Privacy Policy

Last updated February 15, 2025

This privacy notice for Derevex (doing business as Derevex) (“Derevex”, the “Company” “we”, “us”, or “our”), describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:

  • Visit our website at https://www.derevex.com, or any website of ours that links to this privacy notice
  • Use our trading platform at https://app.derevex.com
  • Engage with us in other related ways, including any sales, marketing, or events

We use your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at legal@derevex.com.

PERSONAL DATA WE COLLECT ABOUT YOU, WHY WE PROCESS IT, AND THE LEGAL BASIS FOR PROCESSING

When you access, use, connect to, or interact with the Website, we may collect certain categories of information about you, including personal data, from a variety of sources.

Information you provide to us:

Personal data may include:

  • Email address
  • Full name
  • Gender
  • Date of birth
  • Home address
  • Phone number
  • Nationality
  • Device ID
  • Any digital asset, smart-contract, or protocol address (“Wallet”) information
  • Geolocation data

Should you contact us, we will collect the content of the communications we have with you and any personal data contained within, including the email address you used to contact us.

Information we collect automatically:

When you visit the Website, our servers automatically record certain information, including:

  • The Internet protocol (IP) address used to connect your computer to the Internet
  • Login information, email address, password, and location of your device or computer
  • Derevex usage metrics (e.g., occurrences of technical errors, your interactions with service features and content, and your settings preferences)
  • Version and time zone settings
  • The date and time of access
  • The country from which the website is accessed
  • Any API endpoints being accessed
  • User agent details
  • The operating system of your computer and the browser you are using (provider, version, and language)
  • The transmission protocol used (e.g., HTTP/1.1)

Additional Information:

  • Transaction information and history (such as your public blockchain transaction history and other information associated with a linked address or Wallet)
  • Information from other sources: we may receive information about you from other sources such as credit history information from credit bureaus
  • Information about your behaviour: we may process information about your behaviour and activity for marketing and advertising purposes

Finally, we may use web beacons/clear gifs, geolocation and tracking technologies, and other applications when you visit the Website, including technologies collecting certain information about your access to, use of, connection to, or interaction with the Website (“Usage Data”) that may be integrated with third-party service providers.

LEGAL BASIS FOR PROCESSING PERSONAL DATA

We generally process the information we collect when:

  1. We need to do so to perform our contract with you
  2. It is in our legitimate interests to provide effective services to you
  3. We have your consent
  4. We have a legal obligation to do so

With your consent, we may use any data collected, including Usage Data, to:

  • Tailor features and content to you
  • Ensure content is presented in the most effective manner for you and your device
  • Run analytics to better understand your user experience
  • Conduct marketing activities (where you have opted in)

In our legitimate interests to provide effective services to you, we may also use this data to create aggregated, anonymized, or de-identified data.

COOKIE POLICY

We use cookies to enhance your experience when accessing and using the Website. The cookies we use are:

  • Strictly necessary cookies that help ensure compliance with our Terms of Service
  • Functional cookies that remember your preferences and choices
  • Performance cookies that help us understand how you use our Website
  • Analytics cookies that help us improve our services

These cookies are not used for marketing purposes unless you have explicitly consented. By continuing to use the Website, you consent to the placement of these cookies.

YOUR RIGHTS

Under applicable data protection laws, you may have certain rights in relation to your personal data. These rights may include:

  • Access to your personal data that we hold, information on how we use it, and who we share it with
  • Request the correction of inaccurate or incomplete personal data we hold about you
  • Deletion or removal of your personal data, in certain circumstances
  • Objection to the processing of your personal data, in certain circumstances
  • Restriction of processing of your personal data, to stop us from processing the personal data we hold about you other than for storage purposes
  • Portability of your personal data; we will endeavor to provide you, or a third party, with a copy of the personal data that we hold about you in a structured, commonly used, machine-readable format
  • Withdrawal of consent, where we rely on consent to process personal data

You may submit a written request concerning the processing of your personal data to legal@derevex.com. Please note that, prior to any response to such a request, we will require you to verify your identity.

Note that these rights may be limited by law. Such limitations may apply where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interests, or where we are required by law to retain your personal data.

