Privacy Policy

This Privacy Policy explains how Xenobex handles personal information when you visit our website, create an account, trade spot markets or USDT-margined perpetual futures, deposit or withdraw virtual assets, verify your identity, contact customer support or otherwise use our services (together, the "Service"). Please read it together with the Terms of Use and the Consent to the Collection and Use of Personal Information.

1. Who We Are

Xenobex, registered in [JURISDICTION] under registration number [Xenobex REGISTRATION NUMBER] with its registered office at [REGISTERED ADDRESS], decides why and how personal information is processed in connection with the Service and is responsible for it as the data controller.

This Policy applies to everyone who uses the Service, including visitors who do not have an account. It does not apply to websites or services operated by others, even when the Service links to them.

2. Information We Collect and Where It Comes From

2.1 Information you provide

2.2 Information generated when you use the Service

2.3 Information collected automatically

2.4 Information from other sources

2.5 What we do not collect

We do not use cookies, advertising identifiers, third-party analytics or tracking pixels, and we do not collect your precise location, contacts or other content of your device. Apart from the facial image used for identity verification, we do not ask for sensitive information such as health, political opinions or religious beliefs; please do not send it to us through customer support.

3. How We Use Your Information and Our Legal Bases

We use personal information only for the purposes below. Each purpose rests on one or more legal bases: performing our contract with you (the Terms of Use), complying with a legal obligation, our legitimate interests (weighed against your rights and interests), or your consent.

Before using personal information for a new purpose that is not compatible with those above, we will tell you and, where the law requires, ask for your consent.

4. Sharing and Disclosure

Xenobex does not sell or rent personal information. We disclose it only in the cases below and only to the extent needed.

4.1 Service providers that process data for us

We entrust part of the processing to the providers listed here. They may use the information only to provide their service to Xenobex, under a written agreement that requires confidentiality and security measures, forbids further outsourcing without our approval and requires the information to be returned or deleted when the contract ends. We supervise how they handle it.

We update this list before a new provider receives personal information.

4.2 Public blockchain infrastructure

To confirm deposits and withdrawals, our systems query public blockchain nodes and explorer services run by independent operators. The queries contain blockchain addresses and transaction IDs only, never your name or email address, but the operators may log them. Transactions recorded on a public blockchain can be seen by anyone, and Xenobex cannot change or delete them.

4.3 Other members

Other members never see who you are. The public order book and trade feed show only prices, quantities and times. If you signed up with a referral code, the member who referred you can see a masked form of your email address (for example "ab***@example.com"), the date you joined and the commission earned from your trading fees.

4.4 Authorities and legal process

We disclose personal information to regulators, financial intelligence units, tax authorities, law enforcement agencies and courts when a law requires it or a valid legal order is served on us. Where the law forbids it, for example after a suspicious transaction report, we will not tell you about the disclosure.

4.5 Other virtual asset service providers

Where the law requires information about the sender and the recipient to accompany a virtual asset transfer, we exchange that information with the service provider on the other side of your deposit or withdrawal.

4.6 Business transfers

If Xenobex merges, is acquired, reorganizes or sells all or part of its business, personal information may pass to the successor. We will tell you in advance, and you may close your account if you do not agree.

4.7 With your consent

In any other case we share personal information with a third party only after you have consented, having told you who will receive it, for what purpose, which items and for how long.

5. International Transfers

Xenobex is established in [JURISDICTION]. Our servers are located in [HOSTING LOCATION] and our email service provider processes data in [EMAIL PROVIDER LOCATION]. If you live in another country, your personal information is transferred there over encrypted network connections whenever it is stored on our servers or an email is sent to you.

Public blockchain nodes and explorers may be located in any country. Where the law gives you the right to refuse an overseas transfer, you can exercise it by contacting us; because the Service cannot run without these transfers, refusing may mean that we cannot provide the Service to you.

