Privacy Policy

Effective from 2025-08-11

This is a translation provided for convenience. In case of any discrepancy, the Russian version of this document prevails. Questions: support@waltix.io.

This Privacy Policy sets out how Waltix Group LLC (also referred to as the "Company", "we", "our", "ours") processes personal data and the measures it takes to keep such data secure, in order to protect and respect the privacy of Users of the website https://waltix.io/ and/or of the Company's products/services. The Policy applies to all information the Company may receive from Users. This Policy does not control and the Company bears no responsibility for third-party websites that Users may reach through links available on https://waltix.io/ and on which personal information may likewise be collected or requested from the User.

By continuing to use this Site and/or by registering to use the Company's products/services (our services), you confirm that you have read, understand, accept and undertake to comply with these Terms, Policies and provisions governing the use by Users of the Site and/or of the products/services offered by the Company. The Site's Privacy Policy governs the provision of personal data ("Information") by users.

1. General provisions

1.1. Under this Privacy Policy, the Company is entitled to collect the personal data of persons visiting the Company's Site, to inform them about the purposes and methods of using the Information, and about their rights to control the Company's use of the personal information collected and stored about visitors to the Site.

1.2. Protecting your personal data is the Company's most important task, and we guarantee that we will safeguard your data in accordance with the requirements of the law.

1.3. The Company is the party processing the data you provide and is responsible for processing and storing the information.

1.4. The website https://waltix.io/ and other domains that are updated from time to time, together with the pages associated with it (the "Site"), are developed and operated by the Company.

1.5. Users of the Site and/or of the Company's products/services may, for convenience, be referred to as "you" or "your". Before using the Site or any other Company product/service you must read this Policy carefully, as it governs how the Company processes personal data. If you disagree with any provision of this Policy, we ask that you refrain from using this Site and its services and leave it.

1.5. We recommend that you review the provisions of this Privacy Policy carefully. By continuing to use this Site and/or by registering to use the Company's products/services, you confirm that you have read, understand, accept and undertake to comply with this Privacy Policy.

2. Definitions

Automated data processing
Data processing carried out using information technology.
Data controller
A public institution or a natural or legal person that determines, individually or jointly with others, the purposes and means of processing personal data and carries out the processing directly or through an authorised person.
Regulatory requirements
Any applicable law, statute, regulation, order, court judgment, decision, recommendation, rule, policy (including but not limited to KYC/AML/CTF Policies) or guidance adopted or issued by a parliament, a government or any competent court or authority, or by any payment system (including but not limited to banking payment systems, card payment systems such as Visa or MasterCard, or any other payment, clearing or settlement system, or a similar arrangement used to provide the products/services).
Data processing
Any action performed in relation to data by automated, semi-automated or non-automated means, in particular collection, recording, photographing, audio and video recording, organisation, storage, replacement, restoration, retrieval, use or disclosure for the purposes of transferring or distributing the data or otherwise making it accessible, grouping or combination, blocking, deletion or destruction of the data.
Personal data (Information)
Any information relating to an identified or identifiable natural person. A person is identifiable where it is possible to identify them directly or indirectly, in particular by an identification number or by characteristic physical, physiological, psychological, economic, cultural or social features.
Products and/or services
Products and/or services provided to the User on the website https://waltix.io/.
Policies / Policy
The policies and provisions governing how the products/services are provided, including but not limited to the Customer Risk Management, Anti-Money Laundering and Counter-Terrorist Financing, Sanctions and Country Policy (AML/CTF & KYC & SANCTIONS & COUNTRY POLICY), the Privacy Policy and others.
Semi-automated data processing
Data processing using information technology or non-automated means.
User
A natural person visiting the website https://waltix.io/ and/or using the products/services of the Site and/or of the Company, and who is a data subject.
Consent
The voluntary consent of a data subject to the processing of data concerning them for specified purposes, expressed orally, in writing or in an equivalent form, by telecommunications or other appropriate means, after receiving the relevant information, allowing the data subject's intent to be clearly established.
Data subject
Any natural person whose data is processed.
Authorised person
Any natural or legal person processing data for or on behalf of the data controller.
User Account
The user's personal profile or dashboard created after registration on the website https://waltix.io/.

3. How personal data and information about users is collected, stored and processed

3.1. Under this Privacy Policy, the Company is entitled to process the personal data of persons visiting the Company's Site, to inform them about the purposes and methods of processing personal data, and about their rights to control the Company's use of the personal information collected and stored about visitors to the Site.

3.2. Protecting your personal data is the Company's most important task, and we guarantee that we will safeguard your data in accordance with the requirements of the law.

3.3. The Company may collect information you provide voluntarily during registration and while creating an Account, in particular: first name, last name, email address, postal address, country of residence, phone number, date of birth, electronic wallet address, taxpayer registration number, bank details, payment card information and personal information required for KYC/AML or CTF procedures.

