Date of the last version: 5th of September, 2018

This Privacy Policy is designed to assist you with understanding how (“Chatex”, “platform”,
“we”, “us” or “our”) collect, use and disclose the information that you provide us
when accessing or using the platform, receiving services (“Services”). The terms “you” and “your” refers
to any User either individuals or entities that use our Services or visit our platform.
This Policy describes the types of information that we may collect and hold; how we use and share the
information; and how you can correct or change your personal data. Our Privacy Policy applies to the
Service offered by the Company on the platform, and to any information that becomes available to the
Company relating to any User of the Service or platform.
This Privacy Policy does not apply to the other services of the Company, which have separate privacy


We may change this Privacy Policy in our sole discretion at any time. Any revisions to this Privacy
Policy will be posted with the platform.
User agrees that it is User’s obligation to visit our platform to review any changes that may be made to
this Privacy Policy and other public documents with the platform.
If you continue to use our Services or platform after such changes have been made, you hereby provide
your consent to the changes.
If you do not agree with this Privacy Policy, you shall exit the platform and are not authorized to use
our platform.


When you visit our platform, you may provide us with three types of information: individual and
institutional information that you voluntarily disclose that is collected on an individual basis; and
information collected automatically when you use our platform or the services available on our platform
(collectively, the “Information”).
By providing us with your Individual information or Institutional information, you also expressly agree
that we may collect, hold, use and disclose this Information in accordance with this Privacy Policy. In
addition to providing the foregoing information, if you choose to correspond further with us through
e-mail or through the “contact” section of our platform, we may retain, use and disclose the content of
your messages together with your e-mail address and our responses.
Depending on at what stage the offered product is (pre-start collection of applications; commence of
rendering of the full Service; connection of the additional services), Chatex has a right to:

  • collect full or part of the provided information;
  • process, use or transfer the information by all or part of the claimed methods;
  • stop collecting, processing, using, transferring and storing information.

Such changes shall not be necessarily announced by Chatex and may not be a reason for limitation of
rights of Users, owners of the provided information and may not be a reason for any claims and charges
against Chatex.


Individual information is collected only when it is voluntarily and solely provided for purposes that are
clearly identified on our platform. Individual information means any information that is unique to you,
such as your:

  • Name;
  • Username;
  • E-mail address;
  • Cryptocurrency “wallet” address;
  • Mailing address;
  • Contact details;
  • ID data (if applicable);
  • Password (if applicable);
  • Other personal information that User may decide to provide;

Other information required by Chatex for KYC, AML and supplying new services purpose.


With respect to institutional customer, we attempt to collect, verify, and authenticate the following

  • Institution legal name;
  • Employer Identification Number (“EIN”) or any comparable identification number issued by a
    government (if applicable);
  • Full legal name (of all account signatories and beneficial owners) (if applicable);
  • Email address (of all account signatories);
  • Mobile phone number (of all account signatories);
  • Address (principal place of business and/or other physical location);
  • Proof of legal existence (e.g., state certified articles of incorporation or certificate of
    formation, unexpired government-issued business license, trust instrument, or other comparable legal
    documents as applicable) (if applicable);
  • Contract information of owners, principals, and executive management (if applicable);
  • Proof of identity (e.g., driver’s license, passport or government-issued ID) for each individual
    beneficial owner that owns 10% or more, as well as all account signatories (if applicable);
  • Identifying information for each entity beneficial owner that owns 10% or more (see individual
    customer information collected above for more details).

Other information required by Chatex for KYC, AML and supplying new services purpose.


When you use our platform, we automatically collect information from your devices. We collect the
following information:

  • Server Log Information: We collect server log information when you use our platform, which may
    include (but is not limited to) your login details, the date and time of visits, the pages viewed,
    your IP address, time spent at our platform.
  • Device Information: We collect information about the computer or mobile device you use to access our
    platform, including the hardware model, operating system and version, the web browser you use, and
    other device identifiers.
  • Telemetry Information. If you use any of our open source software, we may collect bandwidth upload
    and download speeds, the amount of free and used storage space on your device and other statistics
    about your device.
  • Usage Information. If you use our platform, we will collect metadata about the files you upload for
    storage and we will record instances in which you have used your private key to authenticate

Information Collected by Cookies and Other Tracking Technologies: We and our Service providers use
various technologies to collect information when you interact with our platform, including cookies and
web beacons. Cookies are small data files that are stored on your device when you visit a platform,
which enable us to collect information about your device identifiers, IP address, web browsers used to
access the platform, pages or features viewed, time spent on pages, mobile app performance and links
clicked. Web beacons are graphic images that are placed on a platform or in an email that is used to
monitor the behavior of User visiting the platform or sending the email. They are often used in
combination with cookies.


