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Introduction As part of our normal daily business
operations, we collect personal information from our clients and
prospective clients in order to provide them with our products and
services, and ensure that we can meet their needs when providing these
products and services, including providing information as part of the
service. Your privacy is of utmost importance to us and it is our policy
to safeguard and respect the confidentiality of information and the
privacy of individuals. This Privacy Policy (hereinafter as 'Privacy
Policy', 'Privacy Notice', 'Policy', or 'Notice', as used
interchangeably) sets out how fiat services provided by MEXC Estonia OÜ
(registration number: 14832615) having its registered office at Harju
county, Tallinn, Kristiine district, Keemia Tn 4, 10616 ), collects,
uses and manages the personal information we receive from you, or a
third party, in connection with our provision of services to you have
requested for or which we collect from your use of our services and/or
our website. The Privacy Notice also informs you of your rights with
respect to the processing of your personal information. Use of the words
“The Company” “we,” “us,” or “our” refer to MEXC Estonia OÜ. Our Privacy
Notice is reviewed regularly to ensure that any new obligations and
technologies, as well as any changes to our business operations and
practices are taken into consideration, as well as that it remains
abreast of the changing regulatory environment. Any personal information
we hold would be governed by our most recent Privacy Notice. Please note
that if you are an employee of the Company, a contractor to the Company
or a third-party provider, your personal information would be used in
connection with your employment contract or your contractual
relationship, whichever applies. This Privacy Notice applies to the
processing activities performed by MEXC Estonia OÜ to the personal
information of its clients and its potential clients and website
visitors. We reserve the right to amend this Privacy Notice at any time
by posting the amended version on this site including the effective date
of the amended version. We shall post any material change to this
Privacy Notice on our website.
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How do we protect personal information? The Company
respects the privacy of any user who access its website and it is
therefore committed to taking reasonable steps to safeguard any existing
or prospective clients, applicants and website visitors. The Company
keeps any personal data of its clients and its potential clients in
accordance with the applicable privacy and data protection laws and
regulations. We have the necessary and appropriate technical and
organisational measures and procedures in place to ensure that your
information remains secure at all times in line with the industry
standard. We conduct periodic training and raise awareness for all our
employees to the importance of maintaining, safeguarding and respecting
your personal information and privacy. We regard breaches of
individuals’ privacy very seriously and would impose appropriate
disciplinary measures, including dismissal from employment. We have also
appointed appropriate personnel to ensure that our Company manages and
processes your personal information in compliance with the applicable
privacy and data protection laws and regulations, and in accordance with
this Privacy Notice. The personal information that you provide us with
when applying to open an account, applying for a role within the
Company, or when using our website, is classified as registered
information, which is protected in several ways. You can access your
registered information after logging in to your account by entering your
username and the password that you have selected. It is your
responsibility to make sure that your password is only known to you and
not disclosed to anyone else. Registered information is securely stored
in a safe location, and only authorised personnel have access to it via
a username and password. All personal information is transferred to the
Company over a secure connection, and thus all reasonable measures are
taken to prevent unauthorised parties from viewing any such information.
Personal information provided to the Company that does not classify as
registered information is also kept in a safe environment and accessible
by authorised personnel only through username and password.
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Information we may collect about you In order to open
an account with us, you must first complete and submit a “create
account” form to us by completing the required information. By
completing this form, you are deemed to consent to disclose personal
information in order to enable the Company to assess your application
and comply with the relevant laws (including their regulations). The
information that we collect from you is as follows (on an
'as-applicable' basis): 1) Full name, current residential address and
contact details (e.g. email address, telephone number, etc.); 2) Date of
birth, place of birth, gender, citizenship; 3) Bank account information,
credit card details, including details about your source of funds,
assets and liabilities, and Office of Foreign Assets Control (OFAC)
information; 4) Trading account balances, trading activity, your
inquiries and our responses; Information on whether you hold a prominent
public function such as Politically Exposed Persons (PEP); 5)
Verification information, which includes information necessary to verify
your identity such as a passport, driver’s licence or Government-issued
identity card; 6) Other Personal Information or commercial and/or
identification information – Any information we, in our sole discretion,
deemed necessary to comply with our legal obligations under various
anti-money laundering Anti Money Laundering (AML) obligations, such as
under the European Union’s appropriate AML Directive. Certain
information we collect about you are done automatically, such as 1)
Browser Information – Information that is automatically collected via
analytics systems providers from your browser, including your IP address
and/or domain name and any external page that referred you to us, your
login information, browser type and version, time zone setting, browser
plug-in types and versions, operating system, and platform; 2) Log
Information – Information that is generated by your use of services
provided by MEXC Estonia OÜ that is automatically collected and stored
in our server logs. This may include, but is not limited to,
device-specific information, location information, system activity and
any internal and external information related to pages that you visit,
including the full Uniform Resource Locators (URL) clickstream to,
through and from our Website or App (including date and time; page
response times, download errors, length of visits to certain pages, page
interaction information (such as scrolling, clicks, and mouse-overs),
and methods used to browse away from the page; Information we receive
about you from other sources. We may obtain information about you
through your usage of our services, including through any of our
websites, the account opening process, webinar sign-up forms, event
subscribing, news and updates subscribing, and from information provided
in the course of on-going support service communications. We may also
receive information about you from third parties such as your payment
providers, payment channels, and through publicly available sources. For
example: 1) The banks you use to transfer money to us would provide us
with your basic personal information, such as your name and address, as
well as your financial information such as your bank account details; 2)
Your business partners may provide us with your name and address, as
well as financial information; 3) Advertising networks, analytics
providers and search information providers may provide us with
anonymized or de-identified information about you, such as confirming
how you found our website; 4) Credit reference agencies do not provide
us with any personal information about you but may be used to
corroborate the information you have provided to us.
