DEXNARY LTD
Registered in England and Wales · Company No. 17198335
Registered office: 7-9 Henrietta Street, Covent Garden, London, WC2E 8PS, United Kingdom
PRIVACY AND COOKIE POLICY
Effective Date: 30 October 2026 · Last Updated: 30 October 2026
1. Introduction
This Privacy and Cookie Policy (the "Policy") explains how DEXNARY LTD ("DexNary", "we", "us" or "our") collects, uses, shares and protects personal data when you access or use our website at https://dexnary.pro and the related trading platform and services (collectively, the "Platform").
For the purposes of the United Kingdom General Data Protection Regulation, the Data Protection Act 2018 and any other applicable data protection legislation (together, the Data Protection Laws), DexNary is the data controller in respect of the personal data described in this Policy.
This Policy should be read together with our Terms of Service, our AML & Compliance Policy and our Payments & Withdrawals Policy. Capitalised terms used in this Policy and not defined here have the meaning given to them in the Terms of Service.
By accessing the Platform or otherwise using our Services, you confirm that you have read and understood this Policy. If you do not agree with how we process your personal data as described here, you should not use the Platform.
2. Personal Data We Collect
We collect only the personal data that is necessary to operate the Platform, to comply with our legal obligations, and to provide and improve our Services. We do not seek or collect data that is not relevant to these purposes.
The categories of personal data we may collect are:
2.1 Identification and Contact Data
The email address you use to register and authenticate, and, where applicable, identifiers associated with the third-party authentication provider you use to sign in (such as a Google account identifier or a self-custodial wallet address).
2.2 Wallet and Blockchain Data
The blockchain addresses you use to deposit funds into the Platform and to receive withdrawals, together with associated on-chain transaction data (transaction hashes, amounts, timestamps and the networks involved).
2.3 Transaction and Account Data
Records of your deposits, withdrawals, Trading Operations, Balance history, Orders, open and closed positions, and any other activity within your Account.
2.4 Technical and Device Data
Information generated automatically when you access the Platform, including your IP address, approximate geographic location derived from the IP address, browser type and version, operating system, device identifiers, language and time-zone settings, referring URL and the dates and times of your visits.
2.5 Usage Data
Information about how you interact with the Platform, including pages visited, features used, session length, and the sequence of actions taken during a session. This data is used to operate, secure and improve the Platform.
2.6 Communication Data
The content of any communications you send to us, including support requests submitted through our live-chat or by email, and our responses, together with the metadata of those communications (sender, recipient, date and time).
2.7 Conditional Verification Data
Where, in accordance with clause 5 of our Terms of Service and our AML & Compliance Policy, we ask you to undergo verification on a risk-based basis, we may collect and process the documents and information you provide for that purpose, which may include a copy of a government-issued identity document, proof of residential address, and documentation evidencing the source of funds. This data is collected only when verification is initiated; it is not collected from all Users in the ordinary course.
2.8 Categories of Data We Do Not Collect
To be clear about the limits of our data processing, we expressly note that we do not seek or collect:
- (a) special categories of personal data within the meaning of Article 9 of the UK GDPR (including data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data for the purpose of uniquely identifying a person, health data, or data concerning sexual orientation), except to the extent that any such information is incidentally contained in a verification document you submit under clause 2.7, in which case we process it only to the minimum extent necessary for the verification purpose and store it under enhanced security measures;
- (b) national identification numbers, social-security numbers or tax-identification numbers, except where the disclosure of such a number is incidental to a verification document you submit under clause 2.7;
- (c) audio recordings of telephone calls, on the basis that we provide customer support primarily through written channels (live-chat and email).
3. How We Collect Personal Data
We collect personal data in the following ways:
3.1 Directly From You
When you register an Account, authenticate, complete your profile, deposit or withdraw funds, place Orders, contact our support team, or respond to a verification request, you provide personal data directly to us.
3.2 Automatically Through Your Use of the Platform
Technical data and usage data are collected automatically when you access the Platform, through server logs, cookies and similar technologies (see clause 5).
3.3 From Third Parties
We may receive personal data from third parties who provide services to us in connection with the Platform, including:
- (a) authentication providers (such as Privy.io and the third-party identity providers it integrates with, including Google sign-in and self-custodial wallet connections) who confirm your identity for sign-in purposes;
- (b) blockchain networks and on-chain data providers, from which we obtain transaction information relating to deposits and withdrawals;
- (c) anti-money-laundering screening providers, who supply risk information about blockchain addresses and transactions, in accordance with clause 7;
- (d) analytics and security providers, who supply aggregated information about usage and threat detection.
3.4 Public Sources
In limited circumstances, where required for compliance purposes, we may consult publicly available sources, including sanctions lists and registers maintained by governmental and regulatory authorities.
4. Why We Process Your Data and Legal Bases
We process your personal data only where we have a lawful basis for doing so under the UK GDPR. The principal purposes and legal bases are summarised below.
