Thank you for exploring the NitroEx Trading Platform ("NitroEx"). Your visit, access, or use of NitroEx and its associated application program interface or mobile applications ("Site") implies your consent to our privacy policy's policies and practices (the "Privacy Policy"). PLEASE REVIEW THIS PRIVACY POLICY THOUGHTFULLY. The Privacy Policy outlines how NitroEx utilizes your Personal Data (defined below) while offering you access and utility through our digital asset trading platform via software, API (application program interface), technologies, products, and/or functionalities ("Service"). In delivering our Service, adhering to the laws in the jurisdictions where we operate, and enhancing our services, we must collect and maintain personal information about you. As a general practice, we do not disclose any personal information about our customers to non-affiliated third parties, except as detailed below. We reserve the right to update this Privacy Policy at any time by posting the revised version on this site.


DATA COLLECTION


NitroEx gathers, processes, and retains Personal Data obtained from you through your utilization of the Service or with your consent. This Personal Data encompasses:


-Virtual Identity: NitroEx Account/ Password, NitroEx Nickname.


-Financial Information: Bank account details, primary account number (PAN) of payment cards, account assets, transaction history, trading data, and/or tax identification.


-Transaction Information: Details about your transactions on the Platform, including recipient names, your name, amounts, and timestamps.


-Message Content: Feedback, Emails, SMS, App Ratings, Comments.


-Application Activity: Browser and tap records, search history, installed apps, running apps, crash logs, user-generated content, favorites, mouse movement, scroll position, key events, and touch events.


-Device Information: Carrier, brand, software version, model name, manufacturer, system language, OS Version, Locale, Fingerprint, Build ID, Baseband Version, SIM Country, SIM Serial Number, Battery Status, network, OAID, IMEI, GUID, MAC address, Android ID, SSID, Advertising ID, and gyroscope/accelerometer data.


-Correspondence: Survey responses, and information provided to our support team, or user research team.


-Audio, electronic, visual, and similar information, such as call and video recordings.


We may collect information provided during the NitroEx onboarding process, regardless of whether it is completed, incomplete, or abandoned. In serving residents of specific jurisdictions, we collect, store, and process your personal information following local data protection laws, such as the General Data Protection Regulation (GDPR) and the Data Protection Act.


Furthermore, to comply with Anti-Money Laundering laws and regulations, we may collect the following Personal Information:


Individual customers:


-Email address

-Mobile phone number

-Full legal name (including former names and names in the local language)

-Nationality

-Passport number or any government-issued ID number

-Date of birth (“DOB”)

-Proof of identity (e.g., passport, driver’s license, or government-issued ID)

-Residential address

-Proof of residency

-Additional Personal Data or documentation at the discretion of our Compliance Team


Corporate customers:


-Corporate legal name (including the legal name in the local language)

-Incorporation/registration Information

-Full legal name of all beneficial owners, directors, and legal representatives

-Address (principal place of business and/or other physical locations)

-Proof of legal existence

-Description of the business

-Percentage of ownership for individual/corporate owners

-Contact information of owners, principals, and executive management (as applicable)

-Proof of identity (e.g., passport, driver’s license, or government-issued ID) for the significant individual beneficial owner of the institutional customer entity

-Personal Data for each entity’s significant beneficial owner of the institutional customer entity (see the “Individual Customer” section above for details on what Personal Data we collect for individuals)

-Source of wealth

-Projected amount of bitcoin or other digital assets to be injected


ACCESS, CORRECTION, DELETION, AND OTHER RIGHTS CONCERNING YOUR PERSONAL DATA


By applicable law, as detailed below, you possess several rights regarding your privacy and the safeguarding of your Personal Data. You have the right to request access to, rectify, and erase your Personal Data, as well as request data portability. Additionally, you can object to our processing of your Personal Data or request the restriction of its processing in specific instances. Moreover, if you have given consent for the processing of your Personal Data for a specific purpose, you have the right to withdraw that consent at any time. Should you wish to exercise any of the rights outlined below, please contact our Data Protection Officer via email at dataprotect@nitroex.io. These rights may be subject to limitations in certain situations, such as when we are obligated by applicable laws or Anti-Money Laundering (AML) compliance practices to process your Personal Data.


- Right to access: You are entitled to confirm that your Personal Data is being processed and to receive a copy of it, along with certain information related to its processing.


