Privacy Policy

1. Introduction

Thank you for visiting offcode.pro. The legal entity responsible for OffCode.pro, acting as data controller, issues this Privacy Policy to describe its practices for collecting, storing, using, sharing, disclosing, and otherwise processing Personal Data.

By accessing or using offcode.pro, its application programming interfaces, mobile applications, and related interfaces, collectively the “OffCode.pro Platform,” you: (a) represent that you have the right, capacity, and authority to accept this Privacy Policy; (b) confirm that you have read and understood it; and (c) agree to the practices described where consent is the applicable legal basis.

This Policy explains which data we collect, why we collect it, how we use and store it, with whom it is shared, the rights you may have, and how to contact us about privacy practices. If you do not want your Personal Data processed as described, you should not use the OffCode.pro Platform, technology, products, or functionality, collectively the “Services,” subject to processing necessary to comply with law or exercise legal rights.

2. Definitions

“Data Protection Officer” means the data-protection officer or privacy contact designated by the entity responsible for OffCode.pro.

“Digital Asset” means an asset based on cryptographic computer-network protocols, whether centralised or decentralised, closed or open source, that may be used as a means of exchange or store of value and may also be known as a virtual financial asset, convertible virtual currency, cryptocurrency, virtual currency, digital currency, digital commodity, or digital-payment token, such as Bitcoin or Ethereum.

“Personal Data” means information relating to an identified or identifiable natural person, directly or indirectly, including through data linkage or an identifier such as a name, voice, image, identification number, online identifier, geographic location, or physical, psychological, economic, cultural, or social characteristic. It does not include effectively anonymised information that cannot reasonably be used to reidentify a person.

“Sensitive Information” or “Sensitive Personal Data” means information that reveals or permits an inference concerning racial or ethnic origin, political or philosophical opinions, religious beliefs, trade-union membership, criminal records where protected by law, genetic or biometric data, health, sex life, sexual orientation, or another sensitive category defined by Applicable Law.

“Processing” means any operation performed on Personal Data, including collection, production, receipt, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation, modification, communication, transfer, dissemination, or extraction.

3. Personal Data We Collect, Hold, and How We Collect It

OffCode.pro collects, processes, and stores Personal Data through use of the Services for performance of a contract, compliance with legal or regulatory duties, protection of the Platform, permitted legitimate interests, and, where applicable, your consent.

Data may include contact information, copies of identity documents supplied by you or obtained from publicly accessible databases and authorised providers, government identification numbers, and device or connection data such as IP address and MAC address.

We collect information supplied during registration or login whether the process is completed, incomplete, or abandoned, to the extent necessary for security, fraud prevention, support, and continuation of registration. We also collect data when you contact customer support, subscribe to marketing, communicate by telephone, email, or another channel, or conduct Transactions.

We may collect, use, store, or transfer:

• identification data, including name, email address, telephone number, nationality, date of birth, address, government documents, and government identifiers;
• institutional data, including legal company name, registration information, government identifiers, proof of identity and legal existence, address, business description, and ultimate-beneficial-owner information;
• commercial data, including information relating to Transactions conducted on the OffCode.pro Platform;
• financial information, including bank information and, where applicable, credit- or debit-card information, subject to security and data-minimisation requirements;
• communication data, including customer-support interactions and survey responses;
• information required by regulators, licensing agencies, authorities, and consumer-protection bodies;
• technical identifiers, including device fingerprint, IP address, MAC address, and approximate or precise geolocation where necessary and legally permitted;
• authentication, security, fraud-prevention, log, session, and Account-event information; and
• records necessary for KYC, anti-money-laundering, counter-terrorist-financing, sanctions compliance, and Transaction monitoring.

We may also receive Personal Data from third parties such as electronic-verification services, references, marketing agencies, liquidity providers, financial institutions, public sources, and fraud-prevention providers. We take reasonable measures to require those parties to comply with applicable privacy laws.

Third parties may analyse Site traffic using Cookies as described in Section 12. Data collected through analytics may not be anonymous and may be associated with online identifiers.

