Privacy Policy
Xelaro Nexum ("we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our platform, website, and associated services (collectively, the "Service"). Please read this Privacy Policy carefully. By using the Service, you agree to the collection and use of information in accordance with this policy.
1. Information We Collect
1.1 Information You Provide
We collect information that you voluntarily provide when you register for an account, use the Service, or communicate with us, including:
- Account Information: Name, email address, telephone number, date of birth, residential address, and other identifying information;
- Verification Information: Government-issued identification documents, proof of address, photographs, and other information required for identity verification and compliance purposes;
- Financial Information: Bank account details, payment card information, transaction history, and trading activity;
- Profile Information: Username, password, preferences, risk tolerance settings, and other account customisation details;
- Communications: Information contained in messages you send to us, feedback, support enquiries, and survey responses.
1.2 Information Collected Automatically
When you access or use the Service, we automatically collect certain information, including:
- Device Information: IP address, browser type and version, operating system, device identifiers, and mobile network information;
- Usage Information: Pages viewed, features accessed, time and date of visits, time spent on pages, click-stream data, and referring website addresses;
- Location Information: General geographic location based on your IP address;
- Cookies and Similar Technologies: We use cookies, web beacons, and similar tracking technologies to collect information about your browsing activities. For more information, please see our Cookie Policy.
1.3 Information from Third Parties
We may receive information about you from third parties, including:
- Identity verification service providers;
- Cryptocurrency exchanges and wallet providers with which you connect your account;
- Payment processors and financial institutions;
- Analytics providers and advertising networks;
- Publicly available sources and databases.
2. How We Use Your Information
We use the information we collect for various purposes, including:
- Providing the Service: To create and maintain your account, process transactions, execute trades, provide customer support, and deliver the features and functionality of the platform;
- Verification and Security: To verify your identity, prevent fraud, detect and prevent security incidents, and comply with legal and regulatory obligations including anti-money laundering (AML) and know-your-customer (KYC) requirements;
- Communications: To send you technical notices, updates, security alerts, administrative messages, and marketing communications (where you have consented);
- Improvement and Development: To analyse usage patterns, improve the Service, develop new features, and conduct research and analytics;
- Personalisation: To customise your experience, provide relevant content and recommendations, and tailor our communications;
- Legal Compliance: To comply with applicable laws, regulations, legal processes, and governmental requests;
- Protection of Rights: To enforce our Terms of Service, protect our rights and property, and ensure the safety of our users and the public.
3. Legal Basis for Processing (UK GDPR)
Under the UK General Data Protection Regulation (UK GDPR), we process your personal information on the following legal bases:
- Contractual Necessity: Processing is necessary to perform our contract with you and provide the Service;
- Legal Obligation: Processing is necessary to comply with legal and regulatory requirements, including AML, KYC, and financial services regulations;
- Legitimate Interests: Processing is necessary for our legitimate interests in operating, improving, and securing the Service, preventing fraud, and marketing our services, provided such interests are not overridden by your rights;
- Consent: Where you have provided explicit consent, such as for marketing communications or certain data processing activities.
4. How We Share Your Information
We may share your information in the following circumstances:
- Service Providers: With third-party vendors, consultants, and service providers who perform services on our behalf, including payment processors, identity verification providers, hosting providers, analytics providers, and customer support services;
- Cryptocurrency Exchanges: With third-party cryptocurrency exchanges and custodians necessary to execute your trades and manage your digital assets;
- Legal Requirements: When required by law, regulation, legal process, or governmental request, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others;
- Business Transfers: In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business;
- With Your Consent: When you have given us explicit permission to share your information for a specific purpose.
We do not sell your personal information to third parties for their marketing purposes.
5. International Data Transfers
Your information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that differ from the laws of your jurisdiction. When we transfer your information internationally, we implement appropriate safeguards to protect your information in accordance with applicable data protection laws.
6. Data Retention
We retain your personal information for as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When determining retention periods, we consider the nature of the information, the purposes for which it was collected, legal and regulatory requirements, and our legitimate business interests.
Generally, we retain account information for the duration of your relationship with us and for a period thereafter as required for legal, regulatory, tax, and audit purposes. In some cases, we may be required to retain certain information for up to seven years or longer following account closure.
7. Your Rights and Choices
Subject to applicable law, you have the following rights regarding your personal information:
- Access: You may request access to the personal information we hold about you;
- Rectification: You may request that we correct inaccurate or incomplete information;
- Erasure: You may request deletion of your personal information in certain circumstances;
- Restriction: You may request that we restrict processing of your information in certain circumstances;
- Portability: You may request a copy of your information in a structured, commonly used, machine-readable format;
- Objection: You may object to processing of your information based on legitimate interests or for direct marketing purposes;
- Withdraw Consent: Where processing is based on consent, you may withdraw your consent at any time;
- Lodge a Complaint: You have the right to lodge a complaint with the Information Commissioner's Office (ICO) or other applicable supervisory authority.
To exercise these rights, please contact us using the details provided at the end of this policy. Please note that certain rights may be subject to limitations and exceptions under applicable law, and we may need to verify your identity before responding to your request.
8. Security
We implement appropriate technical and organisational measures designed to protect your personal information against unauthorised access, alteration, disclosure, or destruction. These measures include encryption, access controls, secure servers, regular security assessments, and employee training.
However, no method of transmission over the internet or electronic storage is completely secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for any activities that occur under your account.
9. Third-Party Links and Services
The Service may contain links to third-party websites, applications, or services that are not operated by us. This Privacy Policy does not apply to such third-party services. We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party services before providing them with your information.
10. Children's Privacy
The Service is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child without parental consent, we will take steps to delete that information.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the updated policy on our website and updating the "Last updated" date. Your continued use of the Service following the posting of changes constitutes your acceptance of such changes.
12. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us through the contact information provided on our website at xelaro-nexum-ai.com.
For data protection enquiries, you may also write to our Data Protection Officer at the address provided on our website.