- Right to rectify: You can request the correction of inaccurate Personal Data and supplement it. Additionally, you have the flexibility to modify your Personal Data in your Account at any time.


- Right to delete: In certain cases, you may request the deletion of your Personal Data.


- Right to object: For reasons related to your specific situation, you can object to the processing of your Personal Data. This right applies, for example, when we rely on legitimate interests or process your Personal Data for direct marketing purposes.


- Right to restrict processing: In specific cases, you have the right to temporarily limit the processing of your Personal Data by us, provided there are valid grounds for doing so. We may continue processing your Personal Data if necessary for legal defense or other reasons permitted by applicable law.


- Right to portability: In certain situations, you can request to receive your Personal Data, provided by you to us, in a structured, commonly used, and machine-readable format. Alternatively, when feasible, we can communicate your Personal Data directly to another data controller on your behalf.


- Right to withdraw consent: For processing requiring your consent, you have the right to withdraw it at any time. This does not affect the lawfulness of processing based on consent before its withdrawal.


Exercising these rights may impact the nature and provision of the services we offer, and in some cases, it may lead to the discontinuation of services and termination of your contractual agreement with us.


We may charge a reasonable fee for handling and processing your requests to access your personal data. If a fee is applicable, we will provide you with a written estimate before proceeding. Please note that we are not obligated to respond to or address your access request unless you agree to pay the associated fee.


COLLECTION OF PERSONAL DATA


You will primarily furnish us with the majority of the personal information we collect. We collect and process your information in the following situations:


(a) When you sign up online, log in, or access NitroEx, or utilize any NitroEx service;


(b) When you voluntarily complete any user survey or provide feedback, whether through email or any other channel;


(c) Through cookies from your browser or software when you use or browse our web pages or clients;


(d) Other instances of self-collecting information as stipulated in this agreement.


Additionally, we may obtain information from public or third-party channels, such as advertising and market research partners, to update or supplement other collected information about you.


USE OF PERSONAL DATA


We may utilize your Personal Data in the following ways:


(a) Compliance with laws and regulations


Many of our services are subject to specific laws and regulations that mandate us to collect, use, and store your Personal Data in prescribed ways. For instance, NitroEx must identify and verify customers using our services to comply with cross-jurisdictional anti-money laundering laws. This involves collecting and storing photos of your ID. Failure to provide the required personal information as mandated by law may result in the closure of your account.


(b) Enforcement of the terms of this agreement


We actively monitor, investigate, prevent, and mitigate potential prohibited or illegal activities, enforce agreements with third parties, and prevent and investigate violations of this Agreement. Additionally, we may need to charge you for your use of our services. We collect information about your account usage and closely monitor your interactions with our services, using any personal information we collected about you for these purposes.


(c) Detection and prevention of fraud and/or loss of funds


We process your personal information to help detect, prevent, and reduce fraud and abuse of our services, ensuring the protection of your account security.


(d) Provision of services


Access to your personal information is necessary to provide you with services. For example, when utilizing the OTC service on our platform, specific information such as your identity, contact details, and payment information is required. Without such information, we cannot furnish you with services. Third parties, such as identity verification service providers, may also collect your personal information when offering identity verification and/or fraud prevention services.


(e) Service communication


We send you management or account-related information to keep you informed about the latest developments in our services, notify you of relevant security issues or updates, or provide other trade-related information. Refusing critical service communications, such as emails or text messages sent for legal or security purposes, is not an option.


(f) Customer service


Access to your personal information is essential when you contact us to resolve any issues. Failure to process your personal information may impede our ability to respond to your request and ensure uninterrupted use of the service.


(g) Ensure network and information security


We process your personal information to enhance security, monitor and verify your identity and access to our services, combat spam or other malicious software or security risks, and comply with applicable security laws and regulations. Timely and accurate information about your use of our services is crucial for ensuring service security. Failure to process your personal information may compromise the security of our services.


(h) Research and development


Access to your personal information is necessary to gain a better understanding of how you use and interact with our services. This information is also used to customize and improve the content and layout of our services and develop further offerings. Failure to process your personal information may impact your continued enjoyment of our services.


(i) Enhancement of your experience


Access to your personal information is employed to provide you with a personalized experience and meet your needs. For instance, allowing us access to specific personal information stored by third parties. Failure to process your personal information may affect your ability to enjoy some or all of our services.


