Privacy Policy

Last Updated: 14 July, 2024

Privacy policy Apax Bit does its utmost to ensure the privacy, confidentiality and security of its clients are preserved both throughout their interaction with the company and afterwards, to the fullest extent achievable by the company. Apax Bit (“Apax Bit,” “we,” or “us”) is fully committed to protecting the privacy of our customers and takes our data protection responsibilities with the utmost seriousness.

1. General introduction. This Privacy Notice outlines the methods by which Apax Bit collects and processes your personal data through the Apax Bit websites and applications referenced herein. The Apax Bit ecosystem encompasses Apax Bit websites (including, but not limited to, www.bitgainpro.net), mobile applications, clients, applets, and other applications developed to provide Apax Bit Services.

By visiting, accessing, or using our Digital Asset Service platform and associated application program interfaces (API) or mobile applications (collectively referred to as the “Site”), you consent to the policies and practices outlined in our Privacy Policy, which explains how Apax Bit uses your Personal Data while providing access to our software, APIs, technologies, products, and functionalities (the “Service”), and ensures compliance with laws and protection of your privacy by not disclosing personal information to non-affiliated third parties except as described herein. Upon registration with Apax Bit, clients acknowledge their consent to share specific personal information with the company. This information is utilized for the purposes of verifying the client’s identity and ensuring the security of their transactions and accounts.

Failure to provide the required data will result in Apax Bit being unable to offer our services to you

2. Personal data collected and processed by Apax Bit

Information you provide to us. To create an account and access our services, you must provide certain information. This may be required by law and regulations, necessary for service provision or relevant for specified purposes. As we expand our services and features, additional information may be required.

Apax Bit collects, processes, and stores Personal Data obtained from your use of the Service or where you have provided your consent. This Personal Data may include:

Virtual Identity: Apax Bit Account number/ password, Apax Bit Nickname (Name)

Contact information: e-mail address, phone number, full legal name (including former name, and names in local language), country

Communications: feedback, e-mails, SMS, information provided to our support team

Device and Identifiers: the IP address, device brand, software version, model name

In addition, in order to stay in compliance to applicable Anti-Money Laundering laws and regulations, we may collect the following information:

General personal data: nationality, date of birth (“DOB”), proof of identity (government issued identity documents such as passport, national identification number, national identity card details, driver license numbers), proof of residency (residential address, utility bills, source of funds/source of wealth), additional personal data or documentation at the discretion of our Compliance department

Sensitive personal data, including facial recognition data or other data that may be used as a method of authentication on the Device used to access our services

Wallet Information. Wallet address, wallet ID, and other information related to integrations that you select. We may analyze public blockchain data, such as transaction ID’s, transaction amounts, wallet address, timestamps or transactions

Transaction Information: Account transaction history, trading data

Interests or inferred interests and marketing preferences.

Information we collect from our affiliates and third parties. In accordance with applicable law, we may obtain information about you from the group of companies related to us by common control or ownership (“Affiliates”) as a normal part of conducting business, so that we may offer our Affiliates’ Services to you.

During the Apax Bit verification process, whether completed, incomplete, or abandoned, we may collect information you provide. In offering services to residents of certain jurisdictions, we collect, store, and process your personal information in compliance with data protection laws, such as the General Data Protection Regulation (GDPR) and the Data Protection Act.

3. Purposes and legal justifications for Apax Bit’s processing and collection of personal data.

Apax Bit processes personal data primarily to provide our services in a secure, efficient, and seamless manner. We use your personal data to facilitate the delivery, operation, and management of our services, support content and advertising activities, and implement loss prevention and anti-fraud measures. Additionally, Apax Bit employs both automated tools and manual assessments to determine whether a transaction or customer account may present a fraud or legal risk, ensuring a comprehensive approach to security and compliance.

What are the reasons and legal grounds for Apax Bit’s processing of personal data? Legal basis for Our use of personal data (EEA and EU GDPR)

Managing our contractual relationship with you: This involves using your personal data to establish and maintain your account, including handling orders and processing payments. The categories of personal data processed include Personal Identification Data, Institutional Information, Contact Information, and Financial Information. Failure to process your personal data for these purposes will result in the inability to open or maintain an account with us. Processing is necessary for the fulfillment of a contractual obligation in which you are involved

To ensure adherence to legal and regulatory requirements. Our core services are governed by stringent laws and regulations mandating the collection, use, and storage of certain personal data, including Personal Identification identity information and, in some instances, Sensitive Personal Data (such as biometric data). This is essential to fulfill our Know Your Customer (“KYC”) obligations under applicable laws and regulations, particularly those concerning Anti-Money Laundering (AML) compliance.

The categories of personal data involved include Personal Identification Data, Institutional Information, Sensitive and Biometric Information, Government Identifiers, Contact Information, and Financial Information. Failure to provide legally required personal information may result in the inability to open an account or necessitate the closure of an existing account.

The processing of this data is imperative to comply with our legal obligations under relevant laws and regulations, including Anti-Money Laundering statutes.

Moreover, processing is justified by substantial public interest as delineated by EU or EU Member State law. We are bound by EU Anti-Money Laundering Directives and the corresponding laws of EU Member States.

Communication on service. We utilize your personal data to communicate with you concerning Apax Bit Services, including administrative or account-related information. These communications are essential to keep you informed about our Services, such as relevant security updates, and other necessary related information. Without these communications, you might miss crucial updates regarding your account, potentially affecting your ability to use our services. You cannot opt-out of receiving critical service communications, including emails or mobile notifications sent for legal or security purposes. This processing is necessary for the performance of a contract to which you are a party.

Provision of customer services. We process your personal data to support you when you contact us with questions, disputes, complaints, troubleshooting issues, and similar inquiries. The categories of personal data processed include Personal Identification Data, Institutional Information, Transactional Information, Communications, Contact Information, Financial Information, Browsing Information, and Usage Data. Without processing your personal data for this purpose, we cannot adequately respond to your requests. This processing is necessary to improve our services and enhance user experience.

