Paxful Privacy Notice

PXF Global Corp. d/b/a Paxful (also referred to as "Paxful," "we," "us," or "our") takes steps to protect your privacy. In this Privacy Notice ("Notice"), we describe the types of personal information we may collect from you in connection with your access to our websites, including but not limited to https://withdraw.paxful.com/ (the "Website"), or when you use our limited wind-down services (the "Limited Services").

This Notice is designed to help you understand our privacy practices during this wind-down period. Our Service offerings are limited and do not vary by region.

For all purposes, the English language version of this Privacy Notice shall be the original, governing instrument. In the event of any conflict between the English language version and any subsequent translation into any other language, the English language version shall govern and control.

Personal Information We Collect

We collect information that relates to you ("Personal Data") in connection with your access to the Website, our Services, or otherwise in the context of our relationship with you during the wind-down. The types of Personal Data that we may obtain from you may include:

Biographical Data, including:

• Name
• Email Address
• Phone Number
• Country
• Full Address
• Date of Birth

Paxful Account Details, including:

• Username
• User Profile Information in the "Bio" section
• Profile Picture
• Joined Date
• Default Currency
• Time Zone
• Default Language
• Your Communication History with us, our support teams.

Paxful Account Activity, including:

• Transaction and trading History including history of trade communications
• Account Status
• Withdrawal Requests

Data Relating to Your Digital Asset Wallet, including:

• Public Keys
• Wallet Balance
• Transactions Received/Sent (historical only)

Data Collected in Connection with Know Your Customer (KYC) Compliance for Withdrawals, including:

• Government-Issued ID
• Proof of Address
• Photographs or Video, if you provide them to us for verification

Device and Website Usage Data, including:

• IP Addresses
• Cookie ID and/or other device identifiers
• Information relating to your access to the Website, such as device characteristics, date & time
• Language preferences
• Information on actions taken while accessing the Website (e.g., login attempts, withdrawal submissions)

Mobile Application Usage Data, including:

• Session data: IP address, version of the operating system, brand and model of the device, unique identifiers of the device, browser used, information about the time the Application was accessed, name and parameters of the network connection (for security and fraud prevention during withdrawals).

We do not collect new trade-related data (e.g., chat messages, offers, or affiliate information) as trading services are discontinued.

How We Use Your Data

The business purposes for which we collect, use, retain, and share your Personal Data during the wind-down are limited to:

To Provide Limited Services through Operating the Website, including to:

• Maintain your existing account for withdrawal purposes;
• Authenticate your identity and access to your account for verification;
• Facilitate and process withdrawals of Digital Assets;
• Communicate with you regarding your account, withdrawals, or wind-down notifications;
• Perform KYC or other compliance reviews required for withdrawals;
• Compare information for accuracy and verification purposes.

To Manage Risk and Protect You, Other Persons, and the Services.

This includes fraud detection and preventing unauthorized access during withdrawals.

To Comply with Our Policies and Obligations, including but not limited to Disclosures and Responses in Response to Any Requests from Law Enforcement Authorities and/or Regulators in Accordance with Any Applicable Law, Rule, Regulation, Judicial or Governmental Order, Regulatory Authority of Competent Jurisdiction, Discovery Request, or Similar Legal Process.

This is essential for sanctions compliance and escheatment of dormant assets.

To Resolve Disputes, Troubleshoot Problems, or Provide Customer Service Related to Withdrawals.

To Manage Our Business During Wind-Down.

This includes internal operations to conclude services responsibly.

We do not use Personal Data for marketing, personalized promotions, or analytics beyond what's necessary for the wind-down. We may also process Personal Data for other purposes based upon our legitimate business interests or your consent when required by applicable law.

Sources from Which We Collect Personal Data

We collect Personal Data from:

• Directly from you: When you access the Website, submit withdrawal requests, or communicate with us.
• From service providers and/or data processors: Who assist in verification, processing withdrawals, or security at our direction.
• From third-parties: Who help verify identity, prevent fraud, or comply with legal obligations (e.g., sanctions screening).

We no longer collect data from other users, affiliates, or social media interactions related to trading.

