Last updated: 12 December 2022
DRXT Group Ltd, is a company established and operating under the laws of the Cayman Islands. We are committed to protecting and respecting your personal data and your privacy. We
recognize that your personal data is your property and that you have provided it to us for a specific
Unless otherwise required by law, we will only process your personal data in accordance with this
contractual arrangements, explains how personal data is processed by us or any processor on our
1.2 This Policy applies to our terms of service. You are therefore advised to read the terms of service
carefully. The terms used in this Policy shall have the meaning(s) given in the European General Data
Protection Regulation (Regulation), as applicable.
1.3 Any changes we make to this Policy will be posted on our website. You are advised to review our
website frequently as any changes to this Policy will be binding on you if you continue to use the
1.4 For more information relating to your rights under this Policy, please see section 10.
1.5 If you have any queries relating to this Policy, please review our website or contact us.
WHO WE ARE
2.1 We operate this website and we process your personal data together with other our group
companies (together referred as “we/us/our”).
2.2 Your data may be processed on our behalf by subcontractors engaged by us in connection with
this website, our activities and any services provided described or available on or through this
website. For example, subcontractors may conduct identity verification and other compliance related
verification, web hosting services, credit checks, payment operations, and other services
(Subcontractors). Subcontractors may only use your personal data to provide services to us.
Subcontractors are not authorized to use your personal data for their own behalf. Subcontractors are
required to comply with security and confidentiality obligations, and implement appropriate measures
so that data processing is carried out in a manner that complies with applicable regulations and
guarantees the security of your personal data.
2.3 Data controllers may provide data processing services to us from time to time. We will operate on
the terms of a written agreement with these data controllers relating to your personal data.
PERSONAL DATA PROCESSING CONDITIONS
3.1 By registering for user account (Account) and/or otherwise using the Website, you allow you to
us, Subcontractors, data controllers and other third parties mentioned in this policy to use, process,
transfer and store your personal data in accordance with this Policy.
3.2 You may decline to the processing of your personal date at any time. However, where the
objection to the processing of your personal date prevents us, Subcontractors, data controllers and
other third parties mentioned in this policy from verifying your identity or otherwise complying with our
compliance obligations, you will be unable to use your Account, our Website or any services or
transactions available through the Account or Website.
WHAT WE COLLECT
4.1 We may generally collect all or some of the following categories of data from you:
(a) Identification Information. Your full name, surname, identification number, passport,
identification card number, date of birth, phone number, residential and/or mailing address,
citizenship, email address, postcode, Account username, e-wallet account details of the sender
and the receiver, password, copies of any documents you have provided for identification
purposes, your image in photo or video and any other information relating to you which you
have provided to us in any form.
(b) Usage Information. Information about your use of our website and services, including cookies,
IP (internet protocol) address, computer and connection information, device type and unique
device identification numbers (e. g. IMEI number, MAC address), bandwidth, mobile network
information, mobile operating system and type of mobile browser, statistics on page views, and
traffic to and from our websites, and other technical data collected through cookies and other
similar technologies that uniquely identifies your browser.
(c) Information collected in accordance with the requirements law. Personal data from, among
other matters as required by law, politically exposed persons (PEP) screening, sanctions
screening, source of funds screening, corporate and business activities screening.
(d) Transaction Information. Transaction information gather from the use of the Account, Website
and related services, including but not limited to, deposit snapshots, account balances, trade
history, order activity and distribution history, bank account number, identification data of
electronic money account, account statement.
(e) Employment Information. Your employment history, education background and income.
(f) Financial Information. Your bank account information, credit card information (including the
card number, expiry date and CVC), tax identification number, transaction history and trading
(g) Correspondence. Responses to promotions and initiatives on our Website or app, and
interactions with our support team and customer service officers via email, app, this Website
and/or other communication channels.