Promotion of safety, security, and integrity. We process your personal data to enhance security, monitor and verify identity or service access, combat malware or security risks, and comply with applicable security laws and regulations. This includes verifying accounts and related activities, identifying and addressing violations of our Terms and Conditions, investigating suspicious activities, detecting, preventing, and combating unlawful behavior, detecting fraud, and maintaining the integrity of our Services. The categories of personal data processed include Personal Identification Information, Institutional Information, Transactional Information, Contact Information, Financial Information, Browsing Information, and Usage Data. Without processing your personal data, we may not be able to ensure the security of our Services.

Improvement of services and user experience. We use your personal data to provide functionality, analyze performance, fix errors, and improve the usability and effectiveness of Apax Bit Services.

Fraud prevention, detection, and credit risk management. We process various categories of personal data to facilitate the prevention, detection, and management of fraud and credit risks. This processing is vital to maintaining the safety, security, and integrity of our Services. Specifically, we utilize Personal Identification Data to detect, prevent, and mitigate fraud and abuse within our services, protect against account compromise or financial loss, and ensure the security of our users, Apax Bit services, and associated third parties. We may also employ scoring methods to assess and manage credit risks.

Please note that automated decision-making may be employed for risk and fraud detection purposes. In such instances, we implement appropriate measures to safeguard your rights, freedoms, and legitimate interests, including the right to request human intervention, express your viewpoint, and contest the decision.

The processing of this data is necessary for the legitimate interests pursued by us and our users, such as detecting and preventing fraud and abuse to protect the security of our users, ourselves, and others.

To deliver Apax Bit services, we process your personal data to facilitate service provision, order processing, and transaction completion as requested by users. Additionally, processing is necessary to serve our legitimate interests and yours by ensuring better documentation for your orders and transactions.

To utilize the services of social media platforms or advertising platforms for purposes including marketing. Apax Bit may periodically contact clients via phone or email to provide additional information regarding trading or financial market activities. Additionally, the company may occasionally reach out to clients through phone or email to inform them of exclusive promotional offers available from Apax Bit.

To enhance our services. We process personal data to refine our services and ensure you have an enhanced user experience.

To furnish you with promotions. We use your information to offer promotions, including offers, rewards, and other incentives for utilizing our services. This also encompasses enabling your participation in prize draws, competitions, or the completion of surveys.

For individuals who are not users, processing is necessary to fulfill our legitimate interests and to support your interest in rewarding customer loyalty.

For users, we rely on your explicit consent to process your personal data for the purpose of providing promotions. Upon granting consent for a specific purpose, you retain the right to withdraw your consent at any time, at which point we will cease processing your personal information for that purpose. Please note that the withdrawal of consent does not affect the legality of processing conducted based on your consent prior to its withdrawal.

To conduct research and foster innovation. We perform surveys to gain insights into your experience with our services. Additionally, we utilize your information to support research and development initiatives and to drive innovations in our services and products. This information may also be used for marketing purposes.

Recommendations and personalization. We utilize your personal information to recommend features and services that may be of interest to you, to identify your preferences, and to personalize your experience with Apax Bit services.

To deliver marketing communications to you. We utilize your information, with your consent, to send targeted marketing communications via email, mobile, in-app, and push notifications. We also use your information to conduct profiling for marketing purposes. Where required by applicable law, we rely on your consent to process your personal information for marketing purposes. You may withdraw your consent at any time, and we will cease processing your personal information for the specified purpose. The withdrawal of consent does not affect the legality of processing based on consent prior to its withdrawal.

Where profiling for marketing purposes is conducted, such as determining which services or promotions may interest you, this processing is based on our legitimate interest. Please note that transactional account messages and communications regarding our business relationship will remain unaffected even if you opt out of marketing communications.

To adhere to legal and regulatory obligations. We may access, review, retain, and disclose information when we reasonably believe it is necessary to comply with laws, legal obligations, regulations, law enforcement requests, governmental requirements, court orders, or disclosures to tax authorities, in accordance with the detailed information provided under Section 5.

4. Underage Users.

Apax Bit prohibits anyone under the age of 18 from using Apax Bit Services and does not knowingly request or collect any information from individuals under this age. If you are under 18, please refrain from providing any personal information to Apax Bit Services.

Should it be suspected that a User or Customer submitting personal information is under 18 years of age, Apax Bit will require the relevant User or Customer to close their account and will promptly take measures to delete the individual’s information.

5. Methods and justifications for disseminating and personal data

Personal data may be conveyed to external parties, including other Apax Bit entities, if it is determined that such dissemination is consistent with, or mandated by, any contractual agreement (including Apax Bit Terms & Conditions), applicable legislation, regulatory requirements, or legal proceedings. When disseminating personal data to other Apax Bit entities, every reasonable effort will be made to ensure that these entities either comply with this Privacy Notice or adopt practices that are equally protective. For example, data may be transmitted based on jurisdiction and the entity responsible for executing KYC checks.

Personal data may also be conveyed to the following entities or under the following conditions:

Affiliates: Personal data collected and processed may be exchanged among Apax Bit companies as part of standard business operations and to render services.

Third Parties: External companies and individuals are engaged to undertake tasks on behalf of Apax Bit, such as data analytics, marketing assistance, payment processing, content delivery, and credit risk evaluation and management. These third-party service providers are granted access only to the personal data required for their functions and are prohibited from utilizing it for any other purposes. They are obligated to handle personal data in accordance with contractual agreements and applicable data protection laws. Additionally, in compliance with relevant legislation, personal data may be transferred to third parties (i.e., another data controller) when exercising the right to data portability. When third-party services are employed or websites are linked through Apax Bit services, those service or product providers may receive information shared by Apax Bit, users, or others. Note that third-party services or Apax Bit affiliate services not governed by this Privacy Policy are subject to their respective terms and privacy policies.

Legal Authorities: Data may be disclosed to courts, law enforcement agencies, regulatory bodies, or other entities: (1) to comply with laws and legal obligations; (2) for the establishment, exercise, or defense of legal or equitable claims; (3) to respond to requests from law enforcement and regulatory bodies, including international requests under a mutual legal assistance treaty (MLAT) or letters of request; (4) to comply with regulatory requirements that necessitate the transmission of data to another financial institution, regulatory bodies, or industry partners; (5) when disclosure is imperative to protect the rights, property, or safety of customers, Apax Bit, or others, including the prevention of imminent physical harm or significant financial loss; (6) to investigate breaches of Terms of Service or other applicable policies; or (7) to detect, investigate, prevent, or address fraud, credit risk, illegal activity, or security and technical issues, and to report suspected illegal activity or assist law enforcement in their investigations.

