Privacy Policy

PLEASE READ THIS POLICY CAREFULLY. BY CONTINUING TO USE OUR WEBSITE AND THE COMPANY'S PRODUCTS/SERVICES, YOU AGREE TO THE POLICY SET FORTH HEREIN AND THE TERMS OF PROCESSING YOUR PERSONAL DATA SPECIFIED THEREIN. IF YOU DO NOT AGREE TO THE SPECIFIED TERMS, DO NOT USE THIS WEBSITE.

This Privacy Policy (together with the User Agreement and other Policies mentioned therein) defines the procedure for processing personal data by UmbrellaX Company (also referred to as "Company," "we," "our") and the measures it takes to ensure the security of such data in order to protect and respect the confidentiality of Users of the Website https://umbrellax.io/ ("Website") and/or the Company's products/services.

1. General Provisions

1.1. The Company, in accordance with the Privacy Policy ("Policy"), has the right to collect personal data of persons visiting the Company's Website https://umbrellax.io/, inform about the purposes and methods of using such personal data, as well as about the rights to control the Company's use of collected and stored personal information about Website visitors.

1.2. This Policy regulates the provision of personal data by Users ("Information") and applies to all information that the Company may receive from Users.

1.3. By continuing to use this Website and/or registering to use the Company's products/services (our services), you confirm that you have read, understand, accept and agree to comply with these Terms, Policies and provisions governing Users' use of the Website and/or the Company's offered products/services.

1.4. In processing personal data, the Company complies with the requirements of applicable legislation on confidentiality and data protection, including, but not limited to, the Seychelles Data Protection Act No. 9 of 2003, as well as international data protection standards ("legislation").

1.5. Protecting your personal data is the most important task for the Company, and we guarantee that we will ensure the protection of your data in accordance with legislative requirements.

1.6. The Company is the data controller of the data you provide and is responsible for its processing and storage.

1.7. Users of the Website and/or the Company's products/services may be referred to as "you," "your" for convenience.

1.8. Please carefully read this Privacy Policy to understand how we process your personal data. If you do not agree with any of the provisions of this Policy, we ask you to refrain from using this Website and the Company's products/services offered on it, and leave it.

2. Basic Concepts and Interpretation

Personal Data (Information) — data consisting of information relating to a living person who can be identified on the basis of this information or other information at the disposal of the data controller, including any expression of opinion about a person, excluding any indication of the data controller's intentions regarding that person.

Data Subject — an individual whose personal data is being processed.

Data Controller — a person who controls data. A person is considered to control data if: (a) the data is part of a collection of data processed or intended to be processed by that person or on their behalf; (b) that person (alone or jointly with other persons) controls the content and use of data included in the collection, and (c) the data is in the form in which it was processed or intended to be processed as specified in paragraph (a), or (although not currently in such form) in the form into which it was converted after such processing for the purpose of further processing subsequently.

Data Processing — means modification, addition, deletion or regrouping of data or extraction of information constituting data. Data processing in relation to personal data means performing any of the above operations in relation to a specific data subject.

Disclosure/transmission — includes disclosure of information extracted from data, when identification of the person who is the subject of personal data partially depends on information at the disposal of the data controller. Data is not considered disclosed or transmitted unless other information is also disclosed or transmitted.

User — an individual visiting the Website https://umbrellax.io/ and/or using the products/services of the Website and/or Company and being a data subject.

User Account — a user's personal profile or personal account that is created after registration on the Website https://umbrellax.io/.

Company Products, Services and/or Services — products, services and/or services provided to the User on the Website https://umbrellax.io/.

