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Privacy Policy

Thank you for choosing the relevant service(s) (the “Services”) and/or product(s) (the “Product”) provided by Tech Jubilant FZCO – a Free Zone Company incorporated in Dubai with Registration Number DSO-FZCO-51601, Trading License Number – 53947, Located at – Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates.

For this Privacy Policy, “Services” include, but are not limited to, user onboarding and verification processes, digital wallet services, cryptocurrency-to-fiat conversion, payment processing, card issuance and management, platform access via web, mobile applications or APIs, security features, and customer support.

“Product” includes any physical or virtual product issued by the Company, including, but not limited to, the Cardaxo Crypto Card (as defined in the Cardaxo Card Terms & Conditions), prepaid crypto-linked cards, and any related financial instruments or access tools made available to you.

By accessing or using Tech Jubilant FZCO’s Services and/or Products, you acknowledge and agree to the policies and practices set out in this Privacy Policy (the “Privacy Policy”). You further represent and warrant that you have obtained all necessary consent and authority from any relevant person(s) (as defined below) for us to collect, use, disclose, and/or process personal data in accordance with this Privacy Policy.

This Privacy Policy outlines how Tech Jubilant FZCO collects, uses, stores, and discloses your personal data when you access or use our Services and/or Products.

We may update this Privacy Policy from time to time by publishing the revised version on our website, application programming interfaces, or mobile applications (collectively, the “Site”), or by notifying you via email. Your continued access to or use of the Services and/or Products following such updates shall constitute your acceptance of the revised Privacy Policy.

1. Personal Data We Collect

We may from time to time collect, process, and store certain personally identifiable information that can be used to contact or identify you and your beneficial owners, directors, officers, authorized signatories, employees, representatives, guarantee/security providers and other natural persons related to you (“Relevant Persons”) via your use of the Services/Products or where you have given your consent (“Personal Data”). Such Personal Data may include contact details, information and data generated in the ordinary course of your relationship with us, information and data collected when you or a Relevant Person participates in events organised by us and information from cookies or the use of any information technology applications. The Personal Data that you may provide to us during the onboarding process may also include, without limitation:

  1. Full legal name (including former name, and names in English and Chinese, if applicable)
  2. Identification document type (e.g. Passport)
  3. Identification document number (e.g. Passport No.)
  4. Gender
  5. Date of birth
  6. Place of birth
  7. Nationality
  8. Residential address
  9. Country/state of residence
  10. Contact phone number
  11. Email address
  12. Bank account information
  13. Blockchain address
  14. Additional Personal Data or documentation at the discretion of our compliance team

2. How do we use your personal data?

We may use your Personal Data for the following purposes:

  • Service Provision and Access Decisions: To evaluate, approve, and manage your access to Tech Jubilant FZCO’s  Services and Products, including decisions relating to onboarding, account maintenance, or suspension/termination where necessary.
  • Operations and Improvement: To administer, operate, deliver, enhance, and personalise our Services and Products, including but not limited to Cardaxo. Permitting the exercise of the right to improve functionality, user experience, and security.
  • Payments and Transactions: To process, validate, and record transactions (including crypto-to-fiat conversions), and to provide statements, invoices, receipts, and other related records associated with your use of the Services and Products.
  • Monitoring and Security: To monitor and record usage of the Services and Products, as well as communications with you and/or relevant persons, for purposes including fraud detection, prevention, investigation, dispute resolution, and platform integrity.
  • Technical Maintenance: To detect, prevent, and resolve technical issues, system errors, or security vulnerabilities affecting the Services and Products.
  • Risk, Compliance, and Analytics: To perform risk assessments, fraud screening, blockchain analysis, anti-money laundering (AML) checks, counter-terrorism financing (CTF) controls, credit and financial assessments, and internal data analysis, as well as to conduct internal and external audits.
  • Communication and Engagement: To communicate with you (and, where applicable, your authorised representatives or affiliates) regarding your account, transactions, updates, security alerts, and information about Tech Jubilant FZCO’s Services and Products, unless you have opted out of non-essential communications.
  • Marketing and Research: To conduct market research, analytics, surveys, promotions, and campaigns, and to better understand user preferences, behaviour, and trends, to improve our offerings.
  • Legal and Regulatory Compliance: To comply with applicable laws, regulations, and regulatory requirements, including obligations relating to AML, KYC, tax reporting, sanctions screening, and financial crime prevention.
  • Rights Protection and Enforcement: To enforce our terms, protect our legal rights, prevent misuse of the Services and Products, and safeguard Tech Jubilant FZCO, its affiliates, users, and partners.
  • Additional Disclosed Purposes: To carry out any other purpose that has been notified to you at the time your Personal Data was collected, or as otherwise permitted or required by applicable law.             

