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Privacy Policy

Effective Date: 15 August 2025

1. Introduction

This Privacy Policy (hereinafter – the “Policy”) explains how TRONEX ENERGY LTD (company number 16618436, address: 85 Great Portland Street, First Floor, London, England, W1W 7LT) и AAA International Services Ltd (company number: 246400, address: House of Francis, Room 303, Ile Du Port, Mahe, Seychelles) (hereinafter – the “Company”, “Troex”, “we”, “us”, “our”) collect, use, store, and protect personal data when accessing the website tronex.energy and other related services.

The Company complies with:

The EU General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) – for users from the European Economic Area (EEA);
The Data Protection Act of the Seychelles 2023 (DPA) – for all other users.

By using our services, you confirm that you have read this Policy and agree to its terms.

2. Terms

Personal Data – any information relating to an identified or identifiable natural person, as defined in the GDPR and Section 2 of the DPA.
Cookies – small text files stored in your browser that allow the website to remember your actions and preferences over time.
The use of cookies is governed by a separate Cookie Policy.

3. What Personal Data We Collect

We may collect the following categories of data:
Identification Data

Address(es) of cryptocurrency wallets in supported blockchains;
Transaction hashes and transaction history related to our service.

Contact Data (if voluntarily provided)

Email address;
Nickname or phone number in Telegram (when using the bot).

Technical Data

IP address;
Browser type and version;
Device type, operating system, time zone;
API request log files.

Transaction Data

Information on the purchase of energy, amounts, date, and time;
Payment details (if payment is made via external providers).

Correspondence Data

Requests to customer support, feedback, communication with the team.

Important: we do not request or store private keys, seed phrases, or other sensitive data for accessing your cryptocurrency wallets.

4. How We Collect Data

The Company may collect your personal data in various ways, namely by processing personal data you provide to us directly and/or collecting information as a result of automated technologies, interactions, and/or from third parties from publicly available sources.

In addition, the Company may collect personal data you voluntarily provide, provided that you are aware of the transfer of such data to the Company.

In particular, information you provide to us directly may include your identification and contact data when contacting customer support via Telegram/email or using the bot.

When using the Company’s website, it may automatically collect technical data about your equipment, browsing actions, and behaviour on the website. The Company collects such personal data using cookies and other similar technologies. The Company may also receive technical data about you if you visit other websites using the Company’s cookies.

5. Purposes of Processing and Legal Bases

We use your data for the following purposes:

Purpose of Processing

Legal Basis (GDPR)

Legal Basis (DPA)

Provision of services (supply of energy, API)

Performance of a contract (Art. 6(1)(b))

Necessary for the performance of a contract

Security support and prevention of abuse

Legitimate interests (Art. 6(1)(f))

Legitimate interests

Responding to inquiries and requests

Contract / Legitimate interests

Contract

Analytics, service improvement

Legitimate interests / Consent

Consent / Legitimate interests

You may withdraw your consent at any time.

6. Disclosure of Data to Third Parties

Confidentiality and protection of your personal data are of fundamental importance to us. We take all appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of data and personal information, and to comply with the relevant provisions of applicable data protection laws.

Access to personal information is limited to employees who need it solely to perform their job duties, ensure the operation, development, or improvement of our services. These employees are bound by confidentiality obligations and are responsible for compliance, including possible disciplinary measures and legal liability for any breach of such obligations.

We do not transfer your personal data to any third parties.

7. Data Retention Periods

We retain different types of personal data for specific periods

Contact and communication data – until deletion upon request or after 2 years of inactivity;
Transaction logs – up to 7 years (for legal compliance and audit purposes);
Technical logs – up to 12 months (for security purposes).
Upon expiration of these periods, the data will be deleted or anonymized.

8. Data Subject Rights

You have the following rights regarding your personal data:

Right of access: you have the right to be informed whether the Company processes your personal data, and, if so, to obtain a copy of such data.
Right to rectification: you may request amendments to your personal data to correct or supplement them.
Right to erasure: you may send the Company a written request to delete specific personal data by emailing business@tronex.energy. Such request will be considered taking into account data retention requirements we are obliged to comply with under applicable laws and regulations, as well as our data retention policy. In some cases, deletion of data may be impossible if it is required for the Company to fulfil its legal obligations.
Right to restriction of processing: you have the right to restrict the processing of your personal data in certain cases. This means you may limit the ways the Company uses your data. This is an alternative to data deletion. Restriction is possible, for example, if you object to the content of the information held by the Company or to the way it is processed.
Right to data portability: you may request that your personal data be provided in a readable electronic format.
Right to object to processing: you may request that the Company stop processing your personal data, and the Company will do so if:
a) it cannot demonstrate compelling legitimate grounds for the processing;
b) the processing is carried out for marketing purposes.
Right to transfer data to you or a third party: the Company will provide you or a third party chosen by you with your personal data in a structured, commonly used, machine-readable format. This right applies only to automated information that you provided with your consent to its use or that is necessary for the performance of a contract with the Company.
Right to lodge a complaint: if you believe the Company is unlawfully using your personal data, you may file a complaint.
Right to withdraw consent: as stated above, you have the right to withdraw your consent. However, in such a case, the Company may be unable to provide you with certain products or services. The Company will inform you of the consequences of withdrawal at the time such a request is received.

9. Data Security

We implement technical and organizational measures, including:

Data encryption during transmission and storage;
Access rights management;
Regular security audits;
Prohibition on storing users’ private keys.

10. Cookies

Our website uses cookies for operation, analytics, and service improvement. Details are provided in a separate Cookie Policy.

11. Policy Updates

We may amend this Policy to comply with new laws or technologies. The updated version will be published on the website with the effective date indicated. In the event of significant changes, we will notify users via the website or by email.