Privacy Policy
Last updated: 30 July 2018

Introduction

Our Privacy Policy designed to be complied with highest standards and international practices to cover the expected personal data we might collect and use and maybe needed from you, therefore you have to read it carefully as this Privacy Policy is legally binding all users of any service or product by ADAX Exchange or any of its channels.

Kindly be aware that we may amend our Privacy Policy at any time by posting the updated version on this site including the effective date, meanwhile, we might announce any material changes to this Privacy Policy via email. Your use of any of our services or products considered acknowledge by you that you have read, understand and agreed on our Privacy Policy and consent by you to commit for any obligations accordingly.

Arabtizor Holdings Inc. provides ADAX Exchange Services as an online portal through multiple local and international operating entities that might be subsidiaries, affiliates, partners or engaged with a kind of business relationship with Arabtizor Holdings Inc. P.O Box 84059 Dubai, United Arab Emirates.

You are contracting with Arabtizor Holdings Inc. as your data controller, and is responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with our global privacy standards, this Privacy Policy, as well as any applicable national laws. We use encryption to protect your information and store decryption keys in separate systems. Data controllers process and retain your personal information on our servers where our data centers are located, including any recent or future centers anywhere around the world, where we have a legal obligation to do so, meanwhile, we have respective data protection staff responsible for our privacy program collected accordingly. For any further questions or information about how we protect or use your Personal data, please contact our respective staff at: [email protected].

Definitions

Below definitions will be used in this Privacy Policy, the following terms are defined as follows:

  • “Digital Asset” is a digital representation of value (also referred to as “cryptocurrency,” “virtual currency,” “digital currency,” “crypto token,” “crypto asset,” “digital commodity” or “ERC20 Token”), such as bitcoin, Ripple or Ethereum, which is based on the cryptographic protocol of a computer network that may be (i) centralized or decentralized, (ii) closed or open-source, and (iii) used as a medium of exchange and/or store of value.
  • “ADAX Account” means a user-accessible account offered via the ADAX Exchange Services where Digital Assets balances are recorded as a database.
  • “ADAX Exchange Services” means ADAX-branded websites, applications, services, tools as an online portal powered by Arabtizor Holdings Inc.
  • “Arabtizor,” “ADAX,” “ADAX Exchange”, “We,” “Our” and “Us” refers to Arabtizor Holdings Inc. and its wholly owned subsidiaries or affiliates (also referred to collectively as "Arabtizor," "ADAX," "we," “Our” or "us").
  • “Customer”, “User”, “You” or” Yours” refers to the user of any service of product available by ADAX Exchange by any mean.
  • “Information”, “Data”, “Personal Information” or “Personal Data”, “your information” or “your data” refers to any information relating to you, as an identified or identifiable natural person, including your name, an identification number, location data, or an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of you as a natural person.

Information Protection

One of our priorities is the privacy of your Personal Information and our workplace environment from unauthorized access to, or unauthorized alteration, disclosure, or destruction of Personal Information we collect and store. Measures we apply include encryption with SSL, the availability of two-factor authentication at your discretion, and periodic review of our Personal Information collection, storage, and processing practices, hence, we restrict access of your Personal Information only to those respective employees, subsidiaries, affiliates, and subcontractors who have a legitimate business need for accessing such information. We continuously direct and train our staff about the importance of confidentiality and privacy of customer information. We maintain physical, electronic, and procedural safeguards that comply with the relevant laws and regulations to protect your Personal Information from unauthorized access.

Important Notice: despite of best practices and technical standards in industry, the transmission of information via the internet is not completely secure always. Although we do our best efforts to protect your Personal Data, but we cannot guarantee the security of your Personal Data during transmission, therefore, any acts of transmission are at your own risk.

Type of Information

A) Direct Information: direct information we collect from you including Manually or Automatically.

Manual Channels – we collect and use the following data from the user manually upon using ADAX Exchange services:

  • Full legal name;
  • Home address, including country of residence;
  • Email address;
  • Mobile phone number;
  • Date of birth;
  • Proof of identity (e.g., driver’s license, passport, or government-issued identity card);
  • U.S. Social Security Number or any comparable identification number issued by a government;
  • Other Personal Information or commercial and/or identification information – Whatever information we, in our sole discretion, deem necessary to comply with our legal obligations under various anti-money laundering (AML) obligations without any limitation.