With Consent: Personal data may also be disclosed as specified in a notice at the time of collection or before sharing, or in any manner to which consent is given.

Apax Bit will neither provide, sell, lease, share, nor trade personal information to any unrelated third party, except with prior consent, or in instances where the third party, along with Apax Bit (including its affiliates), has provided services. Upon the conclusion of such services, access to personal information, including any previously accessible information, will be revoked. Furthermore, Apax Bit strictly prohibits third parties from collecting, editing, selling, or distributing personal information by any means. Should any Apax Bit user engage in such activities, Apax Bit reserves the right to immediately terminate the service agreement with the user upon discovery.

6. Cross-border transfers of personal information

To support global operations, Apax Bit may transfer personal data outside the European Economic Area (“EEA”), the United Kingdom, and Switzerland. The EEA includes the member states of the European Union, as well as Iceland, Liechtenstein, and Norway. Transfers beyond the EEA are referred to as “third country transfers.” Transfers of personal data may occur to Apax Bit Affiliates, third-party partners, and service providers located globally. When transferring personal data to third countries or international organizations outside the EEA, Apax Bit establishes appropriate technical, organizational, and contractual safeguards, including Standard Contractual Clauses, to ensure compliance with applicable data protection laws.

EU-only provisions

The provisions set forth in this section are exclusively applicable to users located within the European Union (“EU”). These provisions shall take precedence over any conflicting provisions within the remainder of this Privacy Policy.

Personal Data may be transferred outside the EU. In such instances, all reasonable precautions are taken to apply appropriate or suitable safeguards as prescribed by the General Data Protection Regulation (GDPR). For example, measures such as appropriate contractual clauses have been implemented to ensure that recipients of such transfers protect and handle personal data in accordance with all applicable personal data protection laws.

Pursuant to the GDPR, individuals are entitled to exercise the following rights:

1. a) The right to access personal information concerning themselves, to correct or rectify inaccurate information, and, where applicable, to object to data processing; b) The right to erasure of data that have been collected solely based on consent or that are no longer necessary for the purposes for which they were collected; c) The right to restrict processing when such data are no longer necessary for the purposes for which they were collected; d) The right to receive personal information in a structured, commonly used, and machine-readable format; e) The right to withdraw consent at any time without any detriment, provided that the processing of personal data is based exclusively on consent.

Hong Kong-Specific provisions

(1) Transfers of Personal Data out of Hong Kong:

Apax Bit may transfer your Personal Data from Hong Kong to a jurisdiction or territory outside Hong Kong under any of the following conditions:

(a) Apax Bit has reasonable grounds to believe that the jurisdiction or territory has in force a law that is substantially similar to, or serves the same purposes as, PDPO;

(b) The data subject has consented to such transfer (which consent is hereby granted if not previously provided).

(2) Apax Bit has reasonable grounds to believe that, under all the circumstances of the case:

(a) Such transfer is necessary for the avoidance or mitigation of adverse action against the data subject;

(b) It is impracticable to obtain the data subject’s written consent for such transfer; and

(c) If it were practicable to obtain such consent, the data subject would provide it.

(3) The data subject’s Personal Data is exempt from Data Protection Principle 3 (as defined in Schedule 1 of the PDPO) by virtue of an exemption under Part 8 of the PDPO.

Apax Bit has taken all reasonable precautions and exercised due diligence to ensure that the data subject’s Personal Data will not, in the destination jurisdiction, be collected, held, processed, or used in any manner that would contravene a requirement under the PDPO if the jurisdiction were Hong Kong.

7. Information storage and collection of personal data

The information and materials collected from you will be maintained on servers operated by Apax Bit and/or its affiliated entities. This data may be transferred to, accessed, stored, and displayed in countries, regions, or locations outside the jurisdiction where the data was initially collected. By providing your personal data, you consent to this international transfer, storage, and processing.

The majority of the personal information collected will be directly provided by the user. The following circumstances outline when information will be collected and processed:

(1) Upon online registration, login, access to Apax Bit, or utilization of any Apax Bit service;

(2) When the user voluntarily completes any user survey or provides feedback through email or any other communication channel;

(3) Through cookies via the user’s browser or software during the usage or browsing of Apax Bit web pages or clients;

(4) Any other self-collection scenarios specified in this agreement.

Additionally, information may be acquired from public sources or third-party channels, including but not limited to advertising and market research partners, for the purposes of updating or supplementing the information already collected about the user.

Apax Bit retains personal data to ensure the continued provision of services, for as long as necessary to fulfill the purposes outlined in this Privacy Notice, and as mandated by law for purposes such as tax and accounting, compliance with Anti-Money Laundering legislation, or to resolve disputes and legal claims, or as otherwise communicated. Although retention requirements differ by jurisdiction, typical retention periods for various categories of personal data are detailed below.

Personal Identifiable Data collected in compliance with legal obligations under financial or anti-money laundering laws may be retained post-account closure for the duration required by such laws.

Contact Information, including name, email address, and telephone number, retained for marketing purposes, is maintained on an ongoing basis until such time as either the individual unsubscribes or the account is deleted. Subsequently, details are added to an unsubscribed list to prevent inadvertent marketing communications.

Data posted on the website, including support communications, photographs, videos, and other information, may be retained post-account closure for auditing and crime prevention purposes.

Information collected through cookies, web page counters, and other analytics tools is retained for a maximum period of one year from the date of collection of the respective cookie.

8. Measures are implemented to ensure information security.

Systems are meticulously engineered with an emphasis on security and privacy. Robust security measures have been instituted to prevent information from being accidentally lost, misused, accessed without authorization, altered, or disclosed. To ensure the protection of personal data during transmission and storage, advanced encryption protocols and software are utilized. Furthermore, stringent physical, electronic, and procedural safeguards are maintained in relation to the collection, storage, and dissemination of personal data.

Access to personal data is strictly limited to employees, agents, contractors, and third parties who possess a legitimate business necessity. Security procedures may require identity verification to safeguard against unauthorized access to accounts. It is strongly recommended to create a unique password for the Apax Bit account that is not employed for any other online accounts and to log out when using a shared computer.