4.2 In addition to the above, we will also provide you with your Account details, which includes your
username which is either created by, or assigned to, you. The Account details should be remembered
by you, but will be stored by us in case you forget them.
HOW WE COLLECT YOUR PERSONAL DATA
The personal data listed in Section 4 is collected in the following ways:
5.1 By you creating an Account – this is any information you give to us that we request from you
when registering for an Account, using our Website or by communicating with us in any way.
5.2 Information collected – each time you visit our Website, we or our Subcontractors may
5.2.1 technical information – includes your IP address used by your device to connect to the internet and details of any other versions; and
5.2.2 information about your visit – includes the pages you visited, links you have clicked on, and
interaction with the Website; and
5.2.3. transaction information – includes the date, time, amount, crypto currencies used, exchange
rate, beneficiary and related details; and
5.2.4. content information – includes information stored on your device, information to which you have
5.3. Received from third parties – we and our Subcontractors work closely to verify your eligibility
for an Account and our services. Accordingly, we search global and local databases for our business purpose and when we are required by law (e.g., PEP or sanctions lists, credit ratings), and, when possible, we obtain personal data from state authorities.
5.4 Additional information provided by you – includes any information you provide to us to access this Website, our services or is related to the performance of our services and/or based to other purpose (e. g. provision of the queries, phone calls that may be recorded).
6.1. Our Cookies Policy addresses the processing of your personal data using Cookies.
WHAT WE DO WITH YOUR PERSONAL DATA
7.1 Your personal data is primarily necessary to verify who you are when accessing your Account and
to ensure you meet our eligibility requirements in order to submit an application for an Account. We or our Subcontractors also will use all or a part of your personal data for performance of our obligations under the terms of service, provision of related services, and/or for compliance with a legal obligations to which we or our Subcontractors are subject.
7.2 Additionally, we will use all or a part of your personal data you provide us to notify you about:
7.2.1 services of which may be of interest to you; or
7.2.2 changes to our Website, our services or your Account.
7.3 We and our Subcontractors use any personal data we collect about you (as a result of your visit to our Website) to:
7.3.1 personalize and improve our services, including the Website and security;
7.3.2 deal with your inquiries and requests;
7.3.3 administer and monitor traffic and behaviors on our Website for analysis, testing, research,
statistical and survey purposes;
7.3.4 ensure that any part of our Website, including any content, is presented in the most effective
manner for you and your device, and to make improvements where necessary; and
7.3.5 keep our Website and services secure.
7.4 Where we change our services, or any applicable terms of service, we will contact you. For more
details please see Clause 1.5 of the Policy.
7.5 Any personal data we obtain from third parties about you is used for the purposes of verifying your eligibility to submit an application for Account through our Website and/or access services through the Website.
HOW AND WHY WE DISCLOSE YOUR PERSONAL DATA
8.1 Subject to this Section 8, we will only disclose your personal data to third parties which are
considered data processors for the following purposes:
8.1.1 credit check and reference agencies and fraud prevention agencies – in order to verify your
identity, perform transactions you instruct on us or for the purposes of fraud detection or protection, or in other situations involving suspicious or illegal activities. We may also obtain your credit file if necessary or required to deliver our services to you;
8.1.2 to process transactions through the Website;
8.1.3 banking, including electronic money institutions, crypto exchanges and financial service partners
such as banking intermediaries, international payment services providers and regulated distribution
agents, in order to provide our services;
8.1.4 our approved email provider – in order to be able to send emails to you;
8.1.5 analytics providers – for performance of Website troubleshooting, data analytics, testing,
research, usage tracking and for the purposes of fraud detection or protection, or other suspicious or illegal activities;
8.1.6 other approved services providers – in order to ensure the proper functioning and provision of
the services and Website.
8.1.7 members of group – in order to provide a proper service for all of our products, we may
disclose personal data to any to any of our subsidiaries, affiliates or related entities.