4.1 To Provide the Services (Performance of a Contract)
To register and operate your Account, to authenticate you, to process deposits and withdrawals, to execute Trading Operations, to display your Balance and history, and to provide customer support. Without this processing we cannot perform our contract with you.
4.2 To Comply With Legal Obligations
To meet our obligations under applicable law, including anti-money-laundering and counter-terrorist-financing regulations, sanctions regimes, tax legislation and any orders or requests received from competent authorities. Where verification is initiated under clause 2.7, the legal basis for processing the resulting data is our legal obligation to prevent financial crime.
4.3 To Protect Our Legitimate Interests
To monitor and secure the Platform, to detect and prevent fraud, market abuse and other prohibited conduct, to enforce our Terms of Service, to investigate suspected breaches, to manage technical performance, to develop and improve our Services, and to defend ourselves in actual or potential legal proceedings. We carry out these activities in pursuit of our legitimate interest in operating a secure, lawful and well-functioning trading platform, and we balance these interests against your rights and freedoms.
4.4 With Your Consent
For optional processing activities, including the use of non-essential cookies (see clause 5) and any direct marketing communications we may send, we rely on your consent. You may withdraw your consent at any time, without affecting the lawfulness of processing carried out before withdrawal.
4.5 To Protect Vital Interests
In rare circumstances, we may process personal data where it is necessary to protect the vital interests of you or another person.
5. Cookies and Similar Technologies
5.1 What Cookies Are
A cookie is a small text file placed on your device by a website you visit. Cookies allow websites to recognise returning users, to remember preferences, to operate authenticated sessions, and to gather information about how the site is used. We use cookies and similar technologies (such as local storage and pixel tags) on the Platform.
5.2 Categories of Cookies We Use
We use the following categories of cookies:
- (a) Strictly necessary cookies - required for the basic operation of the Platform, including authentication, session management and security. Without these cookies the Platform cannot function. We do not require your consent to set these cookies.
- (b) Analytics cookies - used to understand how Users interact with the Platform, in aggregate, so that we can improve performance, identify problems and prioritise development. Where the analytics provider acts as our processor and the data is processed in aggregated form, we set these cookies on the basis of our legitimate interest. Where the analytics involve more granular tracking, we ask for your consent before setting them.
- (c) Marketing cookies - used, where applicable, to measure the effectiveness of marketing campaigns and to deliver relevant content. Marketing cookies are set only with your consent.
5.3 Managing Cookies
You can manage your cookie preferences at any time through the cookie banner displayed on the Platform (where available) or through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or be notified before a cookie is set. Note that disabling strictly necessary cookies will prevent the Platform from functioning correctly.
6. How Long We Keep Your Data
We retain personal data only for as long as is necessary for the purposes set out in this Policy and to comply with our legal obligations.
The principal retention periods are:
- (a) Account and transaction data - for the duration of your Account and for a period of at least five (5) years following the closure of the Account, in accordance with our obligations under the United Kingdom Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended) and other applicable law.
- (b) Verification data (where collected under clause 2.7) - for a period of at least five (5) years following the closure of the Account, in accordance with the same regulations.
- (c) Communication data - for a period reasonable having regard to the nature of the communication, ordinarily not exceeding two (2) years from the date of the communication, except where retention for a longer period is required for legal, regulatory or dispute-resolution purposes.
- (d) Technical and usage data - generally for a shorter period appropriate to the operational and security purpose for which it is held.
After the applicable retention period has expired, personal data is securely deleted or anonymised, save where retention for a longer period is required by applicable law or is necessary for the establishment, exercise or defence of legal claims.
7. How We Share Your Data
We treat your personal data as confidential and we do not sell it to any third party. We share personal data only in the limited circumstances described below.
7.1 Service Providers
We share personal data with carefully selected third-party service providers who process data on our behalf, including: (a) infrastructure and hosting providers; (b) authentication providers; (c) blockchain analytics and anti-money-laundering screening providers; (d) customer-support tooling providers; (e) communication and email-delivery providers; (f) analytics and performance-monitoring providers; (g) security, fraud-prevention and incident-response providers.
We require all such service providers to process personal data only in accordance with our written instructions, to maintain appropriate technical and organisational security measures, and to comply with applicable Data Protection Laws.
7.2 Legal and Regulatory Authorities
We may disclose personal data to regulatory authorities, law-enforcement agencies, tax authorities, courts, or other governmental bodies where we are required to do so by applicable law, where we receive a valid legal request, or where disclosure is necessary to protect our rights, property or safety or those of our users or the public. In particular, we may make Suspicious Activity Reports to the United Kingdom National Crime Agency in accordance with our obligations under applicable anti-money-laundering legislation.
7.3 Professional Advisers
We may share personal data with our professional advisers (including legal, accounting and audit advisers), where necessary in connection with their services to us and subject to appropriate confidentiality obligations.
