1. Purpose

XEX protects your privacy. You will be able to feel confident when you entrust us with your personal data. Therefore, we have established this policy. It is based on current data protection legislation and clarifies how we work to safeguard your rights and integrity. The purpose of this policy is to tell you how we treat your personal data, what we use it for, who will get to access to it and under what pre-requisites, and how you can exercise your rights.

XEX is a platform owned by LONDON CRYPTOASSETS EXCHANGE LTD, 3003 Talisman Tower 6 Lincoln Plaza, London, United Kingdom, E14 9BP

The principles apply if a customer uses, has used or has expressed an intention to use, or otherwise is associated with, any of the services provided by  XEX , including such conditions established before the Policy entered into force.

2. Acceptance of Privacy Policy

By accessing and using our Services, you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. XEX may provide additional "just-in-time" disclosures or additional information about the data collection, use and sharing practices of specific Services. These notices may supplement or clarify XEX privacy practices or may provide you with additional choices about how XEX processes your data. The principles apply if a customer uses, has used or has expressed an intention to use, or otherwise is associated with, any of the services provided by XEX, including such conditions established before the Policy entered into force. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.

3. General Provision

3.1 This policy describes overall how  XEX processes Personal Data. Specific information about the processing of Personal Data may also be disclosed in agreements and other documents related to Euronordic's services.

3.2  XEX Asecures, within the applicable law, the privacy of Personal Data and has appropriate technical and organizational measures to protect Personal Data from unauthorized access, illegal processing or clearing of information, accidental loss, alteration or destruction.

3.3   XEX uses personal data advisory services for the processing of Personal Data, or transmits Personal Data to other recipients. In these cases,  XEX takes exceptional measures to ensure that personal data advisers handle Personal Data according to  XEX's instructions, in accordance with applicable law and require adequate security measures.

4. Changes Of Privacy Policy

We reserve the right to modify this Privacy Policy at any time, and when required by law, we will notify you of changes to this Privacy Policy. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on our Services prior to the change becoming effective.

5. We Collect No Personal Information Using Our Applications

“We do not collect, use, save, or have access to any of your personal data recorded in XEX app.

“Individual settings relating to the XEX apps are not personal and are stored only on your device. We don’t process any information in your device at all and have no access to it.

6. What Personal Data XEX Collects?

“Personal Data” means data that allows someone to identify or contact you. For example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with your account.

Collected Personal Data:

- email address

- name

- gender

- date of birth

- home address

- phone number

- country

- city

- nationality

- device ID

- IP address

- transaction information

- bank details

- ID or driver license ( for KYC )

We collect and process identity information and Sensitive Personal Data to comply with our Know Your Customer (“KYC”) obligations under applicable laws and regulations, and Anti-Money Laundering laws and regulations.

7. Age Restriction

XEX does not allow anyone under the age of 18 to use Our Services. If a user submitting Personal Data is suspected of being younger than 18 years of age, we will require the user to close his or her account. We will also take steps to delete the Personal Data as soon as possible

8. Security Of Personal Data

Information about our users is an important part of our business and we are not in the business of selling our users' personal information to others.

We use a variety of security measures to ensure the confidentiality of your Personal Data and to protect your personal Data from loss, unauthorized access or destruction. We use firewalls and data encryption, we enforce physical access controls to our buildings and files.

When registering to use our Services, it is important to choose a password of sufficient length and keep this password a secret. Please notify us immediately if you become aware of any unauthorized access to or use of your account.

9. How Long XEX Keeps Personal Information?

We keep your personal information to enable your continued use of XEX Services, for as long as it is required in order to fulfill the relevant purposes described in this Privacy Notice, and as may be required by law such as for tax and accounting purposes, compliance with Anti-Money Laundering laws, or as otherwise communicated to you.

Except where prohibited by law, this period may extend beyond the end of your relationship with for so long as is necessary for audit or other accounting or regulatory purposes. When Personal Data are no longer needed we have procedures either to destroy, delete, erase or convert it to an anonymous form.

After you have terminated your use of our Services, we reserve the right to maintain your Personal Data as part of our standard back up procedures in an aggregated format.

10. Why We Use Cookies?

10.1 What are cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to allow websites to work properly or more efficiently, as well as to provide information to the owners of the website.

There are two general categories of cookies. “First-party cookies” cookies are set directly by us. “Third-party cookies” are set by a third party, and that third party can recognize your computer both when it visits the Sites and when it visits certain other websites and/or mobile apps.

Cookies can remain on your computer or mobile device for different periods of time. Some cookies are “session cookies”, which exist only while your browser is open and expire once you close your browser. Other cookies are “persistent cookies”, which survive after your browser is closed. They can be used by websites to recognize your computer when you open your browser and browse the internet again.

10.2 Why we use cookies

We use cookies and similar tools to enhance your user experience, provide our services, and understand how customers use our services so we can make improvements. Depending on applicable laws in the region you are located in, the cookie banner on your browser will tell you how to accept or refuse cookies.

10.3 Cookies types we use

a) Strictly Necessary Cookies: These cookies are necessary because they enable you to move around our Sites and use certain features on our Services. For example, strictly necessary cookies allow you to access secure areas. Without these cookies, some Services cannot be provided.

b) Functionality Cookies: These cookies allow us to remember the choices you make and to tailor our Services so we can provide relevant content to you. For example, a functionality cookie can remember your preferences (e.g., country or language selection), or your username.

c) Performance/Analytics Cookies: These cookies collect information about how you use a website. For example, a performance/analytics cookie will collect information about which pages you go to most often, how much time you spend on that page, or if you get error messages from certain pages. These cookies do not gather information that identifies you. The information these cookies collect is anonymous and is only used to improve how our Services work.

11. Geographical Area For Personal Data Processing

In general, Personal Data is processed within the European Union / European Economic Area (EU / EEA), but may in some cases be transferred and processed in non-EU / EEA countries.

The transfer and processing of personal data outside the EU / EEA may occur if there is a legal basis, i.e. according to a legal obligation or the Customer's consent and that appropriate safeguards are available.

Appropriate safeguards are to:

a.     There is an on-the-spot agreement that includes EU standard agreement clauses or  other approved clauses, codes of conduct, certifications, etc. approved in accordance with the General Data Protection Regulation (GDPR).

b.     The country outside the EU / EEA where the recipient is located has an appropriate level of data protection established as determined by the EU Commission.

c.     The recipient is certified in accordance with Privacy Shield (applicable to recipients in the United States).

Upon request, the Customer may receive further information about the transfer of Personal Data to countries outside the EU / EEA.

12. Storage Periods