Privacy Policy

Last updated: [DATE]

This policy explains what personal information CryoLynx collects about you, why we collect it, who we share it with and what you can do about it. It covers the CryoLynx website and the CryoLynx mobile app.

Who we are What we collect Why we use it Who we share it with International transfers How long we keep it Security Your rights Deleting your account Cookies Children Changes Contact

1. Who we are

CryoLynx is operated by [LEGAL ENTITY NAME] (registration number [COMPANY REGISTRATION NO]), a South African company with its registered address at [REGISTERED ADDRESS]. We are the responsible party for your personal information under the Protection of Personal Information Act, 2013 (POPIA).

Our Information Officer is [INFORMATION OFFICER NAME], reachable at [PRIVACY EMAIL].

2. What we collect

Category	Examples
Account information	Name, surname, email address, mobile number, password (stored hashed, never in readable form), referral code, language and display-currency preferences.
Identity verification (KYC)	Government-issued identity document or passport, a selfie or short face scan, date of birth, nationality and address. Collected and checked through our verification provider, [KYC PROVIDER].
Financial and transaction data	Deposits, withdrawals, trades, conversions, Earn subscriptions and redemptions, wallet addresses and networks you use, and the counterparty details required for Travel Rule checks on withdrawals.
Device and usage data	IP address, device and browser type, operating system, app version, pages or screens used, and the date and time of each session. Used for security, fraud prevention and to keep the service working.
Support and communications	Support tickets and their messages, emails and notification preferences.

We do not sell your personal information, and we do not use it for advertising profiles.

3. Why we use it, and our lawful basis

To provide the service — opening your account, running trades, deposits, withdrawals, Convert and Earn, and showing your balances. This is necessary to perform our contract with you.
To meet legal obligations — identity verification, sanctions and politically exposed person screening, Travel Rule information on transfers, record-keeping and reporting under the Financial Intelligence Centre Act, 2001 (FICA) and related South African law.
To keep accounts secure — two-factor authentication, device linking, fraud and abuse detection, and investigating suspicious activity. This is in our and your legitimate interests.
To support you — answering tickets and sending service messages such as verification emails, security alerts and transaction notifications.
To improve the platform — aggregated usage statistics and error diagnostics.
Marketing — only where you have chosen to receive it. You can opt out at any time from your profile or from the link in the message.

Binance — our liquidity, custody and brokerage partner. Trades, balances and transfers you make are executed on infrastructure operated by Binance, and the account information needed to run them is shared with it.
[KYC PROVIDER] — our identity verification provider, which processes your identity documents and face scan on our behalf.
Service providers — hosting, email and SMS delivery, and error monitoring. They may process your information only on our instructions.
Regulators and law enforcement — where we are legally required to report or disclose, including under FICA, a court order or a valid request from a competent authority.
Professional advisers and a purchaser — auditors and legal advisers, and, if the business is sold or reorganised, the acquiring party, subject to this policy.

5. International transfers

Some of these providers process information outside South Africa. Where that happens, we transfer your information only in line with section 72 of POPIA — the recipient must be bound by laws or an agreement giving protection that is substantially similar to POPIA.

6. How long we keep it

We keep identity verification and transaction records for at least five years after your relationship with us ends, as FICA requires. Support messages and device logs are kept for as long as they are needed for security and dispute resolution. After that, information is deleted or de-identified.

7. How we protect it

Access to personal information is restricted to staff who need it. Traffic to the platform is encrypted in transit, passwords are stored hashed, and accounts support two-factor authentication, recovery codes and device linking. No system is completely secure, so please use a unique password, turn on two-factor authentication and never share your credentials or one-time codes — our staff will never ask you for them.

8. Your rights

Under POPIA you may:

ask what personal information we hold about you and request a copy;
ask us to correct or delete information that is inaccurate, irrelevant, excessive or out of date;
object to processing that relies on legitimate interests;
withdraw consent to marketing at any time;
complain to us first at [PRIVACY EMAIL], and then to the Information Regulator (South Africa) at inforegulator.org.za.

Some information we must keep even if you ask us to delete it, because FICA and other laws require us to retain it for a set period.

9. Deleting your account and data

To close your CryoLynx account and request deletion of your data, either raise a support ticket from the app or website, or email [PRIVACY EMAIL] from the address registered on your account. Withdraw any remaining balance first — we cannot return funds after an account is closed.

We will confirm your identity, close the account and delete or de-identify your personal information, except for the records we are legally required to retain (see How long we keep it). We aim to complete this within 30 days.

10. Cookies

The website uses cookies and similar storage to keep you signed in, remember your theme, language and display currency, and to keep the service secure. You can clear or block cookies in your browser, but parts of the platform will stop working if you do.

11. Children

CryoLynx is for people aged 18 and over. We do not knowingly collect information from children. If you believe a child has given us their information, contact us and we will delete it.

12. Changes to this policy

We may update this policy. The "Last updated" date above shows when it last changed, and we will tell you in the app or by email when a change materially affects you.

13. Contact us

[LEGAL ENTITY NAME]
[REGISTERED ADDRESS]
Email: [PRIVACY EMAIL]