3. Do we share your personal data?

We may share your Personal Data with the following categories of recipients, strictly on a need-to-know basis and for the purposes described in this Privacy Policy:

  • Service Providers and Infrastructure Partners: Third-party service providers that support the provision, operation, security, and enhancement of Tech Jubilant FZCO’s Services and Products. This includes, but is not limited to, identity verification (KYC/KYB) providers, blockchain analytics and compliance partners, payment processors, card networks, banking and financial institution partners, liquidity providers, merchants, loyalty and rewards partners, and vendors providing services such as cloud hosting, data analytics, cybersecurity, telecommunications, and customer support.
  • Affiliates and Group Entities: Any entity within Tech Jubilant FZCO and its affiliated group of companies, provided such entities are subject to appropriate confidentiality and data protection obligations.
  • Professional Advisers: Legal, financial, compliance, audit, and other professional advisers engaged by Tech Jubilant FZCO and its affiliates, to the extent necessary for advisory, risk management, or regulatory purposes.
  • Marketing and Platform Partners: Third parties engaged for marketing, advertising, analytics, or promotional activities (such as social media platforms, advertising networks, and partner websites), subject to applicable data protection laws and user preferences where required.
  • Regulatory, Legal, and Government Authorities: Any competent authority, regulator, law enforcement agency, court, or governmental body where disclosure is required or permitted under applicable laws, regulations, legal processes, or to protect the rights, safety, and integrity of Tech Jubilant FZCO, its users, or the broader financial ecosystem.
  • User-Authorised Parties: Any person or entity you explicitly authorise us to share your Personal Data with, including your representatives, agents, advisors, or beneficiaries.
  • Business Transfers and Corporate Transactions: Any actual or potential acquirer, investor, assignee, or successor-in-interest in connection with a merger, acquisition, restructuring, financing, or sale of assets involving Tech Jubilant FZCO or its affiliates, subject to appropriate confidentiality safeguards.

In addition, we may share aggregated, anonymised, or de-identified data (which does not personally identify you) with the above categories of recipients and other partners for analytics, research, product development, security enhancements, and to improve the overall performance and user experience of our Services and Products.

4. Do we transfer your personal data?

Your information, including Personal Data, may be transferred to and processed on computers located outside your state, province, country, or other governmental jurisdiction, where data protection laws may differ from those in your jurisdiction. This may include storage on our or third-party cloud servers.

Your consent to this Privacy Policy and your submission of such information represent your agreement to that transfer.

We will take reasonable measures to ensure that your Personal Data is treated securely and in accordance herewith and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place, including the security of your Personal Data and other personal information.

5. How long do we retain your data?

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy, also to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. By accessing/using our Services/Products, you consent to our retention of your Personal Data.

6. Marketing Communications

We may communicate company news, promotions, and information relating to our products and services provided by us. We may share Personal Data with our affiliates to send marketing communications. However, this will happen only if we have received your express consent in the relevant channels in the Services/Products.

You may email us at support@cardaxo.com in case you do not wish to receive these communications. Make sure the subject of the mail is – “MARKETING OPT OUT”.

To ensure the quality of our Services/Products, you will continue to receive essential Service/Product-related communications, including updates, operational notifications, and changes to terms and conditions. Please note that you cannot opt out of receiving these communications.

7. Cookie Usage

While you access the Site, we may use industry-standard practices to place a small amount of data on your browser (“Cookies”) or other devices used to visit the Site. This information helps us recognise you as a customer, collect information about your use of our Services/Products to customise our services better and improve your experience. We may also use the information collected to make sure it abides by our compliance program, and to ensure your account security has not been compromised by detecting irregular or suspicious account activities.