We do not collect Sensitive Personal Data without a valid legal basis. Where consent is required, it will be requested specifically. Exceptions may apply where collection is authorised or required by law or necessary to prevent, investigate, or respond to suspected unlawful activity or serious misconduct.

If you do not supply required Personal Data, we may be unable to create or maintain your Account, provide Services, or properly respond to your request. Because of identity and compliance duties, OffCode.pro may not offer anonymous or pseudonymous use.

OffCode.pro processes data relating to individuals and entities in multiple jurisdictions and will apply the data-protection laws relevant to each Processing operation.

4. Unsolicited Personal Data

OffCode.pro may receive unsolicited Personal Data. Data that is unnecessary, unrelated to the purposes described in this Policy, or not lawfully retainable will be securely destroyed or anonymised where permitted.

If additional information is combined with data that OffCode.pro needs or is entitled to collect, it may be retained and protected to the same standard as other Personal Data. Information that is not combined and lacks a lawful basis for retention will be treated as unsolicited data.

5. Persons from Whom We Collect Personal Data

We may collect and hold Personal Data concerning, without limitation:

• Users of the OffCode.pro Platform and Services;
• prospective Users and persons who begin registration;
• representatives, Authorised Persons, and ultimate beneficial owners of Corporate Accounts;
• current or prospective service providers, suppliers, and partners;
• job applicants, employees, and contractors; and
• other third parties with whom OffCode.pro has legitimate contact.

6. How We Use and Disclose Personal Data

OffCode.pro uses Personal Data to administer, provide, protect, improve, and personalise the Services and comply with legal and regulatory obligations. It may also use data to communicate about products or Services offered by OffCode.pro or its partners where permitted and to address concerns, complaints, and disputes.

Personal Data may be used or disclosed for those primary purposes, compatible or related secondary purposes, and other cases authorised by law.

Sensitive Personal Data will be used and disclosed only for the purpose for which it was supplied, a directly related secondary purpose, or another purpose supported by a valid legal basis.

Specific purposes include:

• Providing the Services: creating and administering Accounts, authenticating Users, executing Transactions, processing transfers, providing functionality, and performing the Terms of Use. Financial information may be required for Fiat Currency transfers conducted by third-party providers.
• Detecting and preventing fraud: verifying identity, identifying suspicious behaviour, and preventing fraud, abuse, money laundering, terrorist financing, and sanctions evasion.
• Protecting Service security: processing device, session, network-address, and activity information to protect the Account, Users, and Platform.
• Customer support: understanding requests, verifying identity, resolving problems, and maintaining service records.
• Improving the Services: analysing use, fixing defects, developing features, testing performance, and improving User experience.
• Product marketing: identifying potentially relevant Services and sending communications under Section 11 and the User’s preferences.
• Consent: processing data for additional clearly described and accepted purposes.
• Other legitimate business purposes: auditing, accounting, analytics, loss prevention, risk management, legal defence, and other reasonably expected and permitted activities.

Processing without consent

Where consent is not the appropriate or required legal basis, OffCode.pro may process Personal Data based on:

• public interest: where necessary to protect a relevant public interest;
• legal proceedings: to commence, exercise, or defend rights in administrative, arbitral, judicial, or security-related proceedings;
• vital interests: where necessary to protect the life, integrity, or vital interest of the data subject or another person;
• performance of contract: where necessary to perform a contract with the User or take steps requested before entering into it;
• legal or regulatory obligation: where necessary to comply with a duty applicable to OffCode.pro; or
• legitimate interests: where permitted, necessary, and proportionate to the legitimate interests of OffCode.pro or a third party, taking into account the User’s reasonable expectations and rights.

