This Privacy Policy (hereinafter – "Policy") describes the procedures for collecting, using, storing, and protecting personal data of users of the Exchange Cluster service (hereinafter – "the Service").

By using the Service's website, the User agrees to the terms of this Policy and consents to the processing of their personal data.

If the User disagrees with the terms of this Policy, they must cease using the Service.

This Policy applies only to the Service's website. The Service does not control and is not responsible for third-party websites that the User may access through links.

The following data may be collected during use of the Service:

• email address;
• phone number;
• IP address;
• cryptocurrency wallet addresses;
• transaction data;
• browser and device information;
• cookies.

In the case of KYC procedures, the Service may additionally collect:

• first and last name;
• photo or scan of an identity document;
• selfie or video with the document;
• proof of source of funds;
• proof of ownership of the cryptocurrency wallet or payment instrument.

Personal data may be used for:

• providing exchange services and processing transactions;
• User identification and AML/KYC procedures;
• fraud prevention and enhancing Service security;
• communicating with the User regarding order status or other matters;
• notifying the User about service updates and important information;
• compliance with applicable legislation;
• resolving technical issues and improving Service performance.

Personal data processing may include: collection, recording, systematization, storage, updating, usage, transfer, and deletion.

Processing is carried out using automated and non-automated means in accordance with the purposes defined in this Policy.

The Service may transfer personal data to third parties only when necessary for:

• conducting AML/KYC checks;
• processing payments through payment systems;
• fulfilling requests from law enforcement agencies in accordance with legislation;
• ensuring platform security and fraud prevention.

The Service does not sell Users' personal data to third parties.

The Service applies technical and organizational measures to protect personal data from unauthorized access, alteration, disclosure, or destruction.

Access to personal data is limited to authorized Service employees who are required to maintain confidentiality.

In the event of a data loss or breach, the Service takes all necessary measures to minimize the consequences and notifies the User.

Personal data is stored for the period necessary to fulfill the purposes of its processing, as well as to comply with legal requirements and AML procedures.

Information about transactions and verification results may be stored for up to 5 years.

The User has the right to:

• obtain information about the processing of their personal data;
• request correction or updating of data;
• request deletion of personal data, provided it does not conflict with legal requirements and AML obligations;
• withdraw consent to data processing.

To exercise their rights, the User may contact the Service's customer support.

The Service's website may use cookies to ensure proper operation, improve user experience, and collect statistical information.

Disabling cookies may result in limited website functionality.

The Service is not liable for the disclosure of personal data if:

• the information became publicly available before its loss or disclosure;
• the information was obtained from a third party before it was received by the Service;
• the information was disclosed with the User's consent.

Any disputes related to this Policy shall be resolved through negotiations between the parties.

If no agreement is reached, all disputes shall be resolved in accordance with the legislation of the Respondent's country of residence.

The Service reserves the right to modify this Policy without prior notice. The current version of the Policy is always available on the Service's website.

For questions regarding personal data processing, the User may contact the Service's customer support.

By continuing to use the Service after changes to the Policy, the User confirms their agreement with the updated terms.