PRIVACY POLICY

1. OVERVIEW

Marvelpay LTD, operating under the trading name “Marveltex”, is a distinguished crypto exchange company, duly registered under number 207812 725 and regulated by The Bulgarian National Revenue Agency. Holding a valid license number BB-253 for the provision of crypto exchange and wallet services, our company specializes in providing secure and efficient services for the conversion of digital currencies to FIAT currencies. As a dedicated transaction facilitator, Marvelpay LTD ensures a seamless and reliable platform for our valued clients in the ever-evolving world of cryptocurrency.

Company Information:

• Data Processor: Marvelpay LTD
• Company Code: 207812 725
• Address: Sredets district, “Tzar Ivan Asen II” Str. 12, Entrance B, fl. 2, ap. 4, Sofia, Bulgaria
• Regulatory Authority: The Bulgarian National Revenue Agency
• License Number: BB-253 for provision of crypto exchange and wallet services

This Privacy Policy pertains to Marveltex (referred to as “we,” “our,” “us,” or “Data Processor”) and outlines the purposes and legal grounds for the collection, processing, and sharing of personal data provided by you or gathered by us. It applies whenever you access our content and/or services, irrespective of the device used.

We are dedicated to adhering to relevant laws and regulations in Bulgaria, along with guidelines from regulatory authorities. Adequate technical and administrative measures have been implemented to protect collected data from loss, unauthorized access, and alteration. Data retention is limited to necessary periods. Our employees are bound by written agreements, refraining from disclosing accessed information to third parties, including details about website/social media account visitors.

Individuals below the age of 16 must refrain from providing personal data on our website or social media accounts. Persons under 16 must secure parental or guardian approval before providing personal information.

The definitions used in this Privacy Policy align with the General Data Protection Regulation No 2016/679 (EU).

Please thoroughly examine this Privacy Policy. By accessing our website marveltex.com, you are consenting to abide by the terms specified herein. If you do not agree with these terms, kindly refrain from visiting our website or utilizing our content and/or services.

2. COLLECTION METHODS FOR YOUR INFORMATION

2.1. Information Supplied by You

This includes data directly provided by you and information provided by individuals connected to you, your business, or those representing you. When applying for our products and services, you may supply personal data by filling out registration forms, submitting required documents, etc. Examples include:

• Registering on our website or installing our applications
• Communications via emails, letters, phone calls (including recorded calls)
• Subscriptions to newsletters or other communications
• Participation in surveys

We may collect your personal information if you are affiliated with our clients or potential clients who are legal entities—e.g., as a company director, shareholder, board member, ultimate beneficial owner (UBO), or authorized representative.

2.2. Automatically Collected Data

We collect data regarding your use of our services and account-related activity—examples include:

• Website usage via cookies and similar technologies
• Inquiries through our registration system or social media channels
• Payment and transaction details

We may also obtain data from third-party and publicly available sources—such as LinkedIn, Facebook, Twitter, Instagram, your company’s website, or through partners and marketing agencies—and combine it with data you’ve provided or other sources.

2.3. Additional Collection

On occasion, we may collect information not specifically mentioned here. In such circumstances, we will provide additional notification.

3. DATA PROCESSING PURPOSES AND LEGAL FOUNDATIONS

3.1. Processing Purposes, Legal Grounds, and Data Collected

Purpose

Legal Basis(s)

Personal Data Collected

Providing crypto–fiat exchange and wallet services

– Fulfillment of contractual obligations – Legal obligations – Legitimate interests – Your consent

Name, surname, payment details, payment method, card number, address, passport number, card expiry, service details, phone number, email, preferences, transaction identifiers, wallet data, timestamps

Purpose

Legal Basis(s)

Personal Data Collected

(for AML/KYC checks)

Responding to service inquiries

– Legitimate interests – Your consent – Contractual obligations

Phone number, email, other contact info

Marketing communications

– Legitimate interests – Additional explicit consent

Name, social media details, telephone number, email, interests

Market analysis, surveys, improvements, security

– Legitimate interests – Your consent

IP address, device info, session durations, cookie data, GPS/Wi-Fi data

Quality assurance and complaint handling

– Consent (e.g., for call recording)

Phone number, name, call timestamps, conversation content

Legal defense

– Legal obligations – Legitimate interests

Relevant personal data depending on the context

If you prefer not to receive marketing communications, you can opt out by emailing support@marveltex.com or using the opt-out link in our newsletters. If you do not consent to call recording, please contact us via email at support@marveltex.com instead.

For any processing beyond these purposes, we’ll notify you and, where required, obtain consent.

You have the right to refuse providing certain details (e.g., during registration), but doing so may limit your ability to register or access our services.

3.2. Additional GDPR Disclosures (for EU clients)

In accordance with GDPR, our legal processing bases include:

• Consent: You may withdraw this at any time.
• Legal Obligations: Necessary for legal compliance.
• Vital Interests: To protect your or another’s important interests in emergencies.

4. RETENTION PERIOD

We retain personal data only as long as needed to fulfill original purposes, unless laws require otherwise. Generally, data is kept for up to 5 years after your client relationship ends, then permanently deleted. Examples:

• Payment data: At least 5 years after the transaction
• Cryptocurrency transaction data: 5 years after client relationship ends (blockchain data may remain publicly available)
• Service-related personal data: 5 years post relationship
• Marketing data: 3 years from last website visit
• IT logs: several months
• Analytics: anonymized/aggregated on collection
• Call recordings: up to 3 years
• Correspondence: 5 years after client relationship ends
• Complaints: Up to 10 years

These are approximate ranges and subject to legal requirements.

5. DISCLOSURE OF PERSONAL INFORMATION

We may share your data with:

• Service providers essential for our operations or regulatory compliance
• Banks handling transactions
• Public authorities, regulatory bodies, courts, or investigation entities as needed
• Data processors (e.g., data centers, cloud providers, IT services, marketing, software developers, communications)

6. CROSS-BORDER DATA TRANSFER

When transferring data outside the EEA, we take appropriate measures, such as using EU-standard contractual clauses, binding corporate rules, or working with recipients in countries deemed adequate by the EU.

7. DATA SECURITY

We implement reasonable physical, technical, and administrative safeguards. However, no system can guarantee absolute security.

8. YOUR RIGHTS

You have these rights, subject to verification and legal limits:

• Right to Information: Clear explanation of data processing
• Right of Access: Confirm processing, request your data, understand processing purposes, data recipients, origins, profiling, storage duration

• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure (“Right to be Forgotten”): Under specific conditions (e.g., unnecessary data, consent withdrawn, unlawful processing)
• Right to Suspend Processing: Temporary halt during investigations (excluding storage)
• Right to Restrict Processing: Particularly for marketing
• Right to Object: Against certain processing including profiling
• Right to Data Portability: For data provided under consent or contract, processed automatically

To exercise rights, contact us at support@marveltex.com or via provided links in communications. Some legal obligations may limit these rights.

9. POLICY UPDATES

This Privacy Policy may be updated periodically. Each version will include the “Revised” date, effective upon publication. Significant changes will be highlighted on our site or communicated directly. Please review it regularly.

10. CONTACT US

If you notice inconsistencies, have security concerns, or questions about your personal data, contact us:

• Mailing Address: Marvelpay LTD, Sredets district, “Tzar Ivan Asen II” Str. 12, Entrance B, fl. 2, ap. 4, Sofia, Bulgaria
• Company Registration: Marvelpay LTD, registered under number 207812 725 with the Bulgarian National Revenue Agency. License number BB-253, for crypto exchange and wallet services
• Email: info@marveltex.com