Regulatory Requirements — mean any applicable law, statute, regulation, order, court decision, ruling, recommendation, rule, policy (including, but not limited to, KYC/AML Policy, also including measures aimed at combating the financing of terrorism and proliferation of weapons of mass destruction) or guidance adopted or issued by parliament, government or any competent court or authority, or any payment system (including, but not limited to, banking payment systems, card payment systems such as Visa, MasterCard, or any other payment, clearing or settlement system, or similar arrangement used to provide products/services);

Policies/Policy — Policies and provisions governing the provision of products/services, including, but not limited to, Policies on due diligence, customer risk management, money laundering, terrorism financing and proliferation of weapons of mass destruction, sanctions and countries (CDD, AML/CTF/PWMD & KYC & SANCTIONS & COUNTRY POLICY, Privacy Policy and others);

Third-Party Service Providers — persons processing data for or on behalf of the data controller.

3. Procedure for Collection, Storage and Processing of Personal Data and Information about Users

3.1. The Company may collect information you provide during registration and Account creation, including name, surname, date of birth, email address, postal address, country of residence, phone number, electronic wallet address, taxpayer registration number, bank details, bank card information, personal information for conducting KYC/AML or CTF procedures. Any information regarding your payments may be sent to a third party providing transaction processing to enable the Company to provide its services.

3.2. The Company collects and stores personal data in order to comply with applicable legislation, particularly regarding combating and preventing money laundering, terrorism financing and proliferation of weapons of mass destruction, improving and developing the Company's services, studying User requirements, compiling Website statistics, planning and implementing various marketing activities.

3.3. The Company collects Users' personal information only to the extent necessary to ensure proper provision of services to Users.

3.4. We store your financial information in our secure systems, and only we have access to your information. However, we may transfer such information to third parties in accordance with legislative requirements or this Policy.

3.5. Collection of additional information about your device, your use of services (device network connection, IP address, geolocation information, etc.) is permitted by methods provided for in this Privacy Policy, with your prior consent. Filling out the registration form when creating an account on the Website and/or using the Company's products/services, after reviewing the Company's Policies, will be considered as your consent to the collection, processing, storage and transfer of information to third parties in accordance with the requirements of this Policy and applicable legislation.

3.6. If necessary, the Company may request the provision of additional information in accordance with legislative requirements.

3.7. For the purpose of verifying the data you provide, the Company may make inquiries through third-party service providers to prevent misidentification, fraud, suspicious activity, money laundering or any other prohibited activity; the Company may also take additional measures regarding the results of inquiries that we deem necessary. By agreeing to this Policy, you give us your permission for such inquiries, including inquiries regarding information specified in your Account.

3.8. Notwithstanding the foregoing, the Company may at any time and at its sole discretion refuse you the opportunity to open an Account, also limit your Account that has already been created, or suspend any transaction pending the results of our review of any information you provide.

3.9. We may permanently close the account of any User who fails to comply with our requests for information verification or otherwise violates the above conditions and/or Policies. Such User may be held liable for losses incurred by the Company or any third party due to violation of the terms of use of the Website and/or the Company's products/services.

3.10. We may also collect additional information from you or about you by other lawful means not specified in this Policy. For example, we may collect information related to your communication with our customer support service or store the results of your responses to surveys, results of analysis of your activity using the Website and/or the Company's products/services, and others.

3.11. In the process of collecting and storing personal data, the Company adheres to the following data protection principles:

data is collected and processed fairly and lawfully without degrading the dignity of the data subject; data is collected, processed, used and disclosed only for specific, clearly defined, lawful purposes, namely for the Company to provide its services. The Company does not allow subsequent processing of data for other purposes incompatible with the original purpose; data is processed only to the extent necessary to achieve the relevant lawful purposes. Data is adequate and proportionate to the purposes for which it is processed; data is accurate and precise and updated when necessary. Data collected without lawful basis and not corresponding to the processing purpose is blocked and deleted.

3.12. We will store (a) transaction records for five (5) years from the date of transaction completion, or for another minimum period required by applicable legislation; and (b) other information collected by the Company for the purposes of compliance with legislation on combating money laundering, terrorism financing and proliferation of weapons of mass destruction, throughout the entire period of business relations with the User and for five (5) years from the date of termination of business relations with the User, or for such other minimum period as may be required by applicable legislation.