How We Share Data

Under limited circumstances during the wind-down, we may disclose Personal Data to:

• Service providers and/or data processors: To perform functions on our behalf, such as identity verification, withdrawal processing, or customer support.
• Financial institutions: Involved in facilitating withdrawals.
• Other third-parties for business or legal purposes:
  • To comply with legal, regulatory, or contractual obligations (e.g., court orders, subpoenas, or sanctions reporting);
  • To establish, exercise, or defend legal claims;
  • In response to government agency requests (e.g., law enforcement);
  • To enforce our User Agreement or internal policies;
  • To prevent harm or financial loss in investigations of illegal activity;
  • To support audit, compliance, and wind-down functions (e.g., potential business transfer if applicable).

We do not share Personal Data with other transaction parties, affiliates for marketing, or nonaffiliates for any purpose beyond compliance and wind-down operations.

International Transfers of Data

We may transfer Personal Data to countries other than the country in which it was collected, including to affiliates or service providers in Panama or elsewhere. Those countries may not have the same data protection laws. When we transfer Personal Data, we take steps to ensure compliance with applicable law, such as standard contractual clauses and legally binding data Transfer Agreements in line with relevant data protection laws.

Cookies and Online Advertising

Our Website uses cookies and tracking technologies for essential functions Including security, analytics, fraud detection and prevention, traffic management, authentication and session management. For more information, refer to our Cookie Policy.

You can control cookies at the browser level, but rejecting them may limit access to withdrawal features.

Data Retention

We retain Personal Data only for the period necessary for wind-down purposes (e.g., processing withdrawals) or as required by applicable law 57 years from last transaction or account closure (jurisdiction-specific). Following completion of withdrawals or legal requirements, we will delete or anonymize your Personal Data. Dormant accounts may be subject to escheatment as unclaimed property.

Data Security

We have implemented safeguards to protect Personal Data against loss, misuse, and unauthorized access. However, no system is completely secure, and transmission over the Internet carries inherent risks.

Children Under 18 Years of Age

The Website and Services are not intended for children under 18. We do not knowingly collect data from children under 18. If we learn of such a collection, we will delete it immediately. Please report Underage use of Paxful to privacy@paxful.com

Modifications to the Privacy Notice

We may update this Notice for legal reasons or to reflect wind-down changes. We will notify you by email or prominent notice on the Website. Continued access signifies acceptance.

Contact Us

For questions about this Notice or privacy inquiries, contact us at privacy@paxful.com.

EEA Addendum

The following applies exclusively to individuals in the European Economic Area (EEA).

Data Controller: PXF Global Corp.

Legal Bases for Processing Personal Data:

• Contractual obligations (Art. 6(1)(b) GDPR) for withdrawals.
• Legal obligations (Art. 6(1)(c) GDPR) for compliance.
• Vital interests (Art. 6(1)(d) GDPR) if applicable.
• Legitimate interests (Art. 6(1)(f) GDPR) for risk management and wind-down activities.

European Data Protection Rights:

You have rights to access, rectification, erasure, portability, objection, restriction, and withdrawal of consent. To exercise, contact us at privacy@paxful.com. We may verify identity and respond within legal timelines. Lodge complaints with legal@paxful.com in the first instance, if we are unable to resolve your complaint you have the right to refer it to a national or state supervisory authority.

International Transfers: Safeguards include EU Standard Contractual Clauses. Contact us for copies.

California Addendum

The following applies exclusively to California residents.

Your California Privacy Rights:

Under CCPA, you have rights to know, delete, and opt-out of sales (we do not sell data). For direct marketing disclosures, contact privacy@paxful.com.

Do Not Track Disclosure: We do not respond to "Do Not Track" signals.

California Privacy Notice (GLBA Summary):

Questions? Go to www.paxful.com.

Definitions:

• Affiliates: Companies related by common ownership or control (e.g., under PXF Global Corp.).
• Nonaffiliates: Companies not related (e.g., service providers for verification).
• Joint Marketing: Formal agreements for marketing (none currently).

Other Important Information:

• We may transfer data internationally for compliance.
• California: We do not share beyond permitted uses for wind-down.
• Vermont: We do not share with nonaffiliates without authorization.

Data Controller / Contacts

Controller: PXF Global Corp. Panama, Contact: legal@paxful.com