Document Terms and Conditions

Privacy and GDPR Policy

Effective date: April 2nd, 2024

This Privacy and GDPR Policy governs the manner in which TXN SERVICES UAB, registration number 306702732 duly incorporated under the laws of Lithuania, registration address Žalgirio g. 88-101, LT-09303 Vilnius, Lithuania hereinafter referred to as ("txn.pro", "We", "Us", "Our"), collects, uses, maintains, and discloses information collected from users (each, a "User", "You") of the txn.pro website ("Site", https://txn.pro), API or other services provided by us.

INTRODUCTION
1. Txn.pro respects the privacy of its Users and is committed to protecting their personal information.
2. This Privacy Policy outlines how txn.pro collects, uses, maintains, and discloses information collected from Users of the txn.pro.
3. By accessing or using the txn.pro services Users consent to the collection, use, and disclosure of their information in accordance with this Privacy Policy.
INFORMATION COLLECTION
1. Personal Identification Information: txn.pro may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit the Site, register on the Site, place an order, subscribe to the newsletter, respond to a survey, fill out a form, and in connection with other activities, services, features, or resources we make available on our Site, name, gender, age, unique identifier, particulars from identity documents, data from residence permits, photographic or video images of facial features, signatures, personal identification numbers, birthplace, date of birth, and citizenship(s).
2. Contact details: email addresses, phone numbers, residential or workplace addresses, information from utility bills, or other documents establishing residency.
3. Professional activity data: employer names or workplace locations, industry of employment, educational history, length of service, and professional experience.
4. Regulatory status data: status as a politically exposed person (PEP), sanction status, and other pertinent information accessible through public sources.
5. Tax data: documentation pertaining to tax residency, tax identification numbers (TINs), tax declarations and payments, outstanding tax liabilities.
6. Financial data: forecasts of incoming and outgoing payments, income and expenses, financial commitments, executed and terminated agreements, service charges, breaches of contracts, account balances, sources of wealth, account funding sources, transaction documentation, details from other accounts.
7. Payment instrument data: bank or payment account numbers, virtual IBANs, virtual asset wallet or account identifiers, transaction records associated with payment instruments (e.g., suspensions, seizures).
8. Transaction data: transaction types (fiat currency, virtual assets), currencies involved, timestamps, transaction amounts, counterparty information, details of disputed or canceled transactions, blockchain addresses, public keys.
9. Customer activity data: account statuses, purposes of business relationships, records of communications, login and authentication data, usage activities, cookies, services utilized, inquiries, and complaints.
10. Non-Personal Identification Information: txn.pro may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer, and technical information about Users' means of connection to our Site, such as the operating system and the Internet service providers utilized, and other similar information.
11. We may gather information through automated methods. When you utilize txn.pro and its exchange utilities, we also track and compile usage-related data, including access timestamps, device identifiers, operating systems, browser specifications, and IP addresses. This data may be acquired directly by txn.pro or through third-party services.
HOW WE GATHER PERSONAL DATA
1. Personal data may be gathered directly from you, such as when you apply to engage with our services, submit requests or applications, utilize our services, or engage in interactions with us.
2. Your personal data may also be collected through automated means, including the tracking of your usage of our website, application, and services.
3. Additionally, we obtain your personal data from third parties who are either authorized or obligated to disclose such information to us under applicable laws, including but not limited to:
  1. Third parties with whom you maintain legal or personal relationships, such as transaction counterparts and associated parties.
  2. Our collaborative partners and third-party service providers.
  3. Financial institutions and other providers of virtual asset services.
  4. Public and private registries.
  5. Other public sources (e.g., public blockchains, social media profiles, media publications).
  6. Governmental bodies and judicial authorities at both state and local levels.
HOW WE USE COLLECTED INFORMATION
1. Txn.pro may collect and use Users' personal information for the following purposes:
  1. Your personal details, comprising your name and address, are processed to uphold legal compliance.
  2. Where it is necessary to fulfill a contract with you for the provision of our Services or to initiate a contract with you for the provision of our Services.
  3. Where it is necessary to comply with our legal obligations across jurisdictions concerning the provision of financial services, as mandated by accounting, taxation, and other laws, and to deter criminal activity, fraud, and money laundering.
  4. Where it is necessary for the purposes of our legitimate interests to prevent fraud, money laundering, or unauthorized use of your account, and to analyze your account activity to provide you with adequate and reliable service and to offer you suitable options for your needs.
  5. Where we have obtained your explicit consent as required by applicable law.
  6. To identify you as a client and distinguish you from other users of our Service.
  7. To continuously provide you with functional, secure, efficient, and customized service.
  8. To operate and develop our Service.
  9. To publish content and advertising on the Site and API.
