Privacy Policy

1. Introduction

Fexr ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use our platform, dashboard, APIs, and services (collectively, "Services").

Fexr operates as a technology services provider. We do not custody, manage, or have access to your private keys or virtual assets. This policy covers individual users of the trading platform, users of Fexr Markets pay-per-query intelligence, and business clients on the Enterprise plan.

2. Information We Collect

2.1 Information You Provide

• Account Information: Email address, username, and profile details when you create an account
• Wallet Information: Blockchain wallet addresses you connect to the platform (public addresses only — we never collect or store private keys or seed phrases)
• Transaction Data: Records of trades, swaps, deposits, withdrawals, and intelligence queries executed through the platform, as reflected in the audit log and public blockchain data
• Communications: Messages you send to us or other users through the platform

2.2 Enterprise Client Information

For business clients on the Enterprise plan, we may additionally collect:

• Entity Details: Company name, registration number, and authorised representative information
• Billing Information: Invoice contact details and payment records relating to the annual subscription
• Configuration Data: Watchlists, tracked assets, alert configurations, and API credentials set up for the purpose of delivering the intelligence services

2.3 Information Collected Automatically

• Device Information: Device type, operating system, and unique device identifiers
• Usage Data: Pages visited, features used, and time spent on the platform
• Log Data: IP address, browser type, and access times

3. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our technology services
• Deliver the trading interface, signals, market-intelligence reports, and Enterprise dashboard services
• Send technical notices, service updates, and support communications
• Respond to your comments, questions, and requests
• Monitor and analyse platform usage and performance
• Detect, investigate, and prevent fraudulent activity, Sybil behaviour, and other misuse of our Services
• Calculate and administer the platform fees disclosed in our Terms of Service, and bill Enterprise subscriptions
• Comply with applicable legal obligations

We use your transaction activity only to operate the platform, maintain the audit log, and calculate the fees disclosed in our Terms of Service (percentage-based trading and swap fees, per-query intelligence fees, and Enterprise subscriptions). We do not sell your transaction activity or use it for advertising.

4. Information Sharing

We do not sell your personal information. We may share information in the following circumstances:

• On-Chain Data: Blockchain transactions and wallet addresses are publicly visible by design on the relevant network — this is inherent to blockchain technology and not controlled by Fexr
• Service Providers: Third-party vendors who perform services on our behalf (e.g., hosting, monitoring, analytics), subject to appropriate data processing agreements
• Legal Requirements: When required by applicable law, regulation, or court order, or to protect the rights and safety of Fexr and its users
• Business Transfers: In connection with a merger, acquisition, or sale of all or part of our assets, subject to confidentiality obligations

5. No Sale of Transaction Data

Fexr does not sell, license, or otherwise monetise individual transaction data to financial institutions, data brokers, advertisers, or any other third parties. Our revenue comes from the platform fees disclosed in our Terms of Service — a percentage of trading fees, a percentage of swap fees, per-query intelligence fees paid via x402, and Enterprise plan subscriptions — not from your data. Aggregated, anonymised market statistics (such as leaderboard rankings, copy counts, and backtest results that publishers choose to display) are part of the product and are visible by design.

5A. On-Chain Compliance Infrastructure

Our infrastructure incorporates an automated, on-chain compliance firewall (powered by Chainalysis) that prevents sanctioned entities from interacting with the platform. This is not a manual review process — it is an automated, protocol-level enforcement mechanism that operates continuously and in real time. Sanctioned wallet addresses are blocked at the contract interaction layer, ensuring that neither Fexr nor its users inadvertently transact with restricted parties.

For a full technical explanation of how this works, see On-Chain Sanctions Screening in On The Record.

6. Data Security

We implement appropriate technical and organisational measures to protect your information against unauthorised access, loss, or disclosure. These measures include encryption in transit and at rest, access controls, and regular security reviews. However, no method of transmission over the Internet is 100% secure, and we cannot guarantee absolute security.

7. Your Rights

Depending on your location, you may have rights to:

• Access the personal information we hold about you
• Request correction of inaccurate or incomplete information
• Request deletion of your information, subject to legal retention requirements
• Object to or restrict certain processing activities
• Receive your information in a portable format

To exercise these rights, contact us at hello@fexr.io. We will respond within the timeframe required by applicable law.

8. Data Retention

We retain your information for as long as your account is active or as needed to deliver our Services. Enterprise client data is retained for the duration of the subscription and for such additional period as required by law or for legitimate record-keeping purposes. On-chain records are permanent by nature and outside our control. You may request deletion of your personal data at any time, subject to our legal retention obligations.

9. International Transfers

Your information may be transferred to and processed in countries other than your own. Where such transfers occur, we implement appropriate safeguards (such as standard contractual clauses) to ensure your information remains protected in accordance with this policy.

10. Children's Privacy

Our Services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected such information, we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on this page and updating the "Last updated" date. Continued use of our Services after changes are posted constitutes your acceptance of the revised policy.

12. Contact Us

If you have questions about this Privacy Policy or wish to exercise your data rights, please contact us at:

• Email: hello@fexr.io
• Website: fexr.io