6. Retention and Destruction

We keep personal information only as long as the purposes in section 3 or the law require, and then destroy it. The main periods are:

When you close your account, we sign out every device at once, remove your 2FA settings, anti-phishing code and address book, and replace the email address on the account so that you can sign up again. Your original email address is kept only in encrypted form, separated from active accounts and with restricted access, for the retention period above. When that period ends, a daily housekeeping job erases your identity verification data and images, the IP addresses and browser details in your sign-in history, your sessions, recovery codes and password hash, and the encrypted email address. Ledger, trade, deposit and withdrawal entries remain as accounting records, linked only to an internal account number and without your email address, identity data, IP addresses or device details.

How we destroy information. Electronic records are deleted or overwritten so that they cannot be restored by ordinary means, and encrypted data is erased together with its ciphertext. Paper documents, if any, are shredded or incinerated. Any destruction outside the automatic jobs is approved and recorded by the privacy officer.

7. Your Rights and How to Exercise Them

Subject to the conditions of applicable law, you have the right to:

Self-service tools. When signed in, you can view your sign-in history and signed-in devices and sign them out, change your password and 2FA settings, download your order, trade, deposit and withdrawal history as CSV files, and close your account.

Requests. For anything else, write to the privacy officer at [PRIVACY EMAIL] from the email address registered on your account, or contact customer support. We verify your identity before acting and reply without undue delay, within the period set by applicable law. A legal representative or a person you have authorized in writing may make a request for you with proof of authority. Requests are free of charge unless they are clearly unfounded or excessive.

Limits. We may refuse or limit a request where the law requires us to keep the information (for example the anti-money-laundering records in section 6), where it would harm the rights of others, or where disclosure is prohibited, as with a suspicious transaction report. We will tell you why.

8. Cookies and Browser Storage

The Service does not set cookies and does not use third-party analytics, advertising or social media tracking tools. The chart library is served from our own servers, so viewing a chart sends nothing to the library's author.

The web application keeps a few values in your browser's own storage instead:

These values stay on your device and are not used to follow you across websites. You can delete them at any time in your browser settings; doing so signs you out and resets your preferences. If we start using cookies or similar technologies for any other purpose, we will update this Policy first and ask for your consent where the law requires.

9. How We Protect Your Information

No system is completely secure. Keep your password and 2FA device to yourself, and check the anti-phishing code in any email that claims to come from us. If a breach affects your personal information, we will notify you and the competent authorities as the law requires, explain what happened and tell you what we are doing and what you can do.

10. Children

The Service is only for people aged 19 or older. Every member confirms this at sign-up, and identity verification is refused when the date of birth shows an age under 19. We do not knowingly collect personal information from younger people. If we learn that we have, we will close the account and delete the information, except what the law requires us to keep. If you believe a minor has opened an account, please tell us at [PRIVACY EMAIL].

11. Automated Decision-Making

Some decisions in the Service are made automatically, because they must take effect immediately or are rules applied equally to every member:

Identity verification decisions and account restrictions are made by Xenobex staff, not solely by automated means. Apart from the rules listed, we do not make decisions with legal or similarly significant effects by automated means, and we do not profile you for advertising. To ask for an explanation of an automated decision, have a person review it or contest it, contact the privacy officer.

12. Privacy Officer and Contact

The current contact details are also shown at the bottom of the Service's screens. If you are not satisfied with our answer, you may contact [DATA PROTECTION AUTHORITY] or another authority competent where you live.

14. Changes to This Policy

We may revise this Policy when the law, the Service or the way we process personal information changes. We announce a revision in the Service at least seven (7) days before it takes effect, or at least thirty (30) days before if it reduces your rights or adds new collection, sharing or transfers; until then the upcoming version and its effective date are shown next to the current one. Earlier versions are available on request, and the version and dates at the top of this page tell you which one you are reading.

This Policy is written in English. A Korean version is provided to members for whom Korean is enabled; if the two differ, the [GOVERNING LANGUAGE] version prevails.