We collect, hold and use the Information in accordance with laws of different jurisdictions to protect
our Users, Service and to prevent fraud.

We will only use the Information for purposes of:

  • analyzing and tracking data to determine the usefulness or popularity of certain content and to
    better understand the online activity of our platform users;
  • providing, maintaining, delivering or improving our platform or the products or services provided by
    us our partners;
  • fulfilling our legal or regulatory requirements including KYC, AML and any other requested
  • providing you with the information or products or services;
  • answering your inquiry or responding to a communication from you;
  • developing new products or services;
  • sending you technical notices, support or administrative notifications;
  • communicating with you about news, products, services, events and other information we think will be
    of interest to you or required to be received from you;
  • matching your Information with open data and other resources;
  • monitoring and analyzing trends, usage and activities in connection with our platform;
  • detecting, investigating and preventing potential fraudulent or unauthorized or illegal transactions
    or activities;
  • protecting the rights and property of Parties (as defined below) and others;
  • linking, connecting or combining Information we collect from or about you with other Information;
  • carrying out any other purpose or reason for which the Information was collected.
  • to process transactions and send notices about your transactions;
  • to verify your identity by comparing your personal information against third-party databases;
  • to send administrative or account-related information to you;
  • to provide a personalised experience, and implement the preferences you request;
  • to enhance security, prevent fraud, monitor and verify identity or service access, combat spam or
    other malware or security risks;
  • to deliver targeted marketing, service update notices, and promotional offers based on your
    communication preferences (where this in accordance with the law);
  • to interact with you on third party social networks (subject to that network’s terms of use);
  • to communicate with you about our events or our partner events;
  • to resolve disputes, collect fees, and troubleshoot problems;
  • to comply with legal obligations;
  • to enforce our agreements with third parties;
  • for supervising quality control and staff training.


You empower us and we will share Information about you in the following cases:

  • with our current or future parent companies, affiliates, subsidiaries and with other companies under
    common control or ownership with us or our offices internationally;
  • with third parties or service providers that perform work for us or at your request;
  • certain information you may choose to share may be displayed publicly, such as your username and any
    content you post when you use interactive areas of our platform like our online forums;
  • in connection with a merger, assign or sale of our company assets, or if we do a financing or are
    involved in an acquisition or any other situation where Information may be disclosed;
  • in response to a request for information if we believe disclosure is in accordance with, or required
    by, any applicable law, regulation or legal process;
  • if we believe your actions are inconsistent with our user agreements or policies, or to protect the
    rights, property and safety of any Party or others; and
  • with third parties where aggregate Information is disclosed which cannot be reasonably be used to
    identify you.


In this Section we set out:

  • External services (“processors“) that we use for processing personal data on behalf
    of us;
  • Types of personal data that processors may process;
  • The reason for using them.

For processing ID data, we use verification service by SUM AND SUBSTANCE LIMITED, a
company incorporated and registered in England with company number 09688671, whose registered office is
at Suite 1, 5 Percy Street, Fitzrovia, London, England, W1T 1DG, ID may contain your photo, full name,
address, date and place of birth, social security number and gender. The reason of netverify service is
checking whether the person is on any of the global sanctions lists, PEP lists, watchlists, blacklists
or comes from prohibited countries.

For behaviour statistics, business intelligence and email campaigns we use the service by Google LLC
(“Google Analytics”), a company located in the United States. Data that we may provide to Google
Analytics may include your IP address and that data is used by Google Analytics to generate information
about your usage of our service.

In addition to the specific disclosures of personal data set out in this Section 4, we may also disclose
your personal data 1) to our auditors, lawyers, accountants, consultants and other professional advisors
insofar as it is reasonably necessary for the purposes of obtaining professional advice or managing
legal disputes and risks; 2) where such disclosure is necessary for compliance with a legal obligation
to which we are subject, or in order to protect your vital interests and/or the vital interests of a


Rights of access, correction and deletion

You have a right of access to the personal information that we hold about you, and to some related
information. You can also require any inaccurate personal information to be corrected or deleted.

Right to object

You can object to our use of your personal information for direct marketing purposes at any time and you
may have the right to object to our processing of some or all of your personal information (and require
them to be deleted) in some other circumstances.
If you wish to exercise any of these rights, please contact us as set out below.


