PRIVACY POLICY

Last updated: 01.07.2026

1. General Provisions

1.1. This Privacy Policy sets out how “UNITRADE INTERNATIONAL” LLC, which operates the OurExchangeClub platform, collects, processes, retains, uses, transfers and protects Users’ personal data.

1.2. This Policy applies when a User visits the ourexchange.club Website, registers on the Website, creates a user account, undergoes identification, creates a request for a Transaction to purchase or sell Crypto-assets, uses the Company’s services or communicates with the Company in any way.

1.3. This Policy forms an integral part of the OurExchangeClub Terms of Use. By registering on the Website, undergoing identification, creating a Transaction request or using the services, the User confirms that they have read this Policy and accept the terms governing the processing of personal data.

1.4. The Company processes personal data in accordance with the laws of the Republic of Armenia, including applicable requirements concerning the protection of personal data, Crypto-assets, prevention of money laundering and terrorist financing, taxation, accounting and other applicable legal requirements.

1.5. The Company may process a User’s personal data to provide services, identify the User, conduct Transactions, make payments and transfers, assess risks, conduct compliance checks, fulfil legal obligations, ensure security, resolve disputes and protect the Company’s legitimate interests.

1.6. If the User disagrees with any provision of this Policy, the User must not register on the Website, undergo identification, create a Transaction request or use OurExchangeClub services.

1.7. Terms used but not specifically defined in this Policy have the meanings given to them in the OurExchangeClub Terms of Use.

2.Types of Personal Data Processed

2.1. The Company may collect and process the User’s personal data that are necessary for use of the Website, User registration and identification, creation and execution of Transactions, making payments and transfers, compliance checks, security and fulfilment of legal obligations.

2.2. The Company may process the User’s registration and contact details, including first name, surname, patronymic, date of birth, citizenship, residence or location, email address, telephone number and other contact details.

2.3. The Company may process the User’s identification details, including the type and number of an identity document, its issue and expiry dates, details of the issuing authority, copies of the document, photographs, video recordings, selfies and the results of facial comparison, liveness checks or equivalent checks.

2.4. The Company may process the User’s biometric or equivalent identification data to the extent necessary to verify the User’s identity, prevent fraud, carry out identification or comply with applicable legal and compliance requirements.

2.5. For legal entity Users, the Company may process the legal entity’s registration details, constitutional or registration documents, address, tax or registration number, and information about its director, representatives, authorised persons, participants, shareholders and beneficial owners.

2.6. The Company may process payment and financial data, including bank account details, bank card details, EasyWallet details, EasyPay payment details, payment method, amount, purpose and time, proof of payment, receipts, and bank or payment documents.

2.7. The Company may process data relating to Crypto-assets and blockchain transactions, including Crypto Wallet Addresses, blockchain networks, transaction hashes, transfer amounts, type of Crypto-asset, blockchain confirmation details, time of transfer or receipt, and the results of a Crypto Wallet Address risk assessment or blockchain analysis.

2.8. The Company may process Transaction data, including the type and amount of the Transaction, exchange rate, tariffs, fees, selected payment or transfer method, Transaction statuses, time of creation and execution of the Transaction, changes to the Transaction, and details of rejection, suspension, cancellation or return.

2.9. The Company may process risk assessment and compliance data, including the User’s risk profile, information on the purpose of a Transaction, details of the origin of funds and income, details of the origin of Crypto-assets, and the results of sanctions, politically exposed person (PEP), anti-money laundering and counter-terrorist financing (AML/CFT), fraud prevention or other compliance checks.

2.10. The Company may process technical and device data, including IP address, device type, browser details, operating system, date and time of access, cookies, session details, user account access history, security logs and other technical data relating to use of the Website.

2.11. The Company may process communication data, including the User’s applications, complaints, enquiries, correspondence, electronic messages, telephone or messaging service communications, submitted documents, responses and other communications.

