Privacy Policy

EQ9. GLOBAL PRIVACY NOTICE

Effective Date: 03 Jan 2025

For the purposes of this Privacy Policy:

• "Personal Information" means any information that relates to an identified or identifiable individual.
• "Processing" means any operation or set of operations performed on Personal Information, whether or not by automated means, including collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, or erasure.
• "Services" refers to the EQ9 FX Application and related features, technologies, and functionalities provided through it.

This Privacy Policy ("Policy") explains how EQ9 ("Company," "we," "us," or "our") collects, uses, shares, and protects personal information obtained through the EQ9 FX Application ("App"). By using the App, you agree to the terms of this Policy. If you do not agree, you must cease using the App and uninstall it.

EQ9 is committed to safeguarding your privacy and ensuring the security of your personal information. Our principles include:

• Transparency: Providing clear details about our data collection and usage practices.
• Control: Empowering you to manage your privacy settings.
• Security: Implementing robust measures to protect your information.

EQ9 is committed to providing transparency about how we process your information. In summary, for EQ9 users, this means:

• We do not collect your private keys.
• We do not sell your personal information.
• We only collect and process personal information that is necessary to provide you with the Services and a great user experience.
• We may temporarily process your IP address or other device-related information only when required to ensure the functionality and security of our Services.

Specifically, the information we process includes:

Information You Provide to Us:

• Account Information: When creating an account or interacting with support, you may provide details such as your name, email address, or other relevant information.
• Payment Information: When using on- or off-ramp services, you may need to submit payment or banking details directly to third-party providers. EQ9 does not store this information.
• Feedback and Surveys: If you provide feedback or participate in surveys, we process that information to improve our services.

Information We Automatically Collect:

• Device Information: This may include your operating system, browser type, device identifiers, and IP address. We process this information temporarily to provide the basic functionality of the App, improve your experience, and ensure security (e.g., preventing DDoS attacks).
• Usage Data: Metrics such as feature interactions, session duration, and transaction activity (excluding sensitive financial data) are collected to enhance performance and user experience.
• Cookies and Tracking Technologies: We use cookies and similar technologies to improve the functionality and security of the App, analyse usage, and provide a seamless experience.

• Provide Services: Ensure the functionality of the App, including transactions, notifications, and customer support.
• Improve User Experience: Analyse usage to refine features and performance.
• Legal Compliance: Adhere to applicable laws and regulations, including Anti-Money Laundering (AML) and Know Your Customer (KYC) requirements.
• Security: Detect and prevent fraudulent or unauthorised activities.

• Private Key Control: You retain sole responsibility for securing your private keys and recovery phrases.
• Data Minimisation: We do not access or store private keys, passwords, or transaction details beyond what is essential for service provision.

The App integrates with third-party services for functionalities like payment processing and blockchain interactions. These third parties may collect data in accordance with their own privacy policies. Examples include:

• On- and Off-Ramp Providers: Partners enabling the purchase or conversion of stablecoins.
• Analytics Services: Tools for tracking user engagement and improving services.

• Service Providers: To facilitate operations like transaction processing and customer support.
• Regulatory Authorities: As required by law, including for AML/KYC compliance.
• Legal Obligations: To comply with subpoenas, court orders, or other legal processes.

• Encryption: Secure transmission of sensitive data.
• Access Controls: Restricted access to authorised personnel only.
• Audits: Regular security assessments to identify and mitigate risks.

However, no system can guarantee absolute security. Users are encouraged to safeguard their devices and credentials.

• Access and Correction: Reviewing and updating your personal information.
• Data Portability: Requesting a copy of your data in a structured format.
• Deletion: Requesting the removal of personal data, subject to legal and operational requirements.
• Objections: Opting out of data processing for specific purposes.

• Improve App performance.
• Analyse user behaviour for enhancements.
• Ensure security and prevent fraud.

You can manage your preferences via your device settings or third-party tools.

We may update this Policy to reflect changes in laws or services. Users will be notified of significant updates via in-App notifications or email. Continued use of the App constitutes acceptance of the updated Policy.

