JTX MARKETS · LEGAL

Privacy Policy

DRAFT — not yet effective

> DRAFT — pending counsel review.

Introduction

JTX Markets (the "Platform", "we" or "us"), operated by JTX Markets [Entity name pending confirmation], is committed to protecting your personal data. This Privacy Policy explains how we collect, use, retain and share personal data in connection with the Services.

Data We Collect

•Identity data — name, date of birth, nationality, government ID details, KYC document images

•Contact data — email, phone, residential address

•Financial data — payment method details, USDT wallet addresses, transaction history

•Trading data — orders, fills, position history, rule-state transitions, account balances

•Technical data — IP address, device information, browser fingerprint, session data

•Mobile application data — device push notification tokens (used to deliver order fills, funding, KYC and withdrawal alerts to your device), device operating system and version, app version, in-app preferences stored locally on your device

Purposes for Which We Use Personal Data

•Providing the Services (account provisioning, challenge management, payouts)

•Complying with AML/CTF/Sanctions obligations (KYC, transaction monitoring, sanctions screening)

•Fraud prevention and market surveillance

•Customer support and dispute resolution

•Delivering push notifications you have not opted out of (fills, funding, withdrawals, identity verification updates)

•Marketing (with consent) and product improvement

Mobile Application — Biometric Unlock

If you enable biometric unlock (Face ID, Touch ID, or fingerprint) in the JTX Markets mobile application, your biometric data remains on your device and is processed exclusively by your device's operating system. JTX Markets does not collect, store, transmit or have access to biometric data.

Mobile Application — Push Notifications

The mobile application registers a device-specific push notification token issued by Apple (APNs) or Google (FCM) via Expo's notification service. This token is stored on our servers linked to your account so we can deliver operational alerts. You can disable individual notification categories in the app's Notification Settings screen, and revoke all push permissions at any time from your device's system settings.

Retention

•KYC documentation: 5 years after account closure (AML record-keeping)

•Trading activity: 7 years (market surveillance and regulatory inspection)

•Transaction records: 7 years (tax and audit)

•Support correspondence: 2 years after closure

Blockchain — Important Disclosure

Payout addresses and USDT transaction details are committed to public blockchains and cannot be deleted or redacted by JTX Markets once broadcast.

Sharing

We share personal data with: KYC and sanctions-screening vendors; payment processors; email delivery vendor (Postmark) for transactional notifications; push notification delivery vendor (Expo Push, which relays to Apple APNs / Google FCM); customer support tooling; regulators and law enforcement where legally required; potential acquirers under NDA if the business is being sold.

Your Rights

Where GDPR or equivalent laws apply, you have rights to access, rectify, erase, restrict processing, port and object. Contact [email protected].

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Counsel review required before launch.