  10. To prevent losses and fraud.
  11. To respond to any comments or inquiries you have submitted.
  12. To comply with legal and regulatory requirements, including Know-Your-Customer (KYC) anti-money laundering (AML) requirements.
  13. To provide you with customer and technical support.
  14. To inform you about our and our partners' offers, products, and perform other marketing activities where we have obtained your consent.
2. We may also process personal information, including your email address, to send you service updates and notifications (regarding your account settings), newsletters, marketing messages, and certain email notifications where we have obtained your explicit consent or are otherwise lawfully permitted to do so. You can change your preferences later and opt-out from such emails at any time by following the link provided in every email from txn.pro or through settings.
3. We will request the User's consent before processing the aforementioned information for other purposes. When collecting such consents, we inform the data subject of the respective purposes of processing, and such processing is conducted only when appropriate consent is received.
HOW WE PROTECT YOUR INFORMATION
1. Txn.pro adopts appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of Users' personal information, username, password, transaction information, and data stored on our Site.
2. No method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the absolute security of Users' information.
3. We are not obligated to protect personal data that users choose to store or transfer outside Txn.pro and our subprocessors’ systems, and cannot be held responsible for any negative consequences you may suffer as a result thereof.
SHARING YOUR PERSONAL INFORMATION
1. Txn.pro does not sell, trade, or rent Users' personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates, and advertisers for the purposes outlined above.
2. We may use third-party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We may share Users' information with these third parties for those limited purposes provided that Users have given us their permission.
3. Personal Information might be used for the purposes set out in this Privacy Policy and/or as otherwise permitted by law or regulation. Txn.pro may make available the personal information to our affiliates, agents, representatives, trusted service providers and contractors for the purposes that are in accordance with existing Privacy Policy. Txn.pro may also share User personal information with financial institutions, insurance companies or other companies subject to Data Protection Regulation. Txn.pro may also share User personal information with law enforcement or regulatory agencies, as may be required and prescribed by law. Txn.pro will ensure that third parties are aware of existing obligations under this Privacy Policy and are bound by terms no less protective of any personal information disclosed than the obligations Txn.pro undertakes to User under this Privacy Policy or which are imposed under applicable data protection laws and regulations.
YOUR RIGHTS
1. You have the right to ascertain whether we process your personal data, obtain a copy of your personal data, and request corrections to your personal data in case of inaccuracies or changes. You have the option to contact us to access the personal data we handle. However, please be aware that your right to access the personal data we handle may be subject to limitations imposed by legal statutes, the privacy rights of others, and our own rights and obligations (such as safeguarding business secrets and confidentiality obligations).
2. You may also request the deletion of your personal data if we lack the legal basis to process such data, or if we process the data solely based on your consent and you withdraw your consent. It should be noted that this right may be superseded by our right or legal obligation to process such data (including compliance with laws and regulations, fulfillment of contractual obligations, or pursuit of legitimate interests).
3. You have the option to withdraw your consent for the processing of your personal data. Once you have withdrawn your consent, we will cease processing your data for the purpose to which you consented.
4. You may object to the processing of your personal data, including the conduct of profile analysis, especially if we process the data based on our legitimate interests. Upon receipt of your objection, we will refrain from processing your data unless our interests outweigh the potential impact on your rights (e.g., compliance with legal obligations).
5. You have the right to request the cessation of the processing of your personal data if we lack a legal basis for such processing.
6. To exercise your rights, please reach out to us via the contact details provided in this Policy. In certain circumstances stipulated by applicable legislation, we may require a fee prior to processing your request to exercise your rights as a data subject, and we will inform you of this requirement before proceeding with your request.
CHANGES TO THIS PRIVACY POLICY
1. Txn.pro has the discretion to update this Privacy Policy at any time. When we do, we will revise the updated date at the top of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications.
CONFIRMATION AND CONSENT
1. By applying for an account with txn.pro, you declare and confirm that you have familiarized yourself with this Privacy Policy, understood its content and possible consequences.
2. By applying for an account with Txn.pro you consent to the processing (incl. collection, storing, receipt, forwarding, disclosing, making available, deleting, etc.) of your personal information, as described in this Privacy Policy.
CONTACT DETAILS
1. If you require any additional information or have any further questions concerning this Privacy Policy or you wish to use any of your rights regarding your personal information, please contact us at [email protected].

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