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Disclosure of your personal information The Company
would not disclose any of its clients’ confidential information to a
third party, except: (a) to the extent that it is required to do so
pursuant to any applicable laws, rules or regulations; (b) if there is a
duty to disclose; (c) if our legitimate business interests require
disclosure; (d) in line with our Terms of Service; (e) at your request
or with your consent or to those described in this Privacy Notice. The
Company would endeavour to make such disclosures on a “need-to-know”
basis, unless otherwise instructed by a regulatory authority. Under such
circumstances, the Company would notify the third party regarding the
confidential nature of any such information. As part of using your
personal information for the purposes set out above, the Company may
disclose your personal information to the following: 1) Any members of
the Company, which means that any of our affiliates and subsidiaries may
receive such information; 2) Any of our service providers and business
partners, for business purposes, such as specialist advisors who have
been contracted to provide us with administrative, financial, legal,
tax, compliance, insurance, IT, debt-recovery, analytics, research or
other services; If the Company may be required to disclose your personal
information to service providers and business partners in order to
perform the services requested by you as our client, such providers and
partners may store your personal information within their own systems in
order to comply with their legal and other obligations. We require that
service providers and business partners who process personal information
to acknowledge the confidentiality of this information, undertake to
respect any client’s right to privacy and comply with all relevant
privacy and data protection laws and this Privacy Notice.
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Where we store your personal data Our operations are
supported by a network of computers, servers, and other infrastructure
and information technology, including, but not limited to, third-party
service providers. We and our third-party service providers and business
partners store and process your personal data in, including, but not
limited to, the European Union (including Estonia) and the United
Kingdom.
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Transfers of personal information outside of the European Economic
Area (EEA) and the United Kingdom (UK)
We may transfer your personal information outside the EEA and UK to
other Company subsidiaries, service providers and business partners (i.e
Data Processors) who are engaged on our behalf. To the extent that we
transfer your personal information outside of the EEA and UK, we would
ensure that the transfer is lawful and that any such Data Processor in
these jurisdictions are obliged to comply with the applicable European
Union (EU) General Data Protection Regulation and the UK Data Protection
Act 2018. If transfers of personal information are processed in the US,
we may in some cases rely on standard contractual clauses.
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Transfers of Personal Information outside of your country
By using our products and services, you consent to your Personal Data
being transferred to other countries, including countries that have
differing levels of privacy and data protection laws than your country.
In all such transfers, we would protect your personal information as
described in this Privacy Notice, and ensure that appropriate
information sharing contractual agreements are in place.
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Privacy when using digital assets and blockchains Your
funding of bitcoin, MX, ether, and other Digital Assets, may be recorded
on a public blockchain. Public blockchains are distributed ledgers,
intended to immutably record transactions across wide networks of
computer systems. Many blockchains are open to forensic analysis which
can lead to deanonymization and the unintentional revelation of private
financial information, especially when blockchain data is combined with
other data. As blockchains are decentralized or third-party networks
which are not controlled or operated by us or our affiliates, we are not
able to erase, modify or alter personal data from such networks.
