Privacy Policy
Effective Date: Feb, 05, 2025
CDEX ("CDEX," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy (the "Policy") explains our practices for collecting, using, and disclosing Personal Information (as defined below) when you access or use the CDEX website located at [Website to be filled] (the "Site"), the CDEX mobile application (the "App"), and any other features, tools, content, or services offered by CDEX, including our communication platform designed to streamline user-directed token interactions across supported blockchain networks and our social platform features (collectively, the "Services").
This Policy must be read in conjunction with our Terms of Service ("Terms"), which are incorporated by reference into this Policy. By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by this Policy. If you do not agree to this Policy, you are not authorized to access or use the Services and must immediately cease all use.
We reserve the right to amend our Policy and practices at any time. The most current version of this Policy will be posted on the Site and App. We will indicate at the top of this Policy the date it was last revised. Any changes will be effective immediately upon posting the revised Policy. Your continued use of the Services following the posting of any changes to this Policy constitutes acceptance of those changes. We encourage you to check this Policy periodically for updates.
This policy outlines:
The type of information we collect from you or that you provide when you visit our website, our mobile application (the "App"), or utilize any related tools, web applications, decentralized applications, smart contracts located at any of CDEX’s websites or on its mobile app, including without limitation, successor website(s) or application(s) thereto (collectively, the “Platform”).
Our practices for collecting, using, maintaining, protecting, and disclosing that information.
Please read this Policy carefully to learn about our policies and how we will handle your information. If you do not agree with our policies and practices, please do not continue to use our Platform. You agree to the terms of this Policy by using our Platform.
Information We Collect
"Information," as used in this Policy, refers to information that directly or indirectly identifies or is reasonably capable of identifying an individual, as well as information that can be linked to an identified or reasonably identifiable individual.
We collect the following categories of Personal Information:
A. Account and Identity Information:
Email Address: Your email address is collected and used for registration, login, password reset, receiving transaction notifications, announcements, and account verification. Your email serves as your primary identity credential on the CDEXplatform.
Username: Your username is used for identification within the CDEX platform and for social platform features, allowing you to interact with other users.
Contact Information (Optional): You may choose to provide your phone number for enhanced security measures, such as two-factor authentication (2FA).
User Preferences: We collect information about your preferences, such as language preference and push notification settings, to customize your experience on the CDEX platform.
B. Wallet and Transaction-Related Information:
Wallet Address/Public Key: We collect your public wallet address to facilitate your interactions with decentralized applications (dApps) through the CDEX platform.
Transaction Records:
On-chain Transaction Data: When you use CDEX to interact with supported dApps, we collect and display on-chain transaction data associated with your wallet address. This data is publicly available on the blockchain and includes transaction hashes, block heights, timestamps, trading pairs, and transaction amounts resulting from interactions with the CDEX smart contract.
Off-chain Transaction Data: We temporarily store simplified transaction records or logs for internal purposes and to provide you with a user-friendly display of your activity. This may include information such as order placement time, matching records, and order status. This data is not permanently stored in a way that compromises your security.
Asset Balance: We collect and display data about your asset holdings, including your total asset value and the balance of each asset held in your connected wallet. This information is fetched in real-time from the blockchain and may be temporarily cached for performance and display purposes. We do not permanently store your detailed asset holdings.
Withdrawal/Deposit Records: We collect and display a history of your deposits from external wallets to the platform or withdrawals from the platform to third-party wallets. This includes amounts, blockchain transaction hashes, and timestamps.
Transaction Operation Logs: We keep internal logs of operations such as placing orders, canceling orders, pairing, and matching. These logs include order IDs, order direction, order price, quantity, and execution status. This data is used for internal record-keeping, troubleshooting, platform improvement, and may be used to assist in dispute resolution.
C. Security and Compliance Information:
Login/Access Logs: We collect data about your logins and access to the CDEX platform, including your IP address, device information (browser type, operating system version), and login timestamps. This information is used for security purposes, such as detecting unauthorized access and preventing account theft.
Geolocation Information (IP, Country/Region): We may collect your approximate geographic location based on your IP address to comply with regional restrictions on cryptocurrency transactions, for risk control purposes, and for security analysis.
D. Referral Program Information:
If you participate in the CDEX referral program, we may collect information about the users you refer to the platform and the rewards you earn. This may include the usernames or email addresses of referred users, subject to their consent.
