Flay-Trade Privacy Policy

1. Scope & Overview

This Privacy Policy describes how Flay-Trade ("we", "our", "us") collects, uses, discloses, and protects personal information when you visit or use our website, mobile applications, and other services (collectively, the "Services"). It applies to users worldwide. By using our Services you agree to the terms in this policy.

2. Definitions

• Personal Data / Personal Information: Any information relating to an identified or identifiable individual.
• Processing: Any operation performed on personal data (collecting, storing, accessing, using, sharing, deleting).
• Controller / Processor: Flay-Trade acts as a controller for the purposes of the personal data collected via our Services; third-party providers may act as processors.

3. Information We Collect

We collect the following categories of information:

3.1 Identity & Contact Information

• Full name, email address, phone number, mailing address (if provided), username.
• Profile photo (if uploaded) and other public profile information.

3.2 Financial & Transaction Data

• Cryptocurrency wallet addresses you deposit from or withdraw to, transaction IDs, deposit and withdrawal amounts, timestamps and confirmations.
• Payment processor details (if you use third-party payment services) and any metadata required to complete transactions.

3.3 Identity Verification / KYC Documents

• Government-issued ID, proof of address, selfie photos, and other documents required to comply with Anti-Money Laundering (AML) and Know-Your-Customer (KYC) rules.

3.4 Technical & Usage Data

• IP address, device identifiers, operating system, browser type, time zone, language, referring pages, pages visited, and clickstream data.
• Logs and diagnostic data for fraud detection and troubleshooting.

3.5 Communications

• Records of communications between you and Flay-Trade (support tickets, emails, chat logs) and transactional messages (receipts, confirmations).

3.6 Cookies, Analytics & Third-party Data

• Cookies, device fingerprinting, analytics data (Google Analytics or equivalent), and information from social logins or third-party services when you choose to connect them.

3.7 Public Blockchain Data

• When you transact on blockchains, related data (wallet address, transaction hashes) is public and immutable; we may record and store this public information as part of transaction records.

4. How We Collect Data

We collect information:

• Directly from you when you register, verify your account, transact, or communicate with support.
• Automatically when you use the Services (logs, cookies, analytics).
• From third parties such as payment processors, identity verification providers, and public sources.

5. How We Use Personal Data

We use your information for the following purposes:

• Provide Services: To open and manage your account, process deposits and withdrawals, execute trades and display balances.
• Compliance: KYC/AML checks, sanctions screening, tax and regulatory reporting.
• Security & Fraud Prevention: To detect and prevent fraud, money laundering, unauthorized access, and other security incidents.
• Customer Support: Respond to queries and provide technical assistance.
• Product Improvement: Analytics and research to enhance our platform and services.
• Marketing (with consent): Promotional emails or offers if you opt-in; you can opt-out at any time.
• Legal & Safety: To comply with legal obligations and exercise or defend legal claims.

6. Legal Basis for Processing (if you are in the EU/EEA)

• Performance of a Contract: Processing necessary to provide services (account creation, transactions).
• Legal Obligation: Processing to comply with AML, tax, and regulatory requirements.
• Legitimate Interests: Fraud prevention, platform security, and service improvement (balanced with your rights and freedoms).
• Consent: For marketing communications and certain optional features (you may withdraw consent anytime).

7. Sharing & Disclosure

We may share your personal data with:

• Service Providers: Payment processors, cloud hosting, analytics, identity verification and KYC providers — only as needed and under contract.
• Regulators & Law Enforcement: When required by law, court order, or to prevent fraud and illegal activity.
• Affiliates & Business Transfers: In connection with corporate reorganizations, mergers, acquisitions, or sale of assets (we will notify you where required).
• Public Blockchain: Transaction details you submit to a blockchain are public; we cannot remove or change blockchain records.
• Aggregated / Anonymized Data: We may publish anonymized statistics that do not identify individuals.

8. International Transfers & Storage

Our systems and third-party providers may store and process data in jurisdictions outside your country, including the United States and other countries. When we transfer personal data across borders we use appropriate safeguards (e.g., Standard Contractual Clauses, vendor contracts, or legally required measures).

If you are located in the EU/EEA and wish to receive details of the safeguards used for a specific transfer, please contact us (see "Contact" below).