9. Access, rectification, erasure, and other rights pertaining to your personal information.

Subject to applicable law, as outlined below, you have a number of rights in relation to your privacy and the protection of your Personal Data. You have the right to request access to, correct, and delete your Personal Data, and to ask for data portability. You may also object to our processing of your Personal Data or ask that we restrict the processing of your Personal Data in certain instances. In addition, when you consent to our processing of your Personal Data for a specified purpose, you may withdraw your consent at any time. If you want to exercise any of your rights outlined below, please contact our Data Protection Officer by email via: support@bitgainpro.net. These rights may be limited in some situations – for example, where we are required by applicable laws or AML compliance practices to process your Personal Data.

-Right to access: you have the right to obtain confirmation that your Personal Data are processed and to obtain a copy of it as well as certain information related to its processing;

-Right to rectify: you can request the rectification of your Personal Data which are inaccurate, and also add to it. You can also change your Personal Data in your Account at any time.

-Right to delete: you can, in some cases, have your Personal Data deleted;

-Right to object: you can object, for reasons relating to your particular situation, to the processing of your Personal Data. For instance, you have the right to object where we rely on legitimate interest or where we process your Personal Data for direct marketing purposes;

-Right to restrict processing: You have the right, in certain cases, to temporarily restrict the processing of your Personal Data by us, provided there are valid grounds for doing so. We may continue to process your Personal Data if it is necessary for the defense of legal claims, or for any other reasons permitted by applicable law;

-Right to portability: in some cases, you can ask to receive your Personal Data which you have provided to us in a structured, commonly used and machine-readable format, or, when this is possible, that we communicate your Personal Data on your behalf directly to another data controller;

-Right to withdraw your consent: for processing requiring your consent, you have the right to withdraw your consent at any time. Exercising this right does not affect the lawfulness of the processing based on the consent given before the withdrawal of the latter.

Exercising your rights above may impact the form and substance of the Services we provide to you, and in some circumstances, such exercise may mean that we will not be able to continue providing the Services to you, and we may need to terminate the contract you have with us.

We may charge you a reasonable fee for the handling and processing of your requests to access your personal data. If we choose to charge a fee, we will provide you with a written estimate of the fee that we will be charging. Please note that we are not required to respond to or deal with your request for access unless you have agreed to pay the fee.

10. Cookies.

Implementation of Cookies: When accessing the Platform, Google Stats will deploy Cookies to monitor the Platform’s performance and assess the efficacy of online advertising. Cookies are small data files sent to the user’s browser and saved on the computer’s hard drive. These Cookies are transmitted to the computer’s hard drive only when the Platform is accessed via the user’s computer.

Purpose of Cookies: Cookies are often used to record the behaviors and preferences of visitors as they explore various elements on the Platform. Cookies gather anonymous aggregate statistics that do not include Personal Data. Cookies cannot be used to retrieve information from the user’s hard drive, email address, or Personal Data. They enable the Platform or a service provider’s system to identify the user’s web browser and to capture and remember certain details.

Disabling Cookies: Most web browsers are preset to accept Cookies. Users can configure their web browsers to reject Cookies or to notify them when Cookies are being installed. It should be noted that disabling Cookies may hinder the ability to initiate or use specific features of the Platform. If Cookies are rejected, logging in or using Platform services or functionalities that rely on such Cookies may not be possible. This provision applies to any relevant information acquired through Cookies as stipulated by Apax Bit.

11. Access, correction, and deletion of your personal data

Subject to exceptions set out in the law, you have the right to obtain a copy of your Personal Data upon request and ascertain whether the information we hold about you is accurate and up-to-date. We will provide access within 60 days of your request. If we refuse to provide the information, we will provide reasons for the refusal. We will require identity verification and specification of what information is required before providing you with access. If any of your Personal Data is inaccurate, you may request to update your information. Where we are satisfied that the request to update the information is accurate, we will take reasonable steps to correct the information within 60 days, unless you agree otherwise. If you are entitled by law, you may request to delete your Personal Data, with the exception that we may refuse your deletion request in certain circumstances, such as compliance with law or legal purposes. For data access, correction, or deletion requests, or to request withdrawal of your previously provided consent, please send an email with your request via email address: support@bitgainpro.net

12. Account cancellation.

You may cancel your Apax Bit account at any time, the consequences of account cancellation include but not limited to the following:

(1) You will lose all digital assets and data contained in this account.

(2) You will not be able to recover the personal information, transaction records, business data, and historical information under the account.

(3) You will not be able to use this account to log in to Apax Bit’s services.

IMPORTANT

The account cannot be recovered once it is deleted. To protect your rights, we will remind you of the risks again after you request to cancel an account. The deletion of your account does not mean that all your account operations and responsibilities before account deletion are exempted or mitigated. All records and information associated with your account will be deleted. However, we may retain certain information about your account as required by applicable law and regulations.

13. Announcements and updates

For any privacy concerns related to Apax Bit, please contact us, and we will endeavor to resolve the issue. As our Service evolves, modifications to our Privacy Policy may also occur. It is advisable to frequently review our website for the latest updates. The “Last Updated” date at the beginning of this Privacy Policy will be revised accordingly. Any significant changes to this Privacy Notice will be announced on our Platform. Continued use of Apax Bit following changes to this Privacy Notice signifies understanding and acceptance of these changes. Unless specified otherwise, the most recent version of our Privacy Policy applies to all information held concerning you and your account.

14. Contact Information

When handling requests to exercise your privacy rights, we check the identity of the requesting party to ensure that he or she is the person legally entitled to make such a request. While we endeavor to respond to these requests free of charge, should your request be repetitive or unduly onerous, we reserve the right to charge you a reasonable fee (if applicable) for compliance with your request.

The Data Protection Officer may be reached through the webform provided on the website or via email and will address any inquiries or concerns regarding the collection and processing of personal data.

For inquiries related to account management or Apax Bit products and services, the Data Protection Officer will not be able to provide assistance. In such instances, please direct your queries to our Customer Support team via email: support@bitgainpro.net

15. Languages

This Privacy Policy may be issued in multiple languages. In the event of any inconsistency or discrepancy, the English version shall take precedence and be the authoritative version.