(j) Facilitation of company acquisitions, mergers, or trades


In the event of a corporate acquisition, merger, or other corporate transaction, we may access information about your account and your use of our services. If you do not wish for your personal information to be processed for these purposes, you may choose to close your account.


(k) Engagement in marketing activities


We may send you marketing communications (such as emails or text messages) to inform you about our events or the activities of our partners, provide targeted marketing, and offer promotional offers. Our marketing strategy aligns with your advertising and marketing preferences and is compliant with applicable law. If you do not wish to receive marketing information, please submit a request to our Personal Data Protection Officer at support@nitroex.io.


(l) For any other purpose


We may disclose your personal information for any purpose to which you have given consent.


Notwithstanding the above, we may share your Personal Data with the following persons or entities under specified circumstances:


(a) Affiliates:


Personal information may be transferred between NitroEx companies as part of regular business operations and the provision of services to you.


(b) Third-party service providers:


At NitroEx, we hold a steadfast commitment to safeguarding the privacy and security of our users' data. Unlike many other platforms, we proudly declare that we do not enlist the services of any third-party providers for the collection or distribution of user data.


Our philosophy revolves around transparency, integrity, and user-centric practices. By refraining from engaging with external service providers, we ensure that all user information remains under the direct and secure purview of our internal systems. This decision not only aligns with our core values but also reinforces our dedication to fostering a relationship of trust and accountability with our user community.


The absence of third-party involvement in data handling minimizes the risks associated with potential breaches, unauthorized access, or misuse of information. Users can rest assured that their personal data is treated with the utmost care, and we operate within the strict boundaries of applicable privacy laws and regulations.


At NitroEx, we view user data as a sacred trust, demanding responsible and ethical management. Our deliberate choice to abstain from third-party services underscores our commitment to maintaining the highest standards of privacy, security, and user satisfaction.


As we navigate the evolving landscape of technology and innovation, NitroEx remains resolute in its dedication to controlling and protecting user data. Trust is the cornerstone of our relationship with users, and by keeping data management in-house, we strive to provide a platform that is not only dynamic and efficient but also unwaveringly protective of user privacy.

 


(c) Legal Authorities:


We may be obligated by law or court order to disclose specific information about you or any engagement we may have with you to relevant regulatory, law enforcement, and/or other competent authorities. Information about you may be disclosed to legal authorities in accordance with the law or to enforce our legal rights or prevent fraud.


(d) Business transfers:


As we expand our business, we may acquire or sell other businesses or services. User information generally becomes one of the transferred business assets, subject to the promises made in any pre-existing Privacy Notice (unless, of course, the user consents otherwise). In the unlikely event that NitroEx or substantially all of its assets are acquired by a third party, user information will be one of the transferred assets.


(e) Protection of NitroEx and others:


We release accounts and other personal information when we believe it is appropriate to comply with the law or meet our regulatory obligations, enforce or apply our User Agreement and other agreements, or protect the rights, property, or safety of NitroEx, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.


NitroEx will not provide, sell, lease, share, or trade your personal information with any unrelated third party unless we have obtained your prior consent. NitroEx (including our affiliates) may jointly or individually provide services to you, and after the service concludes, access to such information, including all previously accessible information, will be denied. NitroEx also prohibits third parties from collecting, editing, selling, or distributing your personal information through any means. If any NitroEx user engages in such activities, NitroEx reserves the right to terminate the service agreement immediately.


If you are not a natural person with full capacity for civil rights and civil conduct, you are not authorized to use the service. NitroEx urges you not to provide any of your personal information in such cases.


INFORMATION STORAGE


The information and materials collected about you will be stored on the servers of NitroEx and/or its affiliated companies. It may be transferred to countries, regions, or places outside the country where the information and materials were originally collected by NitroEx. This data may be accessed, stored, and displayed outside the country of origin. By submitting your personal data, you consent to this transfer, storage, and/or processing. Additional details regarding the transfer of personal data and/or information concerning users located in the EU can be found in the section titled "Additional Provisions for EU Users Only."


CROSS-BORDER TRANSFER OF INFORMATION


To facilitate our global operations, NitroEx may transfer your personal information outside of the European Economic Area (“EEA”), which is sometimes referred to as “third country transfers.”


We may transfer your personal information to our affiliates, third-party partners, and service providers worldwide. When intending to transfer personal information to third countries or international organizations outside the EEA, NitroEx implements suitable technical, organizational, and contractual safeguards (including Standard Contractual Clauses) to ensure compliance with applicable data protection rules.


