Privacy Policy

Legal and privacy policy

Privacy is of utmost importance at the Megamatrix Solution group of companies. We recognise the significance of protecting information stored, or intended to be stored, on our servers or network that relates to an individual. The data we protect is "Personal Data": any information relating to an identified or identifiable natural person (sometimes called a data subject). Protecting the privacy and confidentiality of Personal Data is a fundamental part of how we do business.

This Privacy Policy explains how we work to ensure the privacy and confidentiality of Personal Data, the information we gather, how we use it, and the circumstances under which we disclose it to third parties.

This policy is designed to address the regulatory requirements of the jurisdictions in which Megamatrix Solution offers its Services, including the General Data Protection Regulation ("GDPR"). In this Privacy Policy, "Service" and "Services" have the same meaning as in the User Agreement, but exclude API services, which are governed by a separate agreement. If you do not agree with this Privacy Policy, in general or any part of it, you should not use the Services.

We review this policy periodically to take account of new obligations and changes to our business model, and may amend it at any time by posting an updated version on our website.

01Information about Megamatrix Solution

Our Services are offered through one or more subsidiaries of Megamatrix Solution International GmbH. By using the Services, you understand that your Personal Data may be used by one of the following entities (each, a "Controller"):

• Megamatrix Solution UK Ltd
• Megamatrix Solution EU GmbH

02Collection of Personal Data

Information you provide to us

You may give us information about yourself by filling in forms on our website or app, or by corresponding with us by phone, email or otherwise. This includes information you provide when you register for the Services and when you report a problem with the website or app.

Information we collect about you

For each visit to our website or app, we automatically collect:

• Login information: technical information about your use of the Services, including browser type and version, wallet identifier, the last access time of your wallet, the IP address used to create the wallet and the most recent IP address used to access it.
• Device information: the hardware model, operating system and version, and unique device identifiers of the device you use. This information is anonymised and not tied to any particular person.
• Wallet information: if you create a Megamatrix Solution Wallet, you generate a public and private key pair. When you log out of the Wallet, we collect an encrypted file that, if decrypted, would contain these keys along with your transaction history. If you enable notifications in Account Settings, we collect the unencrypted public key to provide them. We never collect an unencrypted private key, and we cannot decrypt any Wallet file data.
• Transaction information: in connection with our Conversion Service (as defined in the User Agreement), we may collect and keep information about transactions in your Wallet that convert one virtual currency to another (for example, Bitcoin to Ether).

03Use of Personal Data

We use your Personal Data to:

• understand and meet your needs and preferences in using our Services;
• develop new, and improve existing, services and products;
• manage and develop our business and operations;
• carry out any actions for which we have your consent;
• prevent and investigate fraudulent or other criminal activity;
• address service requests and resolve user questions; and
• meet legal and regulatory requirements.

We may also use aggregated Personal Data to understand how users use our Services, provided that the data cannot identify any individual.

We use third-party web analytics tools that help us understand how users engage with our website. These may use first-party cookies to track interactions and compile reports that show website trends without identifying individual visitors. You can opt out of these tools without affecting how you use the site; for details, contact support@megamatrixsolution.com.

04Disclosure of Personal Data

We may share your information with selected recipients to perform functions needed to provide certain Services, and to prevent and investigate fraud or other criminal activity. All such third parties are contractually bound to protect data in line with this Privacy Policy. Recipients include:

• companies within the Megamatrix Solution corporate family in the United States, the United Kingdom and the EEA, in order to provide the Services;
• cloud service providers, for data storage, disaster recovery and the performance of any contract we enter into with you;
• fraud detection providers, who run fraud checks against Personal Data provided; and
• spam and abuse detection providers, whose software helps prevent the Services being used programmatically in unsupported ways.

We may also share Personal Data with a buyer or successor in the event of a merger, divestiture, restructuring, reorganisation, dissolution or other sale or transfer of some or all of Megamatrix Solution's assets, whether as a going concern or as part of bankruptcy, liquidation or a similar proceeding.

Except where we are required by law to disclose Personal Data, or are exempt from any legal requirement concerning its disclosure, we require anyone we share it with to comply with our Privacy Policy, or substantially similar requirements, in force at that time. We will make reasonable commercial efforts to ensure they comply but, where not expressly prohibited by law, we have no liability to you if they fail to do so.

We require any third party, including any government or enforcement body, seeking access to the data we hold to provide a court order or equivalent proof that they are legally authorised to access it and that their request is valid and within their statutory or regulatory powers.

05Security of your Personal Data

We protect Personal Data with appropriate physical, technological and organisational safeguards. Because your data reaches us over the internet, which chooses its own routes, we audit our procedures and security measures regularly to ensure they remain effective and appropriate.