3.4. The Company collects and stores personal data in order to comply with the requirements of applicable law, in particular those relating to combating and preventing the legalisation (laundering) of criminally obtained income and the financing of terrorism, to improve and develop the Company's services, to study User requirements, to compile Site statistics and to plan and carry out various marketing activities.

3.5. The Company collects Users' personal information only to the extent necessary to ensure that services are properly provided to Users.

3.6. We store your financial information in our secure systems, and only we have access to your information. However, we may pass such information to third parties as required by law or by this Policy.

3.7. Additional information about your device and your use of the services (device network connection, IP address, geolocation data and so on) may be collected by the means set out in this Privacy Policy, subject to your prior consent. Completing the registration form when creating an account on the Site and/or using the Company's products/services, after reviewing the Company's Policies, will be treated as your consent to the collection, processing, storage and transfer of information to third parties in accordance with this Policy and applicable law.

3.8. Where necessary, the Company may request additional information in accordance with the requirements of the law.

3.9. In order to verify the data you provide, the Company may make enquiries through third-party service providers to prevent misidentification, fraud, suspicious activity, money laundering or any other prohibited activity, and the Company may take further measures in respect of the results of such enquiries where we consider it necessary. By accepting this Policy, you give us your permission to make such enquiries, including in respect of information stated in your Account.

3.10. Notwithstanding the above, the Company may at any time and at its sole discretion refuse to allow you to open an Account, restrict an Account that has already been created, or suspend any transaction pending the outcome of our review of any information you have provided.

3.11. We may permanently close the account of any User who fails to comply with our requests to verify information or otherwise breaches the rules and/or Policies set out above. Such a User may be held liable for losses incurred by the Company or any third party as a result of the breach of the rules for using the Site and/or the Company's products/services.

3.12. We may also collect additional information from you or about you by other lawful means not listed in this Policy. For example, we may collect information relating to your communication with our customer support, or retain the results of your survey responses, the results of analysing your activity on the Site and/or with the Company's products/services, and other similar information.

3.13. We store and process your personal information on specially protected dedicated servers and safeguard it by maintaining physical, electronic and procedural controls in accordance with applicable law. We use computer safeguards such as firewalls and data encryption, we apply physical access controls to our media and files, and we grant access to personal information only to those employees who need it to perform their duties.

3.14. When collecting and storing data, the Company follows these principles:

3.14. - data is processed fairly and lawfully, without demeaning the dignity of the data subject;

3.14. - data is processed only for specific, clearly defined and lawful purposes, namely the provision of the Company's services. The Company does not permit subsequent processing of data for other purposes incompatible with the original purpose;

3.14. - data is processed only to the extent necessary to achieve the relevant lawful purposes. The data is adequate and proportionate to the purposes for which it is processed;

3.14. - data is reliable and accurate and is updated where necessary. Data collected without a lawful basis and not matching the purpose of processing is blocked and deleted.

3.15. We will retain: (a) transaction records for five (5) years from the date the transaction was completed, or for such other minimum period as applicable law requires; (b) other information collected by the Company for the purposes of complying with legislation on combating the laundering of unlawfully obtained income and the financing of terrorism, for the whole period of the business relationship with the User and for five (5) years from the date the business relationship with the User ends, or for such other minimum period as applicable law may require.

4. Confidentiality

You acknowledge that you bear responsibility equally with the Company for keeping your Account information confidential, including your password, for protecting your digital assets, and for all actions and transactions occurring in your Account. You understand that any disclosure of your registration and other information may expose your Account to unauthorised third-party access, which may lead to the loss or theft of digital assets and funds from your Account, including from associated accounts such as withdrawal details.

5. Collecting information for the purposes of the AML/CTF and KYC/CDD Policy and procedures

5.1. Application of KYC/CDD, AML and CTF procedures.

5.1. As part of our commitment to combating financial crime, money laundering, terrorist financing, fraud, sanctions circumvention and other criminal activity, the Company has implemented procedures and systems designed to let us identify and reduce the risks associated with misuse of our Site and of the Company's products/services. These include KYC/CDD, AML and CTF procedures based on collecting information about our users, assessing the AML/CTF risks associated with their activity and continuously monitoring the transactions they carry out.

5.2. Your personal data may be used to:

5.2. - process transactions and send the notifications about your transactions required by the Policies and/or applicable law;

5.2. - resolve disputes, collect payments and troubleshoot problems;

5.2. - send you targeted marketing, service update notices and promotional offers based on your preferences;

5.2. - prevent potentially prohibited or unlawful activity and enforce our Terms of Use;

5.2. - provide services and customer support at your request;

5.2. - configure, measure and improve our services and the content and appearance of our website;

5.2. - cross-check information for accuracy and have it verified by third parties;

5.2. - verify or refute a breach of regulatory requirements and/or the Policies.

