1. General Provisions
This Privacy Policy (hereinafter referred to as the “Policy”) establishes the procedure for the collection, processing, storage, transfer, and protection of personal data provided by clients to Archax Middle East Connect Ltd (hereinafter referred to as the “Company,” “we,” “us,” or “our company”), an international financial technology entity operating in the United Arab Emirates (UAE) and forming part of the global Archax group.

We process personal data strictly in accordance with:

the standards of the Financial Action Task Force (FATF);

the legislation of the United Kingdom, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018;

the laws of the UAE, including Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and applicable regulations within the Dubai International Financial Centre (DIFC).

We recognize the importance of maintaining the privacy and security of your personal data and commit to protecting any information you provide against unauthorized access, loss, alteration, or disclosure.

2. Categories of Personal Data We Collect
We collect and process the following categories of data depending on the services you use, the nature of your interaction with us, and regulatory requirements:

2.1. Identification Data
Full legal name;

Date and place of birth;

Citizenship and tax residency;

Passport or national ID document;

Photo or video selfie for KYC purposes;

Proof of residential address.

2.2. Contact Information
Email address;

Phone number;

Permanent or temporary residential address.

2.3. Financial Data
Source of funds;

Employment and income information;

Bank account details;

Cryptocurrency wallet addresses.

2.4. Technical and Behavioral Data
IP address, device type, browser, and OS;

Cookies and similar technologies;

Login and logout timestamps, session activity;

Transaction and navigation history.

2.5. Marketing Data
Consent for newsletters and promotional messages;

Engagement with marketing communications.

2.6. HR Data (where applicable)
Resumes and CVs;

Diplomas and certifications;

Reference letters.

3. Purpose of Processing Personal Data
We process personal data solely for the following purposes:

To conduct identity verification (KYC/AML);

To comply with legal and regulatory requirements (FATF, UAE and UK regulators);

To fulfill contractual obligations;

To provide technical support and client service;

To enhance and personalize platform functionality;

To ensure security and fraud prevention;

To meet tax, legal, and audit obligations;

To conduct marketing communication (with your prior consent).

4. Legal Grounds for Processing
We process your personal data based on:

Your explicit consent;

The necessity to perform a contract;

Compliance with legal obligations;

Our legitimate interests (e.g. platform security, service improvement).

5. Data Retention
We retain personal data:

For legal, financial, and regulatory purposes — typically up to 10 years;

Until the specific purpose of processing is fulfilled;

Until the consent is withdrawn (where applicable);

As required by document retention regulations.

6. Data Transfers to Third Parties
We may share data with trusted service providers and partners, including:

Cloud hosting and KYC/AML providers;

Governmental authorities and regulators (as legally required);

Legal, tax, and audit consultants;

Affiliates within the Archax group.

Data is only shared when a legal basis is present and adequate protection is ensured.

7. International Data Transfers
Transfers outside of your country of residence may take place under:

Adequate country designations under applicable law;

Standard Contractual Clauses (SCC);

Binding Corporate Rules (BCR);

With your explicit consent (where necessary).

8. Data Security Measures
We implement comprehensive technical, organizational, and legal security measures, including:

SSL encryption and secure data transmission;

Multi-factor authentication (MFA);

Server infrastructure and network protection;

Access control and staff activity logging;

Real-time anomaly detection via AI systems;

Staff training in data protection and security protocols.

9. Data Subject Rights
As a client, you have the right to:

Access your personal data;

Rectify or update your data;

Request erasure (subject to legal exceptions);

Restrict or object to processing;

Data portability;

Withdraw your consent at any time.

All such requests are to be submitted exclusively via our official Telegram support channel or designated email listed on the company’s website.

10. Cookies
We use cookies for the following purposes:

Technical operation of the website and services;

Analytics and performance improvement;

Personalization of the user experience.

You may disable cookies through your browser settings.

11. Client Fund Insurance
All funds transferred from the platform to a client’s account, where the transaction amount is 30,000 USDT or greater, are subject to mandatory insurance.

Insurance is automatically activated upon the client purchasing the relevant coverage;

The insured amount is temporarily reserved at the client’s expense;

Once the primary transaction is confirmed as received, the insurance fee is fully refunded to the client;

The purpose of this mechanism is to protect the client from loss due to causes outside of their control, including but not limited to:
– intermediary banking errors;
– technical malfunctions;
– uncoordinated third-party actions.

12.1. Ban on Direct Peer Transfers
In compliance with FATF guidelines, all direct or indirect financial transfers between the following parties are strictly prohibited:

Clients and other clients;

Clients and traders;

Clients and analysts;

Any third party outside the platform infrastructure.

Violations may result in account suspension and mandatory reporting to authorities. All financial transactions must occur exclusively within the platform.

12.2 Account verification for withdrawal access by our AI security system Archax AI Security Check

Adding a withdrawal account is only possible after passing verification through our unique AI security system — Archax AI Security Check.

Each client is assigned a unique internal ID, which is linked to the selected withdrawal method and transaction currency.

For confirmation, the Archax AI Security Check system generates a test one-time refundable transfer with a unique amount — the client must send the exact amount specified by the system to the designated company account.

Once the funds are received and automatically verified, the information is considered confirmed. Only then does the account become available for withdrawals and is successfully approved by our proprietary AI security system, Archax AI Security Check.

13. Use of Private Banking Details
In certain jurisdictions, the Company may temporarily provide private local bank details for the purpose of accelerating inbound transfers:

These are used exclusively for inbound deposits;

They are linked to a specific client and deactivated automatically after confirmation of payment;

The Company retains full control over such accounts.

14. Transaction Currency
All transactions and balances on the platform are maintained exclusively in USDT (Tether):

Deposits, withdrawals, internal transfers, and account holdings are all denominated in USDT;

If a client uses another currency, they must cover the conversion costs, which are calculated based on the internal rate of the platform;

Reverse conversions are permitted only by prior agreement and may incur additional fees.

15.1. Communication Channels
Official communication with the Company is conducted only through:

Our verified Telegram support;

The email address listed on our official website.

15.2 Access to Funds and Storage Terms — Archax Middle East Connect Ltd

The client gains full access to the funds and the right to use them only after the successful crediting of the amount to the designated account. Until that moment, all funds remain under the management of the company.

If the client chooses to temporarily store funds in the company’s accounts, a storage fee applies as follows:

For amounts up to 30,000 USDT — a fixed fee of 2,985 USDT for every 60 calendar days (including weekends);

For amounts exceeding 30,000 USDT — a 2% fee of the total amount for the same period.

Until the funds are successfully credited:

Deductions,

Partial transfers,

Splitting of the amount

are not permitted and are not provided for under the policy of Archax Middle East Connect Ltd.

⛔️ We do not use WhatsApp, voice calls, social media messengers, or third-party agents for communication.

16. Legal Jurisdiction
All disputes between the client and Archax Middle East Connect Ltd shall be resolved in final and binding arbitration conducted under the Rules of Arbitration of the International Chamber of Commerce (ICC).

Seat of arbitration: Paris, France;

Language of proceedings: English, unless otherwise agreed;

Governing law: Laws of the United Arab Emirates (UAE), unless otherwise specified in a contract between the parties.

Arbitral decisions are final and enforceable in accordance with the New York Convention (1958).