This Privacy Policy (this “Policy”) applies to the trading platform (including any applicable mobile applications and websites used to access the same) (collectively the “Platform”) provided by Xenitar Tech International FZCO (TieBix) (the “Company,” “we,” “us” or “our”). It describes how the Company collects, uses, and discloses Personal Information that we obtain from Users of the Platform and any account services provided through the Platform, and how we use and disclose that information. For purposes of this Policy, “Personal Information” refers to information supplied by a User from which the identity of such User may be directly or indirectly determined. We prioritize the security and privacy of your Personal Information. We are committed to ensuring that all Personal Information is processed in accordance with the highest standards of data protection and privacy regulations, and that technical and organizational measures are put in place. Our robust data management practices are designed to safeguard your information and maintain your trust.

It is important that you familiarize yourself with the provisions of this Policy together with Terms and Conditions and any other privacy notices we may provide on specific occasions when we are collecting or processing Personal Information so that you are fully aware of how and why we are using your Personal Information. By registering for and using the Platform, you agree that your Personal Information will be handled as described in this Policy and the Terms and Conditions applicable to the Platform (the “Service Agreement”); capitalized terms used herein shall have the same meaning as set forth in the Service Agreement.

The Information We Collect About You and How We Collect It

We collect and process Personal Information about you directly from you when you register to use the Platform or submit such information automatically through your use of the Platform, as well as from third parties to comply with the law or with our regulatory obligations. Such information is used to enforce or apply our Service Agreement and other agreements, to protect the rights, property or safety of the Platform and our Users or others, and to facilitate and ensure the provision of services and products offered by the Platform.

Information We Collect Directly From You

Personal Account and Profile Information:

• There are several types of accounts that can be established on the Platform. We collect the following information when you register an Account: name, mobile phone number and/or email address. When your Account meets a certain standard, we may collect additional information: name as in identity card/passport, identity card/passport number, date of birth, nationality, mailing address, residential address, mobile phone number and email address.

Financial Information:

• We may collect additional financial and investment information from you to confirm your status and eligibility to set up other types of accounts or conduct certain transactions on the Platform, including your investment experience, finance-related qualifications and training (including any certifications received, issuing organization and date of issuance), your annual income level, liquid net worth, estimated net worth, source of funds, and source of wealth and whether you have had the opening of an account declined by another financial institution.

Other Required Information:

• We may need to collect certain additional Personal Information to comply with legal requirements, such as whether you are a Politically Exposed Individual or on any restricted persons list, and applicable tax reporting forms, such as a W8-BEN.

Communications with Us:

• We collect information you give us during any support and feedback communications via email or when you contact us through contact forms on the Platform. We use this information to respond to your inquiries, provide support, facilitate transactions, and improve our Platform.

Marketing and Communications:

• This includes your consent and preferences in receiving direct marketing from us and our third parties and your communication preferences.
• Please note that if you are acting as an Authorized Individual on behalf of a User and are providing Personal Information for such User, you are responsible for ensuring that you have all required permissions and consents to provide such Personal Information to us for use in connection with the Platform and that our use of such Personal Information you provide to the Platform does not violate any applicable law, rule, regulation or order. In addition, please be advised that the information you provide will be screened against risk profiles to comply with applicable Anti-Money Laundering rules and internal “Know Your Client” policy.

Information We Collect Automatically

• When you use the Platform, our servers automatically record information using cookies and other tracking technologies, including information that your browser sends whenever you visit the Platform or your mobile application sends when you’re using it. This log data may include your Internet Protocol address, the address of the webpage you visited before coming to the Platform, your browser type and settings, the date and time of your request, information about your browser configuration and plug-ins, language preferences, and cookie data. Such log data is not routinely deleted.
• In addition to log data, we may also collect information about the device you use for the Platform, including what type of device it is, what operating system you’re using, device settings, unique device identifiers, and crash data. Whether we collect some or all of this information may depend on what type of device you’re using and its settings. We may combine this information with other information that we have collected about you, including, where applicable, your name, username, email address, and other Personal Information.

