1. Introduction

This Privacy Policy applies to all users of our crypto trading platform, including visitors, registered account holders, and individuals using integrated services such as MoonPay. Please read it carefully to understand how your data is handled.

2. Information We Collect

2.1 Account Information

When you create an account on our platform, we may collect:

• Full name
• Email address
• Phone number
• Date of birth
• Username and password

2.2 Identity Verification (KYC)

When using MoonPay or certain trading features, additional information may be collected for Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance:

• Government-issued identification documents
• Proof of address (e.g., utility bill, bank statement)
• Biometric verification data (if requested by MoonPay)
• IP address and device information

2.3 Transaction Information

When you perform transactions on the platform, we may collect:

• Details of crypto purchases, sales, swaps, and transfers
• Wallet addresses involved in transactions
• Payment method details (e.g., masked card information)
• Transaction history (amounts, timestamps, confirmations)

2.4 Automatically Collected Information

When you access or use the Service, certain information may be collected automatically:

• IP address
• Browser type and version
• Device type, operating system, and related identifiers
• Approximate location data
• Cookies, session identifiers, and usage analytics data

3. How We Use Your Information

We process your personal information for the following purposes:

• Create, manage, and secure your account
• Process and facilitate crypto transactions
• Integrate and communicate with MoonPay for fiat-to-crypto services
• Comply with KYC/AML, sanctions, and other legal obligations
• Detect, investigate, and prevent fraud or unauthorized activities
• Improve, operate, and customize the Service and user experience
• Provide customer support and respond to inquiries
• Send important updates, security alerts, and legal notices

4. Sharing Your Information

4.1 With Service Providers

We may share your information with trusted third-party service providers who assist us in operating our platform, including:

• MoonPay, for fiat-to-crypto purchases and related payment processing
• KYC/AML verification providers
• Analytics and monitoring services
• Cloud infrastructure and hosting providers

4.2 Legal Compliance

We may disclose your personal information when required by applicable law or in response to:

• Government or regulatory authorities
• Law enforcement agencies
• Supervisory or tax authorities
• Court orders, subpoenas, or other legal processes

4.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of some or all of our assets, your information may be transferred as part of that transaction, subject to the same or equivalent privacy protections.

5. Data Retention

We retain personal information only for as long as necessary to:

• Comply with AML, KYC, tax, and other regulatory requirements
• Support audits, dispute resolution, and legal proceedings
• Maintain appropriate business and financial records

MoonPay may establish and apply its own data retention policies in line with its applicable laws and regulations. For details, please refer to MoonPay’s own privacy policy.

6. Data Security

We implement technical and organizational measures designed to protect your personal information, including:

• SSL/TLS encryption for data in transit
• Secure cloud infrastructure and hardened server configurations
• Cold storage solutions for a portion of crypto reserves
• Two-factor authentication (2FA) options for account access
• Role-based internal access controls and logging

However, no system can be guaranteed to be 100% secure. By using the Service, you understand and accept the inherent risks of internet-based systems and agree to use reasonable caution in protecting your account credentials and devices.

7. Your Rights

Depending on your jurisdiction, you may have some or all of the following rights regarding your personal information:

• Right to access the personal data we hold about you
• Right to correct inaccurate or incomplete information
• Right to request deletion of your data, subject to legal obligations
• Right to restrict or object to specific processing activities
• Right to opt-out of direct marketing communications
• Right to data portability, where applicable

To exercise these rights, please contact us at: privacy@thomboexchange.com . We may need to verify your identity before responding to your request.

8. Cookies

We use cookies and similar technologies to support the operation of the Service, including:

• Authentication and keeping you signed in
• Session management and security
• Usage analytics and performance monitoring

You can control or disable cookies through your browser settings; however, some features of the Service may not function properly if certain cookies are disabled.

9. Third-Party Policies (MoonPay)

Our platform may integrate with MoonPay to enable fiat-to-crypto purchases and related services. MoonPay is an independent third party and maintains its own legal terms and privacy policies. By using MoonPay within our platform, you also agree to MoonPay’s legal documents:

• MoonPay Privacy Policy
• MoonPay Terms of Use

We recommend reviewing MoonPay’s policies to understand how your data is collected and processed when using their services.

10. Children’s Privacy

Our Services are intended for individuals who are at least 18 years old. We do not knowingly collect personal information from anyone under the age of 18. If you believe that a minor has provided us with personal information, please contact us so we can take appropriate action.

11. Contact Information

If you have any questions, concerns, or requests related to this Privacy Policy or the handling of your personal information, please contact us at:

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we do, we will revise the “Last Updated” date at the top of this page. Your continued use of the Service after any updates constitutes your acceptance of the revised Privacy Policy.