Privacy Policy

Purpose for Collecting Personal Information

To provide platform services to Users, Test Stem collects certain personal information for the purposes set out below. That information will be used only for those purposes and not for any other reason. If the purpose of use changes, we will take appropriate steps, such as notifying Users or obtaining additional consent as required by applicable laws.

Account Setup and Management

User identification, customer verification (Test Stem), management of user data and delivery of notifications

Account termination via non-face-to-face authentication, resetting contact details such as phone numbers and email addresses

Supply of Goods or Services

Confirmation of digital-asset trading relationships

Inheritance and Transfer Management

Comprehensive management of digital asset trading relationships, including onboarding, ongoing maintenance and service termination

Protection against unauthorised use

Analysing usage statistics to deliver new, tailored services

Continuous improvement and optimisation of platform services

Event Details and Promotions

Providing information on events and promotional offers

Handling Complaints

Verifying complainants' identities and complaint details

Contacting users for fact‑finding and notifying them of processing results

Resolving Transaction Errors and Damages

AML/CTF and Legal Investigations

Verifying complainants' identities and complaint details

Collaboration with law enforcement agencies on investigations.

Terminology

For the purposes of this Agreement (the 'Agreement'), the Platform is referred to as 'we', 'us' or 'our'. Users and other visitors to the Platform are referred to as 'you', 'your' or 'User'. 'We' and 'you' are collectively referred to as 'both parties' and individually as 'a party'.

Processing and Retention Periods for Personal Information

We will process and retain your personal information for as long as required by law, or for the period agreed when it was collected from you.

Cooperation with law enforcement agencies during investigations.

As a general rule, we retain your personal information for 18 months after you delete your account or if it is deactivated for misuse. This allows time for any reviews by financial institutions or investigations by relevant authorities. If no such reviews or investigations take place, we will permanently delete your data at the end of this period.

If there is an ongoing investigation into a legal violation, we will retain your information until the investigation concludes.

If you have any outstanding debt or credit arising from your use of our services, we will retain your information until the balance is settled.

Scope of Application

This Agreement applies to all Users trading on the Test Stem Global website and mobile app (the 'Platform'). Users must comply with the terms and conditions set out in this Agreement and with applicable laws and regulations governing personal information and data protection in their respective country or region.

Invocation

Any reference in this Agreement to codes, statutory decrees or administrative regulations means the most recently amended version, regardless of whether the amendment took place before or after the Agreement was signed.

Headings

Headings in this Agreement are for convenience only and must not be used to interpret its terms and conditions. Any reference to statements, terms, conditions, annexes or schedules refers to those within this Agreement.

Use of the Term: What It Includes

In this Agreement, the word 'include' shall be understood to mean 'include but not limited to', unless expressly stated otherwise.

Information Collected

Users acknowledge that the Platform may use cookies to monitor activity and collect information, including but not limited to IP addresses, geographical locations and other relevant data. For example, video (including audio) footage may be used to verify the identity of P2P merchants and to serve as evidence in P2P order disputes. Additionally, facial video (including audio) may be used for Test Stem identity verification on third-party platforms..

Limitation of Liability

While the Platform implements technical and security measures to protect your information, we cannot guarantee that data transmitted over the internet will be completely secure. Consequently, we cannot guarantee the security of the personal information you provide and cannot be held liable for any loss or damage resulting from unauthorised access to your personal data.

Amendments to this Agreement

We reserve the right to update this Agreement at any time. If we make changes to the Privacy Policy, we will post the updated version, including the new effective date and details of the changes. In some cases, we may also notify you directly. Please review the Privacy Policy regularly. Continued use of the Platform after changes are made constitutes acceptance of the updated terms.

Official Announcements

We will issue official announcements only via the valid contact details you have provided or by posting them directly on the Platform. We are not liable for any losses arising from reliance on information obtained by other means.