Privacy Policy

1INTRODUCTION

Skyrexio LLC ("Skyrexio LLC", "Skyrexio", "our", "we" or "us" as applicable) provides tools that allow managing cryptocurrency holdings, including application program interface(s) ("Software"). Your privacy is important to us and therefore, it is our policy to respect your privacy and take appropriate measures to protect your personal data.

This privacy Policy ("Policy") explains how we process, including how we use, store and disclose your personal data when: (i) you visit or otherwise interact with our website at https://skyrexio.com ("Website"), our desktop application at https://app.skyrexio.com and / or our mobile application(s) (available via Apple App Store or Google Play Store) (jointly "App"); (ii) you access or interact with our Skyrexio LLC application programming interface ("Skyrexio LLC API"); (iii) you (or the legal entity you represent) wish to register or have registered a user account, including agreeing to our Terms of Use, and using the Software; (iv) you subscribe to our newsletter and/or receive other direct marketing; (v) communicate with us through our Website, App or other communication channels (e.g., by email or our official social media accounts); or (vi) take any other actions on our Website, App, or Skyrexio LLC API, which entails us receiving and processing your personal data. The data we process may differ based on your interactions with us, so if anything here only applies to one specific use case, we'll point this out to you.

We process your personal data as described in this Policy and in accordance with applicable legislation, including the European Union's General Data Protection Regulation (2016/679) ("GDPR") and other relevant laws and regulations, as applicable towards the controller stated in Section 2 of this Policy.

In case you disclose any personal data regarding any third person(s) (e.g., your employee, management board member, co-worker, etc.) to us, you are obligated to refer them to this Policy.

We do not knowingly allow children (under the age of 18) to sign up for a Skyrexio LLC account, and therefore, do not knowingly process children's personal data. Should we discover that an individual below the age of 18 has registered for a Skyrexio LLC account, we will take appropriate measures to promptly remove their personal data from our database. If you believe an underage person has signed up for a user account or is in any way using the Software, please reach out to us at [email protected].

2CONTROLLER

3COOKIES AND TRACKING TECHNOLOGIES

3.1What Are Cookies?

Cookies are small text files that are placed on your device when you visit our Website or App. They help us recognize your device and remember information about your visit, making your experience more convenient and personalized.

3.2Types of Cookies We Use

3.3Managing Your Cookie Preferences

3.4Browser Settings

Most web browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may worsen your overall user experience, as some features may no longer function properly.

For more information about cookies and how to manage them, visit: www.allaboutcookies.org

3.5Third-Party Cookies

Some cookies on our Website are set by third parties with whom we partner to provide certain services. These third parties may collect information about your online activities over time and across different websites.

4CATEGORIES AND SOURCES OF PERSONAL DATA

Personal data is any information that can be used to directly or indirectly uniquely identify you as a private individual. Anonymous data is not personal data, as it cannot be linked back to you. We may obtain and process the following categories of your personal data:

5PURPOSES OF PROCESSING AND LEGAL BASES

We process your personal data lawfully and in a transparent manner, including only where we have a legal basis for doing so. The legal basis for processing your personal data depends on the objective and context in which we collect personal data. We process your personal data for the following purposes:

• To provide and maintain our services: Account creation, authentication, and service delivery (Legal basis: Contract performance)
• To improve our services: Analytics, testing, and product development (Legal basis: Legitimate interest)
• To communicate with you: Customer support, service updates, and notifications (Legal basis: Contract performance and legitimate interest)
• For marketing purposes: Newsletters and promotional communications (Legal basis: Consent)
• To ensure security: Fraud prevention, security monitoring, and legal compliance (Legal basis: Legitimate interest and legal obligation)
• To comply with legal obligations: Regulatory requirements and legal requests (Legal basis: Legal obligation)

We may process your personal data for other purposes, provided that we disclose the purposes to you at the relevant time, and that you either consent to the proposed use of the personal data, other legal grounds exist for the new processing purposes, or the new purpose is compatible with the original purpose stated above.

6RECIPIENTS OF PERSONAL DATA AND DATA TRANSFERS

We may disclose your personal data to separate operators, who process your personal data for their own purposes, and processors, who process your personal data on our behalf to help us provide the Website, App and Software. These data recipients belong to the following categories:

Your personal data is primarily processed within the European Economic Area (EEA). However, some of your data may be transferred to countries outside of the EEA, which may not offer the same level of data protection as your country. In such cases, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission. Upon request, we can provide further information about the specific safeguards applied, including copies of relevant documentation. Please contact us at the address provided in Section 2 of this Policy.

