We, GODEX (hereinafter “COMPANY”, “Company” “We”, “Us”) operate the website
we process users’ data and what rights users have as data subject.
For the purposes of the data protection laws that apply to us, including the GDPR, CLA, We
act as the Data Controller for the Personal data that We collect and process to enable users to
make use of Our Services.
the legal basis for collecting and processing users’ Personal data, the categories of Personal
data that may be collected, what happens to the personal data that We may collect, how long
We are required to retain Personal data, who We may share Personal data with and to also
explain users’ rights as a data subject.
This Policy in the field of Personal data processing and confidentiality of personal
information (hereinafter referred to as the “Policy”) applies to https:/godex.io website
(hereinafter referred to as the “Website”) and is aimed to govern the information received
(gathered) about the user while using the Website or any of the sites, services, services,
programs and products of COMPANY (hereinafter - the Services), as well as during the
execution COMPANY or its affiliates of any agreements and contracts concluded with the
user in connection with the use of the Services.
1. Definitions and Personal data procession
Our Websites and through Our mobile applications.
“Personal data” in accordance with this Policy means any information that can either itself
identify “Data Subject” as an individual (hereinafter - “user” or “users”) as well as the
information that can be connected to user indirectly by linking it to.
“Personal data procession” or “Processing” means any operation or set of operations which
is performed on personal data or on sets of personal data, whether or not by automated
means, such as collection, recording, organization, structuring, storage, adaptation or
alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise
making available, alignment or combination, restriction, erasure or destruction.
COMPANY stores and processes Personal data for as long as it is necessary to achieve the
purpose for which it was collected.
“Third party” means a natural or legal person, public authority, agency or body other than
the Data Subject, Controller, processor and persons who, under the direct authority of the
Controller or processor, are authorized to process personal data.
“Consent” of Personal data procession shall mean any freely given, specific, informed and
unambiguous indication of the Data Subject's wishes by which he or she, by a statement or by
a clear affirmative action, signifies agreement to the processing of personal data relating to
him or her.
“Cookie” means a small text file placed on User’s computer or device by Our Website when
user visits certain parts of Website.
“Automatic processing” includes the following operations if carried out in whole or in part
by automated means: storage of data, carrying out of logical and/or arithmetical operations on
those data, their alteration, erasure, retrieval or dissemination.
“Services” mean all Our products: Website, Applications.
2. Categories of Personal data being processed
A summary of the Personal Data that We process, when We collect it, how We use it and
why We use it (i.e. the legal basis for processing) is listed below:
Directly Provided information: We may collect information you provide directly to us. For
example, we collect information about you when you create an online account, complete a
transaction, fill out a support form, respond to surveys, post messages to our forums or
communicate with us in any other way. The types of information we may collect are as
• Contact information, such as your name, mailing address, telephone number, and
email address. Financial information, such as virtual currency account information.
• Government identification numbers, such as your social security number or a state-
issued identification number.
• Biographic or demographic information, such as your date of birth, gender,
occupation, employment status and any other information you choose to provide about
Transaction information: We collect information about the transaction performed by you
via GODEX website or any third party affiliated or not affiliated with GODEX, including the
amount of funds associated with a trade, wallet addresses, transaction identifiers, the types of
trades executed and other transaction information.
Device and Log information: We collect information about the device you use to access the
Company services, including device identifiers, type of operating system, and the type of
browser used. We also log information about your use of the Company services, including
access times, pages viewed and IP address.
Cookies: To enhance the quality of Our services, We use technologies, such as Cookies.
Cookies do not typically contain any information that personally identifies users, but personal
information that We store about users may be linked to the information stored in and obtained
the design and layout of the Website in order to enhance users’ experience browsing Our
We use the following types of cookies:
● Strictly necessary cookies – these are cookies that are required for the operation of
Through cookies, Personal data is being processed for the purposes as described in Section 3
(“Purposes”) in the following way:
● Cookies are to be deleted when user closes the browser (session cookies).
● Cookies remain stored on end user device even after the browser was closed
User can delete Cookies if wishes; while certain Cookies are necessary for viewing and
navigating on Our Website, most of the features will be still accessible without Cookies. In
order to restrict it to certain cookies, users can use browser settings. *
*Details can be found in browser helpdesk (usually accessible via the F1 key on keyboard).
We collect, process and store only such Personal data that is necessary for the provision of
the Services in strict accordance with applicable law. By giving consent of processing his/her
Personal data listed above user confirms that We are allowed to process his/ her personal
information for the following purposes:
● Identification of a party under agreements and contracts with COMPANY.
● Provision of Services and deliverance full-featured associated Content.
● Compliance with legal obligations that We are subject to (e.g. obligations to keep
certain information under tax laws).
● Fulfillment the contractual obligations of COMPANY to the user.
● Communication with the user, including the sending of notifications, requests and
information regarding the use of the Services, the provision of Services, as well as the
processing of requests and applications from the user.
● Improving the quality of Services, ease of use, development of new Services.