Automatic Channels – we collect and use the following data from the user automatically upon using ADAX Exchange services:

  • Account Information – Information that is generated by your ADAX account activity including, but not limited to, instructions regarding funding and disbursement, orders, trades, and account balances;
  • Log Information – Information that is generated by your use of ADAX Exchange services 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 Websites or Apps such as 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;
  • Location Information – Information that is automatically collected via analytics systems providers to determine your location, including -but is not limited to- 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;
  • Correspondence – Information that you provide to us in written or oral correspondence, including – but not limited to opening an account, and with respect to ongoing customer support and logging of phone numbers used to contact us;
  • Any relative information will let us control our database in best practices and standards to serve our customer needs at any point of time.
    • B) Indirect Information: indirect information we collect about you from other sources or third party database to support our operations in best practices, meanwhile, we may receive information about you if you use any of the other websites we operate or the other services we provide.

      We may receive information about you from third parties, such as, without limitation – the banks you use to transfer money to us which will reveal your basic personal information such as your name, address and your bank account details, in addition to our business partners which may provide us with the same along with the availability of checking your financial or legal listing status.

      We may use advertising networks, analytics providers and search information providers to provide us with anonymized or de-identified information about you, such as confirming how you found our website.

      We may collaborate with credit reference agencies to corroborate and audit the information you have provided to us to make sure our database built in best market practices and upon their applied policies and procedures.

      Use of Information

      Below we set forth a description of all the ways we use your personal data, type of information, purpose and which of the Legitimacy base we rely on to do so, noting that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us for further details or clarifications required at [email protected].

      • Type of Information: Direct Information; by submitting your information manually or collect it automatically.
      • Purpose: to enable us provide ADAX Exchange services and carry out contractual obligations relating to you, including the fulfillment of your orders and trades, the operation of your ADAX accounts and the provision of our support services, in addition to keep our proper functioning and internal operations including registration and types of account, marketing troubleshooting, data analysis, testing, research, statistical, and survey purposes, meanwhile, to notify you about changes to our service, our terms and policies, and as part of our efforts to keep ADAX Exchange Services, safe and secure.
      • Reason: to fulfill contracts and meet our legitimate interests and legal obligations.
      • Legitimacy: to apply efficient process meeting our legal and contractual requirements by implementing best service practices which comply with regulations might be applied at any point of time to keep our business environment safe and secure.
      • Type of Information: Indirect Information; either by collecting and use your information by us or by our business partnerships with third parties.
      • Purpose: to comply with legal and/or regulatory requirements, including, but not limited to prevailing international practices against fraud,money laundry or financial crimes, meanwhile, to verify your real identity and your eligibility to use our services and products and enable us to categorize your ADAX account type eligibility, hence, enable us approving ADAX Exchange applications and sort out types of account which eligible for each customer efficiently, meanwhile, to develop our business along with offering best services and products to our customers about any new promotions, features, functions, related marketing campaigns, updates or announcements related to ADAX Exchange or any of our partners relative services or products, in addition to analyze the potential customers database that might be interested in such services and products while targeting our marketing campaigns.
      • Reason: to fulfill contracts and meet our legitimate interests and legal obligations.
      • Legitimacy: to apply efficient process meeting our legal and contractual requirements by implementing best service practices which comply with regulations might be applied at any point of time to keep our business environment safe and secure.

      - Personal Information you provide during the registration process may be retained, even if your registration is left incomplete or abandoned. If you are located within the EEA, this Information will not be retained without your consent.

      - In providing the personal data of any individual (other than yourself) to us during your use of the Kraken Exchange Services, you promise that you have obtained consent from such individual to disclose his/her personal data to us, as well his/her consent to our collection, use and disclosure of such personal data for the purposes set out in this Privacy Notice.

      - Legitimate Interest: means an interest of ours as a business to continue to innovate and improve ADAX Exchange services and operations to offer the most secure experience possible. We make sure to consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.

      - Fulfilling a Contract: means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

      - Our Legal Obligation: means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to or might be applicable at any point of time.

      - We do not use your personal data for activities where our interests are overridden by the impact on you unless we have your consent or are otherwise required or permitted to by law.

      - We may from time to time send communications promoting services, products, facilities, or activities to you using information collected from you. When you create an account with us, then you are agreeing to opt-in to all communications from us. We will provide you with an opportunity to opt-out of newsletter communications.. We will never provide your Personal Information to third parties for direct marketing or other unrelated purposes without your written consent. Unfortunately, we are unable to allow you to opt-out of the emails we send you for certain legal or administrative purposes.

      - You have to notify us and correct any personal information we hold on you that is inaccurate, incorrect, or out of date.

      - You have the right to ask us to delete your data when it is no longer necessary, or no longer subject to a legal obligation to which we are subject to.

      - You may be able to stop the collection of location information through your device settings or by following the standard uninstall process to remove our applications from your device, however, because such data is used by us to meet legal requirements, as well as for ongoing fraud and risk monitoring purposes, choosing to remove or disable location services may interfere with your use and functionality of our services.

