Effective Date: January, 2024
\n 1.\n Introduction\n
\n\n\n Thank you for visiting\n \n bitradex.com\n . The relevant \n BitradeX\n \n entity acting as data controller provides this Privacy Policy Statement to describe our practices regarding the collection, storage, use, disclosure and other processing of personal data (as defined below). By accessing or using{' '}\n \n \n bitradex.com\n \n and any related application programming interface or mobile application (\n “BitradeX \n Platform\n ”\n ), you \n (a) \n acknowledge that you have the right, power and authority to accept this Privacy Policy Statement (\n “\n Privacy Policy\n ”\n )\n ; (b) \n confirm that you have read and understood this Privacy Policy, and \n (c) \n \n agree to the policies and practices described in this Privacy Policy. Please read it carefully to understand how we operate.\n \n
\n\n \n This Privacy Policy explains what data we collect, why we collect it, how we use and store it, how we share\n it, what rights you may have and how to contact us about our privacy practices. If you do not wish your personal data (as defined below) to be used in the ways described in this Privacy Policy, you must not use the{' '}\n \n BitradeX \n Platform, the technology, products and\n /\n or features provided by the \n BitradeX \n Platform (collectively, the \n “\n Services\n ”\n ).\n
\n\n\n 2. \n Definitions\n
\n\n i. Data Protection Officer: means the relevant \n BitradeX\n Data Protection Officer responsible for data protection.\n
\n\n \n ii. Digital Assets: means digital assets based on cryptographic protocols of computer networks that may be centralized or decentralized, closed or open-source, and that may be used as a medium of exchange and\n \n /\n or store of value (also called \n “\n virtual financial assets\n ”\n , \n “\n convertible virtual currencies\n ”\n , \n “\n crypto-currencies\n ”\n , \n “\n virtual currencies\n ”\n , \n “\n digital currencies\n ”\n , \n “\n digital commodities\n ”\n or \n “\n digital payment tokens\n ”\n ), such as Bitcoin or Ether.\n
\n\n\n Personal Data: means any information relating to an identified natural person (\n “\n data subject\n ”\n \n ), or any information that can directly or indirectly identify that person by linking data, using identifiers (e.g. name, voice, image, identification number, online identifier, location data or one or more special features indicating the individual’s physical, psychological, economic, cultural or social identity). It does not include data from which identity has been removed (anonymous data). This includes sensitive information.\n \n
\n\n\n \n Sensitive Information: means any data that directly or indirectly reveals a natural person’s family, racial origin, political or philosophical opinions, religious beliefs, criminal record, biometric data or any data relating to that person’s health, such as his\n \n /\n \n her physical, psychological, mental, genetic or sexual status, including information related to healthcare services provided that may reveal his or her health status.\n \n
\n\n\n \n v: Digital Assets: means digital assets based on cryptographic protocols of computer networks that may be centralized or decentralized, closed or open-source, and that may be used as a medium of exchange and\n \n /\n or store of value (also called \n “\n virtual financial assets\n ”\n , \n “\n convertible virtual currencies\n ”\n , \n “\n crypto-currencies\n ”\n , \n “\n virtual currencies\n ”\n , \n “\n digital currencies\n ”\n , \n “\n digital commodities\n ”\n or \n “\n digital payment tokens\n ”\n ), such as Bitcoin or Ether.\n
\n\n\n 3. \n What Personal Data We Collect and Hold and How We Collect It\n
\n\n BitradeX \n \n collects, processes and stores personal data through your use of the Services or with your consent. This personal data may include contact details, copies of identity documents you provide or that are obtained from publicly accessible databases, your government identification number and information related to your device or internet service (such as{' '}\n \n IP \n address and \n MAC \n number).\n
\n\n To understand how \n BitradeX \n protects data collected from users, please see Section \n 13 \n (\n “\n Information Security\n ”\n ) below.\n
\n\n We collect information you provide during the \n BitradeX \n \n Platform onboarding process, which may be completed, incomplete or abandoned. We also collect personal data when you communicate with us through customer support, subscribe to marketing communications, communicate with us by phone, email or other communication channels, or when you transact on the{' '}\n \n BitradeX \n \n Platform. We may collect, use, store or transfer your personal data proactively or automatically, which may include, without limitation, the following:\n \n
\n\n · \n \n Personally identifiable information such as name, email, phone number, nationality, date of birth, address and government identity information;\n \n
\n\n · \n \n Institutional details such as company legal name, company registration information, government ID number, proof of identity and legal existence, address, business description and beneficial owner information;\n \n
\n\n · Business information such as data related to transactions conducted on the \n BitradeX\n Platform;\n
\n\n · \n Financial information such as credit card\n /\n debit card numbers and bank account information;\n
\n\n · \n \n Communication information such as communications with our customer support team and responses to user surveys;\n \n
\n\n · \n Information required by regulatory bodies such as state and federal licensing bodies and consumer protection agencies;\n
\n\n · \n Other identifiers such as device fingerprint data, \n IP \n address and geolocation information.\n