2.12. The Company may process data relating to cash operations, including the fact, amount, date and location of a cash payment or receipt, a partner organisation’s report, receipts, records, signatures, video recordings or other data evidencing the cash operation.

2.13. If a referral system operates on the Website, the Company may process data relating to it, including referral links and codes, the referring User’s identifier, the fact of the invited User’s registration or Transaction, the time of registration or Transaction, details needed to calculate a referral reward or other incentive, and technical and Transaction data needed to detect abuse of the referral system, false registrations, duplicate accounts, self-referrals or other fraud risks.

2.14. The Company may also receive data about the User from third parties, including SumSub, banks, payment service providers, partner organisations, blockchain analysis services, public or private registers, open sources or competent authorities, to the extent permitted by law.

2.15. The Company does not request or process data unnecessary for the provision of services, identification, execution of Transactions, legal obligations, security, compliance or protection of the Company’s legitimate interests, except where processing such data is required by law or a lawful request from a competent authority.

2.16. The User must provide the Company with accurate, complete and up-to-date data. Providing incorrect, incomplete, outdated or misleading data may result in rejection of registration, failure to approve identification, suspension, cancellation or rejection of a Transaction, or restricted access to services.

3.Purposes of Processing Personal Data

3.1. The Company processes the User’s personal data for clear, lawful and specific purposes, to the extent necessary to provide OurExchangeClub services, operate the Website properly, execute Transactions, fulfil legal obligations, ensure security and protect the Company’s legitimate interests.

3.2. The User’s personal data may be processed to register the User, create and manage a user account, communicate with the User and enable use of the Website’s functions.

3.3. Personal data may be processed to identify the User, verify their identity, validate documents, conduct liveness checks, prevent fraud and assess the User’s legal capacity or authority.

3.4. Personal data may be processed to accept, check and confirm requests for Transactions to purchase or sell Crypto-assets, and to execute, amend, suspend, reject, cancel, return and record the associated Transactions.

3.5. Personal data may be processed to accept payments in Armenian drams, transfer funds, service Transactions by bank account, bank card, EasyWallet, EasyPay terminal or cash, check payment documents and establish proof of payment.

3.6. Personal data may be processed to carry out Crypto-asset transfers; check Crypto Wallet Addresses; and record blockchain networks, transaction hashes, confirmations and the transfer or receipt of Crypto-assets.

3.7. Personal data may be processed to prevent money laundering and terrorist financing, carry out sanctions checks, identify politically exposed persons, assess risks, detect suspicious Transactions, prevent fraud and comply with other compliance requirements.

3.8. Personal data may be processed to verify the origin of the User’s funds, income and Crypto-assets, the purpose of a Transaction, the beneficial owner, payment source, ownership or control of a Crypto Wallet Address and other material circumstances.

3.9. Personal data may be processed for the Company’s accounting, tax, financial and internal recordkeeping, auditing, preparation of reports and fulfilment of applicable legal obligations.

3.10. Personal data may be processed to secure the Website, user accounts, Transaction environment, technical systems, payment processes and means of communication, and to prevent or respond to unauthorised access, technical failures, cybersecurity incidents and suspicious activities.

3.11. Personal data may be processed to respond to the User’s applications, enquiries, complaints, requests or messages, and to send the User Transaction-related, technical, legal, compliance or security notices.

3.12. Personal data may be processed to operate a referral system; establish a referral relationship; calculate, record, pay or provide referral rewards or other incentives; fulfil tax and accounting obligations; and prevent and detect abuse of the referral system, false registrations, duplicate accounts, self-referrals, fraud or other suspicious activities.

3.13. Personal data may be processed to resolve disputes, examine claims, preserve evidence and protect the rights and legitimate interests of the Company, Users, partners or third parties.

3.14. Personal data may be processed to comply with lawful requests from competent state authorities, courts, regulators, law enforcement agencies or other competent persons.

3.15. The Company does not use the User’s personal data for purposes incompatible with the purposes established by this Policy, the Terms of Use or applicable law.