We take reasonable steps to protect the security of the information communicated through our platform.
However, no computer security system is entirely foolproof and the Internet is not a secure method of
transmitting information. As a result, you indemnify and we do not assume any responsibility for the
data you submit to or receive from us through the Internet or for any unauthorised access or use of that
information and we cannot and do not guarantee that information communicated by you to us or sent to you
by us will be received or that it will not be altered before or after its transmission to us. You agree
to not hold us and our respective past, present and future employees, officers, directors, contractors,
consultants, equity holders, suppliers, vendors, service providers, parent companies, subsidiaries,
affiliates, agents, representatives, predecessors, successors and assigns (collectively the “Parties”)
liable for any loss or damage of any sort incurred as a result of any misappropriation, interception,
modification, deletion, destruction or use of information provided through our platform.

Most web browsers are set to accept cookies as a default. You may wish to opt out by turning off cookies
(please refer to the help menu on your browser); however, switching off cookies may restrict your use of
our platform.

You may also opt out of receiving promotional communications from us at any time by following the
instructions in those communications. If you opt out, we may still send you non-promotional
communications, such as technical notices, support or administrative notifications or information about
your account (if you have one).


This platform may contain links to other third party websites that may collect personal information about
you, including through cookies or other technologies. If you link to another website, you will leave
this platform and this Privacy Policy will not apply to your use of and activity on those other
websites. You should consult these other websites’ privacy policies as we have no control over them and
are not responsible for any information that is submitted to or collected by these third parties.


If any User or visitor of the platform is a European person or from other country that is governed by
data collection law, hereby expressly agrees to transfer personal data to us for the global processing
in different jurisdictions.

Cookie Policy

What is a cookie

Cookies are small text files sent by us to your computer or mobile device, which enables
Chatex features and functionality.
They are unique to your account or your browser.
Session-based cookies last only while your browser is open and are automatically deleted when you close
your browser.
Persistent cookies last until you or your browser delete them or until they expire.

Does Chatex use cookies?

Yes. Chatex uses cookies and similar technologies like single-pixel gifs and web beacons.
We use both session-based and persistent cookies.
Chatex sets and accesses our own cookies on the domains operated by Chatex and its corporate affiliates
(collectively, the “Sites”).
In addition, we use third party cookies, like Google Analytics.

How is Chatex using cookies?

Some cookies are associated with your account and personal information in order to remember that you are
logged in and which workspaces you are logged into.
Other cookies are not tied to your account but are unique and allow us to carry out analytics and
customization, among other similar things.

Cookies can be used to recognize you when you visit a Site or use our Services, remember your
preferences, and give you a personalized experience that’s consistent with your settings.
Cookies also make your interactions faster and more secure.

Categories of Use Description
Authentication If you’re signed in to our Services, cookies help us show you the right information and
personalize your experience.
Security We use cookies to enable and support our security features, and to help us detect malicious
Marketing We may use cookies to help us deliver marketing campaigns and track their performance (e.g.,
a user visited our Help Center and then made a purchase).
Similarly, our partners may use cookies to provide us with information about your
interactions with their services, but use of those third-party cookies would be subject to
the service provider’s policies.

We may use cookies to help us deliver marketing campaigns and track their performance (e.g.,
a user visited our Help Center and then made a purchase). Similarly, our partners may use
cookies to provide us with information about your interactions with their services, but use
of those third-party cookies would be subject to the service provider’s policies.

Performance, Analytics and Research Cookies help us learn how well our Sites and Services perform. We also use cookies to
understand, improve, and research products, features, and services, including to create logs and
record when you access our Sites and Services from different devices, such as your work computer
or your mobile device.

The following are cookies used on and other domains operated by Chatex.

Description Expiration
Visitor Cookie 10 years
Settings 10 years
Tracks session you are logged into 10 years
Timestamp of last authorization Session
Timestamp of last authorization change 30 days
Settings 10 years
Session id cookie Session
Referral code for team creation Session
E-mail confirmation and code expiration cookie 1 hour
Internalization preferences 1 year
Advertising analytics 30 days

What third-party cookies does Chatex use?

You can find a list of the third-party cookies that Chatex uses on our sites along with other relevant

How are cookies used for advertising purposes?

Cookies and other ad technology such as beacons, pixels, and tags help us market more effectively to
users that we and our partners believe may be interested in Chatex.
They also help provide us with aggregated auditing, research, and reporting, and know when content has
been shown to you.

What can you do if you don’t want cookies to be set or want them to be removed, or if you want to opt
out of interest-based targeting?

Some people prefer not to allow cookies, which is why most browsers give you the ability to manage
cookies to suit you. In some browsers you can set up rules to manage cookies on a site-by-site basis,
giving you more fine-grained control over your privacy. What this means is that you can disallow cookies
from all sites except those that you trust.

Browser manufacturers provide help pages relating to cookie management in their products. Please see
below for more information.