\n\n\n \n We may also collect personal data about you from third parties such as electronic verification services, referrers, marketing agencies or liquidity providers. If we do, we will take reasonable steps to ensure they are aware of applicable privacy laws. We may also use third parties to analyze traffic to our website, which may involve{' '}\n \n Cookie \n use (see Section \n 12 \n below for more information on \n Cookie \n use). Information collected through such analysis is not anonymous.\n
\n\n \n We will not collect sensitive information about you without your consent, unless an exemption or exception applies. These exemptions or exceptions include collection required or authorized by law, or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.\n \n
\n\n \n If you do not provide the personal data we request, we may not be able to provide you with our services or properly address your needs. Accordingly, we will not provide you with the option to deal with us anonymously or by pseudonym.\n \n
\n\n \n In addition, we operate our business and collect personal data from individuals and entities located in different jurisdictions. Where applicable, we are required to protect personal data processed in such jurisdictions under applicable data protection laws. To learn more about how we protect data collected from individuals and entities in such jurisdictions, please refer to the relevant local laws\n \n
\n\n 4. \n Unsolicited Personal Data\n
\n\n \n We may receive personal data about you on an unsolicited basis. We will destroy or de-identify all unsolicited personal data we receive, unless the data is relevant to the purposes of collecting personal data described in this Privacy Policy. If we receive additional information about you that is combined with other information we are required or entitled to collect, we may retain that information. If we do, we will retain it in the same way as your other personal data.\n \n
\n\n\n 5. \n Whose Personal Data We Collect\n
\n\n We may collect and hold personal data about \n BitradeX\n \n Platform or Service users, prospective users, service providers or suppliers, prospective employees, employees and contractors and other third parties we deal with.\n \n
\n\n\n 6. \n How We Use Your Personal Data\n
\n\n BitradeX \n \n uses personal data to administer, provide, improve and personalize the Services for you, and to comply with our legal and regulatory obligations. We may also use such data to communicate with you about other products or services offered by{' '}\n \n BitradeX \n and\n /\n \n or its partners, and to consider any concerns or complaints you may have.\n \n
\n\n \n We may use and disclose your personal data for these purposes. We may also use and disclose personal data for secondary purposes related to the primary purposes described in this section or in other circumstances authorized by law.\n \n
\n\n \n Sensitive information will be used and disclosed only for the purpose for which it was provided (or a directly related secondary purpose) unless you expressly consent, or an exemption applies under applicable law. Below are the specific ways we process your personal data:\n \n
\n\n\n · \n \n To provide you with our Services. We use your personal data to provide you with our Services in accordance with our Terms of Service. For example, we need to know certain financial information in order to process fiat deposits to and withdrawals from your account.\n \n
\n\n · \n To detect and prevent fraud. Your personal data is used to detect and prevent fraud.\n
\n\n · \n \n To protect the security of our Services. We process your personal data, such as information about your device and activity, to maintain the security of your account and the{' '}\n \n BitradeX \n Platform.\n
\n\n · \n User\n /\n \n customer support. We process your personal data when you contact our customer support team to help us resolve your issues.\n \n
\n\n · \n \n To enhance our Services. We process your personal data to understand how our Services are used in order to improve our Services and develop new ones.\n \n
\n\n · \n \n Product marketing. We process your personal data to identify services we think may be of interest to you. We may contact you about these. For details, see Section{' '}\n \n 11\n (Communications) below.\n
\n\n · \n Consent. With your consent, we may use your personal data for other purposes.\n
\n\n · \n \n Other business purposes. We may use your personal data for other reasonably expected business purposes permitted by law or required to comply with our legal obligations.\n \n
\n\n\n Processing Personal Data Without Consent\n
\n\n \n If you do not consent to our processing of your personal data, we may still process your personal data on one of the following bases:\n \n
\n\n · \n \n Public interest. We will process your personal data without your consent where necessary to protect the public interest.\n \n
\n\n · \n \n Legal proceedings. We will process your personal data without your consent where necessary to initiate or defend legal proceedings or in connection with judicial or security proceedings.\n \n
\n\n · \n \n Protection of your interests. We will process your personal data without your consent where necessary to protect your interests.\n \n
\n\n · \n \n Performance of a contract. We will process your personal data without your consent where necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into such a contract; we rely on this basis to provide our Services.\n \n
\n\n · \n \n Compliance with legal obligations. We will process your personal data without your consent where we need to comply with a legal obligation to which we are subject.\n \n
\n\n\n To Whom We May Disclose Personal Data\n
\n\n BitradeX\n may disclose personal data to:\n
\n\n · \n \n Members of our corporate group, including our subsidiaries, holding companies and companies under common control, including their respective contractors, affiliates, employees or representatives.\n \n