      - We do not maintain a published list of all our third parties with whom we share your personal information with. However, if you would like further information about whom we have shared your personal information with a list specific to you, you can contact us by writing to [email protected].

      Personal Data Storage

      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 may store and process your personal data anywhere around the world.

      Legal Age

      Our services and products are not directed to persons under the age of 18 and we do not knowingly collect personal information from them. If we learn that we have inadvertently gathered personal information from a person under the age of 18, we will take legally permissible measures to remove that information from our records. We will not allow the use of our services by any person under the age of 18 and will require the user then to close his or her account. If you are a parent or guardian of a user under the age of 18 and you become aware that he/she has provided personal information to us, please contact us at [email protected].

      Accessibility

      Subject to applicable laws, you may have the right to access information we hold about you. Your right of access can be exercised in accordance with the relevant data protection legislation. For further information, please contact [email protected].

      Data Retention

      Our operations might be subject to various legal, compliance and reporting obligations, including recent or any future regulatory requirements, therefore, we will be required by law to store some of your personal and transactional data beyond the closure of your account with us. Your data is only accessed internally on a need to know basis, and it will only be accessed or processed if absolutely necessary. We will delete data that is no longer required by any relevant law or jurisdiction in which we operate according to applicable laws.

      Cookies

      We may 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 to visit our website services. We use Cookies to (i) help us recognize you as a customer, collect information about your use of our website to better customize our services and content for you, and to collect information about your computer or other access devices as part to ensure our compliance with our obligations and (ii) ensure that your account security has not been compromised by detecting irregular or suspicious account activities. We use both session and persistent Cookies. Session Cookies expire when you log out of your account or close your browser. Persistent Cookies remain on your computer or mobile device until deleted or otherwise expire. Most web browsers are set to accept Cookies by default. You are free to decline most of our session Cookies if your browser or browser add-on permits but choosing to remove or disable our Cookies may interfere with your use and functionality of our website services.

      Sharing Personal Data (outside of EEA)

      In order to provide our Services to you, it is sometimes necessary for us to transfer your data to the third parties outlined in section 7.1 that are based outside of the European Economic Area ("EEA"). In these cases, we ensure that both ourselves and our partners take adequate and appropriate technical, physical, and organizational security measures to protect your data. We also ensure we have appropriate contractual protections in place with these third parties.

      By using our services, you consent to your Personal Data being transferred to other countries, including countries that have different data protection rules than your country. In all such transfers, we will protect your personal information as described in this Privacy Policy and in a manner consistent with the principles of the EU-US and Swiss-US Privacy Shield framework. For more information, please contact us at [email protected].

      Privacy of Blockchains (or digital assets)

      Your funding of bitcoin, XRP, ether, and other Digital Assets, may be recorded on a public blockchain. Public blockchains are distributed ledgers and available for public access as inherent nature, intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to de-anonymization and the unintentional revelation of private financial information, especially when blockchain data is combined with other data. Because blockchains are decentralized or third-party networks which are not controlled or operated by Arabtizor Holdings Inc. or its subsidiaries or affiliates, therefore we are not able to erase, modify, or alter personal data or records from such networks. It’s your own risk if any personal data revealed by the parties which we do not have any kind of control on.

      Disclosure of Data

      We may share your personal data with selected third parties including affiliates, operational and business partners, suppliers and sub-contractors for the performance and execution of any contract we enter into with them or you, in addition to analytics and search engine providers that assist us in the improvement and optimization of our site and our group entities, affiliates or subsidiaries. Furthermore, this disclosure of your personal information to third parties might occur in the following cases:

      • When we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets in order to continue the services for which you have contracted;
      • When we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Service and other applicable agreements; or to protect the rights, property, or safety of Arabtizor or any of its affiliates, subsidiaries, partners, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
      • When we conduct or cooperate in investigations of fraud or other illegal activity whenever we believe it is reasonable and appropriate to do so to prevent and detect fraud and financial crime;
      • When we receive a lawful subpoena, warrant, court order, or otherwise required by applicable law;
      • When we seek to develop our customer relationships and services or to protect our business interests from financial and insurance risks and if we seek to recover debt or in relation to your insolvency;

      Changes to Privacy Policy

      Any changes we may apply to our Privacy Policy at any time will be posted on this page and, where appropriate and without obligation, notified to you by email. It’s your responsibility part to check back frequently to see any updates or changes to our Privacy Policy.

      Contact us

      We welcome any questions, comments and requests regarding our Privacy Policy over our dedicated email address [email protected]. Furthermore, if you feel that we have not addressed your concerns adequately, you may contact regional data controller for any further queries.