EXUP™ Privacy Policy

Last updated: 09.12.2025

This Privacy Policy (hereinafter referred to as the "Policy") governs the processing and protection of personal data when using EXUP™ services (website, applications, software modules, API, and other products, hereinafter referred to as the "Service").

By using the EXUP™ Service, you confirm your consent to this Policy. If you do not agree, please stop using the Service.

1. Data Controller

The data controller is:
EXUP™
Email for data protection inquiries: admin@exup.io

2. What Data We Collect

EXUP™ may process the following categories of personal data:

2.1. User-Provided Data

Name, username, email.
Information provided when contacting support.
Other data that the user provides voluntarily.

2.2. Technical Data

Automatically collected data:

IP address, device type, OS version.
Login time, activity logs, interface usage data.
Cookies and similar technologies (if the user has given consent or it is necessary for the Service to function).

2.3. Payment Data

Subscription status, transactions, payment information.

2.4. Exchange Integration Data

When connecting via API, the following may be processed:
Public API keys, user-authorized permissions.
Technical data necessary for algorithm execution.
EXUP™ does not receive or store access to withdraw funds on exchanges.

3. Purposes of Data Processing

We use personal data for:
• User registration and providing access to EXUP™ functionality.
• Ensuring stable and secure service operation.
• Analytics, product quality improvement, and development of new features.
• User support, notifications, and service communications.
• Managing subscriptions, tariffs, and payment operations.
• Compliance with legal requirements in operating jurisdictions.

Analytical data may be used in anonymized and aggregated form.

4. Legal Basis for Processing

EXUP™ processes data based on:
User consent — for newsletters, cookies, and analytics.
Contract fulfillment — for registration, service provision, and service functionality.
Legitimate interests — improving security, preventing fraud.
Legal obligations, if required by regulators.

5. Data Sharing with Third Parties

EXUP™ does not share personal data with third parties, except in the following cases:
• Contractors servicing infrastructure (hosting, analytics, payment providers) who are required to maintain confidentiality.
• In connection with corporate restructuring transactions (merger, asset transfer) provided that the level of data protection is maintained.

We do not sell or transfer personal data to third parties for marketing purposes.

6. International Data Transfer

EXUP™ may use servers located outside the user's country of residence. Data transfer is carried out only with adequate protection measures in accordance with international requirements (GDPR, UK GDPR, etc.).

7. Data Retention

Data is stored for as long as necessary to achieve the purposes specified in this Policy:
• account data — while the account exists,
• log data — limited period necessary for security,
• payment and legal data — within the retention obligation.

After the expiration of the term, data is deleted or anonymized.

8. Data Protection

We apply technical, organizational, and legal protection measures, including:
• data transmission encryption,
• employee access restrictions,
• API security control,
• data storage on secure servers,
• security audit and monitoring.

However, no method of data transmission can be guaranteed 100% secure.

9. User Rights

The user has the right to:
• Receive information about their data and processing methods.
• Request correction of incorrect data.
• Request deletion of data (if there are no legal grounds for storage).
• Restrict data processing.
• Withdraw consent to processing (if processing is based on consent).
• Request data export (right to portability).

All requests can be sent to: admin@exup.io

10. Cookies and Tracking Technologies

We may use cookies:
• for user authorization,
• for interface operation,
• for analytics (e.g., Google Analytics),
• for experience personalization.

Users can disable cookies in browser settings, but this may limit the functionality of certain Service features.

11. Policy Updates and Changes

EXUP™ reserves the right to update the Policy.

The new version takes effect upon publication. In case of significant changes, we will notify users through the website, email, or within the service.

12. Contact Information

If you have questions about processing or protecting personal data, you can contact us:
EXUP™
Email: admin@exup.io

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