4. Confidentiality

You acknowledge that you are equally responsible with the Company for maintaining the confidentiality of your Account information, including password, protecting your digital assets, as well as for all actions and transactions occurring in your Account. You understand that any disclosure of your registration and other information may subject your Account to unauthorized access by third parties, which may lead to loss or theft of digital assets and funds from your Account, including associated accounts such as withdrawal credentials.

5. Collection of Information for the Purpose of Implementing Customer Due Diligence (CDD), AML/KYC and Other Procedures Related to Combating Terrorism Financing (CTF) and Proliferation of Weapons of Mass Destruction (PWMD).

5.1. As part of our commitment to combating financial crimes, money laundering, terrorism financing, proliferation of weapons of mass destruction, fraud, circumvention of sanctions and other criminal actions, the Company has implemented procedures and systems aimed at enabling us to identify and mitigate risks associated with improper use of our Website, as well as the Company's products/services. These include CDD, AML/KYC, CTF and PWMD procedures based on collecting information about our users, assessing AML/CTF/PWMD risks associated with their activities, and ongoing monitoring of their transactions.

5.2. Your personal data may be used for:

processing transactions and sending notifications provided for in the Policies and/or applicable legislation about your transactions; resolving disputes, collecting payments and troubleshooting; sending you targeted marketing, service update notifications and promotional offers based on your preferences; preventing potentially prohibited or illegal actions and ensuring compliance with our Terms of Use; providing services and customer support upon your request/inquiry; customizing, measuring and improving our services, as well as the content and appearance of our website; comparing information for accuracy and verifying it with third parties; confirming or refuting violations of regulatory requirements and/or Policies.

5.3. If we have any suspicions that our business relationship with you or a specific transaction you wish to conduct is associated with any risk of money laundering, terrorism financing or any other financial crime or prohibited activity, we may at our sole discretion refuse to accept you as a client, terminate any interaction with you, refuse to process any transaction and take any other actions we deem necessary, including reporting our suspicions to competent authorities. We will not inform you of any such actions decided to be taken, and we also have the right not to provide you with any explanations for the reasons for such decisions or our suspicions.

5.4. For the purposes of conducting the above checks, we may collect certain personal information not only from you but also from external sources. Any such information about you will be stored and used in accordance with the Privacy Policy.

6. Cookies

Our Website uses Cookies to distinguish you from other users of our website. This helps us provide you with effective and convenient use of our Website and allows us to improve it. For detailed information about what Cookies are, how we use them, what types of Cookies we use, please refer to our Cookie Policy.

7. Links to Third-Party Websites

7.1. This Policy does not control and is not responsible for third-party websites that Users may navigate to via links available on the Website https://umbrellax.io/, and where personal information may also be collected or requested from the User.

8. Disclosure of Information to Third Parties

8.1. We may disclose your personal data to:

Related and associated persons of the Company; Banking partners and/or payment processing service providers for payment processing; Service providers to the Company under contract, under which they assist in conducting business operations (fraud prevention, marketing, technology services and others). Our contracts stipulate that these service providers have the right to use your personal data only to provide services to the Company, and not for their own benefit; Companies with which we merge or which acquire or which acquire the current Company. In such case, we will require the new Company to follow this Policy regarding your personal data. If your personal data will be used contrary to this policy, you will receive advance notice and will be able to refuse the new Company's use of your personal data; representatives of law enforcement, judicial and other authorized bodies upon their request; in other cases provided for by applicable legislation.

8.2. The Company will not, without your consent, sell or allow third parties to use your personal data for their personal marketing purposes and undertakes to share your personal data with third parties as described in this Policy.