Geolocation

• If you have provided permission through your mobile device to allow us to collect location information through a mobile application, we may obtain your physical location information in terms of latitude and longitude from technologies like GPS, Wi-Fi, or cell tower proximity. You are able to withdraw your permission for us to acquire such physical location information from your mobile device through your mobile device settings, although we do not control this process. If you have questions about how to disable your mobile device’s location services, we recommend you contact your mobile device service provider or the mobile device manufacturer.

Information We Collect From Third Parties

• We may obtain information about you from third parties such as our affiliates, subsidiaries, vendors, analytics service providers, advertising service providers, information search service providers, or publicly available sources as required or permitted by applicable law as set out below:

Maintain legal and regulatory compliance:

• Processing is necessary to comply with our legal obligations under applicable laws and regulations, including Anti-Money Laundering laws and regulations. For example, the verification of details concerning sanctions screening and politically exposed persons listings.

Provide services:

• Our legitimate interest is that you and other Users could access and utilize services and products offered by the Platform with a smooth and personalized experience, as well as be informed about the crypto news or updates. For instance, the aggregation of relevant posts or updates from financial platforms, forums, and social media regarding emerging crypto investment opportunities enables us to curate personalized crypto investment suggestions or alerts for Users based on their preferences and past engagement with the Platform.
• These third parties may collect Personal Information on behalf of the Company, or act as separate controllers in accordance with their own privacy policies. Some of these third parties may have obtained your data from publicly accessible sources.

Lawful Basis for Processing Personal Information:

We process your Personal Information using one of the following legal basis:

• Performance of a contract means processing your Personal Information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• Legal requirement means processing your Personal Information where it is necessary for compliance with a legal or regulatory obligation that we are subject to
• Consent means processing your Personal Information using your written consent.

Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your Personal Information. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Information.

Generally, we do not rely on consent as a legal basis for processing your Personal Information other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

How We Use Your Information

We use your information, including Personal Information, for various purposes to enhance your experience on our Platform. Primarily, we utilize your information to provide and facilitate communications and transactions, ensuring that our services are delivered effectively. We may also use your information to communicate with you regarding your use of our Platform, respond to your inquiries, fulfill your orders, and provide customer support. Additionally, we personalize your experience on the Platform by tailoring content and information, offering location-based customization, and providing personalized assistance.

We may also analyze user behavior to better understand how our Platform is accessed and used, both on an aggregate and individual basis. This helps us improve our services, respond to user preferences, and conduct research and analysis. Furthermore, we use the information to send you marketing communications, such as newsletters, special offers, promotions, sweepstakes, and contests. This communication aims to keep you informed about products or services that may be of interest to you. Our platform may also use this information to assist in advertising and promoting the Platform on third-party websites.

For safety and security reasons, we may disclose your information to protect the rights, property, or safety of the Platform, its users, or others. This includes troubleshooting, data analysis, system maintenance, and the hosting of data. Moreover, your information may be shared with third-party service providers to comply with legal requirements, enforce agreements, or prevent illegal activities and fraud. Information sharing may also occur when necessary to protect our rights, engage in litigation, or respond to a subpoena.

How We Share Your Information

We may disclose your information to our affiliates and subsidiaries for the purpose of providing services on our Platform. These entities are bound by the terms of this Policy, ensuring that your personal data is handled in accordance with the same level of protection. Additionally, we share your information with third-party service providers who perform functions on our behalf, such as processing payments, customer service, and marketing. These third parties are only permitted to use your information to provide services to us and are contractually bound to handle your information securely.

In the event of a business transfer, such as a merger or acquisition, or in bankruptcy proceedings, your information may be transferred to the acquiring entity. We may also disclose your information to comply with legal processes, such as court orders, subpoenas, or other legal requirements. We may share your information if necessary to investigate or prevent illegal activities, fraud, or violations of our agreements. Additionally, aggregated or de-identified information may be shared with third parties for research, marketing, or statistical purposes.

Our Use of Cookies and Other Tracking Mechanisms

To improve your experience, we and our third-party service providers use cookies and tracking technologies to monitor your usage of the Platform. Cookies are small files placed on your device that allow us to enhance your navigation experience, personalize content, and track usage patterns. There are two types of cookies we use: Session Cookies and Persistent Cookies

Session Cookies are temporary cookies that are deleted once you close your browser. They are used to track your session and help us authenticate your identity during your visit. Persistent Cookies remain on your device after the session ends and are used for statistical analysis, remembering your preferences, and improving user experience over time.