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Data Retention Safeguarding the privacy of your
personal information is of utmost importance to us, whether you interact
with us personally, by phone, by email, over the internet or any other
electronic medium. We would hold personal information, for as long as we
have a business relationship with you, in secure computer storage
facilities, and we take the reasonable and necessary measures to protect
the personal information we hold from misuse, loss, unauthorised access,
modification or disclosure. When we consider that personal information
is no longer necessary for the purpose for which it was collected, we
would remove any details that would identify you or we would securely
destroy the records. However, we may need to maintain records for a
significant period of time (after you cease being our client). For
example, we are subjected to anti-money laundering regulations which may
require us to retain the following, for a certain period of up to 5
years after our business relationship with you has ended or other
periods as directed by a regulator: 1) A copy of the records we used in
order to comply with our client due diligence obligations; 2) Supporting
evidence and records of transactions with you and your relationship with
us. Also, the personal information we hold in the form of a recorded
information, by telephone, electronically or otherwise, would be held in
accordance with applicable local regulatory requirements (i.e. 5 years
after our business relationship with you has ended or longer if you have
legitimate interests (such as handling a dispute with you)). If you have
opted out of receiving marketing communications we would hold your
details on our suppression list so that we know you do not want to
receive these communications. We may keep your data for longer than 5
years if we cannot delete it for legal, regulatory, or technical
reasons.
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Cookies When you use our products and services, we may
make use of the standard practice of placing tiny data files called
cookies, flash cookies, pixel tags, or other tracking tools (herein,
“Cookies”) on your computer or other devices used when engaging with us.
We use Cookies to (i) help us recognize you as a customer, collect
information about your use of our products and services, to better
customize our services and content for you, and to collect information
about your computer or other access devices to ensure our compliance
with our BSA and AML obligations.
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Your rights regarding your personal information The
rights that are available to you in relation to the personal information
we hold about you are outlined below.
Information Access
If you ask us, we would confirm whether we are processing your personal
information and, if so, what information we process and, if requested,
provide you with a copy of that information within 30 days from the date
of your request.
Rectification
It is important to us that your personal information is up to date. We
would take all reasonable steps to make sure that your personal
information remains accurate, complete and up-to-date. If the personal
information we hold about you is inaccurate or incomplete, you are
entitled to have it rectified. If we have disclosed your personal
information to others, we would let them know about the rectification
where possible. If you ask us, if possible and lawful to do so, we would
also inform you with whom we have shared your personal information so
that you can contact them directly. You may inform us at any time that
your personal details have changed by emailing us at service@mexceu.com.
The Company would change your personal information in accordance with
your instructions within a reasonable time. To proceed with such
requests we may sometimes require supporting documents from you as proof
i.e. personal information that we are required to keep for regulatory or
other legal purposes.
Erasure
You can ask us to delete or remove your personal information in certain
circumstances such as if we no longer need it, provided that we have no
legal obligation to retain that data. Such requests would be subject to
the contract that you have with us, and to any retention limits we are
required to comply with in accordance with applicable laws and
regulations. If we have disclosed your personal information to others,
we would let them know about the erasure request where possible. If you
ask us, if possible and lawful to do so, we would also inform you with
whom we have shared your personal information so that you can contact
them directly.
Processing restrictions
You can ask us to block or suppress the processing of your personal
information in certain circumstances such as if you contest the accuracy
of that personal information or object to us processing it. It would not
stop us from storing your personal information. We would inform you
before we decide not to agree with any requested restriction. If we have
disclosed your personal information to others, we would let them know
about the restriction of processing if possible. If you ask us, if
possible and lawful to do so, we would also inform with whom we have
shared your personal information so that you can contact them directly.
Data portability
In certain circumstances, you may have the right to request for personal
information you have provided us with previously (in a structured,
commonly used and machine readable format) and to re-use it elsewhere or
request us to transfer this to a third party.
Objection
You may request us to stop processing your personal information, and we
would do so, if we are: 1. Relying on our own or someone else’s
legitimate interests to process your personal information except if we
can demonstrate compelling legal grounds for the processing; 2.
Processing your personal information for direct marketing; or 3.
Processing your personal information for research unless we reasonably
believe such processing is necessary or prudent for the performance of a
task carried out in the public interest (such as by a regulatory or
enforcement agency).
Automated decision-making and profiling
If we have made a decision about you based solely on an automated
process (e.g. through automatic profiling) that affects your ability to
access our products and services or has another significant effect on
you, you can request not to be subject to such a decision unless we can
demonstrate to you that such decision is necessary for entering into, or
the performance of, a contract between you and us. Even if a decision is
necessary for entering into or performing a contract, you may contest
the decision and require human intervention. We may not be able to offer
our products or services to you, if we agree to such a request (i.e. end
our relationship with you).
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Changes to this Privacy Notice Our Privacy Notice is
reviewed regularly to ensure that any new obligations and technologies,
as well as any changes to our business operations and practices are
taken into consideration, as well as that it remains abreast of the
changing regulatory environment. Any personal information we hold would
be governed by our most recent Privacy Notice. If we decide to change
our Privacy Notice, we would post those changes to this Privacy Notice
and other places we deem appropriate.
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Data Protection Authorities If you are not satisfied
with our response to your complaint, you have the right to submit a
complaint with the appropriate governing regulatory body or bodies.