E. Social Platform Information:
When you use the social features of the CDEX platform, we collect information related to your interactions, discussions, and posts. This may include the content you share, your interactions with other users, and your participation in discussions.
F. Information Collected Automatically:
Usage Data: We automatically collect information about your interactions with the CDEX platform, including internal and external information related to CDEX website pages or app screens that you visit, features you use, and actions you take.
Device Information: We collect information about the device you use to access the CDEX platform, such as your device type, operating system, browser type, and IP address.
Cookies: We use cookies and similar tracking technologies to collect information about your activity on the CDEX platform. Please refer to our "Cookies" section below for more details.
G. Information Collected from Third Parties:
Referral Program Partners: We may receive information about you from our referral program partners if you were referred to CDEX by a third-party service provider. The information shared may include your username or email and is subject to agreements with these partners.
Blockchain Data: We collect publicly available data from supported blockchains, including transaction information associated with your wallet address, to provide you with real-time updates and information about your asset holdings.
How We Use Your Personal Information
We use your Personal Information for the following purposes:
To Provide and Maintain the CDEX Services:
To enable your access to and use of the CDEX platform, including facilitating your interactions with supported dApps.
To process and display your on-chain and off-chain transaction data.
To display your asset holdings and provide real-time updates based on blockchain data.
To maintain your account and provide customer support.
To operate and improve the social platform features, including displaying user interactions and facilitating discussions.
To Communicate with You:
To send you transaction notifications, announcements, and updates about the CDEX platform.
To respond to your inquiries and provide customer support.
To send you marketing communications, subject to your consent and applicable laws. You can opt out of marketing communications at any time.
For Security and Fraud Prevention:
To monitor for and detect suspicious activity, unauthorized access, and other security threats.
To protect your account and the CDEX platform from fraud and abuse.
To verify your identity and prevent fraudulent accounts.
For Compliance with Legal Obligations:
To comply with applicable laws and regulations, including anti-money laundering (AML) and know-your-customer (KYC) requirements, if applicable.
To respond to lawful requests from law enforcement and regulatory authorities.
For Research and Development:
To analyze usage patterns and trends to improve the CDEX platform and develop new features.
To conduct research and analysis to better understand the cryptocurrency and DeFi landscape.
For the Referral Program:
To track referrals, calculate rewards, and administer the CDEX referral program.
To communicate with you about your referral activity and rewards.
For Social Platform Features:
To enable user interactions, discussions, and the sharing of insights within the platform.
To moderate content and maintain a positive user experience.
How We Share Your Personal Information
We will never sell your Personal Information. We may share your Personal Information with the following categories of third parties:
Service Providers: We may share your Personal Information with third-party service providers who assist us in providing the CDEX Services. These service providers may include:
Hosting providers: To store data and operate the CDEX platform.
Analytics providers: To analyze usage patterns and improve the CDEX platform.
Email service providers: To send you transactional emails, announcements, and marketing communications (subject to your consent).
Security providers: To help us protect the CDEX platform and your account from security threats.
Customer support providers: To assist us in responding to your inquiries and providing customer support.
These service providers are contractually obligated to protect your Personal Information and are prohibited from using it for any purpose other than providing services to CDEX.
Third-Party Wallet Providers: To enable your interaction with dApps through CDEX, we may share your public wallet address with your third-party wallet provider. We do not share other sensitive information with wallet providers. Your use of a third-party wallet is subject to the wallet provider's terms of service and privacy policy.
Referral Program Partners: If you participate in the CDEX referral program, we may share limited information about you (such as your username or email) with our referral program partners to facilitate reward tracking and distribution, subject to agreements with these partners.
Legal and Regulatory Authorities: We may disclose your Personal Information to law enforcement, government officials, or regulators if required by law, legal process, or regulation, or if we believe in good faith that such disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
Business Transfers: In the event of a merger, acquisition, reorganization, sale of assets, or other business transfer involving CDEX, your Personal Information may be transferred to the acquiring entity or successor. We will notify you of any such transfer and any choices you may have regarding your Personal Information.
With Your Consent: We may share your Personal Information with other third parties with your explicit consent.
Social Platform Features: When you use the social features of the CDEX platform, your interactions, discussions, and posts may be visible to other users of the platform. Please exercise caution when sharing information on the social platform.
Data Security
We take the security of your Personal Information seriously and have implemented reasonable technical and organizational measures to protect it from unauthorized access, use, disclosure, alteration, or destruction. These measures include:
Encryption: We use industry-standard encryption to protect data transmitted to and from the CDEX platform.