4.Legal Grounds for Processing Personal Data

4.1. The Company processes the User’s personal data only where, and to the extent that, there is a legal ground for processing under this Policy, the Terms of Use and applicable law.

4.2. Personal data may be processed on the basis of the User’s consent when the User registers on the Website, accepts the Terms of Use and this Policy, undergoes identification, provides documents or data, creates a Transaction request or continues to use OurExchangeClub services.

4.3. Personal data may be processed to establish or perform contractual relations between the User and the Company, or to take pre-contractual steps, including creating a user account; accepting, checking, confirming and executing a Transaction request; and making payments and Crypto-asset transfers.

4.4. Personal data may be processed to fulfil the Company’s legal obligations, including those relating to identification, prevention of money laundering and terrorist financing, sanctions checks, accounting, taxation, reporting, data retention, responding to lawful requests from competent authorities and other applicable requirements.

4.5. Personal data may be processed to protect the Company’s legitimate interests, including securing the Website and services, preventing fraud, managing risks, checking Transactions, preserving evidence, resolving disputes, defending claims and protecting the rights and legitimate interests of the Company, Users, partners or third parties.

4.6. Personal data may be processed to protect the rights, legitimate interests or safety of the User or others where such processing is necessary to prevent or respond to unauthorised access, fraud, security incidents, suspicious activities or other risks.

4.7. Where processing is based on the User’s consent, the User may withdraw that consent in accordance with the procedure established by the Company, unless continued processing is necessary on another legal ground. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

4.8. The User acknowledges that providing certain personal data is necessary to use OurExchangeClub services, undergo identification, create a Transaction request or execute a Transaction. If those data are not provided, the Company may decline to approve registration, not complete identification, decline to accept or execute a Transaction, or restrict access to services.

4.9. If several legal grounds for processing apply at the same time, the Company may continue processing data on the ground applicable to the particular purpose, type of data and circumstances of processing.

4.10. The Company does not process the User’s personal data without a legal ground or use them for purposes incompatible with those established by this Policy or applicable law.

5.Disclosure of Personal Data to Third Parties

5.1. The Company may transfer or make the User’s personal data available to third parties only where, and to the extent that, this is necessary for the proper operation of the Website, User identification, execution of Transactions, making payments and transfers, compliance checks, security, fulfilment of legal obligations or protection of the Company’s legitimate interests.

5.2. The User’s personal data may be transferred to identification and verification service providers, including SumSub, to verify the User’s identity, check documents, conduct liveness checks, prevent fraud and comply with compliance requirements.

5.3. The User’s personal data may be transferred to banks, payment service providers, the ArCa system, EasyPay, EasyWallet or other participants in the payment infrastructure to accept payments, transfer funds, verify payments, make returns, prepare payment documents or resolve payment disputes.

5.4. The User’s personal data may be transferred to a partner organisation engaged by the Company for the acceptance, collection and disbursement of cash, identification, recordkeeping, security, documentation and evidentiary purposes.

5.5. The User’s personal data may be transferred to providers of blockchain analysis, risk assessment, sanctions, PEP, anti-money laundering and counter-terrorist financing, fraud prevention or other compliance services to assess the risk associated with Transactions and Crypto Wallet Addresses.

5.6. The User’s personal data may be transferred to technical service providers and providers of hosting, server, software, information security, communication, email, SMS or other technical services to ensure the proper operation and security of the Website and services and enable communications.

5.7. The User’s personal data may be transferred to the Company’s legal, accounting, tax or financial advisers, auditors or other professional service providers for accounting, tax, legal, audit, dispute resolution, defence of claims or advisory purposes.

5.8. The User’s personal data may be transferred to competent state authorities, courts, law enforcement agencies, regulators, tax authorities or other competent persons if the transfer is required by applicable law, a lawful request from a competent authority or a judicial act, or is necessary to protect the rights and legitimate interests of the Company, Users, partners or third parties.

