Privacy Policy

1. Introduction

This policy explains how Tempx Valnex ("we," "us," "our," or "the Platform") collects, uses, shares, stores, and safeguards your personal data when you use our website, apps, and related services (the "Services"). We handle your data in line with UK data protection law.

By using Tempx Valnex, you confirm that you have read, understood, and accept the practices described here. If you do not agree, you must not use our Services.

We follow the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018). For users in the European Economic Area, we also apply the EU General Data Protection Regulation (GDPR) where it applies.

2. Information We Collect

We gather different kinds of information so we can run, improve, and protect our Services:

2.1 Personal Information You Provide

When you register for an account, we collect:

• Identity Information: Full name, date of birth, gender, residential address
• Contact Information: Email address, phone number, postal address
• Financial Information: Bank account details, payment card information, transaction history
• Verification Documents: Government-issued ID (passport, driving licence), proof of address (utility bills, bank statements dated within the last 3 months)
• Account Credentials: Username, password, security questions and answers

2.2 Information Collected Automatically

When you use our Services, we automatically collect:

• Device Information: IP address, browser type and version, operating system, device identifiers
• Usage Data: Pages visited, features used, time spent on pages, click patterns, session recordings
• Location Data: Approximate geographic location based on IP address
• Cookies and Tracking Technologies: Session cookies, persistent cookies, web beacons, analytics tags (see our Cookies Policy for details)

2.3 Information from Third Parties

We may receive information about you from:

• Identity Verification Services: Third-party verification providers for KYC (Know Your Customer) compliance
• Payment Processors: Transaction confirmation and payment status information
• Crypto Exchanges: Trading activity, account balances (via secure API connections you authorise)
• Analytics Providers: Aggregated usage statistics and performance metrics

3. How We Use Your Information

We use the information we collect for these purposes:

• Service Provision: To create and manage your account, execute trades, process payments, and deliver platform features
• Identity Verification: To comply with UK Anti-Money Laundering and counter-terrorism financing regulations
• Customer Support: To respond to enquiries, troubleshoot issues, and provide assistance
• Security and Fraud Prevention: To detect, prevent, and investigate suspicious activity, unauthorised access, and fraudulent transactions
• Platform Improvement: To analyse usage patterns, develop new features, and optimise user experience
• Communication: To send account notifications, security alerts, updates, promotional materials (with your consent)
• Legal Compliance: To meet regulatory requirements, respond to lawful requests, and enforce our Terms & Conditions
• Research and Analytics: To conduct market research and generate statistical insights (using anonymised data)

4. Legal Basis for Processing (GDPR Compliance)

For users in the European Economic Area, we process personal data based on:

• Contractual Necessity: Processing required to fulfil our agreement with you
• Legal Obligation: Compliance with UK anti-money laundering and counter-terrorism financing laws, tax regulations, and financial reporting requirements
• Legitimate Interests: Fraud prevention, security improvements, business analytics (balanced against your rights)
• Consent: Marketing communications, optional data collection (which you can withdraw at any time)

5. How We Share Your Information

We do not sell, rent, or trade your personal data. We may, however, share it with:

5.1 Service Providers

Third-party vendors who perform services on our behalf, including:

• Payment processors (for transaction processing)
• Cloud hosting providers (for data storage and server infrastructure)
• Identity verification services (for KYC compliance)
• Email and communication platforms (for notifications)
• Analytics and monitoring tools (for performance tracking)

All service providers are contractually obligated to protect your data and use it only for specified purposes.

5.2 Regulatory and Legal Authorities

When required by law, we may disclose information to:

• National Crime Agency (NCA)
• Financial Conduct Authority (FCA)
• Law enforcement agencies (in response to valid legal requests)
• Tax authorities (for tax reporting obligations)

5.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity, subject to the same privacy protections outlined in this policy.

6. Data Security

We use industry-standard measures to protect your data:

• Encryption: All data transmissions use SSL/TLS encryption; sensitive data at rest is encrypted using AES-256
• Access Controls: Strict role-based access controls limit employee access to personal data
• Two-Factor Authentication (2FA): Available for all user accounts
• Regular Security Audits: Independent third-party penetration testing and vulnerability assessments
• Secure Infrastructure: Data stored in ISO 27001-certified data centres with physical security controls
• Incident Response: Comprehensive breach notification procedures in place

While we strive to protect your information, no method of transmission or storage is 100% secure. Users are responsible for maintaining the confidentiality of their account credentials.

7. Data Retention

We keep personal data only as long as needed for the purposes in this policy, or longer where the law requires or allows:

• Active Accounts: Data retained while your account remains active
• Closed Accounts: Identity verification records retained for 7 years (UK AML requirement)
• Transaction Records: Retained for 7 years for financial reporting and tax compliance
• Communications: Support enquiries retained for 3 years
• Marketing Data: Deleted within 90 days of consent withdrawal

8. Your Privacy Rights

Under UK data protection law and GDPR (where applicable), you have the following rights:

• Access: Request a copy of the personal data we hold about you (subject access request)
• Rectification: Request correction of inaccurate or incomplete data
• Erasure: Request deletion of your personal data where the law allows
• Object: Object to processing of your data for direct marketing or where we rely on legitimate interests
• Data Portability: Request transfer of your data to another provider where technically feasible
• Restriction: Request that we limit how we use your data in certain circumstances
• Withdraw Consent: Withdraw consent at any time where processing is based on consent

To exercise any of these rights, contact our Data Protection Officer at [email protected]. We will respond within one month. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO).

9. International Data Transfers

Your data may be transferred to and processed in countries outside the United Kingdom (including the USA, EU, and Singapore). We ensure appropriate safeguards under UK GDPR, including:

• UK International Data Transfer Agreement (IDTA) or EU Standard Contractual Clauses (SCCs) where applicable
• Transfer Impact Assessments and contractual safeguards with processors
• Compliance with ICO guidance on international transfers

10. Children's Privacy

Tempx Valnex is not intended for individuals under 18 years of age. We do not knowingly collect personal information from minors. If we become aware that a user is under 18, we will promptly delete their account and associated data.

11. Updates to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or business operations. Significant changes will be communicated via email or prominent notice on our website at least 30 days before taking effect.

Your continued use of the Services after changes take effect constitutes acceptance of the updated Privacy Policy.

12. Contact Us and Your Right to Complain

For any questions about this Privacy Policy or our use of your personal data, contact our Data Protection Officer:

Data Protection Officer
Tempx Valnex
27 Soho Square, London W1D 3QR, United Kingdom
Email: [email protected]
Phone: 0808 169 2847 (Freephone from UK landlines and mobiles)

If you are not satisfied with our response, you have the right to make a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection: ico.org.uk or telephone 0303 123 1113. Users in the EEA may also contact their local data protection authority.