For questions, concerns, or to exercise your rights, contact us at: admin@eq9.app

As a global platform, EQ9 may transfer your personal information to servers and service providers located in countries outside your jurisdiction. We ensure that such transfers comply with applicable data protection laws and maintain the security of your information by:

• Using EU Standard Contractual Clauses for users in the European Economic Area (EEA) and other regions requiring data protection safeguards.
• Adopting equivalent measures as recognised by local laws for international data transfers.

By using the App, you consent to the transfer of your data to these locations for processing in accordance with this Policy.

We retain personal information only for as long as necessary to:

• Fulfil the purposes outlined in this Privacy Policy.
• Comply with legal and regulatory obligations (e.g., AML/KYC requirements).
• Resolve disputes, enforce agreements, and maintain operational records.

When no longer required, data will be securely deleted or anonymised.

EQ9 does not knowingly collect or solicit personal information from anyone under the age of 18. If we discover that we have inadvertently collected data from a minor, it will be promptly deleted. If you believe we may have collected such information, please contact us at admin@eq9.app.

The App may contain links to third-party websites or services not operated by EQ9. We are not responsible for the privacy practices or content of these external platforms. Users are encouraged to review the privacy policies of third-party services before providing personal information.

As a non-custodial platform, EQ9 requires users to:

• Maintain the confidentiality of their private keys, recovery phrases, and credentials.
• Use secure devices and connections when accessing the App.
• Regularly review their account activity and report any suspicious transactions or unauthorised access.

Failure to meet these responsibilities may result in the loss of funds or access to the App, for which EQ9 bears no liability.

EQ9 complies with applicable data protection and financial regulations, including but not limited to:

• General Data Protection Regulation (GDPR) for users in the EEA.
• California Consumer Privacy Act (CCPA) for residents of California, USA.
• Other jurisdiction-specific laws where EQ9 operates.

For region-specific details, refer to the Supplemental Privacy Notices section.

This section applies to users in regions with additional legal and regulatory requirements. EQ9 is committed to adhering to regional privacy laws and providing users with the rights and protections outlined by applicable regulations.

European Economic Area (EEA), UK, and Switzerland Residents:

• Data Access: Users have the right to access the personal data we process about them.
• Data Rectification: Users may request corrections to any inaccurate or incomplete personal data.
• Data Portability: Users can request their personal data in a structured, commonly used, and machine-readable format, and may transfer it to another controller.
• Data Deletion: Users have the right to request the deletion of personal data under certain conditions, such as when the data is no longer necessary for the purposes for which it was collected.
• Right to Object: Users may object to the processing of their data for direct marketing or other legitimate interests.
• International Data Transfers: When transferring personal data outside the EEA, UK, or Switzerland, EQ9 ensures compliance with recognized safeguards, such as Standard Contractual Clauses (SCCs) or adequacy decisions, to protect user data in line with GDPR standards.
• Complaints: Users may lodge complaints with their local data protection authority if they believe their data rights have been violated.

United States Residents:

• Right to Know: Users can request information about the categories of personal data collected, sources of data, purposes of use, and any third parties with whom data is shared.
• Right to Opt-Out: Users can opt out of the "sale" or "sharing" of personal information for targeted advertising purposes. Note: EQ9 does not sell user data.
• Right to Delete: Users may request the deletion of their personal information, subject to legal or operational exceptions.
• Right to Non-Discrimination: EQ9 will not discriminate against users who exercise their privacy rights, such as by denying services or imposing penalties.

International Users: For users outside the regions specifically mentioned above, EQ9 adheres to applicable privacy laws and industry best practices in those jurisdictions. Users are encouraged to contact us for region-specific privacy details or to exercise their rights.

Any disputes arising from this Privacy Policy will be resolved under the laws specified in EQ9's Terms of Use. Users may also lodge complaints with local data protection authorities if applicable.

By using EQ9, you consent to the data practices described in this Privacy Policy. Users can withdraw consent for non-essential data processing or delete their accounts by contacting EQ9 support.

To exercise your rights or submit inquiries, email us at: admin@eq9.app

For questions, concerns, or to exercise your rights, contact us at: admin@eq9.app