Most browsers are set up to accept Cookies automatically. Some Cookies expire when you finalise the session, and other Cookies remain on your computer or other devices until deleted or expired. You have the option to decline the use of our Cookies, but this may affect the functionality of the Services/Products or your user experience.

Some browsers have a do-not-track feature that lets you tell websites that you do not want to have your online activities tracked. At the moment, we do not respond to browser do-not-track signals.

8. Information Security

We take the security of your data seriously and strive to protect both you and our systems from unauthorised access, alteration, disclosure, or destruction of the information we collect and store. To safeguard your Personal Data, we implement a range of security measures, including encryption of communications, SSL, mandatory two-factor authentication for all sessions, regular reviews of our data collection, storage, and processing practices, and restricting access to Personal Data strictly on a need-to-know basis.

While we are committed to using commercially acceptable means to protect your Personal Data, you acknowledge that no method of transmission over the Internet or method of electronic storage is completely secure. Accordingly, we cannot guarantee absolute security.

9. Links to other sites

Our Site may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit. You understand we have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

10. Minor policy

We do not provide Services/Products to anyone who is regarded as a “minor” or equivalent under applicable law. We do not knowingly and intentionally collect the personally identifiable information from anyone who is regarded as a “minor” or equivalent under applicable law. If you are a parent or guardian and you are aware that your child (being a “minor” or equivalent under applicable law) has provided us with Personal Data, please contact us, and we will take appropriate measures.

11. Your contact with other customers

You understand you are solely responsible for your interactions with other Users. We reserve the right, but have no obligation, to monitor disputes between you and other Users.

12. Contacting us about privacy questions or concerns

If you have any questions about this Privacy Policy or the use of your Personal Data, please contact us by sending an email to the following address: support@cardaxo.com with the subject “PRIVACY QUESTION”.

If you wish to access the Personal Data we hold about you, or request that it be updated, corrected, or deleted from our systems, please contact us at support@cardaxo.com with the subject line “DATA INQUIRY.” We will make reasonable efforts to process your request as soon as possible. However, please note that we may decline deletion requests in certain circumstances, including where retention is required for legal or regulatory purposes.

If you wish to withdraw your consent, please contact support@cardaxo.com with the subject “DATA INQUIRY”. Where you or a Relevant Person withdraws your/its/their consent or fails to supply relevant information or data required for us to provide our Services/Products to you, we may be unable to provide or continue to provide Services/Products to you.

In response to a data access, correction, deletion or data portability request, we will verify the requesting party’s identity to ensure that he or she is legally entitled to make such a request. While we aim to respond to these requests free of charge, we reserve the right to charge you a reasonable fee, especially if the request is repetitive or onerous.

13. Language

If this Agreement is translated into any other language from English, the English language version shall prevail to the extent of any inconsistency.

14. Specific Rights under different jurisdictions

Depending on your location, you may have additional rights regarding the collection, use, and processing of your Personal Data under applicable data protection laws. These rights may include the right to access, correct, delete, restrict, or object to the processing of your Personal Data, as well as the right to data portability.

We are committed to honouring such rights in accordance with the laws applicable to your jurisdiction. If you wish to exercise any of these rights, please contact us using the details provided in this policy.

Please note that the scope and applicability of these rights may vary depending on your country or region, and we may require verification of your identity before processing your request.

14.1 Your Rights if your Personal Data is covered by the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (“EEA”), our legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it. We may process your Personal Data because:

  • We need to use your Personal Data to contract with you or to perform our obligations thereunder.
  • You have given us consent to do so.
  • The processing is in our legitimate interests or necessary to comply with our legal obligations.
  • To comply with applicable laws and regulations.

If you are a resident of the EEA, you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. Please see section 12 (Contacting Us About Privacy Questions or Concerns) above. In certain circumstances, you have the following data protection rights:

  • The right to access, update, or delete the information we have on you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time, where we relied on your consent to process your personal information.

Sensitive personal information. – The categories of information that Tech Jubilant FZCO collects and discloses for a business purpose include “sensitive personal information” as defined under the CCPA. Tech Jubilant FZCO does not use or disclose sensitive personal information for any purpose not expressly permitted by the CCPA.