, consulting, sales, customer support operations, payment processing, authentication services, and technical support or services;
9.10. to law enforcement authorities, government officials or other third parties when the Company is compelled to do so by subpoena, judgment, court order or similar legal process, or when the Company believes in good faith that disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of any of the Company's terms and conditions or any other applicable policies;
9.11. Disclose information about your account or transactions to third parties if you give the Company written permission;
9.12. Other circumstances under which the Company may disclose your Personal Information include, but are not limited to, the following:
(1) comply with applicable laws and regulatory requirements, as appropriate;
(2) respond to mandatory legal or governmental requests or demands for information;
(3) meet national security requirements;
(4) enforce our agreements, policies, procedures and/or the provisions of the Terms and Conditions;
(5) to protect the Company, its affiliates, users, contractors or the public from unlawful acts; and
(6) to respond to an emergency that requires disclosure of that information. The Company will not share your personal information with affiliates and third parties for their benefit unless you consent. However, you may freely refuse to share your personal information with third parties or to authorize the Company to use your personal information for any purpose that is incompatible with the purposes for which the Company originally collected or subsequently obtained your authorization, as set forth in this Privacy Policy. All affiliates and third parties with whom the Company shares your personal information have their own privacy policies. However, they are expected to protect that information in a manner that is consistent with the terms described in this Privacy Policy.

10. Collection of personal information by third parties

10.1 This Privacy Policy applies only to the use and disclosure of Personal Information that the Company collects from you. To the extent that you disclose your information to others as a result of using the Company's Services, such as by linking to any other website, different rules regarding the Privacy Policy may apply to their use or disclosure of the Personal Information you share with them.
10.2 YOU HEREBY ACKNOWLEDGE THAT THE COMPANY IS NOT RESPONSIBLE FOR THE PRODUCTS, SERVICES OR DESCRIPTIONS OF PRODUCTS OR SERVICES THAT YOU OBTAIN FROM THIRD PARTY WEBSITES, OR THE CONTENT OR PRIVACY PRACTICES OF THOSE WEBSITES.
10.3 THIS PRIVACY POLICY DOES NOT APPLY TO ANY THIRD PARTY PRODUCTS AND SERVICES THAT YOU ACCESS THROUGH THE COMPANY PLATFORM.  

YOU KNOWINGLY AND VOLUNTARILY ASSUME ALL RISKS ASSOCIATED WITH THE USE OF THIRD PARTY SITES TO PURCHASE GOODS AND SERVICES AND AGREE THAT THE COMPANY ASSUMES NO RESPONSIBILITY OR LIABILITY WITH RESPECT TO SUCH THIRD PARTY SITES AND YOUR USE THEREOF.

11. Rights of the User

In certain circumstances, you have rights under data protection legislation in relation to your personal information.  These rights include the following:
11.1 The right to receive information
You reserve the right to be informed about the collection, use and processing of your personal data.
11.2 Right of access

You reserve the right to request a copy of the personal information we hold about you and specific information relating to the Company's handling of that information.
11.3 Right of rectification

You reserve the right to request that the Company update, correct or supplement your Personal Information that you believe is outdated, inaccurate or incomplete. You may make corrections at any time by logging into your account with the Company and accessing the "Profile" feature to make the appropriate changes.
11.4 Right to erasure of personal information

You may request that your personal information be removed from the Company's database under certain conditions.  
In order to prevent fraudulent activity by ensuring that those attempting to commit fraud cannot avoid detection by simply closing their accounts(s) and opening new accounts(s), the Company will mark your account(s) as "Closed" in its database, but will retain certain account information, including your request to delete your Personal Information, in our database for a specified period of time.
However, if you close your account, your personal information will not be used by the Company for any further purpose or shared with third parties, except as necessary to prevent fraud and assist law enforcement as required by law or in accordance with this Privacy Policy.
11.5 Right to data portability

