Last Updated: Jan 16, 2026

This Privacy Policy explains how ANDX USA LLC (“ANDX USA”, “we”, “us”, or “our”) collects, uses, and shares personal information when you access or use our website, mobile application, or related services (collectively, the “Platform”). By using the Platform, you agree to the practices described in this Privacy Policy.

1. Information We Collect

We may collect the following categories of information:

1.1 Identification Information (KYC Information)

This includes your name, date of birth, address, nationality, government-issued identification documents, and any other information required to verify your identity.

1.2 Contact Information

Email address, phone number, and other similar information.

1.3 Transaction & Account Information

Information about digital asset transactions you initiate through the Platform, account activity, balances, and related operational data.

1.4 Compliance & Risk Information

Information required for anti-money laundering (AML), counter-terrorist financing (CTF), sanctions screening, fraud monitoring, and regulatory reporting.

1.5 Technical Information

IP address, device identifiers, browser information, log data, security event data, and similar technical information.

1.6 Fiat Connectivity Information

If you connect a bank account or initiate a fiat deposit or withdrawal, we may receive information from financial connection service providers (e.g., verification status or transaction metadata).

2. How We Use Your Information

We use personal information for the following purposes:

• Creating and maintaining your Platform account

• Verifying your identity and completing KYC requirements

• Performing AML/CTF checks and sanctions screening

• Facilitating digital asset transactions initiated through the Platform

• Supporting the custodial and settlement functions performed through BitGo

• Ensuring security, preventing fraud, and detecting suspicious activity

• Meeting legal, regulatory, and compliance obligations

• Communicating with you about your account or Platform updates

3. How We Share Your Information

We may share your information with the following categories of recipients:

3.1 BitGo

To enable custodial, settlement, compliance, and operational functions performed under BitGo’s regulated framework, we may share:

• Identity and verification information

• Account and transaction information

• Compliance-related information

• Technical or operational metadata necessary to support the Platform

only to the extent necessary for BitGo to perform its custodial and settlement obligations

3.2 Financial Connectivity Partners

For fiat-related functions—such as account verification or initiating deposits/withdrawals—we may share limited information with service providers that connect to banks or payment systems.

These providers do not receive your digital asset balances or trading information.

3.3 Service Providers

Companies that help us with hosting, security, analytics, customer support, or similar functions.

3.4 Regulatory and Legal Obligations

We may disclose information to regulators, law enforcement, or other authorities when required by applicable law.

3.5 Corporate Transactions

In case of a merger, acquisition, or similar corporate event, personal information may be transferred as permitted by law.

4. KYC, AML, and Compliance

ANDX USA performs identity verification, sanctions screening, fraud monitoring, and other compliance measures required by U.S. law.

BitGo may perform additional compliance checks as part of its custodial and settlement obligations.

Both parties process personal information only as necessary to meet regulatory requirements and to operate within their respective legal frameworks.

5. Data Retention

We retain personal information for as long as required to:

• Maintain your account

• Satisfy legal and regulatory record-keeping obligations (including AML/CTF)

• Resolve disputes and enforce agreements

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

6. Your Rights

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

• Access the information we hold about you

• Request corrections to inaccurate information

• Request deletion of certain information (subject to legal retention requirements)

• Withdraw consent for certain processing (where applicable)

Requests may be submitted to: privacy@andxus.io

Some requests cannot be fulfilled where regulatory obligations require us to retain data.

7. Security

We implement administrative, technical, and physical security measures designed to protect personal information from unauthorized access, loss, misuse, or alteration.

8. International Transfers

We may process or store personal information in jurisdictions outside your state or country of residence.

Such transfers are performed in accordance with applicable law and with appropriate safeguards. Where applicable, we implement appropriate safeguards such as contractual data protection clauses.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

Material changes will be communicated through the Platform or via email.

Continued use of the Platform after changes become effective constitutes acceptance of the updated policy.

10. Contact Information

For questions about this Privacy Policy or to exercise your privacy rights, please contact our Data Protection Officer at: compliance@andxus.io ANDX USA LLC

Email: support@andxus.io

Address: 7901 4th St N, Ste 300, St. Petersburg, FL 33702.