5.9. The Company transfers to third parties only the personal data necessary for the specific purpose of the transfer and does not transfer data beyond what is necessary to provide the relevant service, comply with a legal requirement or protect a legitimate interest.

5.10. Processing of the User’s personal data by third parties may be governed by their privacy policies, terms or applicable law if they act as independent data processors or persons subject to separate legal obligations.

5.11. The Company takes reasonable measures to ensure that service providers and partners it engages process personal data securely, for specified purposes and lawfully, to the extent within the Company’s control.

5.12. The User agrees that engaging third parties and transferring data may be necessary to use OurExchangeClub services, undergo identification, conduct Transactions, make or receive payments, and comply with legal and compliance requirements.

6.International Transfers of Personal Data

6.1. The User’s personal data may be transferred to, or made available to, third parties located outside the Republic of Armenia to provide OurExchangeClub services, conduct identification, provide technical support, process payments, carry out compliance checks, ensure security or fulfil legal obligations.

6.2. An international transfer may take place, in particular, where the Company uses foreign identification, technical, hosting, information security, communication, blockchain analysis, risk assessment, payment, legal, accounting or other professional services.

6.3. The User’s personal data may be transferred to SumSub or other foreign identification and verification service providers to verify the User’s identity, check documents, conduct liveness checks, prevent fraud and comply with compliance requirements.

6.4. International transfers are made only to the extent necessary for the specific purpose of the transfer, and the Company does not transfer the User’s personal data beyond what is necessary to provide a service, comply with a legal requirement or protect the Company’s legitimate interests.

6.5. The Company takes reasonable measures to ensure that personal data transferred internationally are processed securely, for specified purposes and lawfully, taking into account the purpose of the transfer, type of data, nature of the recipient and applicable legal requirements.

6.6. The User acknowledges that some service providers located outside the Republic of Armenia may operate under different legal rules and that the use of those services may entail different conditions for data processing under the provider’s jurisdiction, privacy policy or applicable law.

6.7. If the User’s consent is required for an international transfer of personal data, the User’s registration on the Website, completion of identification, creation of a Transaction request or use of services may be regarded as consent to that transfer, to the extent that the transfer is necessary to provide services, conduct identification, execute Transactions or comply with legal requirements.

6.8. If the User does not want their personal data transferred outside the Republic of Armenia, they may refrain from using services for which such a transfer is necessary. In that case, the Company may decline to approve registration, not complete identification, decline to accept or execute a Transaction, or restrict access to services.

7.Personal Data Retention Periods

7.1. The Company retains the User’s personal data for as long as necessary for the purposes for which they were collected or processed, and for as long as required by applicable law, legal obligations, compliance requirements, and accounting, tax, security, dispute resolution and evidentiary purposes.

7.2. Data relating to the User’s registration, user account, identification, Transactions, payments, Crypto-asset transfers, documents, communications, blockchain data and compliance checks may be retained throughout the relationship with the User and after it ends for periods required by law, internal policies or protection of legitimate interests.

7.3. The Company may retain identification and verification data, including copies of identity documents, photographs, video recordings, selfies, liveness check results, and biometric or equivalent verification data, for as long as necessary to evidence identification, fulfil legal obligations, ensure compliance and security, resolve disputes and respond to requests from competent authorities.

7.4. Transaction data, payment documents, blockchain transaction hashes, Crypto Wallet Address details, Transaction status history, and details of returns, rejections, suspensions or cancellations may be retained for as long as necessary for accounting, tax, legal, compliance, anti-money laundering and counter-terrorist financing, security and evidentiary purposes.

7.5. Communication data, complaints, applications, enquiries, responses, notices and other messages may be retained for as long as necessary to respond to User enquiries, resolve disputes, protect the Company’s rights and fulfil legal or compliance obligations.

7.6. Technical and security data, including IP addresses, device details, access history, session details, cookies and security logs, may be retained for as long as necessary for Website security, prevention of unauthorised access, fraud detection, investigation of technical failures and evidentiary purposes.

