Privacy Policy

How we protect and handle your personal information

Your Privacy Matters

We implement industry-leading security measures and follow strict privacy practices to protect your personal and financial information.

Privacy Overview

CYNEX is committed to protecting your privacy and personal information.

This Privacy Policy explains how we collect, use, protect, and share your information when you use our tokenization platform.

We comply with applicable privacy laws including GDPR, CCPA, and other relevant regulations.

Your trust is fundamental to our business, and we implement industry-leading security measures to protect your data.

Information We Collect

**Personal Information**: Name, address, email, phone number, date of birth, and government-issued ID.

**Financial Information**: Bank account details, investment history, income verification, and accreditation documents.

**Identity Verification**: Documentation required for KYC/AML compliance including passport, driver's license, and utility bills.

**Platform Usage**: Login timestamps, transaction history, device information, and interaction analytics.

**Investment Data**: Portfolio holdings, transaction records, and investment preferences.

How We Use Your Information

**Platform Operations**: Account creation, authentication, and platform functionality.

**Regulatory Compliance**: KYC/AML verification, accreditation confirmation, and regulatory reporting.

**Investment Processing**: Transaction execution, portfolio management, and investor communications.

**Security**: Fraud prevention, account protection, and platform security monitoring.

**Customer Support**: Responding to inquiries and providing platform assistance.

**Research**: Improving our services and developing new investment opportunities (anonymized data only).

Information Sharing

**Service Providers**: Trusted third parties who assist with platform operations, including custody partners and KYC providers.

**Legal Requirements**: Disclosures required by law, regulation, or court order.

**Business Transfers**: In the event of merger, acquisition, or sale of assets.

**Consent**: With your explicit consent for specific purposes.

**We never sell personal information to third parties for marketing purposes.**

Data Protection Measures

**Encryption**: All data is encrypted in transit (TLS 1.3) and at rest (AES-256).

**Access Controls**: Multi-factor authentication and role-based access limitations.

**Network Security**: Firewalls, intrusion detection, and regular security assessments.

**Data Minimization**: We collect only the information necessary for platform operations.

**Regular Audits**: Third-party security audits and penetration testing.

**Employee Training**: Regular privacy and security training for all team members.

Data Retention

We retain personal information for as long as necessary to provide our services and comply with legal obligations.

**Active Accounts**: Information retained while your account is active and for legitimate business purposes.

**Regulatory Requirements**: Certain information must be retained for periods specified by financial regulations (typically 5-7 years).

**Inactive Accounts**: Accounts inactive for more than 3 years may have non-essential data purged.

You may request deletion of your data subject to legal and regulatory retention requirements.

Your Privacy Rights

**Access**: Request copies of your personal information.

**Correction**: Update or correct inaccurate information.

**Deletion**: Request deletion of your data (subject to legal requirements).

**Portability**: Receive your data in a machine-readable format.

**Restriction**: Limit how we process your information.

**Objection**: Object to certain types of data processing.

To exercise these rights, contact us at privacy@cynex.io.

Cookies and Tracking

We use cookies and similar technologies to enhance your platform experience.

**Essential Cookies**: Required for platform functionality and security.

**Analytics Cookies**: Help us understand platform usage and improve services.

**Preference Cookies**: Remember your settings and preferences.

You can control cookie settings through your browser, though some platform features may not function properly without certain cookies.

International Data Transfers

Your information may be transferred to and processed in countries other than your residence.

We implement appropriate safeguards for international transfers, including:

**Adequacy Decisions**: Transfers to countries with adequate data protection laws.

**Standard Contractual Clauses**: EU-approved contract terms for data protection.

**Binding Corporate Rules**: Internal policies ensuring consistent data protection standards.

Children's Privacy

Our platform is not intended for individuals under 18 years of age.

We do not knowingly collect personal information from children.

If we become aware that we have collected information from a child, we will promptly delete it.

Parents who believe their child has provided information should contact us immediately.

Policy Updates

We may update this Privacy Policy to reflect changes in our practices or legal requirements.

Material changes will be communicated through email or platform notifications.

Continued use of the platform after updates constitutes acceptance of the revised policy.

We encourage periodic review of this policy to stay informed about our privacy practices.

Questions About Privacy?

If you have questions about this Privacy Policy or our data practices, please contact our Privacy Officer:

Email: privacy@cynex.io

Address: 123 Financial District, New York, NY 10004

Response Time: We respond to privacy inquiries within 30 days

Last Updated: July 22, 2025

Effective Date: July 22, 2025