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Legal

Privacy Policy

Last updated June 26, 2026

This Privacy Policy explains how Ezorex collects, uses, stores, shares, and protects personal data in connection with your use of our Platform. Please read it together with our Terms of Service.

I. Introduction

1. This Privacy Policy (the “Policy”) explains how Limited Liability Company “Kosmoteka” (“Ezorex”, “we”, “us”, or “our”), a company organized and existing under the laws of the Kyrgyz Republic, collects, uses, stores, shares, and protects personal data in connection with your use of the Ezorex website, mobile application, and related services (collectively, the “Platform”).

2. This Policy should be read together with our Terms of Service. Capitalized terms not defined in this Policy have the meaning given to them in the Terms of Service.

3. By creating an Account, completing identity verification, or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

4. Ezorex may update this Policy from time to time. Material changes will be communicated via the Platform or by email, and the “Last Updated” date above will reflect the most recent revision. Continued use of the Platform after such changes take effect constitutes your acceptance of the updated Policy.

II. What Data We Collect

We collect the following categories of personal data:

1. Registration Data. Email address, password (stored in encrypted/hashed form), and any other information you provide when creating your Account.

2. Identity Verification (KYC) Data. To comply with applicable law and to verify your identity, we collect: full name, date of birth, nationality and country of residence, government-issued identification documents (e.g., passport, national ID, driver’s license) and the data contained therein, a live selfie or video taken during the verification process, proof of address documents, and any other documents or information reasonably required to complete identity verification.

3. Transaction Data. Details of your Exchange Transactions, including the Source Asset and Counter Asset, amounts, Exchange Rates, Service Fees, timestamps, the Recipient Address you provide, and the blockchain transaction hash associated with each transfer.

4. Wallet and Blockchain Data. Public wallet addresses you provide for sending or receiving Digital Assets. We do not collect, request, or store private keys, seed phrases, or wallet passwords, and you should never share these with us or anyone else.

5. Technical and Usage Data. IP address, device identifiers, browser type, operating system, log files, approximate location derived from IP address, referral source, and information about how you interact with the Platform (e.g., pages visited, actions taken).

6. Communications. Records of correspondence between you and Ezorex, including support requests, complaints, and any documents or information you submit in connection with such correspondence.

7. Risk and Compliance Data. Information generated or obtained as part of sanctions screening, watchlist checks, source-of-funds analysis, fraud detection, and other compliance processes, including data obtained from third-party verification or screening providers.

III. How We Collect Data

We collect personal data:

1. Directly from you, when you register, complete KYC verification, initiate an Exchange Transaction, or contact our support;

2. Automatically, through cookies, log files, and similar technologies when you use the Platform;

3. From third parties, including identity verification providers, sanctions and watchlist screening providers, blockchain analytics providers, and, where legally required, public registries or databases used to confirm the accuracy of the information you provide.

IV. Legal Basis and Purposes of Processing

We process your personal data for the following purposes:

1. Providing the Service. To create and manage your Account, process Exchange Transactions, calculate Exchange Rates and Service Fees, and deliver Counter Assets to the Recipient Address you specify.

2. Compliance with Law. To perform identity verification (KYC), conduct sanctions and watchlist screening, detect and prevent money laundering, terrorist financing, and fraud, and to comply with requests from competent authorities, court orders, or other legal obligations applicable to Ezorex under the laws of the Kyrgyz Republic or other applicable jurisdictions.

3. Security. To protect the Platform, our Users, and our systems against unauthorized access, fraud, abuse, and security incidents.

4. Communication. To respond to your inquiries, send transaction confirmations, and notify you of material changes to our Terms of Service, this Policy, or the Platform.

5. Improvement of the Platform. To analyze usage patterns, diagnose technical issues, and improve the functionality, security, and user experience of the Platform.

6. Legitimate Business Interests. To enforce our Terms of Service, establish or defend legal claims, and manage our relationship with Users.

