1. Introduction

Nummularius (“Nummularius,” “we,” “us,” or “our”) operates a cryptocurrency exchange platform that enables users to trade digital tokens backed by earth minerals. We are committed to protecting your privacy, safeguarding your personal data, and maintaining transparency regarding how your information is collected, used, stored, and disclosed.

This Privacy Policy explains our practices regarding personal information when you access or use the Nummularius website, mobile applications, APIs, wallets, and related services (collectively, the “Platform”).

By using the Platform, you agree to the collection and use of information in accordance with this Privacy Policy.

2. Tokens Offered on the Platform

Nummularius supports the trading of the following asset-backed digital tokens:

• Nummu Gold (NGT): Trading price guidance is linked to the COMEX Gold market price.
• Nummu Oil (NOT): Trading price guidance is linked to the West Texas Intermediate (WTI) crude oil market price.
• Nummu Cell (NCT): Trading price guidance is linked to spot market prices of Lithium Carbonate.

Price guidance does not guarantee price parity and is subject to market dynamics, liquidity, and platform conditions.

3. Information We Collect

3.1 Personal Information You Provide

We may collect the following information when you register or use the Platform:

• Full legal name
• Date of birth
• Nationality and country of residence
• Email address and phone number
• Government-issued identification (passport, driver’s license, national ID)
• Proof of address (utility bill, bank statement, or similar)
• Selfie or biometric verification (where required)
• Wallet addresses and transaction identifiers

3.2 Automatically Collected Information

When you access the Platform, we may automatically collect:

• IP address
• Device identifiers
• Browser type and operating system
• Log files and access times
• Usage patterns and interaction data

3.3 Financial & Transaction Data

• Token balances and transaction history
• Deposit and withdrawal records
• Blockchain transaction hashes
• Linked payment or custody provider identifiers (where applicable)

4. Legal Basis for Processing

We process personal data based on one or more of the following legal grounds:

• Performance of a contract
• Compliance with legal obligations (e.g., KYC/AML laws)
• Legitimate business interests
• User consent (where applicable)

5. How We Use Your Information

We use your information to:

• Create and manage user accounts
• Verify identity and comply with KYC/AML regulations
• Enable trading, transfers, and custody of tokens
• Process deposits and withdrawals
• Monitor transactions for fraud, abuse, or illegal activity
• Improve platform performance and user experience
• Communicate service updates, security alerts, and regulatory notices
• Enforce our Terms of Service and legal rights

6. Know Your Customer (KYC) & Anti-Money Laundering (AML)

To comply with applicable financial regulations, Nummularius conducts identity verification and ongoing monitoring. This may include:

• Identity checks through third-party verification providers
• Sanctions and watchlist screening
• Transaction monitoring and reporting to regulatory authorities when required by law

Failure to provide required verification may result in restricted or suspended access to the Platform.

7. Cookies & Tracking Technologies

We use cookies and similar technologies to:

• Maintain secure sessions
• Remember user preferences
• Analyze platform usage
• Enhance security and fraud prevention

You may adjust cookie settings through your browser, though certain features may be unavailable if cookies are disabled.

8. Data Sharing & Disclosure

We may share your information with:

• Regulatory authorities when legally required
• Law enforcement agencies in response to lawful requests
• Service providers (identity verification, cloud hosting, analytics, payment processors)
• Affiliates and successors in the event of a merger, acquisition, or restructuring

We do not sell or rent personal information to third parties for marketing purposes.

9. Blockchain Transparency

Blockchain transactions are inherently public. Information recorded on public blockchains (including wallet addresses and transaction hashes) is not controlled by Nummularius and may be visible indefinitely.

Users are responsible for safeguarding their wallet privacy.

10. Data Retention

We retain personal data only for as long as necessary to:

• Provide services
• Comply with legal, tax, and regulatory obligations
• Resolve disputes
• Enforce agreements

Retention periods may extend beyond account closure where required by law.

11. Data Security

We implement administrative, technical, and physical safeguards designed to protect personal information, including:

• Encryption of sensitive data
• Secure access controls
• Regular security audits
• Incident monitoring and response protocols

However, no system is completely secure. Users acknowledge and accept inherent risks associated with digital platforms.

12. International Data Transfers

Your information may be transferred to and processed in countries other than your own. Where applicable, we implement safeguards to ensure adequate data protection consistent with international standards.

13. Your Privacy Rights

Depending on your jurisdiction, you may have the right to:

• Access your personal data
• Correct inaccurate or incomplete data
• Request deletion of personal data
• Restrict or object to processing
• Withdraw consent where applicable

Requests may be subject to legal and regulatory limitations.

14. Children’s Privacy

Nummularius does not knowingly collect information from individuals under the age of 18. If we become aware of such data, it will be deleted promptly.

15. Third-Party Links

The Platform may contain links to third-party websites or services. Nummularius is not responsible for the privacy practices or content of those third parties.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted on the Platform with an updated “Last Updated” date. Continued use of the Platform constitutes acceptance of the revised policy.

17. Contact Information

For privacy-related inquiries, requests, or concerns, please contact:

Nummularius – Privacy Office
Delaware company registration: 10072767
📧 privacy@nummularius.com
🌐 www.nummularius.com