Last Updated: 14 July, 2024

Privacy policy Apax Bit does its utmost to ensure the privacy, confidentiality and security of its clients are preserved both throughout their interaction with the company and afterwards, to the fullest extent achievable by the company. Apax Bit (“Apax Bit,” “we,” or “us”) is fully committed to protecting the privacy of our customers and takes our data protection responsibilities with the ultimate seriousness.

1. General introduction. This Privacy Notice outlines the methods by which Apax Bit collects and processes your personal data through the Apax Bit websites and applications referenced herein. The Apax Bit ecosystem encompasses Apax Bit websites (including, but not limited to, www.Apax Bit.com/en), mobile applications, clients, applets, and other applications developed to provide Apax Bit Services.

By visiting, accessing, or using our Digital Asset Service platform and associated application program interfaces (API) or mobile applications (collectively referred to as the “Site”), you consent to the policies and practices outlined in our Privacy Policy, which explains how Apax Bit uses your Personal Data while providing access to our software, APIs, technologies, products, and functionalities (the “Service”), and ensures compliance with laws and protection of your privacy by not disclosing personal information to non-affiliated third parties except as described herein.Upon registration with Apax Bit, clients acknowledge their consent to share specific personal information with the company. This information is utilized for the purposes of verifying the client’s identity and ensuring the security of their transactions and and accounts.

Failure to provide the required data will result in Apax Bit being unable to offer our services to you

2. Personal data collected and processed by Apax Bit

Information you provide to us. To create an account and access our services, you must provide certain information. This may be required by law and regulations, necessary for service provision or relevant for specified purposes. As we expand our services and features, additional information may be required.

Apax Bit collects, processes, and stores Personal Data obtained from your use of the Service or where you have provided your consent. This Personal Data may include:

Virtual Identity: Apax Bit Account number/ password, Apax Bit Nickname (Name)

Contact information: e-mail address, phone number, full legal name (including former name, and names in local language), country

Communications: feedback, e-mails, SMS, information provided to our support team

Device and Identifiers: the IP address, device brand, software version, model name

In addition, in order to stay in compliance to applicable Anti-Money Laundering laws and regulations, we may collect the following information:

General personal data: nationality, date of birth (“DOB”), proof of identity (government issued identity documents such as passport, national identification number, national identity card details, driver license numbers), proof of residency (residential address, utility bills, source of funds/source of wealth), additional personal data or documentation at the discretion of our Compliance department

Sensitive personal data, including facial recognition data or other data that may be used as a method of authentication on the Device used to access our services

Wallet Information. Wallet address, wallet ID, and other information related to integrations that you select. We may analyze public blockchain data, such as transaction ID’s, transaction amounts, wallet address, timestamps or transactions

Transaction Information: Account transaction history, trading data

Interests or inferred interests and marketing preferences.

Information we collect from our affiliates and third parties. In accordance with applicable law, we may obtain information about you from the group of companies related to us by common control or ownership (“Affiliates”) as a normal part of conducting business, so that we may offer our Affiliates’ Services to you.

During the Apax Bit verification process, whether completed, incomplete, or abandoned, we may collect information you provide. In offering services to residents of certain jurisdictions, we collect, store, and process your personal information in compliance with data protection laws, such as the General Data Protection Regulation (GDPR) and the Data Protection Act.

3. Purposes and legal justifications for Apax Bit’s processing and collection of personal data.

Apax Bit processes personal data primarily to provide our services in a secure, efficient, and seamless manner. We use your personal data to facilitate the delivery, operation, and management of our services, support content and advertising activities, and implement loss prevention and anti-fraud measures. Additionally, Apax Bit employs both automated tools and manual assessments to determine whether a transaction or customer account may present a fraud or legal risk, ensuring a comprehensive approach to security and compliance.

What are the reasons and legal grounds for Apax Bit’s processing of personal data? Legal basis for Our use of personal data (EEA and EU GDPR)

Managing our contractual relationship with you: This involves using your personal data to establish and maintain your account, including handling orders and processing payments. The categories of personal data processed include Personal Identification Data, Institutional Information, Contact Information, and Financial Information. Failure to process your personal data for these purposes will result in the inability to open or maintain an account with us. Processing is necessary for the fulfillment of a contractual obligation in which you are involved

To ensure adherence to legal and regulatory requirements. Our core services are governed by stringent laws and regulations mandating the collection, use, and storage of certain personal data, including Personal Identification identity information and, in some instances, Sensitive Personal Data (such as biometric data). This is essential to fulfill our Know Your Customer (“KYC”) obligations under applicable laws and regulations, particularly those concerning Anti-Money Laundering (AML) compliance.

The categories of personal data involved include Personal Identification Data, Institutional Information, Sensitive and Biometric Information, Government Identifiers, Contact Information, and Financial Information. Failure to provide legally required personal information may result in the inability to open an account or necessitate the closure of an existing account.

The processing of this data is imperative to comply with our legal obligations under relevant laws and regulations, including Anti-Money Laundering statutes.

Moreover, processing is justified by substantial public interest as delineated by EU or EU Member State law. We are bound by EU Anti-Money Laundering Directives and the corresponding laws of EU Member States.

Communication on service. We utilize your personal data to communicate with you concerning Apax Bit Services, including administrative or account-related information. These communications are essential to keep you informed about our Services, such as relevant security updates, and other necessary related information. Without these communications, you might miss crucial updates regarding your account, potentially affecting your ability to use our services. You cannot opt-out of receiving critical service communications, including emails or mobile notifications sent for legal or security purposes. This processing is necessary for the performance of a contract to which you are a party.

Provision of customer services. We process your personal data to support you when you contact us with questions, disputes, complaints, troubleshooting issues, and similar inquiries. The categories of personal data processed include Personal Identification Data, Institutional Information, Transactional Information, Communications, Contact Information, Financial Information, Browsing Information, and Usage Data. Without processing your personal data for this purpose, we cannot adequately respond to your requests. This processing is necessary to improve our services and enhance user experience.

