AML

1. General Provisions
This document defines the principles and rules for processing personal data of users of the website https://protonplus.co/ (hereinafter — the Service). In its operations, the Service is guided by the principles of transparency, proportionality, and respect for the rights of each user. By continuing to use the Service, the User confirms that they have read this document and accept the terms set forth herein.

2. Key Definitions
Personal data — any information that directly or indirectly identifies a specific individual.
Processing — any set of operations performed on personal data, including collection, recording, organisation, storage, clarification, retrieval, use, transfer, anonymisation, and destruction.
Operator — a party that independently or jointly with others determines the purposes and means of processing personal data and bears responsibility for such processing.

3. Categories of Data Processed
Depending on the nature of interaction with the Service, the following data may be processed:

Contact data — email address, phone number;
Identification data — last name, first name, patronymic, identity document details (as part of KYC verification);
Verification files — scans and photocopies of identity documents (passport, driver's licence, and other official documents); photos and selfies of the User, including those taken with a document; documents confirming the User's residential address (statements, utility bills, and similar materials); other files submitted by the User as part of the identity verification procedure;
Financial data — payment details, transaction history, verification status;
Technical data — IP address, cookies, information about the device used;
Communication data — content of support requests.

All verification files are submitted voluntarily by the User, stored securely, and used solely for identity verification and compliance with AML/KYC requirements. The Service does not process special categories of data relating to health, religious beliefs, political views, or other sensitive information.

4. Purposes of Data Processing
The collected data is used exclusively for:

identity verification and user registration in the Service;
processing of exchange transactions;
compliance with anti-money laundering (AML) and know-your-customer (KYC) requirements;
detection and prevention of fraudulent activities;
fulfilment of obligations to the User;
provision of technical and advisory support;
compliance with financial, accounting, and tax legislation;
notification of transaction status and changes in Service operations;
internal analytics aimed at improving the quality of services provided.

5. Legal Grounds for Processing
Personal data is processed on the basis of one or more of the following grounds:

voluntary and informed consent of the User;
necessity of performing a contract to which the User is a party;
requirements of applicable legislation;
legitimate interests of the Service, including ensuring security and preventing financial violations.

6. Disclosure of Data to Third Parties
Personal data may be disclosed to the following categories of recipients:

financial institutions and payment systems involved in processing transactions;
KYC verification providers;
technical partners ensuring the infrastructure of the Service;
government and regulatory authorities — exclusively upon lawful and duly formalised requests.

Data is transferred only to the extent minimally necessary for the performance of a specific task.

7. Data Retention Periods
Personal data is retained for a period determined by the following factors:

existence of active user relationships and pending transactions;
requirements of legislation on financial monitoring and anti-money laundering;
applicable limitation periods;
existence of ongoing audits, investigations, or legal proceedings.

Data related to identity verification and financial transactions is retained for no less than five years from the date of completion of the relevant transaction, unless a different period is provided for by applicable law.

8. Restrictions on the Right to Erasure
The User may request the deletion of their personal data. However, such a request cannot be fulfilled if data processing is necessitated by:

applicable legal requirements;
obligations under AML/KYC procedures;
financial, accounting, or tax reporting requirements;
the need to protect the legitimate interests of the Service;
unresolved claims or disputes;
instructions from law enforcement or regulatory authorities.

For requests concerning completed financial transactions, the Service reserves the right to defer their execution until the end of the mandatory retention period. If a lawful request is received from competent authorities after the User has submitted a deletion request, the relevant data will be disclosed in the manner prescribed by law, regardless of such request.

9. User Rights
With respect to their personal data, the User has the right to:

obtain full information about the composition and nature of its processing;
request correction of inaccurate or outdated information;
seek restriction of processing in cases provided for by law;
withdraw previously given consent to processing;
lodge a complaint with the competent supervisory authority.

The exercise of these rights is subject to the limitations set out in this document and applicable legislation.

10. Data Protection Measures
The Service applies a range of technical and organisational measures to protect personal data against unauthorised access and unlawful use:

access control to information systems;
encryption of data in transit;
protection of server and network infrastructure;
internal security incident response procedures;
regular monitoring of employee compliance with access policies.

11. Use of Cookies
To ensure the proper functioning of the platform, collect aggregated statistics, and enhance user experience, the Service uses cookies. The User may modify cookie settings through their browser at any time.

12. Document Updates
The Service reserves the right to amend this document as necessary. The current version is always available at https://protonplus.co/. Amendments take effect from the moment of their publication on the website.

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