Recipients of Personal Data

OffCode.pro may disclose Personal Data to:

• members of its corporate group, subsidiaries, parent entities, and entities under common control, including contractors, Affiliates, employees, and representatives who need access;
• service providers and third parties assisting with payments, support, analytics, information technology, Processing, infrastructure, security, storage, communications, and tax reporting;
• entities involved in financing, acquisition, merger, reorganisation, asset sale, dissolution, or another corporate transaction, subject to appropriate contractual protections;
• governmental, law-enforcement, judicial, tax, regulatory, or other parties in legal proceedings to comply with law, an order, a subpoena, or a valid governmental requirement;
• professional advisers, including lawyers, accountants, auditors, insurers, and consultants needed to satisfy obligations;
• KYC, AML, blockchain-analysis, Transaction-monitoring, credit-verification, fraud-prevention, and security-threat providers; and
• liquidity providers, financial institutions, and Fiat Service Providers necessary to execute requested operations.

Apart from the situations described in this Policy, OffCode.pro will not disclose Personal Data to another third party without a valid legal basis or reporting obligation. Links to third-party websites may lead to separate privacy policies for which OffCode.pro is not responsible.

A service provider processing data for OffCode.pro may use it only for the contracted purpose and must protect confidentiality and security and comply with Applicable Law. OffCode.pro will take reasonable contractual steps to impose those requirements.

OffCode.pro maintains standards intended to prevent money laundering, terrorist financing, and sanctions evasion. These standards may require due diligence and third-party data matching for identity verification, fraud prevention, Transaction monitoring, credit checking, and security.

7. How We Store and Retain Personal Data

OffCode.pro recognises the importance of protecting Personal Data and takes measures designed to prevent misuse, interference, loss, and unauthorised access, alteration, or disclosure.

Personal Data may be stored in databases owned or operated by OffCode.pro, its Affiliates, or third-party storage and infrastructure providers. Appropriate security controls and data-management standards will be applied.

Personal Data is retained only for as long as reasonably necessary to provide the Services, pursue legitimate business interests, establish or defend legal rights, and comply with legal and regulatory obligations. After an Account is closed, certain information may continue to be retained where required, including identification and due-diligence records required under anti-money-laundering laws.

After the applicable retention period ends, Personal Data will be deleted, securely destroyed, or anonymised unless another valid basis requires continued retention.

8. International Transfers of Personal Data

The group responsible for OffCode.pro operates globally. Personal Data may be stored or processed in a country where OffCode.pro, an Affiliate, or a service provider operates.

Personal Data may be transferred to a country other than the country in which it was collected. That country’s privacy or data-protection rules may differ. OffCode.pro will use the mechanisms and safeguards required by Applicable Law to provide protection consistent with this Policy.

In certain countries, courts, law-enforcement agencies, regulators, or national-security authorities may have a lawful right to access Personal Data. By using the Services, you acknowledge the international nature of Processing. That acknowledgement does not replace a legal basis, safeguard, or specific consent required by law.

Where the Brazilian General Data Protection Law (“LGPD”) applies, an international transfer will comply with the lawful transfer mechanisms recognised by the LGPD and the Brazilian National Data Protection Authority.

9. Access, Correction, Deletion, and Other Rights

Subject to legal exceptions, you may request:

• confirmation that Personal Data is being processed;
• access to and a copy of Personal Data;
• correction of incomplete, inaccurate, or outdated data;
• anonymisation, blocking, or deletion of unnecessary, excessive, or unlawfully processed data;
• deletion of data processed on the basis of consent, where applicable;
• portability where legally available and technically regulated;
• information about public and private entities with which Personal Data has been shared;
• information about the ability to withhold consent and the consequences;
• withdrawal of consent;
• objection to Processing based on grounds other than consent where Processing is unlawful;
• review of a decision made solely by automated Processing that affects your interests, where the law provides that right; and
• information about the criteria and procedures used for automated decision-making, subject to protection of commercial and industrial secrets.

OffCode.pro will seek to supply access or a response within 30 days after a valid request or within another period required by Applicable Law. If access is refused, OffCode.pro will provide a legally permitted reason.

Before responding, OffCode.pro may verify identity and request clarification about the information sought. Corrections will be made within a reasonable period when the request is shown to be accurate.

A deletion request may be refused where retention is necessary to comply with a legal or regulatory duty, perform a contract, prevent fraud, exercise legal rights, or pursue another lawful purpose.

Requests must be sent to [email protected] with the subject line “Data Enquiry Request.” Withdrawal of consent does not affect the lawfulness of Processing conducted before withdrawal or Processing based on another lawful ground.

