Privacy Policy

Effective Date: December 30, 2025

1. INTRODUCTION AND ACCEPTANCE

This Privacy Policy describes how XMT Exchange (referring to the operating entity as defined in the Terms of Service, hereinafter "XMT Exchange", "we", "us", or "our") collects, uses, stores, shares, and protects your personal information.

By accessing and using our Services, you signify acceptance to the terms of this Privacy Policy and our Terms of Service. You explicitly acknowledge and consent that your personal data will be processed and stored by the legal entity defined in the Terms of Service.

If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.

2. CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. When required by law or in the event of significant operational changes (such as a change in the operating entity), we will notify you of changes. If we make any material changes, we will notify you by email or by means of a notice on our Services prior to the change becoming effective. Continued use of the Service after such changes constitutes acceptance of the new policy.

3. WHAT INFORMATION DOES XMT EXCHANGE COLLECT?

3.1 Personal & Anonymous Data

We collect Personal Data and Anonymous Data. "Personal Data" means data that allows someone to identify or contact you (e.g., name, address, email). "Anonymous Data" means data that is not associated with or linked to your Personal Data.

We collect Personal Data when you use our Site, verify your identity, or contact support. This includes basic contact details, government identification, and biometric information.

3.2 Automatically Collected Info

Our servers collect browser type, IP address, and log files. We use cookies to collect information (See Section 16).

4. INFORMATION ABOUT CRIMINAL CONVICTIONS

When you register for or otherwise use our Services, we may receive information about your criminal convictions when we perform certain verification or compliance checks (AML/CTF).

5. IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law or under contract, failure to provide that data may prevent us from performing the contract, potentially leading to account closure.

6. COLLECTION OF PERSONAL INFORMATION

We collect Personal Data to provide you with our Services:

  • Information you provide to us: Personal identification information (name, address, etc.), Formal identification information (passport, tax ID, etc.), Account information, Financial information, and Residence verification information.
  • Information we collect when you use our services: Device Information, Location Information, Log Information, Account Information (trading activity, deposits, withdrawals), and Residence verification information.
  • Information we collect from other sources: We may collect information from third party partners, public authorities, and public websites.

7. HOW WE USE YOUR PERSONAL INFORMATION

We only use your Personal Data if we have a proper reason for doing so.

7.1 Legal Obligations: To maintain legal and regulatory compliance (AML/KYC), and to ensure network and information security.

7.2 Contractual Obligations: To provide the Services, to provide communications, to provide customer service, and to ensure quality control.

7.3 Legitimate Interests: To ensure network and information security, to enforce our terms of use, for research and development purposes, to enhance your website experience, and to engage in marketing activities (for eligible users).

Corporate Transfers: We may process and transfer your data in the context of corporate structural changes, such as the migration of the operating entity.

[SPECIAL NOTE FOR EU/EEA RESIDENTS]

Due to the termination of services for residents of the European Union (EU) and European Economic Area (EEA), XMT Exchange will no longer process the personal data of such users for the purpose of providing active trading services or marketing. Data of EU/EEA residents will be retained solely for the purposes of: processing final withdrawals and account closure; complying with legal obligations (including AML); and defending against legal claims.

8. AUTOMATED DECISION MAKING

We may make automated decisions on certain matters, such as to fulfill our obligations imposed by law (such as to verify your identity), to detect fraudulent or prohibited activities.

9. OUR USE OF COOKIES

Please see Part 16 (Cookies Policy).

10. DISCLOSURES TO THIRD PARTIES

We may share your Personal Data with:

  • Identity verification and transaction monitoring services.
  • Service providers (legal, accounting, marketing, IT).
  • Financial institutions and payment processors.
  • Corporate Affiliates and Successors: We may share your Personal Data with companies or other entities that we plan to merge with, be acquired by, or transfer our business operations to.
  • Law enforcement, government officials, or regulators.

11. CONSENT TO INTERNATIONAL TRANSFERS OF PERSONAL DATA

XMT Exchange operates internationally. By using our Services, you acknowledge and consent that your Personal Data may be transferred to, stored, and processed in the jurisdiction of our principal place of business and other jurisdictions globally.

  • Global Infrastructure: Your data may be processed in data centers located worldwide.
  • Global Support & Operations: Your Personal Data may be accessed by our support teams and operational staff located in various jurisdictions.
  • User Consent: By accepting this Privacy Policy, you specifically and voluntarily consent to the transfer of your personal information to these jurisdictions.

12. YOUR RIGHTS

You have certain rights concerning your Personal Data (Access, Correction, Erasure, Restriction, Data Portability, Objection).

Limitation on Rights for Closed Accounts: Please note that if your account is closed, we may be unable to fulfill requests for Erasure or Restriction if retention of your data is mandated by applicable laws. In such cases, your data will be securely archived.

Contact: privacy@xmtexchange.com

13. SECURITY OF PERSONAL DATA

We use a variety of security measures (encryption, firewalls, access controls) to ensure the confidentiality of your Personal Data. However, we cannot guarantee absolute security.

14. RETENTION OF PERSONAL DATA

We retain Personal Data for as long as necessary to fulfill the purposes described in this Privacy Policy, subject to our own legal and regulatory obligations.

  • Active Accounts: Retained while the account is active and for a reasonable period thereafter.
  • Terminated/Closed Accounts: We retain personal data for a period required by applicable laws (typically 5 to 7 years) to comply with Anti-Money Laundering (AML), tax, and audit obligations. After this mandatory period expires, data will be securely deleted or anonymized.

15. CHILDREN'S PERSONAL INFORMATION

We do not knowingly request to collect Personal Data from any person under the age of 18.

16. COOKIES POLICY

16.1 Description of Cookies

Cookies are small text files placed on your computer by websites you visit. They are widely used to allow websites to work properly or more efficiently. There are "First-party cookies" (set by us) and "Third-party cookies" (set by others).

16.2 Why We Use Cookies

These technologies help us better understand user behavior and inform us about which parts of the Sites people have visited.

16.3 We use cookies to:

  • Track traffic flow and patterns of travel in connection with the Sites;
  • Understand the total number of visitors and their device types;
  • Monitor performance and continually improve the Sites;
  • Customize and enhance your online experience; and
  • Enable us and third parties to advertise both on and off the Sites.

16.4 Categories of Cookies We Use

  • Strictly Necessary Cookies: Necessary for basic site navigation and features.
  • Functionality Cookies: Used to remember choices and tailor content.
  • Performance/Analytics Cookies: Collect anonymous information about site usage.
  • Advertising and Tracking Cookies: Used by third-party companies to track activity and show relevant ads.

16.5 Other Similar Technologies We Use

In addition to cookies, we may use web beacons (clear gifs) to track online movements of web users and manage content effectiveness.

16.6 Your Choice

You have the right to choose whether or not to accept cookies. Most browsers allow you to change settings, though refusing cookies may limit site functionality.