Promotion of safety, security, and integrity. We process your personal data to enhance security, monitor and verify identity or service access, combat malware or security risks, and comply with applicable security laws and regulations. This includes verifying accounts and related activities, identifying and addressing violations of our Terms and Conditions, investigating suspicious activities, detecting, preventing, and combating unlawful behavior, detecting fraud, and maintaining the integrity of our Services. The categories of personal data processed include Personal Identification Information, Institutional Information, Transactional Information, Contact Information, Financial Information, Browsing Information, and Usage Data. Without processing your personal data, we may not be able to ensure the security of our Services.

Improvement of services and user experience. We use your personal data to provide functionality, analyze performance, fix errors, and improve the usability and effectiveness of Apax Bit Services.

Fraud prevention, detection, and credit risk management. We process various categories of personal data to facilitate the prevention, detection, and management of fraud and credit risks. This processing is vital to maintaining the safety, security, and integrity of our Services. Specifically, we utilize Personal Identification Data to detect, prevent, and mitigate fraud and abuse within our services, protect against account compromise or financial loss, and ensure the security of our users, Apax Bit services, and associated third parties. We may also employ scoring methods to assess and manage credit risks.

Please note that automated decision-making may be employed for risk and fraud detection purposes. In such instances, we implement appropriate measures to safeguard your rights, freedoms, and legitimate interests, including the right to request human intervention, express your viewpoint, and contest the decision.

The processing of this data is necessary for the legitimate interests pursued by us and our users, such as detecting and preventing fraud and abuse to protect the security of our users, ourselves, and others.

To deliver Apax Bit services, we process your personal data to facilitate service provision, order processing, and transaction completion as requested by users. Additionally, processing is necessary to serve our legitimate interests and yours by ensuring better documentation for your orders and transactions.

To utilize the services of social media platforms or advertising platforms for purposes including marketing. Apax Bit may periodically contact clients via phone or email to provide additional information regarding trading or financial market activities. Additionally, the company may occasionally reach out to clients through phone or email to inform them of exclusive promotional offers available from Apax Bit.

To enhance our services. We process personal data to refine our services and ensure you have an enhanced user experience.

To furnish you with promotions. We use your information to offer promotions, including offers, rewards, and other incentives for utilizing our services. This also encompasses enabling your participation in prize draws, competitions, or the completion of surveys.

For individuals who are not users, processing is necessary to fulfill our legitimate interests and to support your interest in rewarding customer loyalty.

For users, we rely on your explicit consent to process your personal data for the purpose of providing promotions. Upon granting consent for a specific purpose, you retain the right to withdraw your consent at any time, at which point we will cease processing your personal information for that purpose. Please note that the withdrawal of consent does not affect the legality of processing conducted based on your consent prior to its withdrawal.

To conduct research and foster innovation. We perform surveys to gain insights into your experience with our services. Additionally, we utilize your information to support research and development initiatives and to drive innovations in our services and products. This information may also be used for marketing purposes.

Recommendations and personalization. We utilize your personal information to recommend features and services that may be of interest to you, to identify your preferences, and to personalize your experience with Apax Bit services.

To deliver marketing communications to you. We utilize your information, with your consent, to send targeted marketing communications via email, mobile, in-app, and push notifications. We also use your information to conduct profiling for marketing purposes. Where required by applicable law, we rely on your consent to process your personal information for marketing purposes. You may withdraw your consent at any time, and we will cease processing your personal information for the specified purpose. The withdrawal of consent does not affect the legality of processing based on consent prior to its withdrawal.

Where profiling for marketing purposes is conducted, such as determining which services or promotions may interest you, this processing is based on our legitimate interest. Please note that transactional account messages and communications regarding our business relationship will remain unaffected even if you opt out of marketing communications.

To adhere to legal and regulatory obligations. We may access, review, retain, and disclose information when we reasonably believe it is necessary to comply with laws, legal obligations, regulations, law enforcement requests, governmental requirements, court orders, or disclosures to tax authorities, in accordance with the detailed information provided under Section WWWW.

4. Underage Users. Apax Bit prohibits anyone under the age of 18 from using Apax Bit Services and does not knowingly request or collect any information from individuals under this age. If you are under 18, please refrain from providing any personal information to Apax Bit Services.

Should it be suspected that a User or Customer submitting personal information is under 18 years of age, Apax Bit will require the relevant User or Customer to close their account and will promptly take measures to delete the individual’s information.

5. Methods and justifications for disseminating personal data

Personal data may be conveyed to external parties, including other Apax Bit entities, if it is determined that such dissemination is consistent with, or mandated by, any contractual agreement (including Apax Bit Terms & Conditions), applicable legislation, regulatory requirements, or legal proceedings. When disseminating personal data to other Apax Bit entities, every reasonable effort will be made to ensure that these entities either comply with this Privacy Notice or adopt practices that are equally protective. For example, data may be transmitted based on jurisdiction and the entity responsible for executing KYC checks.

Personal data may also be conveyed to the following entities or under the following conditions:

Affiliates: Personal data collected and processed may be exchanged among Apax Bit companies as part of standard business operations and to render services.

Third Parties: External companies and individuals are engaged to undertake tasks on behalf of Apax Bit, such as data analytics, marketing assistance, payment processing, content delivery, and credit risk evaluation and management. These third-party service providers are granted access only to the personal data required for their functions and are prohibited from utilizing it for any other purposes. They are obligated to handle personal data in accordance with contractual agreements and applicable data protection laws. Additionally, in compliance with relevant legislation, personal data may be transferred to third parties (i.e., another data controller) when exercising the right to data portability. When third-party services are employed or websites are linked through Apax Bit services, those service or product providers may receive information shared by Apax Bit, users, or others. Note that third-party services or Apax Bit affiliate services not governed by this Privacy Policy are subject to their respective terms and privacy policies.

Legal Authorities: Data may be disclosed to courts, law enforcement agencies, regulatory bodies, or other entities: (1) to comply with laws and legal obligations; (2) for the establishment, exercise, or defense of legal or equitable claims; (3) to respond to requests from law enforcement and regulatory bodies, including international requests under a mutual legal assistance treaty (MLAT) or letters of request; (4) to comply with regulatory requirements that necessitate the transmission of data to another financial institution, regulatory bodies, or industry partners; (5) when disclosure is imperative to protect the rights, property, or safety of customers, Apax Bit, or others, including the prevention of imminent physical harm or significant financial loss; (6) to investigate breaches of Terms of Service or other applicable policies; or (7) to detect, investigate, prevent, or address fraud, credit risk, illegal activity, or security and technical issues, and to report suspected illegal activity or assist law enforcement in their investigations.