7.7. If retention of personal data is no longer necessary for the purposes set out in this Policy, applicable law, legal obligations or protection of the Company’s legitimate interests, the Company may erase or anonymise the data or otherwise restrict their processing.

7.8. A User’s request to close a user account or cease using the services does not mean that the Company must immediately erase all personal data if continued retention is necessary under law or for accounting, tax, legal, compliance, security, dispute resolution, evidentiary or legitimate interest purposes.

7.9. The Company may retain certain data for a longer period if there is an incomplete Transaction, unresolved dispute, request from a competent authority, legal proceeding, compliance check, security incident or other substantiated need.

7.10. Data retention periods may differ depending on the type of data, purpose of processing, legal requirements, nature of the Transaction, the User’s risk profile and the Company’s internal policies.

8.User Rights

8.1. The User has the rights provided by law concerning the processing of their personal data to the extent applicable to the particular data, purpose of processing, legal ground and the Company’s legal obligations.

8.2. The User may contact the Company to request information on whether it processes their personal data, which data are processed, for which purposes, on what legal grounds, for how long and to whom they may be transferred.

8.3. The User may request correction, completion or updating of their personal data if they are incorrect, incomplete or outdated.

8.4. The User may request restriction or cessation of processing of their personal data if the request complies with applicable law and does not impede the Company’s fulfilment of its legal, compliance, accounting, tax, security, dispute resolution or evidentiary obligations.

8.5. The User may request erasure of their personal data if retaining them is no longer necessary for the purposes of processing and the Company has no legal ground or legitimate need to retain them further.

8.6. The User acknowledges that certain data cannot be erased, or their processing cannot be stopped, immediately if their retention or processing is necessary to comply with applicable law, anti-money laundering and counter-terrorist financing requirements, tax and accounting obligations, evidencing Transactions, dispute resolution, security or lawful requests from competent authorities.

8.7. The User may withdraw consent where the processing of personal data is based exclusively on consent. Withdrawal does not affect the lawfulness of processing carried out before withdrawal or limit the Company’s right to continue processing on another legal ground if one exists.

8.8. The User may object to processing of their personal data where such an objection is permitted by applicable law and does not conflict with the Company’s legal obligations or legitimate interests.

8.9. A request to exercise User rights must be submitted through the Website or official communication channels specified in this Policy, subject to adequate identification and a clear statement of the nature of the request.

8.10. The Company may request additional identification, documents or information to ensure that the request has been submitted by the User concerned or a duly authorised person.

8.11. The Company examines the User’s request within a reasonable period, taking into account its nature, the extent of the action requested, the type of data, legal obligations, and security and compliance requirements.

8.12. The Company may reject the User’s request in whole or in part if it conflicts with applicable law, legal obligations, requirements of a competent authority, the rights of others, the Company’s legitimate interests, security or compliance requirements, or if the request is manifestly unfounded, excessive or repetitive.

8.13. If the User believes that their personal data have been processed unlawfully or their rights have been violated, they may contact the Company to clarify and resolve the matter and use other remedies provided by law.

9.Data Security

9.1. The Company takes reasonable technical, organisational and administrative measures to protect the User’s personal data against unauthorised access, use, alteration, loss, destruction, disclosure or other forms of unlawful processing.

9.2. Data security measures may include access restrictions, controls over identification and permissions, technical logging, security monitoring, limiting access to data on a need-to-know basis, confidentiality obligations for employees and other persons engaged, and other appropriate measures.

9.3. The Company limits access to personal data to those employees, representatives, service providers, partners or other authorised persons who need the data to perform their functions, provide services, execute Transactions, conduct compliance checks, ensure security or fulfil legal obligations.

9.4. The Company takes reasonable measures to ensure that service providers and partner organisations it engages process personal data securely, for specified purposes and lawfully, to the extent necessary to perform their functions.