\n\n · \n Our service providers and other third parties who assist us in providing services to you and\n /\n \n or as required or permitted by legal or professional standards, for example, including payment processing, customer support, data analysis, information technology, data processing, network infrastructure, storage and tax reporting.\n \n
\n\n · \n Entities involved in corporate transactions involving \n BitradeX\n \n , including any financing, acquisition or dissolution proceedings involving the disclosure of part or all of our business or assets.\n \n
\n\n · \n \n Government entities or other parties to legal proceedings, including law enforcement agencies and authorities, officials, regulators or other third parties, to comply with any law, court order, subpoena or government request.\n \n
\n\n · \n \n Professional advisers, including legal, accounting or other advisory services for auditing or compliance with our legal obligations.\n \n
\n\n\n Except as disclosed in this Privacy Policy, \n BitradeX \n \n will not share your personal data with any other third party unless required to do so by law or legal reporting obligations.\n \n BitradeX\n \n Platform may contain links to other third-party websites that may have their own privacy policies, and{' '}\n \n BitradeX\n is not responsible for the privacy policies of such third-party websites.\n
\n\n \n If we disclose your personal data to service providers who carry out business activities for us, they may only use your personal data for the specific purpose for which we provided the data. We will take reasonable steps to ensure that all contractual arrangements with third parties fully comply with applicable privacy laws. In addition, we have implemented standards to prevent money laundering, terrorist financing and circumvention of trade and economic sanctions that comply with applicable local jurisdictional requirements and require us to conduct due diligence on users. This may include the use of third-party data and service providers that will cross-reference your personal data for identity verification, fraud detection and prevention, transaction monitoring, credit verification and security threat detection.\n \n
\n\n\n 7. \n How We Store Your Personal Data\n
\n\n \n We recognize the importance of protecting our users’ personal data. We take steps to ensure that your personal data is not misused, interfered with or lost, and is not subject to unauthorized access, alteration or disclosure. Your personal data is generally stored in computer databases operated by us or our affiliates and\n \n /\n \n or third-party storage providers. For information held in our computer databases, we implement data security guidelines to ensure that your personal data is managed securely.\n \n
\n\n For more information, please see Section \n 13 \n (Information Security) below.\n
\n\n \n We retain your personal data for as long as is reasonably necessary to provide you with the Services, for our legitimate business purposes and to comply with our legal and regulatory obligations. If you close your account on the{' '}\n \n BitradeX\n \n Platform, we will continue to retain your personal profile to comply with legal and regulatory obligations. For example, we are required to comply with certain anti-money laundering laws that require us to retain records used for customer identification and due diligence obligations for an additional period after our business relationship with you ends.\n \n
\n\n 8. \n Sending Information to Other Countries\n
\n\n BitradeX\n \n Group operates globally, and personal data may be stored and processed in any country in which we operate or in which we engage service providers. We may disclose information to third-party storage providers or affiliates located outside your country\n \n /\n \n region, or to third-party storage providers or affiliates located outside your country\n \n /\n region.\n
\n\n \n We may transfer personal data we hold about you to recipients in countries other than the country in which the personal data was originally collected. The data protection or privacy rules of these other countries may differ from those of your country. However, we will take steps to ensure that any such transfer complies with applicable data protection laws and that your personal data is always protected by the standards described in this Privacy Policy. In some cases, courts, law enforcement agencies, regulators or security authorities in these other countries may be entitled to access your personal data. By communicating with{' '}\n \n BitradeX\n electronically, you acknowledge and agree to your personal data being processed in this way.\n
\n\n 9. \n Access, Correction and Deletion of Your Personal Data\n
\n\n \n Subject to exceptions provided by law, you have the right to obtain a copy of your personal data upon request and to ascertain whether the information we hold about you is accurate and up to date. We will provide access within{' '}\n \n 30 \n \n days of your request. If we refuse to provide the information, we will provide reasons for the refusal. Before providing you with access, we will require identity verification and specify the information requested. If any of your personal data is inaccurate, you may request that your information be updated. Unless you agree otherwise, if we are satisfied that the request to update information is accurate, we will take reasonable steps to correct the information within{' '}\n \n 30 \n \n days. You may also request the deletion of your personal data, but in some cases (such as compliance with laws or legitimate purposes) we may refuse your deletion request. For data access, correction or deletion requests, or to withdraw consent you previously provided, please send an email containing your request to the relevant email address with the subject\n \n “\n Data Inquiry Request\n ”\n .\n
\n\n\n 10. \n Children’s Personal Data\n