With Consent: Personal data may also be disclosed as specified in a notice at the time of collection or before sharing, or in any manner to which consent is given.

Apax Bit will neither provide, sell, lease, share, nor trade personal information to any unrelated third party, except with prior consent, or in instances where the third party, along with Apax Bit (including its affiliates), has provided services. Upon the conclusion of such services, access to personal information, including any previously accessible information, will be revoked. Furthermore, Apax Bit strictly prohibits third parties from collecting, editing, selling, or distributing personal information by any means. Should any Apax Bit user engage in such activities, Apax Bit reserves the right to immediately terminate the service agreement with the user upon discovery.

6. Cross-border transfers of personal information

To support global operations, Apax Bit may transfer personal data outside the European Economic Area (“EEA”), the United Kingdom, and Switzerland. The EEA includes the member states of the European Union, as well as Iceland, Liechtenstein, and Norway. Transfers beyond the EEA are referred to as “third country transfers.” Transfers of personal data may occur to Apax Bit Affiliates, third-party partners, and service providers located globally. When transferring personal data to third countries or international organizations outside the EEA, Apax Bit establishes appropriate technical, organizational, and contractual safeguards, including Standard Contractual Clauses, to ensure compliance with applicable data protection laws.

EU-only provisions

The provisions set forth in this section are exclusively applicable to users located within the European Union (“EU”). These provisions shall take precedence over any conflicting provisions within the remainder of this Privacy Policy.

Personal Data may be transferred outside the EU. In such instances, all reasonable precautions are taken to apply appropriate or suitable safeguards as prescribed by the General Data Protection Regulation (GDPR). For example, measures such as appropriate contractual clauses have been implemented to ensure that recipients of such transfers protect and handle personal data in accordance with all applicable personal data protection laws.

Pursuant to the GDPR, individuals are entitled to exercise the following rights:

1. a) The right to access personal information concerning themselves, to correct or rectify inaccurate information, and, where applicable, to object to data processing; b) The right to erasure of data that have been collected solely based on consent or that are no longer necessary for the purposes for which they were collected; c) The right to restrict processing when such data are no longer necessary for the purposes for which they were collected; d) The right to receive personal information in a structured, commonly used, and machine-readable format; e) The right to withdraw consent at any time without any detriment, provided that the processing of personal data is based exclusively on consent.

Hong Kong-Specific provisions

(1) Transfers of Personal Data out of Hong Kong:

Apax Bit may transfer your Personal Data from Hong Kong to a jurisdiction or territory outside Hong Kong under any of the following conditions:

(a) Apax Bit has reasonable grounds to believe that the jurisdiction or territory has in force a law that is substantially similar to, or serves the same purposes as, PDPO;

(b) The data subject has consented to such transfer (which consent is hereby granted if not previously provided).

(2) Apax Bit has reasonable grounds to believe that, under all the circumstances of the case:

(a) Such transfer is necessary for the avoidance or mitigation of adverse action against the data subject;

(b) It is impracticable to obtain the data subject’s written consent for such transfer; and

(c) If it were practicable to obtain such consent, the data subject would provide it.

(3) The data subject’s Personal Data is exempt from Data Protection Principle 3 (as defined in Schedule 1 of the PDPO) by virtue of an exemption under Part 8 of the PDPO.

Apax Bit has taken all reasonable precautions and exercised due diligence to ensure that the data subject’s Personal Data will not, in the destination jurisdiction, be collected, held, processed, or used in any manner that would contravene a requirement under the PDPO if the jurisdiction were Hong Kong.

7. Information storage and collection of personal data

The information and materials collected from you will be maintained on servers operated by Apax Bit and/or its affiliated entities. This data may be transferred to, accessed, stored, and displayed in countries, regions, or locations outside the jurisdiction where the data was initially collected. By providing your personal data, you consent to this international transfer, storage, and processing.

The majority of the personal information collected will be directly provided by the user. The following circumstances outline when information will be collected and processed:

(1) Upon online registration, login, access to Apax Bit, or utilization of any Apax Bit service;

(2) When the user voluntarily completes any user survey or provides feedback through email or any other communication channel;

(3) Through cookies via the user’s browser or software during the usage or browsing of Apax Bit web pages or clients;

(4) Any other self-collection scenarios specified in this agreement.

Additionally, information may be acquired from public sources or third-party channels, including but not limited to advertising and market research partners, for the purposes of updating or supplementing the information already collected about the user.

Apax Bit retains personal data to ensure the continued provision of services, for as long as necessary to fulfill the purposes outlined in this Privacy Notice, and as mandated by law for purposes such as tax and accounting, compliance with Anti-Money Laundering legislation, or to resolve disputes and legal claims, or as otherwise communicated. Although retention requirements differ by jurisdiction, typical retention periods for various categories of personal data are detailed below.

Personal Identifiable Data collected in compliance with legal obligations under financial or anti-money laundering laws may be retained post-account closure for the duration required by such laws.

Contact Information, including name, email address, and telephone number, retained for marketing purposes, is maintained on an ongoing basis until such time as either the individual unsubscribes or the account is deleted. Subsequently, details are added to an unsubscribed list to prevent inadvertent marketing communications.

Data posted on the website, including support communications, photographs, videos, and other information, may be retained post-account closure for auditing and crime prevention purposes.

Information collected through cookies, web page counters, and other analytics tools is retained for a maximum period of one year from the date of collection of the respective cookie.

8.Measures are implemented to ensure information security. Systems are meticulously engineered with an emphasis on security and privacy. Robust security measures have been instituted to prevent information from being accidentally lost, misused, accessed without authorization, altered, or disclosed. To ensure the protection of personal data during transmission and storage, advanced encryption protocols and software are utilized. Furthermore, stringent physical, electronic, and procedural safeguards are maintained in relation to the collection, storage, and dissemination of personal data.

Access to personal data is strictly limited to employees, agents, contractors, and third parties who possess a legitimate business necessity. Security procedures may require identity verification to safeguard against unauthorized access to accounts. It is strongly recommended to create a unique password for the Apax Bit account that is not employed for any other online accounts and to log out when using a shared computer.