7SECURITY OF YOUR PERSONAL DATA

8PERSONAL DATA RETENTION PERIODS

We retain your personal data only for as long as necessary to fulfill the purposes outlined in Section 5 of this Policy or as required by law. Our retention periods are based on:

When personal data is no longer needed for the purposes specified in Section 5, we will securely delete or anonymize it. However, some data may be retained longer if required by legal, regulatory, or contractual obligations.

Please note that you should maintain your own adequate and up-to-date backup copies of important data, as we cannot guarantee recovery of deleted information.

9AUTOMATED DECISION MAKING

We may incorporate Artificial Intelligence technologies, such as Generative Pre-trained Transformer ("GPT"), into our services, including our FAQ Chatbot. When you interact with AI-powered features:

• Any personal data you input may be processed using automated decision-making tools
• These automated processes help provide personalized responses and improve service quality
• You have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects
• You can request human intervention or challenge automated decisions by contacting us

If you choose to use AI-powered features, please be mindful of the information you share. For questions about how your personal data is processed through automated systems, or to exercise your rights regarding automated decision-making, please contact us at [email protected].

10YOUR RIGHTS AS A DATA SUBJECT

You may, at any time, exercise the following rights with respect to our processing of your personal data:

• Right to access: you have the right to request access, including receive a copy, of your personal data. This includes the right to be informed on whether we process your personal data, what personal data categories are being processed by us, and the purpose of the data processing.
• Right to rectification: you have the right to request that we correct any of your personal data if you believe that we are processing incorrect, inaccurate or incomplete personal data.
• Right to object: you are entitled to object to certain processing of your personal data, for example when we process your personal data based on our legitimate interest or for direct marketing purposes.
• Right to erasure: you have the right to request that we erase your personal data for example if the personal data is no longer necessary for the purposes for which it was collected or if you consider that the processing is unlawful.
• Right to data portability: you have the right to receive your personal data in a structured, commonly used and machine-readable format if the processing is carried out by automated means and is based on your consent or a mutual contractual relationship.
• Right to restriction of processing: you have the right to request that we restrict the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data or object to the processing.
• Right to withdraw consent: where our processing is based on your consent, you have the right to withdraw your consent at any time. You can manage your consent settings in your account or by contacting us. Please note that withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
• Right to stop direct marketing: you have the right to stop receiving our direct marketing messages at any time. You can opt out by clicking the "Unsubscribe" button in our marketing emails or by adjusting your preferences in the Account Settings page. Please note that even after opting out of marketing communications, we may still need to send you service-related emails regarding your account, security, or legal matters.
• Right not to be subject to automated decision-making: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects. For more information about our use of automated decision-making, please refer to Section 9.
• Right to lodge a complaint: if you wish to make a complaint about how we process your personal data, please contact us first. We will promptly investigate your complaint and respond to you. If you are not satisfied with our response or believe we are processing your personal data in violation of applicable laws, you have the right to lodge a complaint with the relevant data protection supervisory authority in your country.

10.1How to Exercise Your Rights

We will respond to your request promptly and in any case within one month from the date we receive it. If your request is particularly complex, we may extend this period by up to two additional months. We will inform you of any such extension within one month of receiving your request, along with the reasons for the delay.

If you reside in the United States, you may also contact the Federal Trade Commission (FTC) or your state's Attorney General's Office regarding privacy concerns.

11OTHER JURISDICTIONS

Depending on your location, you may have additional rights under state or country-level privacy laws. For example, residents of California, Virginia, Colorado, and other US states may have specific rights under their state privacy laws. If you have questions about your specific rights based on your jurisdiction, please contact us at [email protected].

12LINKS TO OTHER WEBSITES, APPS OR SERVICES

Our Website and App may contain links to external websites, apps, or services that are not operated by us. This Privacy Policy applies solely to personal data that we collect and process. We are not responsible for the privacy practices or content of third-party websites, apps, or services.

We strongly encourage you to review the privacy policies and terms of service of any third-party websites, apps, or services you visit or use. We do not endorse and have no control over the content, privacy policies, or practices of third parties.

13CHANGES TO THIS POLICY

We regularly review and update this Privacy Policy to reflect changes in our practices, technology, legal requirements, and other factors. When we make changes, we will update the "Last updated" date at the bottom of this Policy.

We encourage you to review this Policy periodically, especially before providing any new personal data. If we make material changes that significantly affect your rights or how we process your personal data, we will notify you by:

• Sending an email to the address associated with your account
• Displaying a prominent notice on our Website or App
• Requiring you to accept the updated Policy before continuing to use our services

Your continued use of our services after the effective date of any changes constitutes your acceptance of the updated Privacy Policy.