● Preventing potentially prohibited or illegal activities and enforcing our user
● Link or combine your personal information with information we obtain from other
parties to provide you with better service;
● Conducting statistical and other studies based on anonymized data.
By accessing or using Company services or otherwise providing information to us, you give
your clear consent for processing your Personal data. The Personal data can be processing
and transferred to the other countries, including, but not limited to the United States, where
data protection and privacy regulations may be different. If you are a resident of the European
Union or Switzerland, please refer to the U.S. – EU / Swiss Safe Harbor Compliance section
We do not control and are not responsible for third party websites or services provided by
third party that can be accessed by the user clicking on the links available on the Website. On
such sites, other personal information may be collected or requested from user, and other
actions may be performed.
The user’s consent to the processing of personal data is valid indefinitely from the moment of
acceptance of terms of this Policy in full.
If you are located in EU, you specifically and voluntarily consent to the transfer of your
personal information to our servers in 5 years for storage, collection and use of your personal
data, for the specific purposes of performing identity verification or checking, to enable us to
prevent fraud and comply with our legal obligations.
You may revoke your consent to this section at any time by emailing us at [email protected]
6. Personal data procession termination
Personal data procession shall end and the collected data itself shall be deleted immediately
after it is no longer required by law or for executions of purposes described in Section 3.
In determining the necessary Personal data retention period.
Your personal data will be deleted in 14 days after had been collected.
7. Personal data protection and Security
When Personal data provided through Our Website, this information is transmitted across the
internet securely using industry standard encryption. Personal data will be held encrypted on
We implement protection of your information with physical, technical and administrative
security measures, including, but not limited to, restricting access to your information for
employees with a need to know such information. U.S. – EU / SWISS SAFE HARBOR
"GODEX" complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe
Harbor Framework as set forth by the United States Department of Commerce regarding the
collection, use, and retention of personal information from European Union member
countries and Switzerland. Company adheres to the Safe Harbor Privacy Principles of notice,
choice, onward transfer, security, data integrity, access, and enforcement. To learn more
about the Safe Harbor program, please visit http://www.export.gov/safeharbor/
8. Disclosure of information
We may also share users’ Personal Data with our third party providers that provide customer
support services in connection with goods, content and Services distributed via Websites, and
other affiliated or nonaffiliated companies that subscribe to the Safe Harbor Privacy
Principles or are subject to the Directive or another adequacy finding. We may also share
certain information (including user’s IP address and the identification details with our third
party network providers that provide content delivery network services. Our content delivery
network providers enable the delivery of digital content users have requested, e.g. when using
Website, by using a system of distributed servers that deliver the content to users, based on
users’ geographic location.
We may share user information to ensure current functioning of business processes, such as
to process transactions, maintain accounts, respond to court orders and legal investigations or
report to credit bureaus. We may make such disclosures as follows:
● With any party you intend to distribute funds to, or that intends to distribute funds to
you via the Company services.
● With vendors, wallets and other service providers who need access to your
information to carry out work on our behalf.
● To report suspected illegal activity, or to investigate violations of or enforce our user
agreements or other policies and agreements.
● If Company is under a duty to disclose or share your information to comply with its
We do not share user’s Personal data with third parties for any reason except for the reasons
described above or unless this is required by the law.
We neither provide Services, nor process Personal data of children. We will not knowingly
collect Personal data from children under the age of 18 (eighteen) year old. Insofar as certain
countries apply a higher age of consent for the collection of Personal Data. We encourage
parents to instruct their children to never give out personal information when online.
10. Users’ rights and choices
With respect to Personal data procession the users have the following rights:
● The “right to information” – user has the right to request COMPANY for information
about what Personal data (about him or her) is being processed and the rationale for such
processing. For example, user may ask for the list of processors with whom his or her
Personal data is shared.
● The “right to access” - user has the right to get access to his or her Personal data that
is being processed. This request provides the right to see or view user’s own Personal data, as
well as to request copies of such data.
● The “right to withdraw Consent” - user has right to withdraw a previously given
Consent for processing of his or her Personal data.
● The “right to be forgotten” – users have the right to ask COMPANY for the deletion
of their Personal data. Upon receiving such request, user’s Personal data shall be deleted
without undue delay (unless personal data is stored in accordance with the law).
● The “right to rectify” – users have the right to rectify inaccurate Personal data without
● The “right to object” – user has the right to object to the processing of his/her
● The “right to object automated procession” - user has the right to object to a decision
based on automated processing. Using this right, a user may ask for his or her request to be
reviewed manually, because he or she believes that automated processing may not consider
the unique situation of user.
● The “right for data portability” - user has the right to ask for transfer of his or her
Personal data. As part of such request, user may ask for his or her Personal data to be
provided back (to him or her) or transferred to another controller. When doing so, the
personal data must be provided or transferred in a machine-readable electronic format.
In case user wishes to exercise any of the aforementioned rights, he or she shall contact Us
(contact details below).
11. Contact details
Users can contact Our data protection officer at the address below:
email: [email protected]
Where appropriate, We will notify You of the changes when You next visit Our Website.