If you prefer not to use cookies, most web browsers allow you to disable them. However, doing so may impact the functionality of certain areas of the Platform. We also use third-party analytics tools, such as Google Analytics, to evaluate Platform usage, which may involve the use of cookies and tracking technologies to collect and analyze data.

Third-Party Links

Our Platform may contain links to external websites that are not governed by this Policy. Accessing these links will direct you to the privacy policies of the respective websites. We are not responsible for the privacy practices or content of third-party websites.

Security of Your Personal Information

We implement reasonable measures to protect your Personal Information from unauthorized access, misuse, and loss. Despite these efforts, please note that no security system is impenetrable. We advise all users to follow best practices to safeguard their data, including selecting strong passwords, installing antivirus software, and ensuring regular software updates. It is essential to log out after using the Platform, particularly when accessing it from shared devices. We are not responsible for any unauthorized access to your account due to compromised login credentials

Security of Your Personal Information

We implement reasonable measures to protect your Personal Information from unauthorized access, misuse, and loss. Despite these efforts, please note that no security system is impenetrable. We advise all users to follow best practices to safeguard their data, including selecting strong passwords, installing antivirus software, and ensuring regular software updates. It is essential to log out after using the Platform, particularly when accessing it from shared devices. We are not responsible for any unauthorized access to your account due to compromised login credentials

Rights of Access, Correction, and Deletion

You have the right to access, update, or delete your Personal Information at any time by logging into your account settings or contacting us directly. We will respond to your request promptly, in compliance with applicable laws. However, please be aware that in certain situations, we may be unable to honor requests for modification or deletion of information, particularly if retention is required for legal compliance, dispute resolution, or other essential purposes. In these cases, we will inform you accordingly.

Please note that notwithstanding the foregoing, there may be circumstances in which we are unable to accommodate a request to edit, update, access, or delete an account profile or Personal Information. This includes but is not limited to:

• Any basis where such request can be denied under applicable law;
• Where we need to retain the information to comply with federal, state, or local laws or for accounting or tax purposes;
• Where we need to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
• Where we need to cooperate with law enforcement agencies concerning conduct or activity that the business, service provider, or third party reasonably and in good faith believes may violate federal, state, or local law;
• Where we need to retain information to exercise or defend legal claims;
• Where the information contains legal privilege or proprietary information of another party;
• Where complying with the request would compromise others’ privacy or other legitimate rights.

If we determine that we cannot respond to any request in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before responding to any request under this provision, including complying with any applicable legal requirement for verifying your identity.

Transfer of Information

Please note, we may store your Personal Information on servers located in the countries where our main offices are located. If such jurisdiction is outside your jurisdiction of residence, you consent to the transfer of your Personal Information to such jurisdiction for purposes of providing the Platform to you, even if such other jurisdiction has fewer protections for Personal Information than your jurisdiction of residence. We will ensure that security provisions are in place consistent with our obligations to maintain the security of your Personal Information under the laws of your jurisdiction of residence.

Retention

We retain your Personal Information as long as you maintain an Account on the Platform. We will cease to retain your Personal Information, or remove the means by which the Personal Information can be associated with particular individuals, as soon as it is reasonable to assume that:

• The purpose for which that Personal Information was collected is no longer being served by its retention; and
• Retention is no longer necessary for legal, accounting, or business purposes.

Please note that certain laws may require us to retain records of transactions or accounts for a certain period of time.

Blockchain Information

You should be aware that due to the inherent transparency of the blockchain networks, transactions that you approve when using the Platform may be publicly accessible. This includes, but is not limited to, your public key address, the public key address of the receiver, the amount of crypto sent or received, and any other data a User has chosen to include in a given transaction. Transactions and addresses available on blockchain networks may reveal Personal Information about the User’s identity, and Personal Information can potentially be correlated now or in the future by any party who chooses to do so, including law enforcement. We encourage you to review how privacy and transparency on blockchain networks works.

Children Under 18

Our Platform is not designed for children under 18. If we discover that a child under 18 has provided us with Personal Information, we will delete such information from our systems.

Contact Us

If you have questions about the privacy aspects of our Platform or would like to make a complaint, please contact us via our live chat services or at [email protected].