7.4 Corporate Transactions
In the event of a corporate reorganisation, merger, acquisition, sale of assets or similar transaction, we may transfer personal data to the relevant counterparties and their advisers, subject to appropriate confidentiality and data-protection safeguards.
7.5 With Your Consent
We may share personal data in other circumstances where you have specifically consented to such sharing.
7.6 No Sale of Personal Data
We do not sell, rent or otherwise commercialise your personal data, and we do not share your personal data with third parties for their own marketing purposes.
8. International Transfers
The Platform operates internationally, and personal data may be transferred to, and processed in, countries other than the country in which it was collected. Where we transfer personal data outside the United Kingdom, we do so in accordance with the requirements of the UK GDPR, including by relying on adequacy decisions of the United Kingdom government, by entering into the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses with the recipient, or on another lawful basis recognised under the UK GDPR.
9. Your Rights
Under the UK GDPR, you have a number of rights in relation to your personal data. The principal rights are summarised below.
9.1 Right of Access
You have the right to obtain confirmation as to whether or not we process personal data concerning you, and, where we do, to obtain access to that data and certain related information.
9.2 Right to Rectification
You have the right to ask us to correct any inaccurate or incomplete personal data we hold about you.
9.3 Right to Erasure
In certain circumstances, you have the right to ask us to delete personal data we hold about you. This right is not absolute; in particular, it does not apply where we are required to retain data to comply with a legal obligation (for example, our obligation to retain anti-money-laundering records for at least five years).
9.4 Right to Restriction of Processing
In certain circumstances, you have the right to ask us to restrict the processing of your personal data, for example while a request for rectification is being considered.
9.5 Right to Data Portability
In respect of personal data processed by automated means on the basis of your consent or in performance of a contract with you, you have the right to receive that data in a structured, commonly used and machine-readable format, and to have it transmitted to another controller where technically feasible.
9.6 Right to Object
In certain circumstances, you have the right to object to our processing of your personal data on the basis of our legitimate interests. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or where processing is necessary for the establishment, exercise or defence of legal claims.
9.7 Right to Withdraw Consent
Where we rely on your consent as the legal basis for processing, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
9.8 Right Not to Be Subject to Automated Decision-Making
We do not make decisions producing legal or similarly significant effects on you that are based solely on automated processing.
9.9 How to Exercise Your Rights
To exercise any of your rights, please contact us at [email protected]. We will respond to your request without undue delay and in any event within one month, although we may extend this period by up to two further months for complex or numerous requests, in which case we will inform you of the extension and the reason for it within the original month.
We may need to ask you to verify your identity before responding to a request, in order to ensure that personal data is not disclosed to a person who is not entitled to receive it.
We will not charge a fee for responding to most requests; however, we reserve the right to charge a reasonable fee, or to refuse the request, where the request is manifestly unfounded or excessive, in particular where it is repetitive.
9.10 Right to Lodge a Complaint
If you are not satisfied with the way we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the United Kingdom's data-protection regulator (https://ico.org.uk). We would, however, appreciate the opportunity to address your concerns directly before you contact the ICO.
10. Data Security
We have implemented appropriate technical and organisational measures to protect personal data against unauthorised or unlawful processing, accidental loss, destruction, damage and unauthorised disclosure. These measures include, without limitation:
- (a) encryption of personal data in transit using industry-standard protocols (such as Transport Layer Security);
- (b) access controls limiting access to personal data to those of our personnel and service providers who need such access for the purposes set out in this Policy;
- (c) network segmentation, intrusion detection and ongoing monitoring of our infrastructure;
- (d) backup and disaster-recovery procedures;
- (e) staff training in data protection and information security;
- (f) procedures for managing personal-data breaches, including notification of the Information Commissioner's Office and affected individuals where required by the UK GDPR.
You play an important role in keeping your personal data secure. You must keep your authentication credentials confidential, not share them with any other person, and must notify us without undue delay at [email protected] of any suspected unauthorised use of your Account.
11. Children
The Platform is not intended for, and may not be used by, any person under the age of eighteen (18). We do not knowingly collect personal data from any person under the age of eighteen. If you believe that we may hold personal data of a person under the age of eighteen, please contact us at [email protected] and we will take reasonable steps to delete such data.
12. Changes to this Policy
We may update this Policy from time to time. The current version is available on the Platform, and the date of the latest revision is shown at the top of this document. Where a change is material, we will use reasonable endeavours to give advance notice through the Platform or by email. By continuing to use the Services after a change has taken effect, you accept the revised Policy.
13. Contact
For all enquiries relating to this Policy, the personal data we hold about you, or the exercise of your rights, please contact us at:
DEXNARY LTD
Registered in England and Wales · Company No. 17198335
Registered office: 7-9 Henrietta Street, Covent Garden, London, WC2E 8PS, United Kingdom
Email: [email protected]
Website: https://dexnary.pro
This Privacy and Cookie Policy was last updated on 30 October 2026 and is effective from 30 October 2026.
