Privacy Policy

This Privacy Policy describes how our site collects and processes your personal information through the websites and applications that reference this Privacy Policy and adherence to the regulatory requirements including the General Data Protection Regulation (“GDPR”) as enacted by the European Commission If you do not agree with this Privacy Policy, in general, or any part of it, you should not use the Services. This Privacy Policy is periodically reviewed to ensure that any new obligations and changes to our business model are taken into consideration. We may amend this Privacy Policy at any time by posting an amended version on our website.

This Privacy Policy applies to all platforms, websites, and departments of our site including Operators. By using our Services, you are consenting to the collection, storage, processing and transfer of your personal information as described in this Privacy Policy.

SpireX recognizes the paramount significance of protecting information which is stored on our servers or network and the protection of “Personal Data” which is any information which can identify a natural person. This Privacy Policy advises you how we gather and use Personal Data and circumstances under which such data is disclosed to third parties.

By using our services, you confirm your agreement to our Privacy Policy. We reserve the right to change or amend this Policy at any time and you are encouraged to check this page frequently to see any updates or changes.

For the purposes of applicable state and/or international data protection laws, the respective SPIREX Entity with whom you have registered is the“controller”of personal information collected through the website www.spirex.io, other websites, widgets, mobile applications (including the SPIREX App) and other platforms (together the“Site”), and please contact the Company if you have any questions about the use of your personal information (see the “Contact Us” section below). This Policy also applies to personal data about each authorized representative of a client and about other persons or entities where any personal data is collected in the course of providing the Services (such as directors of corporate clients)

1. What Personal Information does our site collect and process?

When you access our site or use our services, we collect the following information;

Information you may provide to us includes information you provide by completing a form listed on our website or app or corresponding with us via any means.

The following information is collected as required by Law, Rule or Regulation:

email address;
name;
gender;
date of birth;
home address;
phone number;
nationality;
country code
information that helps us identify your identity

On each occasion you visit our website or app, the following information is automatically collected by us:

the Internet Protocol (IP) address used to connect your computer to the Internet. This is to collect sufficient information to determine whether an attempt is made to fake a current location by the use of VPN spoofing or other tools;
login, e-mail address, browser, version used and time settings, address used to create the wallet, and location of your device or computer;
our services metrics (e.g., the occurrences of technical errors, your interactions with service features and content, and your settings preferences);
4. transactional information and transaction history regarding transactions that you effect in your wallet;

Information we collect from other sources. For example, amongst other things,we may receive information about you from other sources such as credit history information from credit bureaus, banks or payment processors used for transferring fiat currency may provide us with basic Personal Data such as your name, address and bank account.

Some of the information we collect from you upon installation of the mobile app will be shared by us with vendors and other service providers who are engaged by, or working with, us in connection with operating and analyzing the Services we provide to you.

2. Can Children Use Services Provided by Our Site?

Our site does not allow anyone under the age of 18, or the age of maturity in your jurisdiction, to use our services.

3. Why does our site process your personal information?

We use your Personal Data to:

provide better transaction services, to process your orders, and to communicate with you about orders and services.
communicate with you in relation to our site’s services.
comply with applicable laws and regulations.
provide, troubleshoot, enhance, develop and improve our services. We use your personal information to provide functionality, analyse performance, fix errors, and improve the usability and effectiveness of our sites services.
process personal information to prevent and detect fraud and abuse in order to protect the security of our users. We may also use scoring methods to assess and manage credit risks.
improve our services and operations to enable you to have a better user experience.
use your personal information to recommend features and services that might be of interest to you, identify your preferences, and personalise your experience with our services.

We will not use your Personal Data outside of the purposes described.

4. Cookies and Other Identifiers?

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 in, the cookie banner on your browser will tell you how to accept or refuse cookies.

We use Cookies and similar tools to provide services, such as to:

Identify the user when you are logging in and using our services
Provide personalized function and services
Advertising
Prevention of fraudulent activities
Improving security
Know your preferences

7. know how users use our services in order to improve our services by using third party web analytics. These third parties may use first party cookies to track users interaction and use of our site and compile reports to improve our site. You can opt out of such third party analytic tools without affecting how you interact with the site. To opt out please contact [email protected]

5. Does Our Site Share Your Personal Information?

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. Our site shares users” personal information only as described below and with the subsidiaries or affiliates of our site that are either subject to this Privacy Notice or follow practices at least as protective as those described in this Privacy Notice.

Third party service providers: We employ other companies and individuals to perform functions on our behalf. Examples include analysing data, providing marketing assistance, processing payments, transmitting content, and assessing and managing credit risk. These third-party service providers only have access to personal information needed to perform their functions, but may not use it for other purposes. Further, they must process the personal information in accordance with our contractual agreements and only as permitted by applicable data protection laws.

Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to any pre-existing Privacy Notice (unless, of course, the user consents otherwise).

Protection of our site and others: We release account and other personal information when we believe release is appropriate to comply with the law or with our regulatory obligations; enforce or apply our Terms of Use and other agreements; or protect the rights, property or safety of our site, our users or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction.

