Privacy Policy

INTRODUCTION

Welcome to EADX privacy policy (this “Privacy Policy”).

EADX, gizliliğinize saygı duyar ve kişisel bilgilerinizi veya başka bir deyişle “kişisel verilerinizi” korumayı taahhüt eder. Bu bağlamda EADX, EADX.com (önceden hesap kaydına tabi olmak kaydıyla) EADX.com ( web) veya mobil uygulamalarımız veya EADX tarafından Site ile ilgili olarak sağlanan herhangi bir uygulama programlama arayüzü (API) aracılığıyla erişilebilir. Platform, diğer yatırımcıların açık emirleri ile alım satım işlemlerini otomatik olarak eşleştirir, Platform üzerinden sunulan eşleştirme ve alım satım hizmetlerine ek olarak, Platform, kayıtlı hesap kullanıcılarına dijital cüzdan hizmetleri de sunarak, işlem gören sanal finansal varlıkları saklamalarına olanak tanır. Platformu.

This Privacy Policy explains how information about you is collected, used, and disclosed by EADX and to set out the basis on which we will process your personal data when you:

  • visit and use the Site and/or the Platform (regardless of where you visit or use them from);
  • apply for and open an account in respect of our Platform (your “Account”); and
  • apply for, receive or use any of the related services that we offer in connection with the Platform, including our virtual financial assets exchange and digital wallet services (the “Services”).

This includes any data that you may provide for and in relation to our newsletters, updates, events and other marketing and promotional communications.

This Privacy Policy also informs you about: (i) how we will handle and look after your personal data, (ii) our obligations in regard to processing your personal data responsibly and securely, (iii) your data protection rights as a data subject, and (iv) how the law protects you. It should be read in conjunction with our IP Address and Cookie Policy which is available at https://EADX.zendesk.com

KEY DEFINITIONS

Set out below are key definitions of certain data protection terms which appear in this Privacy Policy.

Consent Form

refers to separate documents which we might from time to time provide you where we ask for your explicit consent for any processing which is not for purposes set out in this Privacy Policy.

Data subjects

means living individuals (i.e. natural persons) about whom we collect and process personal data.

Data controller

or “controller” means any entity or individual who determines the purposes for which, and the manner in which, any personal data is processed.

Data processor

or “processor” means any entity or individual that processes data on our behalf and on our instructions (we being the data controller).

Personal data

means data relating to a living individual (i.e. natural person) who can be identified from the data (information) we hold or possess. This includes, but is not limited to, your name and surname (including maiden name where applicable), address, date of birth, nationality, gender, civil status, tax status, identity card number & passport number, contact details (including mobile and home phone number and personal email address), photographic image, bank account details, emergency contact information as well as online identifiers. The term “personal information”, where and when used in this Privacy Policy, shall be taken have the same meaning as personal data.

Processing

means any activity that involves use of personal data. It includes collecting, recording or holding the data, or carrying out any operation or set of operations on the data including, organising, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting, erasing or destroying it. Processing also includes transferring personal data to third parties.

Sensitive personal data

“sensitive data” or “special categories of personal data” includes information about a person's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, genetics and genetics-related aspects, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings, or the conviction or the sentence of any court in such proceedings. This type of sensitive data can only be processed under strict conditions set forth in articles 9 and 10 of the GDPR.

Note that personal data does not include information relating to a legal person (for example, a company or other legal entity). In that regard, information such as a company name, its company number, registered address and VAT number does not amount to personal data in terms of both the Act and the GDPR. Therefore, the collection and use of information strictly pertaining to a legal person does not give rise to data controller obligations at law. Naturally, we will still treat any and all such information in a confidential and secure manner.

THE PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified (as stated above). It does not include data where the identity has been removed and is not relatable to an identified or identifiable person (anonymous data). In the course of your relationship with us (including during the account opening stage), we may collect, use, store and transfer different kinds of personal data about you which we have grouped together.

We collect information you provide directly to us. For example, we collect information when you create an account, participate in any interactive feature of the Services, fill out a form, participate in a community or forum discussion, complete an exchange transaction, apply for a job at EADX, request customer support or otherwise communicate with us. The types of information we may collect include your name, date of birth, email address, postal address, phone number, certain virtual financial asset information, and, in addition any further information you choose to provide. Only personal information necessary for carrying out and performing our tasks and services, or made available by you on a voluntary basis, is collected.