9.5. Despite the measures taken, the User acknowledges that use of the internet, blockchain networks, payment systems, electronic communication channels, third-party technical systems and Crypto Wallet services may involve security risks and that the Company cannot guarantee their absolute security.

9.6. The User must independently maintain the confidentiality and security of their user account, passwords, email, telephone number, two-factor authentication methods, devices, SIM card, Crypto Wallet, payment instruments and other means of access or security.

9.7. The User must promptly notify the Company if they suspect unauthorised use, loss or disclosure of their user account, personal data, passwords, devices, email, telephone number, payment or Crypto Wallet details, or another security incident involving them.

9.8. Where a security incident, unauthorised access, data breach, fraud or another risk is suspected, the Company has the right to temporarily restrict access to the user account, suspend Transactions, require additional identification, change security procedures or take other necessary measures to protect the rights and legitimate interests of the User, Company, other Users or third parties.

9.9. The Company is not liable for unauthorised access, data breaches, Transactions or losses arising from the User’s failure to safeguard their access details, devices, email, telephone number, two-factor authentication methods, Crypto Wallet or payment instruments properly, unless they resulted from the Company’s intentional conduct or culpable act proven in accordance with law.

9.10. The Company may retain security logs, access history, IP addresses, device details, technical information and other relevant data for security, fraud prevention, incident investigation, dispute resolution and evidentiary purposes.

10.Cookies and Technical Data

10.1. The Company may use cookies, session data, log files and other technical means to operate the Website properly, ensure security, improve the User experience, identify technical problems, conduct analysis and provide services properly.

10.2. Cookies are small data files that may be stored on the User’s device or in their browser and used to operate the Website, remember User preferences, maintain user account security, manage sessions or conduct technical analysis.

10.3. The Company may process technical data, including IP address, device type, browser type and version, operating system, date and time of access, pages visited, actions taken on the Website, session data, security logs and other technical information relating to use of the Website.

10.4. Cookies and technical data may be used for the following purposes:

a) ensuring the proper operation of the Website and user account;

b) maintaining the User’s authenticated session;

c) ensuring security and preventing unauthorised access;

d) detecting fraud, suspicious activities or technical incidents;

e) analysing and improving the Website’s operation;

f) investigating technical errors, failures or capacity problems;

g) fulfilling legal, compliance and evidentiary purposes.

10.5. Some Website functions may depend on mandatory or technically necessary cookies. Disabling those cookies may cause the Website, user account, identification or Transaction functions to operate improperly or become unavailable.

10.6. The User may restrict or delete certain cookies through browser or device settings but acknowledges that doing so may affect the availability, security or functions of the Website or services.

10.7. The Company may use third-party technical, analytical, security or communication tools that may process cookies or technical data to the extent necessary for the Website’s operation, security, analysis or provision of services.

10.8. Cookies and technical data are processed for the purposes set out in this Policy and are not used for purposes incompatible with the operation of the Website, provision of services, security, compliance or protection of the Company’s legitimate interests.

10.9. The Company may retain information relating to cookies and technical data for as long as necessary for Website operation, security, technical analysis, fraud prevention, dispute resolution, evidentiary purposes or fulfilment of legal obligations.

10.10. If a referral system operates on the Website, the Company may use referral links and codes, cookies, URL parameters, session data or other technical means to identify the source of a User’s registration or Transaction, establish the referral relationship, and calculate, record and monitor referral rewards or other incentives.

10.11. Within the referral system, the Company may process data such as the referral code and link, the referring User’s identifier, the fact of the invited User’s registration or Transaction, time of registration, Transaction activity, data needed to calculate a reward, and technical and Transaction data needed to detect abuse of the referral system, false registrations, self-referrals, duplicate accounts or other fraud risks.

10.12. Data received or processed through the referral system may be used only to operate the referral system; calculate and record rewards; fulfil tax or accounting obligations; prevent fraud; ensure security and compliance; and protect the Company’s legitimate interests.