Access Controls: Access to your Personal Information is restricted to authorized personnel who need it to perform their duties.
Regular Security Audits: We conduct regular security audits and assessments to identify and address potential vulnerabilities.
Secure Storage: We store your Personal Information on secure servers with appropriate physical, electronic, and procedural safeguards.
However, no method of transmission over the Internet or method of electronic storage is completely secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. You are responsible for maintaining the confidentiality of your account credentials and for any activity that occurs under your account. You should never share your private keys with anyone, including CDEX.
Data Retention
We will retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected, as outlined in this Policy, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:
The length of time we have an ongoing relationship with you and provide the CDEX Services to you.
Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time).
Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).
When your Personal Information is no longer needed for the purposes for which it was collected, we will securely delete or anonymize it.
Your Rights
You have certain rights regarding your Personal Information, subject to applicable law. These rights may include:
Access: You have the right to request access to the Personal Information we hold about you and to receive a copy of that information.
Rectification: You have the right to request that we correct any inaccurate or incomplete Personal Information we hold about you.
Erasure: You have the right to request that we delete your Personal Information, subject to certain exceptions (for example, where we are required by law to retain the information).
Restriction of Processing: You have the right to request that we restrict the processing of your Personal Information under certain circumstances.
Data Portability: You have the right to receive your Personal Information in a structured, commonly used, and machine-readable format and to transmit that data to another controller, where technically feasible.
Objection to Processing: You have the right to object to the processing of your Personal Information under certain circumstances, including for direct marketing purposes.
Withdraw Consent: Where we rely on your consent to process your Personal Information, you have the right to withdraw your consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.
To exercise any of these rights, please contact us using the contact information provided at the end of this Policy. We may need to verify your identity before fulfilling your request. We will respond to your request within a reasonable timeframe, in accordance with applicable law.
Cookies
When you access the CDEX platform, we may use cookies and similar tracking technologies (collectively, "Cookies") to collect information about your activity. Cookies are small data files that are placed on your computer or mobile device when you visit a website or use an app.
We use Cookies for the following purposes:
Essential Cookies: These Cookies are necessary for the CDEX platform to function properly and enable you to navigate and use its features.
Performance Cookies: These Cookies collect information about how you use the CDEX platform, such as which pages you visit most often and if you encounter any errors. This information helps us improve the performance and usability of the platform.
Functionality Cookies: These Cookies allow the CDEX platform to remember choices you make (such as your username or language preference) and provide enhanced, more personalized features.
Analytics Cookies: We use third-party analytics providers, such as Google Analytics, to collect information about your use of the CDEX platform. This information helps us understand usage patterns, improve the platform, and measure the effectiveness of our marketing campaigns.
You can manage or disable Cookies through your browser settings. However, please note that if you disable Cookies, some features of the CDEX platform may not function properly.
Third-Party Links
The CDEX platform may contain links to third-party websites or services that are not owned or controlled by CDEX. This includes links to third-party wallet providers, dApps, and other resources. We are not responsible for the privacy practices of these third-party websites or services. We encourage you to review the privacy policies of any third-party websites or services you visit.
International Data Transfers
CDEX is operated globally, and your Personal Information may be transferred to, stored, and processed in countries other than your country of residence. When we transfer your Personal Information to countries outside of your jurisdiction, we will take appropriate measures to ensure that your Personal Information is protected in accordance with this Policy and applicable data protection laws. These measures may include:
Standard Contractual Clauses: We may use standard contractual clauses approved by the European Commission or other relevant authorities to safeguard the transfer of Personal Information to countries that do not provide an adequate level of data protection.
Adequacy Decisions: We may transfer Personal Information to countries that have been deemed to provide an adequate level of data protection by the European Commission or other relevant authorities.
Your Consent: In some cases, we may rely on your explicit consent to transfer your Personal Information outside of your jurisdiction.
Children's Privacy
The CDEX Services are not intended for individuals under the age of 18. We do not knowingly collect Personal Information from children under 18. If you are a parent or guardian and believe that your child has provided us with Personal Information, please contact us immediately. If we become aware that we have collected Personal Information from a child under 18, we will take steps to delete such information from our records and terminate the child's account.