5.3. If we have any suspicion that our business relationship with you, or a specific transaction you wish to carry out, involves any risk of money laundering, terrorist financing or any other financial crime or prohibited activity, we may, at our sole discretion, refuse to accept you as a client, terminate any interaction with you, refuse to process any transaction and take any other action we consider necessary, including reporting our suspicions to the competent authorities. We will not inform you of any such action we decide to take, and we are entitled not to provide you with any explanation of the reasons for such decisions or of our suspicions.

5.4. In order to carry out the checks described above, we may collect certain personal information not only from you but also from external sources. Any such information about you will be stored and used in accordance with the Privacy Policy.

6. Sharing information with other parties

6.1. We may share your personal data with:

6.1. - related and associated entities of the Company;

6.1. - banking partners and/or processing service providers, for payment processing;

6.1. - companies we merge with or acquire. In that case we will require the new combined entity to follow this Privacy Policy in respect of your personal data. If your personal data is to be used contrary to this policy, you will receive advance notice and will be able to opt out of the new combined entity's use of your personal data;

6.1. - in other cases provided for by applicable law.

6.2. The Company will not sell your personal data or allow third parties to use it for their own marketing purposes, and undertakes to share your personal data with third parties only as described in this Policy.

7. Processing of personal data

7.1. By registering on the Site, and by using its services without registration, under this Policy the User:

7.1. - consents to the use of their personal data and to its processing: collection, recording, systematisation, accumulation, storage, clarification (updating, amendment), retrieval, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion and destruction of any information relating directly or indirectly to the User, their operations and payments;

7.1. - confirms they are aware that personal data will be processed by the Service in the User's interests and for the purposes of providing the User with advice or clarifications and/or offering the User services provided by the Service and/or by persons on whose behalf the Service acts, and/or for the purposes of conducting surveys, questionnaires, advertising and marketing research relating to the services provided by the Service and/or by persons on whose behalf the Service acts, and for the purposes of informing about advertising and/or marketing campaigns run by the Service and/or the persons named above in relation to the services provided by the Service and by persons on whose behalf the Service acts, by contacting Users directly or by telephone, post, facsimile, email or other means of communication, and for the purposes of preparing to conclude, concluding, performing, amending and terminating contracts (agreements) between Users and the Service or persons on whose behalf the Service acts, including proper identification of the User, and for the purposes of preparing forms of applications, notices, agreements and contracts that do not in themselves result in the conclusion, termination or amendment of the relevant contract or agreement, and for other purposes consistent with the aims set out above.

7.2. The User confirms that they have been duly informed of the purposes for which their personal data is processed.

7.3. The User confirms that they have been notified that personal data is processed by the Service by any means, including both with automated tools (including software) and without them (using various physical media, including paper).

7.4. The User confirms that personal data may be processed both by the Service and by other persons who have entered into an agreement with the Service on terms of confidentiality and liability for disclosure of personal data.

7.5. This right (consent) is valid for 10 (ten) years and may be withdrawn by sending written notice to the Service. This consent is deemed withdrawn upon expiry of 30 (thirty) days from the date the Service receives the written notice of withdrawal. The day the notice is received is not counted within the thirty-day period.

7.6. The User understands that the Company also uses and processes cookies in accordance with the Cookie Policy.

8. Users' rights

8.1. In connection with your provision of personal information, the Company guarantees your rights in respect of personal data, in particular:

8.1. - the right to ask the Company to update and correct incomplete, inaccurate or out-of-date information;

8.1. - other actions within the requirements of data protection legislation.

8.2. During processing you have the right to restrict the processing of your personal data in the manner provided for by applicable law. However, in line with our legitimate interests, we may continue processing your data within a reasonable balance between your interests and those of the Company, and in the manner provided for by applicable law.

8.3. A data subject may at any time and without explanation withdraw the consent they have given and demand that processing cease and/or that the processed data be destroyed. In that case the Company undertakes, in accordance with the data subject's request, to block the User Account and cease processing the data and/or destroy the processed data within 5 days of the request being submitted, unless there is another ground for processing the data.

8.4. The provisions of clause 7.3 do not apply to personal data relating to completed transactions or to personal data collected by the Company for the purposes of complying with legislation on combating the laundering of unlawfully obtained income and the financing of terrorism. In that case the Company is entitled to retain such personal data and use it in the manner provided for by clause 5.1 of this Policy and by the Company's other Policies.

9. Protection of personal data

The Company takes the technical and organisational measures necessary to protect your personal data and prevent unauthorised access and processing, damage, loss, misuse and other unlawful forms of processing of the personal data provided to the Company.

10. Final provisions

10.1. The Company reserves the right to amend this Privacy Policy without prior notice to or consent from the User. The current version of the AML/KYC Policy is published on the website https://waltix.io/. The Company recommends that you review this Policy periodically for updates. If you disagree with any amendments, you should stop accessing the Site and cease using the Company's products/services.

10.2. Any clarifications, suggestions or questions regarding this Policy should be sent to: support@waltix.io.