8.2 In addition to the transfers contemplated by part 8.1, we or our Subcontractors may transfer or
disclose your personal data to:
8.2.2 comply with any legal requirements;
8.2.3 enforce any part of our terms of service and/or any other agreements between you and us or to
investigate potential breaches; or
8.2.4 protect our rights or our property, or those of our other Account holders, includes by exchanging
information with third parties to prevent fraud and reduce credit risk.
8.3 Any websites which are linked from the Website are outside of our control and not covered by this
Policy. If you access those websites using the links provided, the website operators may collect
information from you which will be used by them in accordance with their own privacy policies (if any).
These policies may differ from ours, and we cannot accept any responsibility or liability in respect of
9.1 Each member of our staff has access to your personal data only for the purposes of performing
their functions in connection with the Website and our services.
9.2 You may have set a password in order to access certain parts of our Website. You are
responsible for keeping this password confidential. We ask you not to share your password with
9.3 We have put in place procedures to deal with any suspected personal data breach and will notify
you and any applicable regulator of a personal data breach where we are legally required to do so.
9.4. We seek to put in place appropriate technical and organizational measures to help protect your
personal data from unauthorized access, use, disclosure, alteration or destruction consistent with the
Regulation and other applicable data protection laws. Nevertheless, the transmission of information
via the Internet is not entirely secure. We cannot guarantee the security of your personal data
transmitted to our Website. Any transmission of personal data is at your own risk.
RETAINING YOUR INFORMATION
10.1. We are obligated to retain your personal data and your transactions for such time until the
retention of your personal data is no longer necessary for any business or legal purpose.
11.1 In addition to any rights you may have under the Regulation, you have the following rights with
respect to your personal data:
11.1.1 to receive a copy of the personal data we store;
11.1.2 to receive information on what personal data we store, how it was obtained, to whom it has
been disclosed and for how long it will be stored;
11.1.3 to amend any inaccurate personal data;
11.1.4 to delete any of your personal data unless not permitted by applicable law;
11.1.5 to object to the processing of your personal data in whole or in part;
11.1.6 to forward the personal data you provided to another data controller or to you in a commonly
used and computer-readable format, if technically possible;
11.1.7 to stop the processing of your personal data, except if we process personal data for our
legitimate interest or other person to whom personal data are provided;
11.1.8 to withdraw consent at any time where we are relying on your consent to process your
11.1.9 not to be the subject only to automated processing, including profiling;
11.1.10 to appeal our actions or inactions related to your rights to the Lithuanian Data Protection
authority that is located in a member state of the European Union where you reside;
11.1.11 if you have suffered damage as a result of a violation of your rights, you may apply to the
competent court located in a member state of the European Union where you reside; and
11.2 If you wish to exercise any of your rights at any time, please contact us on [_]. We will
require you to verify your identity before we provide any personal data, and reserve the right to
require that you specify the personal data to which your request relates. We will try to respond to your
legitimate requests within 1 month. Occasionally it may take us longer than 1 month if your request is
complex or you have made a number of requests.
11.3 Where you wish to exercise any of your rights, we may require that you pay a nominal
administration fee (to cover our costs incurred in processing your request) and provide any
clarification reasonably required in relation to your request. Such fees may be charged where we
consider (acting reasonably) that your request is excessive, unfounded or repetitive.
11.4 Any personal data provided to you in accordance with your rights will be in a structured and in
12.1. You confirm that you have provided true and accurate personal data about yourself in every
required form and that afterwards, when changing or adding any personal data on the Website, you
will enter only correct data. We will not accept invalid, false or otherwise incorrect personal data and
will pursue all legal remedies available to us. You shall bear any losses suffered by us in connection
to the submission by you of invalid, false or otherwise incorrect data.
12.2 Your email address and any other contact information you have chosen to link to your Account
may be used for identification and communication. You undertake to protect email address and any
other contact information linked to your Account, including passwords. You are liable for loss due to
the use and disclosure of your passwords.