Any third party, including government or enforcement agency seeking access to Personal Data we hold will be required to produce a court order or equivalent proof to confirm they are legally authorized to access your data and their request is valid and within statutory or regulatory power.

Because some transactional information may be recorded on a public blockchain, they are open to forensic analysis and this can result in deanonymization and unintentional private financial information being revealed. Furthermore, because blockchains are decentralized or third party networks, the Company cannot erase, alter or modify Personal Data from such networks.

6. How Secure is Your Personal Data?

We design our systems with your security and privacy in mind. We work to protect the security of your personal information during transmission by using encryption protocols and software.

We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personal information. Our security procedures mean that we may ask you to verify your identity to protect you against unauthorised access to your account password. We recommend using a unique password for your account that is not utilized for other online accounts and to log outwhen you finish using a shared computer.

7. What About Advertising?

In order for us to provide you the best user experience, we may share your personal information with our marketing partners for the purposes of targeting, modelling, and/or analytics as well as marketing and advertising. You may opt-out of sharing personal information with our marketing partners by contacting [email protected]

8. What Information Can I Access?

You can access your information, including your name, address, payment options, profile information, and transaction history by reaching out to our support team.

9. What Rights Do I Have?

If you have any questions or objection as to how we collect and process your personal information, please contact our customer support.

When you consent to us processing your personal information for a specified purpose, you may withdraw your consent at any time.

In addition, subject to applicable law, you have the right to request access to, correct, and delete your personal data, and to ask for data portability. You may also object to our processing of your personal data or ask that we restrict the processing of your personal data in certain instances, by contacting our customer support.

Right to access: you have the right to obtain confirmation of what information we process and to obtain a copy of it as well as certain information related to. We will provide you with a copy of that information within 30 days of receiving your request.

its processing. (Art. 15 GDPR)

Right to rectify: you can request the rectification of your data which is

inaccurate, and add to it. You can also change your personal information in

your account at any time to ensure it remains complete and up-to-date. To proceed with such rectification requests we may require supporting documentation from you as proof and which we are required to keep for legal and/or regulatory purposes. (Art. 16 GDPR)

Right to delete: you can, in some cases, request to have your data deleted provided we have to legal or regulatory obligation to retain that data. Requests will be subject to any agreements you have with us and any legal retention limits we are required to comply with (Art. 17 GDPR)
Right to object: you can object to the processing of your Personal Data. For instance, you have the right to object to the processing of your Personal Data for direct marketing. (Art. 21 GDPR)
Right to limit the processing: in certain circumstances, such as if you contest the accuracy of that Personal Data, you have the right to limit the processing of your Data. This does not stop us from storing your Personal Data. (Art. 18 GDPR)
Right to portability: in some cases, you can ask to receive your data which

you have provided to us in a structured, commonly used and

machine-readable format, or, when this is possible, that we communicate and transfer your data on your behalf directly to another third party data controller. (Art. 20 GDPR)

Right to withdraw your consent: for processing requiring your consent, you have the right to withdraw your consent at any time. Exercising this right does not affect the lawfulness of the processing based on the consent given before the withdrawal of the latter. (Art. 7(3) GDPR)
Right to define the instructions relating to the use of your personal data post mortem: you have the right to define instructions relating to the

retention, deletion and communication of your Personal Data after your death. (Art. 6(1) GDPR)

Right to lodge complaint to the relevant data protection authority. (Art. 77 GDPR)

10. Questions and Complaints

If you are interested in exercising any of the rights, outlined in clause 9 above, (or confirming whether they apply to our processing of your personal data), you can log into your account or contact us. Any such request should be submitted to: [email protected]. If you have a concern about our processing of your personal data which we are not able to resolve, you may have the right to lodge a complaint with the relevant data protection supervisory authority where you reside. As noted above, even where such rights apply, they are subject to limits. This means that, in certain circumstances, we may not be required or be able to satisfy your request in full, or we may only be able to satisfy your request in part.

11. How Long Does Our Site Keep Your Personal Data?

We keep your personal information to enable your continued use of our sites services for as long as it is required in order to fulfil the relevant purposes described in this Privacy Policy, 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. After you have terminated the 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.

12. Promotional Communications

You may opt out of receiving promotional emails or text messages from SpireX by following the instructions in those emails or text messages or by visiting the “Notifications” tab in the “Settings” menu on our platform. If you opt out, we may still send you non-promotional emails, such as service messages about your SpireX Account or our ongoing business relationship with you.

13. Links

The Site may include links to other websites on the internet. We are not responsible for the content of such websites or for any privacy practices of such websites. You should read the terms of use and the privacy statements of any such websites. Our terms of use and our Privacy Policy apply only to information collected by us in accordance with this Policy.

14. Conditions of Use, Notices and Revisions

If you choose to use our services, your use and any dispute over privacy is subject to this Privacy Policy and our Terms of Use. If you have any concerns about privacy at our site, please contact us with a thorough description, and we will try to resolve it. All questions and complaints should be redirected to [email protected] in the first instance. You also have the right to contact your local Data Protection Authority if you believe we have violated any data protection laws.