10. Personal Data of Children

OffCode.pro does not knowingly provide Services to a person under 18 years old or seek to collect that person’s Personal Data. If OffCode.pro learns that it collected Personal Data from a person under 18, it will take reasonable steps to remove the information unless limited retention is necessary for security, fraud prevention, or legal compliance.

If you become aware that a person under 18 is using the Services, notify [email protected] so that OffCode.pro can investigate and prevent access.

11. Communications and Marketing

OffCode.pro will use Personal Data for direct marketing without consent only where Applicable Law permits, the data are not sensitive, the User reasonably expects the use, a simple opt-out method is provided, and the User has not asked OffCode.pro to stop.

Personal Data obtained from a third party will be used for marketing only where consent or another valid legal basis exists and a simple method of opting out is provided.

OffCode.pro may communicate company news, promotions, and information relating to its products and Services. It may share limited Personal Data with third parties that assist with marketing projects or message delivery under appropriate obligations.

A User may opt out of promotional communications at any time through the unsubscribe link or customer support. Opting out does not prevent transactional or essential communications concerning security, operational surveys, policy or terms updates, Account matters, or Service operation.

12. Cookies and Similar Technologies

When you visit www.offcode.pro, small amounts of data known as “Cookies” may be stored in your browser or device.

Cookies are used to improve experience, identify sessions, remember preferences, enable navigation between pages, avoid repeated entry of information, and recognise a return visit. They may also measure and analyse use patterns, improve functionality, satisfy regulatory and AML requirements, and protect Accounts by detecting unusual, suspicious, or potentially fraudulent activity.

You may block Cookies or receive alerts through browser settings or, where available, the consent-management panel. Blocking may limit functionality.

Session Cookies are created during navigation or interaction with a feature and are generally deleted when the browser closes. Persistent Cookies may remain until their expiry date or manual deletion.

Where required, the Platform must implement a Cookie-consent mechanism that distinguishes strictly necessary Cookies from analytical, functional, and advertising Cookies and prevents non-essential categories from loading before a valid User choice.

13. Information Security

OffCode.pro implements appropriate technical and organisational measures designed to reduce the risk of accidental loss, unauthorised access, alteration, disclosure, use, or destruction of Personal Data.

Measures may include encrypted Platform communications, two-factor authentication where applicable, periodic review of collection, storage, and Processing practices, security logging and monitoring, need-to-know access controls, segregation of duties, vulnerability management, backups, incident response, and contractual confidentiality duties for employees and suppliers.

No system is absolutely secure. If an incident occurs, OffCode.pro will take containment, investigation, remediation, and notification measures required by Applicable Law.

Questions about information security or security reports should be sent to the verified official security address with the subject line “Information Security Request.” Do not expose vulnerabilities, credentials, or Sensitive Personal Data through a public channel.

14. Contacting OffCode.pro About Privacy

For questions about this Policy, Processing of Personal Data, or exercise of privacy rights, email [email protected] with the subject line “Privacy Request” or “Data Enquiry Request,” as applicable.

When processing a request, OffCode.pro will verify the requester’s identity to ensure that the requester has authority to make it. Responses are free of charge unless Applicable Law permits a reasonable fee for a repetitive, manifestly unfounded, or excessively burdensome request.

Where required, the legal page must also identify the Data Protection Officer or privacy contact of the responsible legal entity and provide verified contact information.

15. Changes to This Privacy Policy

OffCode.pro may update this Policy by publishing a revised version on the Platform with a new effective date and version number.

Users will be notified of a material change through an appropriate method, and renewed consent will be requested where consent is the necessary legal basis. Continued access or use may indicate acknowledgement or acceptance only to the extent permitted by Applicable Law.

Users should periodically review the current Policy. OffCode.pro will preserve a history of versions previously accepted by Users.

16. Language

This Privacy Policy may be published in languages other than English. A translation is provided for convenience only. In the event of inconsistency or ambiguity, the English version prevails to the extent permitted by Applicable Law and without limiting mandatory rights of a data subject.