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Privacy Policy

EXCH.BLACK
Last updated: jan 14, 2026

1. Introduction

EXCH.BLACK ("Platform", "Service", "we", "us") is committed to protecting the privacy of its users. This Privacy Policy describes what information we collect, how we use it, and your rights regarding that information.

We operate under the jurisdiction of the Republic of Seychelles and adhere to the principle that financial privacy is a fundamental human right. Our data practices reflect this principle.

2. Information We Do NOT Collect

Unlike traditional financial platforms, EXCH.BLACK does not collect:

  • Full legal names or aliases
  • Government-issued identification documents (passport, ID card, driver's license)
  • Photographs, selfies, or biometric data
  • Social security numbers, tax identification numbers, or equivalent
  • Bank account or traditional payment card details
  • Physical addresses or proof of residence
  • Phone numbers
  • Employment or income information

We do not perform Know Your Customer (KYC) or Anti-Money Laundering (AML) identity verification. This is lawful under the regulatory framework of the Republic of Seychelles for non-custodial exchange services of our classification.

3. Information We Collect

We collect the minimum data necessary to operate the Service:

3.1 Transaction Data

  • Cryptocurrency addresses (sender and recipient)
  • Transaction amounts and identifiers (hashes)
  • Supported network/chain information
  • Transaction status and timestamps

This data is inherently public on the respective blockchains and is collected solely to process and monitor your transactions.

3.2 Communication Data

  • If you contact us through support channels, we retain the content of the communication for the purpose of resolving your inquiry.

3.3 Cookies and Similar Technologies

  • We use minimal, functional cookies to ensure proper operation of the Platform (session management, language preferences).
  • We do not use advertising cookies, tracking pixels, or third-party analytics that profile individual users.
  • You may disable cookies in your browser settings; however, some Platform features may not function correctly.

4. How We Use Information

The information we collect is used exclusively for:

  • Processing and completing cryptocurrency exchange transactions in real time.
  • Providing technical support when requested.
  • Complying with applicable laws of our operating jurisdiction.

We do not use collected data for advertising, profiling, analytics, or sale to third parties. All data processed in the course of providing the Service exists only for the duration of the operation and is not retained after its completion.

5. Data Sharing

We do not sell, rent, or trade user data to any third party.

We do not comply with extraterritorial data requests from jurisdictions where we do not operate, except as expressly required under the laws of the Republic of Seychelles.

Due to our Zero-Log Policy (Section 6), we technically do not possess data subject to disclosure. Even in the event of a legally binding request from a competent court of the Republic of Seychelles, we cannot provide data that was never collected and does not exist in our systems.

5.1 No Nexus with United States Jurisdiction

  • EXCH.BLACK is not registered, incorporated, or in any way legally present within the territory of the United States of America or its territories.
  • We do not have physical servers, offices, employees, agents, bank accounts, or any other assets within the territory of the United States.
  • We do not engage in purposeful availment directed at the United States and do not direct our services at U.S. residents.
  • We do not recognize the jurisdiction of U.S. federal or state courts, or U.S. regulatory agencies, including but not limited to: SEC, FinCEN, CFTC, OFAC, IRS, DOJ.
  • Any subpoenas, court orders, National Security Letters, FISA orders, or other legal process instruments issued by U.S. authorities have no legal force with respect to EXCH.BLACK and are not subject to enforcement.
  • We do not participate in tax data exchange programs (CRS/FATCA) with respect to U.S. citizens or residents.

6. Zero-Log Policy

EXCH.BLACK adheres to a strict zero-logging policy:

  • We do not maintain or store server access logs containing IP addresses, User-Agent strings, or other identifying metadata.
  • We do not retain connection logs, session timestamps, or page visit history.
  • All system logs required for operational diagnostics exist exclusively in volatile memory (RAM) and are automatically destroyed upon each service restart cycle. These logs are never written to persistent storage (disks, SSDs, network storage).
  • Transaction data is retained only for the duration of the exchange processing. Upon completion of the transaction and all blockchain confirmations, associated records are automatically purged from our systems.
  • We do not maintain persistent user profiles, create accounts, or link multiple sessions or transactions to one another.
  • We do not use analytics, tracking, or telemetry systems capable of identifying or profiling users.