Information for Persons Subject to EU Data Protection Law
While customers who are located in the European Union (“EU”), European Economic Area (“EEA”), the Channel Islands, or other locations subject to EU data protection law (collectively, “Europe”) may interact with our global services, we recognize and, to the extent applicable to us, adhere to relevant EU data protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”). For purposes of this section, “personal data” has the meaning provided in the GDPR.
A. Lawful Basis for Processing: We process personal data subject to GDPR on one or more of the following legal bases:
Legal Obligation: To comply with our legal obligations, including anti-money laundering (AML) and know-your-customer (KYC) requirements (if applicable), as well as responding to lawful requests from law enforcement and regulatory authorities.
Contractual Obligation: To fulfill our contractual obligations to you under our Terms of Service, including providing you with the CDEX Services, customer support, and maintaining your account.
Legitimate Interest: To pursue our legitimate interests, such as:
Operating and improving the CDEX platform and developing new features.
Protecting the security of the CDEX platform and your account.
Conducting research and analysis to better understand the cryptocurrency and DeFi landscape.
Monitoring usage of CDEX.
Conducting automated and manual security checks of our Services.
Protecting our rights.
Administering the referral program.
Maintaining the social platform features and moderating content.
Consent: Where we rely on your consent to process your personal data, such as for sending marketing communications or for certain aspects of the referral program. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before your consent is withdrawn.
B. European Privacy Rights: If you are located in Europe, you have the following rights under the GDPR, subject to certain exceptions provided under the law, with respect to your personal data:
Rights to Access and Rectification: You may submit a request at any time that CDEX disclose the personal data that we process about you and correct any factually inaccurate personal data.
Right to Erasure: You may submit a request at any time that CDEX delete your personal data.
Right to Restriction of Processing: You have the right to restrict or object to our processing of your personal data under certain circumstances.
Right to Data Portability: You have the right to receive the personal data you have provided to us in an electronic format and to transmit that personal data to another data controller.
To submit a request to exercise these rights, please contact us using the methods described at the end of this Policy. When handling requests to exercise European privacy rights, we will check the identity of the requesting party to ensure that he or she is the person legally entitled to make such requests.
C. Transfers of Data Outside the EEA: Please refer to Section 9 "International Data Transfers" for information on how we handle transfers of personal data outside the EEA.
California Privacy Rights
This section applies to residents of California under the California Consumer Privacy Act of 2018 ("CCPA") and other applicable California laws.
A. Categories of Personal Information Collected: We collect the following categories of personal information, as defined under California law:
Identifiers: Such as your name, email address, username, phone number (if provided), IP address, and wallet address.
Internet or other electronic network activity information: Such as your browsing history on the CDEX platform, interactions with our website and app, device information, and usage data.
Geolocation data: Approximate location derived from your IP address.
Financial information: Limited to your public wallet address and transaction information publicly available on the blockchain, which we collect and display for your convenience.
Other Information that Identifies or Can Be Reasonably Linked to You: Information you provide through the social platform features, referral program data, and any other information you choose to share with us.
B. Your Rights Under CCPA: California residents have the following rights:
Right to Know, You have the right to request that we disclose to you:
The categories of personal information we have collected about you.
The categories of sources from which the personal information is collected.
The business or commercial purpose for collecting or selling (if applicable) personal information.
The categories of third parties with whom we share personal information.
The specific pieces of personal information we have collected about you.
Right to Delete: You have the right to request that we delete any personal information we have collected from you, subject to certain exceptions.
Right to Opt-Out of Sale: CDEX does not sell your personal information. However, you have the right to direct us not to sell your personal information if our practices change in the future.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights. This means we will not deny you goods or services, charge you different prices, or provide you with a different level of service solely because you exercised your rights under the CCPA.
C. Exercising Your Rights: To exercise your CCPA rights, please contact us using the contact information provided at the end of this Policy. We may need to verify your identity before fulfilling your request. We will respond to your request within the timeframe required by the CCPA.
D. Do Not Track Signals: Some web browsers offer a "Do Not Track" ("DNT") signal. A DNT signal is an HTTP header field indicating your preference regarding tracking or cross-site user tracking. We currently do not respond to DNT signals.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will post any changes to this Policy on the CDEX Site and App and update the "Last Revised" date at the top of this Policy. We encourage you to review this Policy periodically for any updates. Your continued use of the CDEX Services after the posting of changes constitutes your acceptance of such changes.
Contact Us
If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:
[Email Address to be filled]
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