For avoidance of doubt, categories marked in blue are applicable to customers (i.e. individuals who hold a registered customer account with us). We shall request this information in order to be able to register you on our Platform.

Identity Data includes your first name, maiden name (where applicable), last name, address, username or similar identifier, marital status, title, nationality, date of birth, gender, photograph, identity card and/or passport number. This will form part of your account information on the Platform.

Contact Data includes your billing address, email address and contact number (telephone and/or mobile).

Financial Data includes your bank account and payment details.

AML / KYC Data includes the following due diligence / KYC information and documentation about you: (i) copy of valid I.D. card or passport, (ii) proof of residence (e.g. confirmation of identity), (iii) KYC database checks, (iv) fraud database checks and (v) any documentation or information which we may, from time to time:

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

The categories of personal data marked in green below are applicable to customers holding a registered account with us who start trading over the Platform and otherwise make use of our Services, thus coming in addition to the data categories marked in blue above.

In accordance with the relevant legal obligations, AML / KYC Data will be stored until ten years after the termination of the customer relationship. The storage’s purpose is based on ensuring the operability of the system, ensuring the performance of the transactions on the Platform, the compliance with the legal duties concerning KYC/AML/due diligence duties.

Transaction Data includes details about:

Portfolio Data includes details about the virtual financial assets and amounts credited to your Account and your Account balances.

Enhanced KYC Data applies in respect of instances mandated by our AML-KYC Policy, which would include, amongst other scenarios, situations where a higher risk of money laundering and funding of terrorism has been identified.

The storage’s purpose is based on ensuring the operability of the system, ensuring the performance of the transactions on the Platform, the compliance with the legal duties concerning KYC/AML/due diligence duties, and to maintain the integrity of the system.

HOW IS YOUR PERSONAL DATA COLLECTED?

  1. Account Registration and Opening. We will ask you to provide us with your Identity, Contact, Financial and AML/KYC Data when you apply to register and open an account with us on our Platform (including at account finalisation stage). You provide these personal details and information to us, which we collect and process, when you fill in and submit our application form (together with other related forms), and complete our required application steps.
  2. Service Use. This encompasses all of the data categories listed in Section 3 (namely, Identity, Contact, Financial, AML and KYC Data, Marketing and Communication Data; Enhanced KYC Data, Portfolio Data, and Transaction Data).
  3. Direct Interactions. You may also give us your Identity, Contact, Financial, AML/KYC Data, Marketing and Communications Data, and Transaction Data by filling in our other forms (i.e. separate to our account opening and registration form), or by corresponding with us by post, phone, e-mail or otherwise. This includes personal data that you provide when you, as applicable:
    • apply to open an account;
    • update or edit your account details;
    • subscribe to our Platform;
    • request withdrawals from your Account;
    • contact us with complaints or queries;
    • report issues;
    • submit the (additional or supplementary) AML / KYC Data that we may request from you;
    • request marketing to be sent to you;
    • participate in a survey; or
    • provide us with feedback.

Automated Technologies or Interactions. As you interact with the Platform and the Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns (please see the bullet point “Technical/LOG Data” for the relevant information that is collected and processed). We collect this personal data by using cookies, server logs and other similar technologies.

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that choosing to remove or reject cookies could affect the availability and functionality of our Services.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when Liechtenstein law allows us to. Most commonly, we will use our personal data in the following circumstances:

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out above.

  • External third parties.
  • Suppliers and external agencies that we engage to process information on our and/or your behalf, including to provide you with the information and/or materials that you have requested.
  • Our subsidiaries, associates and agents where necessary to facilitate your relationship with us.
  • Professional advisers such as consultants, bankers, professional indemnity insurers, brokers and auditors.
  • Other organisations where exchange of information is for the purpose of fraud protection or credit risk reduction.
  • Debt recovery agencies who assist us with the recovery of debts owed to us.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets (successors in title). Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way and for the same purposes as set out in this Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law (including applicable data protection and privacy law). We do not allow our third party business partners or service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our documented instructions. Furthermore, these third parties access and process your data on the basis of strict confidentiality and subject to the appropriate security measures and safeguards.