We process your personal data on the basis of: (i) the necessity to perform our contractual obligations to you under the Terms of Service; (ii) compliance with legal obligations to which Ezorex is subject; (iii) our legitimate interests, where these are not overridden by your rights; and/or (iv) your consent, where applicable.

V. Sharing of Personal Data

1. We do not sell your personal data. We may share your personal data with:

1.1. Identity Verification and Screening Providers. Third-party providers engaged to perform KYC checks, document verification, sanctions and watchlist screening, and fraud detection on our behalf.

1.2. Liquidity and Blockchain Infrastructure Providers. Third parties involved in facilitating the technical execution of Exchange Transactions, to the extent necessary to process your order.

1.3. Competent Authorities. Regulators, law enforcement, courts, or other governmental authorities, where required by applicable law, a valid legal request, or to protect the rights, property, or safety of Ezorex, its Users, or the public.

1.4. Professional Advisors. Auditors, legal counsel, and other professional advisors, where necessary for the purposes described in this Policy.

1.5. Successors. In connection with a merger, acquisition, reorganization, or sale of assets, in which case personal data may be transferred as part of that transaction, subject to confidentiality protections.

2. Any third party with whom we share personal data is contractually or legally obligated to protect such data and to use it solely for the purposes for which it was disclosed.

VI. International Data Transfers

Given the nature of the Platform and our use of third-party service providers, your personal data may be transferred to, and processed in, countries other than your country of residence, including countries that may have different data protection standards than your home jurisdiction. Where we transfer personal data internationally, we take reasonable steps to ensure that such transfers are conducted in accordance with applicable law and that appropriate safeguards are in place.

VII. Data Retention

1. We retain personal data, including KYC documentation and Transaction Data, for as long as necessary to fulfill the purposes described in this Policy, including to comply with applicable anti-money laundering, counter-terrorist financing, tax, and other legal record-keeping obligations, which may require retention for a minimum period following account closure or your last transaction, as prescribed by applicable law.

2. Upon expiry of the applicable retention period, we will securely delete or anonymize your personal data, except where further retention is required by law or necessary to establish, exercise, or defend legal claims.

VIII. Data Security

1. We implement technical and organizational measures designed to protect personal data against unauthorized access, alteration, disclosure, or destruction, including encryption of sensitive data, access controls, and regular security reviews.

2. No system is completely secure. While we take reasonable measures to protect your personal data, we cannot guarantee absolute security, and you acknowledge that any transmission of data over the internet carries inherent risk.

3. If we become aware of a security incident affecting your personal data, we will notify you and any applicable authority in accordance with applicable law.

IX. Your Rights

Subject to applicable law, you may have the right to:

1. Access the personal data we hold about you;

2. Rectify inaccurate or incomplete personal data;

3. Erase your personal data, subject to our legal obligation to retain certain data (e.g., KYC and Transaction Data) for the periods described in Section VII;

4. Restrict or object to certain processing of your personal data, subject to our legitimate interests and legal obligations;

5. Data portability, where applicable, to receive a copy of personal data you have provided to us in a structured, commonly used format;

6. Withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, please contact us using the details in Section XII. We may need to verify your identity before responding to your request and may decline requests that conflict with our legal obligations, including our obligations under anti-money laundering law.

X. Cookies and Tracking Technologies

1. The Platform uses cookies and similar technologies to operate core functionality, remember your preferences, and analyze usage of the Platform.

2. You may control or disable cookies through your browser settings; however, disabling certain cookies may affect the functionality of the Platform.

XI. Children’s Privacy

The Platform is not intended for, and we do not knowingly collect personal data from, individuals under the age of 18. If we become aware that we have inadvertently collected personal data from a minor, we will take steps to delete such data and may suspend the associated Account.

XII. Contact Us

If you have questions about this Policy or wish to exercise any of your rights described in Section IX, please contact us through the support channel indicated on the Platform.

XIII. Governing Law

This Policy is governed by the laws of the Kyrgyz Republic, without prejudice to any mandatory data protection rights you may have under the laws of your country of residence.

Acknowledgement

By creating an Account or using the Ezorex Platform, you acknowledge that you have read and understood this Privacy Policy.