Everyone at Megamatrix Solution is committed to our privacy policies and procedures. Our site has measures in place to protect against the loss, misuse and unauthorised alteration of information under our control. In particular, our servers use TLS (Transport Layer Security) to encrypt your Personal Data in transit.

06Retention of your Personal Data

How long we keep Personal Data outside our backup system depends on why it was collected:

• Data you provide when subscribing to our Services: while you remain active; stored in England, UK.
• Country location data: while you remain active; stored in England, UK.
• Preference data: while you remain active; stored in England, UK.
• Login IP address: until your next login from a new IP; stored in England, UK.

When Personal Data is no longer needed for the purpose it was collected for, we remove identifying details or securely destroy the records where permitted. However, regulation may require us to keep some records for a significant period after you stop using a Service. For example, anti-money-laundering laws require us to keep the following for five (5) years after our business relationship ends:

• a copy of the records used to meet our client due-diligence obligations; and
• supporting evidence and records of transactions with you and your relationship with us.

Except where prohibited by law, this period may extend beyond the end of the relationship, but only for as long as we are required to for audit, regulatory or accounting purposes. When Personal Data is no longer needed, we destroy, delete, erase or anonymise it. If you opt out of marketing, we keep your details on a suppression list so we know not to contact you.

After you stop using our Services, we may keep your Personal Data in aggregated form as part of our standard backup procedures.

07Storage of Personal Data

Megamatrix Solution stores your Personal Data at secure locations in the EU and ensures appropriate standards are in place for its safeguarding, confidentiality and security.

Information we collect may be transferred to and stored in destinations outside your country and the European Economic Area ("EEA"). We may transfer Personal Data outside the EEA and the UK to other subsidiaries, service providers and business partners (Data Processors) engaged on our behalf. Where we do, we ensure the transfer is lawful and that Data Processors in third countries are obliged to comply with the GDPR and the UK Data Protection Act 2018. For transfers to the US, we may rely on applicable standard contractual clauses.

08Your rights

You have the following rights in relation to the Personal Data we hold about you. To exercise any of them, contact support@megamatrixsolution.com.

Information access

If you ask, we will confirm whether we process your Personal Data and, if so, what information we process. If requested, we will provide a copy within 30 days of your request.

Rectification

We take reasonable steps to keep your Personal Data accurate, complete and up to date. If it is inaccurate or incomplete, you are entitled to have it corrected. Where we have disclosed it to others, we will tell them about the correction where possible and, if you ask and it is lawful, tell you who they are so you can contact them directly.

You can tell us about changes to your details at any time by emailing support@megamatrixsolution.com. In some cases we may need supporting documents, which we must keep for regulatory or legal purposes.

Erasure

You can ask us to delete your Personal Data in certain circumstances, for example if we no longer need it, provided we have no legal or regulatory obligation to keep it. Requests are subject to any agreements you have with us and to applicable retention requirements. Where we have shared the data, we will tell recipients about the erasure where possible.

Processing restrictions

You can ask us to block or suppress processing of your Personal Data in certain circumstances, for example if you contest its accuracy or object to our processing it. This does not stop us storing it. We will tell you before we decide not to agree to a requested restriction, and inform recipients of the restriction where possible.

Data portability

In certain circumstances you may have the right to receive the Personal Data you provided to us in a structured, commonly used, machine-readable format, and to reuse it elsewhere or have it transferred to a third party of your choice.

Objection

You can ask us to stop processing your Personal Data, and we will do so if we are:

• relying on our own or someone else's legitimate interests, unless we can show compelling legal grounds for the processing;
• processing it for direct marketing; or
• processing it for research, unless we reasonably believe the processing is necessary for a task carried out in the public interest (such as by a regulatory or enforcement agency).

Automated decision-making and profiling

If we make a decision about you based solely on an automated process (such as automatic profiling) that affects your access to our Services or otherwise significantly affects you, you can ask not to be subject to it unless we can show it is necessary for entering into, or performing, a contract between us. Even then, you may contest the decision and request human intervention. If we agree to such a request, we may not be able to continue offering our Services and may end our relationship with you.

09Acceptance

By using the Services, you agree to this Privacy Policy. Megamatrix Solution may change or amend it at any time. If we make material changes, we will post the revised policy here and notify users at least 30 days before the changes take effect, so you always know what we collect, how we use it and when we disclose it. Please check this page regularly for updates.

10Questions and complaints

Questions about this Privacy Policy, how Megamatrix Solution collects, uses and discloses Personal Data, or access to your Personal Data should be sent to support@megamatrixsolution.com.

If you wish to complain about how we process your personal data, contact us at the same address and we will handle your request promptly. This does not affect your right to contact your local data protection supervisory authority.