9. Access, rectification, erasure, and other rights pertaining to your personal information.

Subject to applicable law, as outlined below, you have a number of rights in relation to your privacy and the protection of your Personal Data. You have the right to request access to, correct, and delete your Personal Data, and to ask for data portability. You may also object to our processing of your Personal Data or ask that we restrict the processing of your Personal Data in certain instances. In addition, when you consent to our processing of your Personal Data for a specified purpose, you may withdraw your consent at any time. If you want to exercise any of your rights outlined below, please contact our Data Protection Officer by email via: support@bitgainpro.net. These rights may be limited in some situations – for example, where we are required by applicable laws or AML compliance practices to process your Personal Data.

-Right to access: you have the right to obtain confirmation that your Personal Data are processed and to obtain a copy of it as well as certain information related to its processing;

-Right to rectify: you can request the rectification of your Personal Data which are inaccurate, and also add to it. You can also change your Personal Data in your Account at any time.

-Right to delete: you can, in some cases, have your Personal Data deleted;

-Right to object: you can object, for reasons relating to your particular situation, to the processing of your Personal Data. For instance, you have the right to object where we rely on legitimate interest or where we process your Personal Data for direct marketing purposes;

-Right to restrict processing: You have the right, in certain cases, to temporarily restrict the processing of your Personal Data by us, provided there are valid grounds for doing so. We may continue to process your Personal Data if it is necessary for the defense of legal claims, or for any other reasons permitted by applicable law;

-Right to portability: in some cases, you can ask to receive your Personal Data which you have provided to us in a structured, commonly used and machine-readable format, or, when this is possible, that we communicate your Personal Data on your behalf directly to another data controller;

-Right to withdraw your consent: for processing requiring your consent, you have the right to withdraw your consent at any time. Exercising this right does not affect the lawfulness of the processing based on the consent given before the withdrawal of the latter.

Exercising your rights above may impact the form and substance of the Services we provide to you, and in some circumstances, such exercise may mean that we will not be able to continue providing the Services to you, and we may need to terminate the contract you have with us.

We may charge you a reasonable fee for the handling and processing of your requests to access your personal data. If we choose to charge a fee, we will provide you with a written estimate of the fee that we will be charging. Please note that we are not required to respond to or deal with your request for access unless you have agreed to pay the fee.

9. Cookies.

Implementation of Cookies: When accessing the Platform, Google Stats will deploy Cookies to monitor the Platform’s performance and assess the efficacy of online advertising. Cookies are small data files sent to the user’s browser and saved on the computer’s hard drive. These Cookies are transmitted to the computer’s hard drive only when the Platform is accessed via the user’s computer.

Purpose of Cookies: Cookies are often used to record the behaviors and preferences of visitors as they explore various elements on the Platform. Cookies gather anonymous aggregate statistics that do not include Personal Data. Cookies cannot be used to retrieve information from the user’s hard drive, email address, or Personal Data. They enable the Platform or a service provider’s system to identify the user’s web browser and to capture and remember certain details.

Disabling Cookies: Most web browsers are preset to accept Cookies. Users can configure their web browsers to reject Cookies or to notify them when Cookies are being installed. It should be noted that disabling Cookies may hinder the ability to initiate or use specific features of the Platform. If Cookies are rejected, logging in or using Platform services or functionalities that rely on such Cookies may not be possible. This provision applies to any relevant information acquired through Cookies as stipulated by Apax Bit.

10. Access, correction, and deletion of your personal data

Subject to exceptions set out in the law, you have the right to obtain a copy of your Personal Data upon request and ascertain whether the information we hold about you is accurate and up-to-date. We will provide access within 60 days of your request. If we refuse to provide the information, we will provide reasons for the refusal. We will require identity verification and specification of what information is required before providing you with access. If any of your Personal Data is inaccurate, you may request to update your information. Where we are satisfied that the request to update the information is accurate, we will take reasonable steps to correct the information within 60 days, unless you agree otherwise. If you are entitled by law, you may request to delete your Personal Data, with the exception that we may refuse your deletion request in certain circumstances, such as compliance with law or legal purposes. For data access, correction, or deletion requests, or to request withdrawal of your previously provided consent, please send an email with your request via email address: support@bitgainpro.net

11. Account cancellation.

You may cancel your Apax Bit account at any time, the consequences of account cancellation include but not limited to the following:

(1) You will lose all digital assets and data contained in this account.

(2) You will not be able to recover the personal information, transaction records, business data, and historical information under the account.

(3) You will not be able to use this account to log in to Apax Bit’s services.

IMPORTANT

The account cannot be recovered once it is deleted. To protect your rights, we will remind you of the risks again after you request to cancel an account. The deletion of your account does not mean that all your account operations and responsibilities before account deletion are exempted or mitigated. All records and information associated with your account will be deleted. However, we may retain certain information about your account as required by applicable law and regulations.

12. Announcements and updates

For any privacy concerns related to Apax Bit, please contact us, and we will endeavor to resolve the issue. As our Service evolves, modifications to our Privacy Policy may also occur. It is advisable to frequently review our website for the latest updates. The “Last Updated” date at the beginning of this Privacy Policy will be revised accordingly. Any significant changes to this Privacy Notice will be announced on our Platform. Continued use of Apax Bit following changes to this Privacy Notice signifies understanding and acceptance of these changes. Unless specified otherwise, the most recent version of our Privacy Policy applies to all information held concerning you and your account.

13. Contact Information

When handling requests to exercise your privacy rights, we check the identity of the requesting party to ensure that he or she is the person legally entitled to make such a request. While we endeavor to respond to these requests free of charge, should your request be repetitive or unduly onerous, we reserve the right to charge you a reasonable fee (if applicable) for compliance with your request.

The Data Protection Officer may be reached through the webform provided on the website or via email and will address any inquiries or concerns regarding the collection and processing of personal data.

For inquiries related to account management or Apax Bit products and services, the Data Protection Officer will not be able to provide assistance. In such instances, please direct your queries to our Customer Support team via email: support@bitgainpro.net

14. Languages

This Privacy Policy may be issued in multiple languages. In the event of any inconsistency or discrepancy, the English version shall take precedence and be the authoritative version.