This Privacy Policy explains how Market X LTD, a company incorporated under the laws of the Federal Republic of Nigeria (“Market X,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal data when you access or use our platform, website, applications, APIs, and related services (collectively, the “Services”).

By using the Services, you acknowledge that you have read and understood this Privacy Policy.

1. LEGAL BASIS & SCOPE

This Privacy Policy is issued in accordance with:

• The Nigeria Data Protection Act 2023 (NDPA)
• Applicable AML, CFT, and financial crime regulations

This Policy applies to all users, including visitors, registered users, and customers.

2. INFORMATION WE COLLECT

2.1 Personal Information You Provide

We may collect:

• Full name
• Date of birth
• Nationality
• Residential address
• Email address and phone number
• Government-issued identification (e.g., passport, national ID)
• Selfies or biometric verification data (where required)
• Proof of address documents

2.2 Financial & Transactional Information

• Wallet addresses
• Transaction history
• Deposit and withdrawal records
• Trading activity (spot and derivatives)

2.3 Technical & Usage Information

• IP address
• Device identifiers
• Browser type and operating system
• Log data, cookies, and usage analytics

3. HOW WE USE YOUR INFORMATION

We use personal data to:

• Provide and operate the Services
• Verify identity and conduct KYC/AML checks
• Comply with legal and regulatory obligations
• Facilitate trading, custody, and withdrawals
• Prevent fraud, abuse, and security incidents
• Improve platform performance and user experience
• Communicate with you regarding your account or legal notices

We do not sell your personal data.

4. LEGAL BASES FOR PROCESSING

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

• Performance of a contract (providing the Services)
• Compliance with legal obligations
• Legitimate interests (fraud prevention, security)
• Consent, where required by law

5. SHARING & DISCLOSURE OF DATA

5.1 Service Providers

We may share data with trusted third parties who assist us in operating the Services, including:

• Bybit, as a third-party execution and infrastructure provider
• KYC and identity verification providers
• Cloud hosting and security providers
• Analytics and monitoring services

These parties process data only under our instructions.

5.2 Legal & Regulatory Disclosure

We may disclose information:

• To regulators, law enforcement, or courts
• To comply with subpoenas or legal obligations
• To prevent fraud, financial crime, or security threats

5.3 Business Transfers

In the event of a merger, acquisition, or restructuring, user data may be transferred subject to applicable law.

6. CROSS-BORDER DATA TRANSFERS

Your personal data may be transferred to and processed in countries outside Nigeria, including jurisdictions where our service providers operate.

Where required, we implement safeguards to ensure an adequate level of data protection consistent with Nigerian law.

7. DATA RETENTION

We retain personal data:

• As long as your account remains active
• As required to comply with legal, regulatory, and AML obligations
• For legitimate business purposes

Retention periods may extend beyond account closure where legally required.

8. DATA SECURITY

We implement reasonable administrative, technical, and physical safeguards to protect personal data, including:

• Encryption
• Access controls
• Secure storage systems

However, no system is completely secure, and we cannot guarantee absolute security.

9. YOUR RIGHTS

Subject to applicable law, you may have the right to:

• Access your personal data
• Request correction of inaccurate data
• Request deletion (where legally permitted)
• Object to or restrict certain processing
• Withdraw consent where processing is based on consent

Requests may be subject to identity verification and legal limitations.

10. COOKIES & TRACKING

We use cookies and similar technologies to:

• Enable platform functionality
• Analyze usage
• Improve performance

You may manage cookie preferences through your browser settings.

11. THIRD-PARTY LINKS

The Services may contain links to third-party websites. We are not responsible for the privacy practices of such third parties.

12. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time.

Changes will be effective when posted on the Platform.

Continued use of the Services constitutes acceptance of the updated Policy.

13. CONTACT INFORMATION

If you have questions or requests regarding this Privacy Policy, you may contact us at:

Market X LTD
[email protected]
Nigeria