Privacy Policy

Last Updated: April 2025

We at BurjX MENA Ltd (“BurjX,” “we,” “our,” “us”, or the “Company”) have created this privacy policy (this “Privacy Policy”) because we know that you care about how information you provide to us is used and shared. This Privacy Policy is designed to help you understand how we collect, use, process, and share information we collect via our website located at https://burjx.com/ and other domain names offering or linking to the website (the “Site”), our cryptocurrency trading exchange, our services, including but not limited to, broker dealer services, and any corresponding mobile applications (the “Apps”) offered by BurjX and to help you understand and exercise your privacy rights within the scope of applicable laws. The Site, App, and our services are collectively called the “Services.”

PERSONAL INFORMATION WE COLLECT
HOW WE USE YOUR INFORMATION
HOW WE DISCLOSE YOUR INFORMATION
YOUR PRIVACY CHOICES AND RIGHTS
SECURITY OF YOUR INFORMATION
RETENTION OF PERSONAL INFORMATION
CHILDREN’S INFORMATION
OTHER PROVISIONS

1. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

A. Information You Provide to Us Directly

We may collect the following personal information that you provide to us.

- Account Creation. To create an account with us and use our Services, we may collect the following information from you:

- Identification information: First and last name, date of birth, gender, phone number, email, government identification number (including passport number) and other information necessary to verify your identity to comply with our regulatory obligations under financial or anti-money laundering laws.

- Institutional information: If you are an institutional customer, we may collect your institution’s legal name, Employer Identification number (or comparable number issued by a government), proof of legal formation (e.g. Articles of Incorporation), and personal identification information for all material beneficial owners.

- Financial information: Bank account information, routing number, transaction history, trading data and/or tax identification.

- Transaction information: Information about the transactions you make using our Services, such as the name of the recipient and the trading amount.

- Employment information: Your job title, office location or source of income.

- Correspondence: Information you provide to our support teams.

·Wallet. To access some of the Services, you may need to provide us with information related to your digital asset wallet (each, a “Wallet”). Please note that we will not host, custody, or take possession of your private key or the contents of the Wallet.

·Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter or loyalty program, request customer or technical support, apply for a job, or otherwise communicate with us.

·Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we may be required to publicly share information of sweepstakes and contest winners.

·Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend conferences, trade shows, and other events.

·Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

Job Applications. We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications.

B. Information Collected Automatically

We may collect personal information automatically when you use our Services:

·Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.

·Cookies, and Other Tracking Technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other tracking technologies (“Technologies”) to automatically collect information through your use of our Services.

·Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.

Our uses of these Technologies fall into the following general categories:

·Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, and improve security or that allow you to make use of our functionality.

·Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services. For example, we may track your activity on the Services, including recordings of your interactions with the Services.

·Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed.

·Advertising or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.

·Social Media Platforms. Our Services may contain social media buttons such as Discord, Twitter, Instagram, Facebook, and LinkedIn (that might include widgets such as the “share this” button or other interactive mini programs). These features may collect your IP address, which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

C. Information Collected from Other Sources

We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.

2. HOW WE USE YOUR INFORMATION

We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and our Services, as described below.

A. Provide Our Services

We use your information to fulfill our contract with you and provide you with our Services, such as:

Managing your information and accounts.
Providing access to certain areas, functionalities, and features of our Services.
Answering requests for customer or technical support.
Communicating with you about your account, activities on our Services, and policy changes.
Processing applications if you apply for a job we post on our Services.
Allowing you to register for events.

B. Administrative Purposes

We use your information for various administrative purposes, such as:

Pursuing our legitimate interests such as direct marketing, research, and development (including marketing research), network and information security, and fraud prevention.
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Measuring interest and engagement in our Services.
Short-term, transient use, such as contextual customization of ads.
Improving, upgrading, or enhancing our Services.
Developing new products and Services.
Ensuring internal quality control and safety.
Authenticating and verifying individual identities, including requests to exercise your rights under this policy.
Debugging to identify and repair errors with our Services.
Auditing relating to interactions, transactions, and other compliance activities.
Enforcing our agreements and policies.
Complying with our legal obligations.

C. Marketing and Advertising our Products and our Services.

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

Some of the ways we market to you include email campaigns, custom audiences advertising.

If you have any questions about our marketing practices, you may contact us at any time as set forth in the “Contact Us” section of the Site.

D. Other Purposes

We also use your information for other purposes as requested by you or as permitted by applicable law.

Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
Blockchain Data: We may analyze public blockchain data to ensure parties utilizing our Services are not engaged in illegal or prohibited activity under our Terms of Service, and to analyze transaction trends for research and development purposes.
De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, information about the device from which you access our Services, or other analyses we create.
Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend neighbor, or co-worker).

3. HOW WE DISCLOSE YOUR INFORMATION

We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide our Services.

The categories of third parties with whom we may share your information are described below.

Collaborations and Influencers. We may share your information with other collaborators, influencers, and charities.
Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes, but is not limited to, service providers that provide us with IT support, hosting, payment processing, customer service, and related services.
Business Partners. We may provide personal information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.
Affiliates. We may share your personal information with members of our corporate family, subsidiaries, or other companies under common control with us. (“Affiliates”).
Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”
APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in the “Contact Us” section of the Site.

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction in compliance with applicable laws and regulations.

4. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

- Email and Telephone Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms of Service or this Privacy Policy). We process requests to be placed on do-not-mail, do-not-phone, and do-not-contact lists as required by applicable law.

- “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

- Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.

Please note you must separately opt out in each browser and on each device.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information in a structured, commonly used, and machine readable format; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (the “right of data portability”).

·Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information.

·Request Deletion of your personal information.

·Request Restriction of or Object to our processing of your personal information.

·Withdraw your Consent to our processing of your personal information.

If you would like to exercise any of these rights, please contact us as set forth in the “Contact Us” section of the Site. We will process such requests in accordance with applicable laws.

5. SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services.

If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

6. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

7. CHILDREN’S INFORMATION

The Services are not directed to persons under 18 (or other age as required by local law), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in the “Contact Us” section of the Site. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account if applicable.

8. OTHER PROVISIONS

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion and will post changes on the Services as soon as they go into effect. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.