9. Processing of Personal Data

9.1. By registering on the Website and using its services without registration, in accordance with this Policy, the User:

consents to the collection of their personal data, their use, as well as their processing: collection, recording, systematization, accumulation, storage, clarification (update, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of any information relating directly or indirectly to the User, their operations and payments; confirms that they are aware that personal data processing will be carried out by the Company in the User's interests and for the purposes of providing/offering the User any consultations (explanations) and/or for the purpose of offering the User services provided by the Company, and/or services provided by persons on whose behalf the Company acts, and/or for the purpose of conducting surveys, questionnaires, advertising and marketing research regarding services provided by the Service and/or persons on whose behalf the Company acts, as well as for the purpose of informing about advertising and/or marketing promotions conducted by the Company and/or the above persons regarding services provided by the Company, as well as persons on whose behalf the Company acts, by contacting Users directly or by phone, mail, using facsimile communication, email, as well as using other means of communication, as well as for the purpose of preparation for conclusion, for the purpose of conclusion, execution, modification, termination of agreements between Users and the Company or persons on whose behalf the Company acts, including proper identification of the User, as well as for the purpose of preparing forms of applications, notifications, agreements, contracts that do not directly entail the conclusion, termination, modification of the corresponding contract, agreement and for other purposes corresponding to the direction of the above purposes.

9.2. The User confirms that they have been properly informed of the purposes of processing their personal data.

9.3. The User confirms that they have been notified that personal data processing is carried out by the Company in any way, including both using automation means (including software) and without using automation means (using various physical media, including paper media).

9.4. The User confirms that personal data processing may be carried out both by the Company and by third-party service providers who have entered into an agreement with the Company on terms of confidentiality and responsibility for disclosure of personal data.

10. User Rights

10.1. You have the right to request and receive from the Company free of charge information about your stored personal data. In addition, you have the right to request corrections to your personal data or their deletion.

10.2. If deletion of your personal data would contradict data protection principles or legal norms aimed, in particular, at protecting national security, as well as preventing and suppressing crimes, you will be refused deletion of such data.

10.3. The provisions of clause 10.1 also do not apply to personal data related to completed transactions and personal data collected by the Company for the purposes of compliance with legislation on combating money laundering, terrorism financing and proliferation of weapons of mass destruction. In this case, the Company has the right to retain such personal data and use it in the manner provided for by this Policy, as well as other Company Policies.

10.4. Requests for providing information about your personal data, as well as correcting and deleting your personal data, must be sent to email support@umbrellax.io.

10.5. A request for information about your personal data must be made in writing and is processed within 40 days from its receipt.

10.6. You also have the right to ask us not to process your personal data for marketing purposes. Usually the Company informs you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to a third party for such purposes. You can exercise your right to prevent such processing by contacting us by email: support@umbrellax.io.

11. Protection of Personal Data

11.1. The Company trains its employees working with personal information to respect the confidentiality of User information and people's privacy. The Company takes violations of your confidentiality very seriously and will apply appropriate sanctions, including dismissal, for any such violation if it deems it necessary.

11.2. We take all necessary technical and organizational security measures to protect your personal data and prevent unauthorized access and processing, damage, loss, misuse, other illegal forms of processing of personal data provided to the Company.

11.3. We store and process your personal information on specially protected specialized servers and protect it by maintaining physical, electronic and procedural safeguards in accordance with applicable legislation. We use computer security measures such as firewalls and data encryption, we apply physical access control to our media and files, and we allow access to personal information only to those employees who require it to perform their job duties.

12. Policy Changes

The Company reserves the right to make changes to this Privacy Policy without prior notice or consent of the User. Any changes made to this Policy will be published on this page. The Company recommends that you periodically review this Policy for updates. If you disagree with the changes made, you should refuse access to the Website and stop using the Company's products/services.

13. Contacts

If you have any questions, require additional information regarding this Policy or believe that any of our actions violates this Policy or we otherwise fail to comply with your confidentiality, you can contact us: by visiting this page on our website: https://umbrellax.io/policy; by sending us an email: support@umbrellax.io