Decisions from the European Commission, recognizing certain countries and territories outside the EEA as providing an adequate level of protection for personal information, are relied upon and referred to as “adequacy decisions.”


COOKIES


Installation of Cookies: When you visit the Platform, Google Stats via Cookies are utilized to record the Platform’s performance and assess the effectiveness of online advertising. Cookies, a small amount of data sent to your browser and stored in your computer hard drive, are only sent when you use your computer to access the Platform.


Function of Cookies: Cookies are commonly used to record the habits and preferences of visitors when browsing various items on the Platform. They collect anonymous collective statistics devoid of Personal Data. Cookies cannot obtain data from your hard drive, email address, or Personal Data. They enable the Platform or a service provider’s system to recognize your web browser and capture and remember information.


Disabling Cookies: Most browsers are set to accept Cookies, and users can choose to reject Cookies or receive notifications upon their installation. However, disabling Cookies may impact the initiation or use of certain features on the Platform. If Cookies are rejected, logging in or using platform services or functions reliant on such Cookies may be affected. This applies to relevant information obtained through cookies set by NitroEx.


INFORMATION SECURITY


Your account is secure and protected; please manage your account and password information carefully. We safeguard your information from loss, abuse, and alteration by storing backups on other servers and encrypting user passwords. Despite these security measures, note that there are no "perfect security measures" on the information network. When using our platform services for online trades, personal information, such as contact details or postal addresses, will be disclosed to the counterparty or potential counterparties. Protect your personal information and provide it only when necessary. If any personal information, especially account and password details, is suspected of being leaked, contact our customer service immediately for appropriate measures.


We retain personal data in line with the Personal Data Protection Act and/or other applicable laws. Personal data will be destroyed or anonymized when it is reasonably determined that (i) the purpose for which the personal data was collected is no longer served by retention; (ii) retention is no longer necessary for legal or business purposes; and (iii) no other legitimate interests warrant further retention. If you cease using our services, we may continue storing, using, and/or disclosing your personal data in accordance with this Privacy Policy and our obligations under the Personal Data Protection Act and/or other applicable laws.


ACCOUNT DELETION


You can delete your NitroEx account at any time; however, the consequences include:


(a) Loss of all digital assets and data within the account.


(b) Inability to recover personal information, transaction records, business data, and historical information under the account.


(c) Inability to use the account for logging into NitroEx’s services.


IMPORTANT


Account deletion is irreversible. To safeguard your rights, we will remind you of the risks after selecting the "Delete Account" button.


Deletion of your account does not absolve or mitigate all account operations and responsibilities before deletion. All records and information linked to your account will be deleted. However, certain account information may be retained as required by applicable law and regulations.



EU-EXCLUSIVE PROVISIONS


The content in this Section is specifically applicable if you are a user situated in the European Union ("EU"). These provisions hold precedence over any conflicting sections in the remainder of this Privacy Policy.


Your Personal Data may be transferred outside the EU. In such instances, we take all necessary precautions to apply suitable safeguards as stipulated by the GDPR. For instance, we have implemented measures such as appropriate contractual clauses to ensure that recipients of such transfers will protect and handle your personal data in accordance with all applicable personal data protection laws.


According to the GDPR, you are entitled to exercise the following rights:


a) The right to access personal information concerning yourself, correct or rectify inaccurate information, and, where applicable, object to data processing;

 

b) The right of erasure of data collected solely based on your consent or data no longer necessary for the purpose(s) for which they were collected;


c) The right to restrict processing when such data are no longer needed for the purpose(s) for which they were collected;


d) The right to receive personal information in a structured, commonly used, and machine-readable format;


e) The right to withdraw consent at any time without detriment, provided the personal data processing is exclusively based on your consent.


CONTACT

Our data protection officer can be reached via email at dataprotect@nitroex.io and will address any questions or concerns you have regarding the collection and processing of your personal information.


NOTICES AND REVISIONS

If you have privacy concerns at NitroEx, please feel free to contact us. We strive to respond to your inquiries as promptly as reasonably possible.


Given that our business undergoes regular changes, our Privacy Notice may also evolve. It is advisable to check our websites frequently for recent updates. Unless explicitly stated otherwise, our current Privacy Notice applies to all information we have about you and your account.


Our Privacy Notice is distinct from the privacy policies of any third parties, such as Trading View or other entities not covered by this Privacy Notice.