Privacy Policy and Personal Data Processing

Privacy Policy and Personal Data Processing

1. General Provisions


1.1. This Privacy Policy governs the procedures for processing and protecting personal data and has been developed in accordance with the applicable laws of the Russian Federation, including Federal Law No. 152-FZ “On Personal Data”.

1.2. This Policy defines how personal data of individuals (hereinafter referred to as “Users”) is collected, used, stored, and protected when using the digital asset exchange service (hereinafter referred to as the “Service”).

1.3. This Policy applies to all information that the Service may obtain about the User when using the website, personal account, mobile applications, or when contacting customer support.

1.4. By using the Service, the User confirms acceptance of this Policy. If the User does not agree, they must stop using the Service.


2. Definitions

2.1. Personal Data — any information that directly or indirectly identifies a User.

2.2. Processing of Personal Data — any operation performed on personal data, including collection, storage, use, transfer, updating, blocking, and deletion.

2.3. Operator — the entity that processes personal data and determines the purposes and methods of such processing.

2.4. User — an individual who interacts with the Service.


3. Categories of Data Collected

3.1. The Service may process the following categories of personal data:

  • identification data (full name, date of birth, citizenship, etc.);
  • identity document details;
  • contact information (phone number, email, address, etc.);
  • data required for KYC/AML procedures (photos, videos, proof of address);
  • financial information (payment details, transaction history);
  • transaction data (amounts, wallet addresses, transaction parameters);
  • technical data (IP address, cookies, device and browser information).

3.2. The Service does not process special categories of personal data (such as health or political opinions), except where required by law or necessary for identification purposes.


4. Purposes of Data Processing

4.1. Personal data is processed for the following purposes:

  • providing access to the Service functionality;
  • fulfilling contractual obligations;
  • conducting digital asset exchange operations;
  • complying with AML/KYC and legal requirements;
  • user identification and verification;
  • fraud prevention and security;
  • handling support requests;
  • fulfilling legal obligations;
  • improving and analyzing the Service;
  • informing Users about important updates and notifications.


5. Legal Grounds for Processing

5.1. Personal data is processed based on:

  • User consent;
  • necessity for contract performance;
  • legal obligations;
  • legitimate interests of the Operator, provided User rights are not violated.


6. Data Processing and Protection

6.1. Data processing may be carried out with or without automation.

6.2. The Service implements appropriate security measures, including:

  • data encryption;
  • secure storage systems;
  • access control;
  • logging of data-related actions;
  • regular security updates.

6.3. Access to personal data is granted only to authorized personnel as required for their duties.


7. Data Sharing with Third Parties

7.1. Personal data may be shared with:

  • banks and payment providers;
  • KYC/AML service providers;
  • IT infrastructure providers;
  • government authorities when required by law;
  • other parties with User consent or in case of business transfer.

7.2. All third parties must comply with confidentiality requirements.

7.3. Cross-border data transfers are carried out in accordance with applicable legal requirements.


8. Data Retention

8.1. Personal data is retained only as long as necessary for processing purposes.

8.2. Certain data may be retained longer as required by law (e.g., financial and AML records).

8.3. Upon expiration, data is deleted or anonymized.


9. User Rights

9.1. The User has the right to:

  • obtain information about data processing;
  • request correction or deletion of data;
  • withdraw consent;
  • file complaints with competent authorities.

9.2. Some rights may be restricted due to legal requirements.


10. Cookies

10.1. The Service uses cookies to ensure proper functionality, analytics, and personalization.

10.2. Users may disable cookies in browser settings, which may affect Service functionality.


11. Policy Updates

11.1. The Operator reserves the right to amend this Policy.

11.2. The updated version becomes effective upon publication on the website.

11.3. Continued use of the Service constitutes acceptance of the updated Policy.