Consequence: in the event of any data request from any authority, we are technically unable to provide data that does not exist. We cannot disclose what we do not store.

7. Data Security

We implement industry-standard security measures, including:

  • TLS encryption for all data in transit.
  • In-memory encryption of data during processing.
  • Full Disk Encryption (FDE) on all servers.
  • No persistent storage of user data on physical media.
  • Access controls limiting data visibility to the minimum necessary systems.
  • Regular security audits.

8. Your Rights

You have the right to:

  • Access: Request information about what data, if any, we hold related to your transactions.
  • Deletion: Request deletion of any data associated with your transactions, subject to legal retention obligations.
  • Objection: Object to any processing you believe is unlawful.

To exercise these rights, contact us through the communication channels listed on the Platform. We will respond within 30 days.

9. Tor and VPN Access

We support and encourage access to the Platform via Tor, VPN, or other privacy-enhancing technologies. Use of such tools does not affect your ability to use the Service and is not treated as suspicious activity.

10. Minors

The Platform is not intended for use by individuals under the age of 18. We do not knowingly collect data from minors.

11. International Users

The Platform is operated from the Republic of Seychelles. If you access the Service from another jurisdiction, you acknowledge that your data may be processed in Seychelles, which may have different data protection standards than your country of residence.

Users from the United States are prohibited from using the Service, as outlined in our Terms of Service. The Platform is not intended for U.S. citizens, residents, or tax residents. Any use of the Platform by persons from the United States is undertaken entirely at their own risk and in violation of these Terms.

12. Warrant Canary

As of the date of the last update to this Policy:

  • EXCH.BLACK has not received any search warrants, subpoenas, disclosure orders, or National Security Letters from any governmental authority of any jurisdiction.
  • EXCH.BLACK has not been subject to gag orders or any other prohibitions on disclosing the fact of governmental requests.
  • EXCH.BLACK has not provided encryption keys or backdoors to any third party.
  • No backdoors have been implanted into EXCH.BLACK's infrastructure at the request of governmental authorities.
  • EXCH.BLACK has not received any orders to suspend, block, or cease operations from regulatory authorities of any jurisdiction.
  • EXCH.BLACK domain names have not been the subject of judicial or administrative disputes initiated by governmental authorities.

This section is updated with each revision of the Privacy Policy. The absence of this section or the cessation of its updates should be treated as a signal that circumstances have changed.

13. Protection Against Malicious Complaints

Due to the nature of the cryptocurrency industry, EXCH.BLACK may become a target of false complaints from competitors, bad-faith actors, or automated systems. In this context, we state:

  • EXCH.BLACK is a lawfully operating service under the jurisdiction of the Republic of Seychelles.
  • Our Zero-Log Policy (Section 6) means that we are technically incapable of engaging in activity that could be classified as "personal data fraud", as we do not collect or store personal data.
  • The non-custodial nature of the Service means that we do not have access to user funds and cannot misappropriate them.
  • Complaints alleging "fraud" or "scam" filed without completing the mandatory pre-dispute resolution procedure (see Terms of Service, Section 15.2) are unfounded and potentially malicious.

Detailed provisions on dispute resolution procedures and liability for filing false complaints are set forth in the Terms of Service (Section 15).

14. GDPR and Other Regulatory Frameworks

EXCH.BLACK does not operate within the territory of the European Union and is not formally subject to the General Data Protection Regulation (GDPR). Nevertheless, our data processing practices meet or exceed GDPR standards with respect to data minimization, purpose limitation, and the right to erasure — by virtue of the Service's architecture itself, not regulatory obligation.

15. Changes to This Policy

We may update this Privacy Policy from time to time. Changes become effective upon posting to the Platform. We encourage you to review this page periodically. Material changes will be announced via the Platform with at least 7 days notice.

16. Contact

For questions or concerns regarding this Privacy Policy, contact us through the communication channels listed on the Platform.

By using EXCH.BLACK, you acknowledge that you have read and understood this Privacy Policy.