\n\n BitradeX \n does not knowingly provide services to or collect personal data from anyone under the age of \n 18\n \n . If we learn that we have collected personal data from anyone under the age of{' '}\n \n 18\n \n , we will promptly delete it from our systems. If you discover that anyone under the age of{' '}\n \n 18\n \n is using our Services, please notify us so that we can promptly take steps to block their access to our Services.\n \n
\n\n 11. \n Communications\n
\n\n \n We may only use personal data collected from you for direct marketing purposes without your consent if: the personal data does not include sensitive information; you would reasonably expect us to use or disclose the information for direct marketing purposes; we provide a simple method to opt out of direct marketing and you have not requested to opt out of receiving our direct marketing.\n \n
\n\n \n If we collect your personal data from a third party, we will only use that information for direct marketing purposes if you have consented (or it is impracticable to obtain your consent), and we will provide a simple way for you to easily request not to receive our direct marketing communications. We will draw your attention to this in our direct marketing communications.\n \n
\n\n We may communicate company news, promotions and information related to \n BitradeX \n \n products and services. We may share personal data with third parties to help us with marketing and promotional projects, or to send marketing messages.\n \n
\n\n \n Users can opt out of these marketing communications at any time by clicking the unsubscribe link in any marketing communication sent to you or by contacting our customer service at the{' '}\n \n Help Center\n .\n
\n\n For service-related communications, such as surveys, policy\n /\n terms updates and operational notices, you will not be able to opt out of receiving such information.\n
\n\n 12. Cookie \n Use\n
\n\n When you visit our website (i.e.\n \n www.bitradex.com\n ), we may place small amounts of data (\n “Cookies”\n \n ) in your browser in accordance with industry practice. This information may be stored on your computer or other device used to access our website. We use{' '}\n \n Cookie \n \n to enhance your experience of using our website. This information is used to identify users, remember user preferences, and enable users to complete tasks without re-entering information when browsing from one page to another or when revisiting our website at a later date. We also use{' '}\n \n Cookies \n \n to collect and analyze website usage data related to user usage and patterns. This data is used to improve our website and enhance user experience. We may also use the information collected to ensure compliance with our regulatory and anti-money laundering (\n \n “AML”\n \n ) requirements and to ensure that your account security is not compromised by detecting abnormal, suspicious or potentially fraudulent account activity.\n \n
\n\n Through settings, you can set your browser to block or alert you to these \n Cookies\n \n , but this may affect the functionality of the Services or your user experience. Session{' '}\n \n Cookies \n \n are added when the user begins browsing our website or interacting with specific features and are deleted when the browser is closed. Persistent{' '}\n \n Cookies \n \n are added when the user begins browsing our website or interacting with specific features, but may remain on your device until a certain expiration date.\n \n
\n\n 13. \n Information Security\n
\n\n \n We have implemented appropriate information security measures to prevent your personal data from being accidentally lost, accessed, altered, disclosed, used or destroyed without authorization (or other similar risks). We have taken various measures to ensure information security, including encrypting communications to the{' '}\n \n BitradeX\n \n Platform; requiring two-factor authentication for all sessions; regularly reviewing our personal data collection, storage and processing practices; and limiting access to your data by our employees and suppliers based on necessity, and our employees and suppliers are subject to strict contractual confidentiality obligations.\n \n
\n\n \n If you have any questions about information security or wish to report any security issues, please contact us by sending an email to the relevant email address with the subject{' '}\n \n “\n Information Security Request\n ”\n .\n
\n\n\n 14. \n Contacting \n BitradeX\n About Privacy Questions or Concerns\n
\n\n \n If you have any questions about this Privacy Policy or the use of your personal data, please contact us by sending an email to the relevant email address with the subject{' '}\n \n "\n Privacy Request \n "\n .\n
\n\n \n When processing your request to exercise your privacy rights, we will verify the identity of the requester to ensure that he or she is legally entitled to make such a request. While we endeavor to respond to these requests free of charge, we reserve the right to charge you a reasonable fee (if applicable) to comply with your request if your request is repetitive or unduly burdensome. To exercise your privacy rights, please send an email containing your request to the relevant email address with the subject\n \n “\n Data Inquiry Request\n ”\n .\n
\n\n 15. \n Changes to Our Privacy Policy\n
\n\n We may update this Privacy Policy at any time and post the revised version on the \n BitradeX \n \n Platform with the effective date of the revised version, so please check this Privacy Policy frequently for updates and changes.\n Your continued access to or use of the{' '}\n \n BitradeX \n Platform and\n /\n or Services constitutes your acknowledgment and acceptance of such changes to this Privacy Policy.\n
\n\n 16. \n Language\n
\n\n \n This Privacy Policy may be published in different languages. In case of any discrepancies, the English version shall prevail.\n \n