SHARING OF PERSONAL DATA

In certain circumstances, we may share your information with third parties with your consent, as necessary, or as otherwise required or permitted by law, including:

Service providers and vendors:

We may share your personal data with third parties to process on our behalf. Such third parties could include:

  • Blockchain analysis service providers
  • Know-your-customer and screening service providers
  • Developers
  • Content delivery service providers
  • Data analytics service providers
  • Payment processors
  • Credit bureaus

Professional advisors:

As necessary, we will share your personal data with professional advisors such as:

  • Auditors
  • Law firms
  • Cybersecurity specialists
  • Data analysis organizations
  • Consulting or accounting firms

Legal and security reasons:

We may share your data:

  • To comply with legal obligations
  • To enforce our terms of service
  • To protect our rights, privacy, safety, or property
  • To protect against legal liability

International Data Transfers:

Your personal information may be transferred to and stored or processed in countries outside the jurisdiction in which you live and reside, including outside the Cayman Islands, European Economic Area (“EEA”) and United Kingdom (“UK”), and including to the United States of America.

We will take steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy. These measures include seeking entry into the standard contractual clauses (“SCCs”) approved by the European Commission (for transfers outside the EEA) and/or an international data transfer agreement/addendum to the SCCs approved by the UK Information Commissioner’s Office (“ICO”).

RETENTION

We will retain your personal data only for so long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements, or as otherwise required by law. The length of time we retain your data will depend on the nature of the data and the purpose for which it was processed.

CHILDREN’S PRIVACY AND DATA PROTECTION

If we become aware that we have unknowingly collected information about any person under eighteen (18) years of age, we will make commercially reasonable efforts to delete such personal data and other information from our records. The Website and our services are not intended for use by individuals under the age of 18.

SECURITY MEASURES

Be aware that despite our efforts to protect your personal data and other information, we cannot guarantee perfect security of your information transmitted through the Website. In addition, note that any information you send to us electronically may not be secure while in transit. Any transmission is at your own risk.

We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including:

  • Encryption of personal data
  • Ability to ensure ongoing confidentiality, integrity, availability, and resilience of processing systems and services
  • Ability to restore availability and access to personal data in a timely manner in the event of a physical or technical incident
  • Regular testing, assessing, and evaluating the effectiveness of technical and organizational measures

THIRD-PARTY WALLET CONNECTIONS AND DISCLAIMER

Certain features of the Website may require you to connect a compatible third-party digital Wallet. By using such Wallet, you agree that your access to, use of, connection to, and/or interactions with such third-party Wallets are governed by the policy for the applicable Wallet, and you agree that you are using the Wallet in accordance with the terms and conditions of the applicable third-party provider of such Wallet.

Wallets are not maintained or supported by, or associated or affiliated with, the Company. We expressly disclaim any and all liability for actions arising from your use of third-party Wallets, including but without limitation, actions relating to the use and/or disclosure of personal information by such third-party Wallets.

SOCIAL MEDIA AND OTHER THIRD-PARTY WEBSITES

We may provide links on the Website to other websites or online platforms operated by third parties, including social media platforms. We do not own, operate, or control such third-party websites. If you follow links to sites not owned or operated by us, you should review their privacy and security policies and other terms and conditions.

When you open a link to any Social Media Platform from the Website, a direct connection may be established between your browser and the server of the Social Media Platform. This provides the Social Media Platform with information that you visited the Website and accessed the link.

PERIODIC REVIEWS AND UPDATES TO POLICY

This Policy takes into account the requirements of the Cayman Islands Data Protection Act 2021 and general privacy principles. Individuals located in the European Union (“EU”) and the United Kingdom (“UK”) may have rights under the EU General Data Protection Regulation 2016/679 and the UK General Data Protection Regulation, respectively (collectively, the “GDPR”).

We may review and update this Policy from time to time. Updates to this Policy will apply only to information collected after the date of the change. If we make material changes, we will update the “Last Updated” date at the top of this Policy.

CONTACT

Should you have any questions or complaints about our privacy or data protection practices, your personal data, or this Policy, you can email us at legal@derevex.com.