11.Automated Checks and Risk Assessment

11.1. To provide OurExchangeClub services safely, lawfully and properly, the Company may conduct automated or semi-automated checks on Users, Transactions, payments, Crypto-asset transfers, Crypto Wallet Addresses and other data.

11.2. Automated or semi-automated checks may be carried out for User identification, document validation, liveness checks, fraud prevention, sanctions checks, identification of politically exposed persons, prevention of money laundering and terrorist financing, risk assessment and compliance with compliance requirements.

11.3. The Company may use internal systems, SumSub or other third-party technological solutions, blockchain analysis tools, risk assessment services, open sources, registers, payment or bank data and other permissible sources to assess the risk profile of a User or Transaction.

11.4. Automated or semi-automated checks may produce risk assessments, alerts, compliance notes, technical or Transaction indicators that may be used to assess User registration, identification, a Transaction request, payment, Crypto-asset transfer or access to services.

11.5. Based on the results of automated or semi-automated checks, the Company may request additional documents, information or explanations, extend the verification period, restrict access to the user account or services, or suspend, cancel or reject a Transaction or move it to the return stage, in accordance with the Terms of Use and applicable law.

11.6. The Company’s use of automated or semi-automated checks does not mean that decisions are always made solely by automated means. Where necessary, the Company may conduct further manual examination, review documents or make an internal compliance assessment.

11.7. The Company is not obliged to disclose to the User all internal rules, algorithms, criteria or risk models used in risk assessment, complete results of third-party checks or security procedures if disclosure could impair the effectiveness of its compliance system, fraud prevention, AML/CFT controls, sanctions risk management, security measures or third-party rights.

11.8. The User acknowledges that automated or semi-automated checks are necessary to provide OurExchangeClub services safely and lawfully, check Transactions, reduce risks, fulfil legal obligations and protect the Company’s legitimate interests.

11.9. If the User does not agree to necessary automated or semi-automated checks, the Company may decline to approve registration, not complete identification, decline to accept or execute a Transaction, or restrict access to services.

12.Amendments to the Policy and Contact

12.1. The Company has the right to amend, supplement or update this Privacy Policy at any time, taking into account legislative changes, development of services, changes to Website functions, technical or organisational needs, security requirements, compliance requirements or the Company’s internal policies.

12.2. The amended Privacy Policy is published on the Website or made available to the User through another official communication channel designated by the Company.

12.3. Amendments take effect upon publication on the Website or on another date specified in the amended Policy, unless applicable law requires otherwise.

12.4. The User must regularly review the current version of the Privacy Policy. Continued use of the Website, user account or OurExchangeClub services after amendments constitutes acceptance of the amended Policy by the User.

12.5. If the User does not agree with the amended Policy, they must cease using the Website and services and may contact the Company to discuss matters relating to their user account or personal data in accordance with law and this Policy.

12.6. The User may contact the Company through the official contact channels specified on the Website about the processing of personal data, privacy, exercise of User rights, correction, erasure or restriction of data, or other matters.

12.7. Official communications with the Company concerning personal data protection may be made using the following details:

a) Website: ourexchange.club

b) Email: info@ourexchange.club,

c) Telephone: +374 94 048 044,

d) Location / registered address: Republic of Armenia, Yerevan, 0002, Tumayan 31/3:

e) Address for complaints, applications and official communications: privacy@ourexchange.club

12.8. Messages sent by the User through unofficial communication channels, social networks, personal messaging services or third parties may not be regarded as official requests concerning the protection of personal data unless the Company has expressly accepted them as official communications.

12.9. The Company may require additional identification or documents from the User to ensure that a request concerning personal data has been submitted by the User concerned or a duly authorised person.

12.10. The Armenian version of this Policy is the primary and prevailing version. In the event of any conflict, difference or discrepancy in interpretation between the Armenian version and translations into English, Russian or any other language, the Armenian version shall prevail.