You reserve the right to request that a machine-readable copy of your personal information be transmitted to you or a third party of your choice. The Company must provide you or a third party with your personal information in a machine-readable format. This right extends only to personal information that you have consented to the Company's use.
11.6 Right to restrict processing

You may ask the Company to restrict or stop processing your personal information in certain circumstances as set out below:
(1) to establish the accuracy of personal information;
(2) where the processing is deemed unlawful but you do not want your personal data to be deleted;
(3) when the Company no longer needs to process your personal information but it must be retained for legal reasons;
(4) if you have objected to the company processing your personal information, but it needs to determine whether its legitimate interest overrides your objection.
11.7 Right to object

You may object to our reliance on the Company's legitimate interests as a basis for processing your personal information that affects your rights.  
You may also object to the Company's processing of your Personal Information for direct marketing purposes.
11.8 Right to withdraw consent ("Opt-out")

You reserve the right to withdraw your consent at any time if the Company relies on it to process your Personal Information. Withdrawing your consent does not affect the lawfulness of the Company's processing of your Personal Information prior to the withdrawal. If you wish to exercise the above rights, please notify the Company and contact the Company through its Platform, including the Company's website.

12. Rights of residents of the European Economic Area ("EEA")

12.1 If you are a resident of the European Economic Area, the UK or Switzerland at the time your personal data is collected, you retain all legal rights under clause 10 as set out above.  
12.2 The Company will comply with legal requirements under the General Data Protection Regulation ("GDPR") when collecting, using or processing your personal information.  
In the event that some recipients are located outside the EEA, the Company will only transfer your personal information to such countries that are approved by the European Commission as providing an adequate level of data protection or enter into legal agreements that provide an adequate level of data protection in the jurisdiction of the party receiving the information.

13. Restrictions

13.1 The Company Services are not intended for persons under the age of eighteen or under the age of consent under the applicable laws of the country or jurisdiction in which you use the Company Services.  
IF YOU ARE UNDER EIGHTEEN YEARS OF AGE OR UNDER THE LEGAL AGE OF CONSENT IN YOUR COUNTRY, YOU MUST NOT PROVIDE THE COMPANY WITH ANY PERSONAL INFORMATION OR USE THE COMPANY'S SERVICES. THE COMPANY RESERVES THE RIGHT TO ACCESS AND VERIFY ANY PERSONAL INFORMATION RECEIVED FROM YOU. IF THE COMPANY LEARNS THAT YOU ARE UNDER EIGHTEEN YEARS OF AGE OR UNDER THE AGE OF MAJORITY AND HAVE ALREADY PROVIDED THE COMPANY WITH YOUR PERSONAL INFORMATION, THE COMPANY WILL BE REQUIRED TO DELETE SUCH INFORMATION AND TERMINATE YOUR ACCOUNT IMMEDIATELY.
13.2 The Company cannot guarantee that there will be no loss, misuse, unauthorized access or alteration of your Personal Information. You agree that you play a critical role in protecting your Personal Information, including your personal credentials. When registering on the Company Platform, you are strongly encouraged to choose a password of sufficient length and complexity and not to share it with third parties or unauthorized persons.  You agree that you must notify the Company immediately if you become aware that your Company account has been accessed by unauthorized persons.

14. Changes to the Privacy Policy

THE COMPANY WILL PERIODICALLY, IN ITS SOLE DISCRETION, REVIEW AND UPDATE THIS PRIVACY POLICY AND THE MOST CURRENT VERSION WILL BE POSTED ON THE COMPANY'S WEBSITE.  
In the event of any material changes that may affect your use of the Company Services and Platform, we will notify you through your email address or other communication channels you provide to the Company. We encourage you to actively review this Privacy Policy. If you do not agree, in part or in whole, with the revised Privacy Policy, you must stop accessing or using the Company Services. Your continued access to and use of the Company Services following changes to this Privacy Policy constitutes your acceptance of such changes and consent to your continued use of the Services.

15. Contact us

If you have any questions or concerns about this Privacy Policy, please contact our privacy team at [email protected].