9. Data Retention

We retain personal data only as long as necessary for the purposes listed above, subject to legal and regulatory requirements. Typical retention periods include:

• Transaction Records: retained for regulatory and audit obligations (commonly 5–10 years, depending on jurisdiction).
• KYC / Identity Documents: retained while your account is active and for a period after account closure as required by law (commonly several years for AML).
• Support & Communication Logs: retained for a reasonable period for service quality and dispute resolution.
• Marketing Data: retained until you unsubscribe or withdraw consent.

10. Security Measures

We take multiple technical and organizational measures to protect your data, including:

• Encryption in transit (TLS) and encryption at rest for sensitive data where feasible.
• Access controls and role-based permissions for internal systems.
• Two-factor authentication (2FA) support for user accounts.
• Regular security testing, vulnerability scanning and audits.
• Secure key management and periodic backups.

While we work to protect your data, no online system is 100% secure. If a data breach affecting your information occurs and notification is required by law, we will notify you and the relevant authorities in accordance with applicable regulations.

11. Cookies & Tracking Technologies

We use cookies and similar technologies for:

• Essential cookies: Required for site operation (e.g., login sessions).
• Performance & Analytics: To analyze and improve site performance (e.g., Google Analytics).
• Functionality: To remember preferences and settings.
• Marketing: To deliver relevant advertising where applicable (only with consent where required).

You can manage cookies through your browser settings or via our cookie banner (if shown). Disabling certain cookies may limit functionality of the Services.

12. KYC / AML & Identity Verification

To comply with applicable laws and prevent fraud, money laundering and terrorist financing, we may require identity verification. You may be asked to provide government-issued ID, proof of address, selfies, and other documents. Refusal to provide required information can lead to restricted account access, withholding of funds, or account closure, as permitted by law.

All identity documents are handled securely and only retained as required by law.

13. Your Rights

Depending on where you live, you may have the following rights:

• Access: Request a copy of personal data we hold about you.
• Correction: Request correction of inaccurate or incomplete data.
• Erasure: Request deletion of your personal data (subject to legal exceptions, e.g., AML retention).
• Restriction: Request limitation of processing in certain circumstances.
• Portability: Request a machine-readable copy of your data to transfer to another provider.
• Object: Object to processing based on legitimate interests (reviewed case-by-case).
• Withdraw Consent: Where processing is based on consent, you can withdraw it at any time.

To exercise any of these rights, contact us at support@flay-trade.com. Please include "Privacy Request" in the subject and provide sufficient information to verify your identity.

14. California Consumer Privacy Act (CCPA)

If you are a California resident, you may have additional rights, including:

• Right to Know: The categories and specific pieces of personal information collected and sold or shared.
• Right to Delete: Request deletion of personal information (with exceptions).
• Right to Opt-Out: Opt out of sale of personal information. (We do not sell personal information in the traditional sense; if this changes we will provide a clear opt-out mechanism.)
• Non-Discrimination: We will not discriminate against you for exercising CCPA rights.

To submit a CCPA request, contact support@flay-trade.com with “CCPA Request” in the subject.

15. Children

Our Services are not directed to children under the age of 18 (or the applicable age in your jurisdiction). We do not knowingly collect personal information from children. If we learn we have collected such information, we will take steps to delete it. If you believe a child has provided us personal information, please contact us.

16. Changes to this Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. When we make material changes we will provide prominent notice (for example via email or on our site) and update the "Effective date" at the top of the policy.

17. Contact & Data Requests

If you have questions about this policy or wish to exercise your rights, contact us:

• Email: support@flay-trade.com
• Postal Address: Flay-Trade (Data Protection), 123 Finance Ave, New York, NY, USA

For identity verification requests we may ask for government ID or other proof to confirm your identity before processing sensitive requests.

18. Dispute Resolution & Supervisory Authorities

If you are not satisfied with our response, you may lodge a complaint with your local data protection authority (if applicable). For EU/EEA residents, you have the right to file a complaint with your national supervisory authority.

Additional Notes

Blockchain note: Cryptocurrency transactions recorded on public blockchains are immutable and publicly viewable. Flay-Trade cannot remove, alter, or make private blockchain transaction data (wallet addresses, txids) once broadcast.

Third-party services: Our Services may contain links to third-party websites and services. We are not responsible for their privacy practices. Review their privacy policies before providing any personal information.

Last updated: September 2, 2025

Important: This Privacy Policy is provided for informational purposes and does not constitute legal advice. You should consult legal counsel to ensure compliance with specific laws applicable to your jurisdiction.