Privacy Policy

1. Introduction

Kotova ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website and use our cryptocurrency exchange and financial services.

By using our services, you agree to the collection and use of information in accordance with this policy. If you do not agree with our policies and practices, please do not use our services.

2. Data Controller

3. Information We Collect

Personal Information

We may collect the following types of personal information:

• Contact Data: Email address
• Financial Data: Wallet address, transaction ID
• Technical Data: IP address, browser type, device information, operating system
• Usage Data: Information about how you use our website and services

Kotova X API

If you use the Kotova X API, or place an order through an application that uses it, we also process:

• API Account Data: If you create an API key in your Kotova account: the key's public identifier, a one-way hash of the secret key and its last four characters (we never store the secret key itself), the version of the API Terms of Use you accepted and when, the times the key was created, last used and revoked, the reason for a revocation, and the IP address and browser from which the key was created. If you request a higher rate limit or commission: the current and the requested values, the website and the description of your use case that you provide, the IP address and browser from which you sent the request, and our decision. We also keep daily counts of your API requests, including requests refused under the rate limit.
• Quote and Order Data Received Through the API: If you request a quote or place an order through an application, website or service that uses the Kotova X API (an "Integrator"): the assets and amounts of the order, your receiving and refund addresses and memos, the Integrator through which you placed the order and its own reference for the order and, where the Integrator provides it, your IP address. We do not receive your name or email address from the Integrator.

4. How We Use Your Information

We use the collected information for the following purposes:

• Service Provision: To provide, operate, and maintain our cryptocurrency exchange services
• Transaction Processing: To process your cryptocurrency and fiat currency transactions
• Communication: To send you service updates, security alerts, and support messages
• Fraud Prevention: To detect, prevent, and address fraud and security issues
• Analytics: To analyze usage patterns and improve our services
• API Provision: To authenticate API requests, enforce rate limits and order limits, notify account holders when an API key is created, regenerated or deleted, review requests for a higher rate limit or commission and inform you of the decision, attribute orders placed through the API to the Integrator's affiliate profile, and detect and prevent abuse of the API

5. Legal Basis for Processing (GDPR)

Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal grounds:

• Contract Performance: Processing necessary to fulfill our contractual obligations to you
• Legitimate Interests: Processing for our legitimate business interests, such as fraud prevention
• Consent: Where you have given explicit consent for specific processing activities

Order data that an Integrator transmits to us is processed to execute the order you placed through the Integrator (Art. 6(1)(b) GDPR). Where the Integrator provides your IP address, we process it on the basis of our legitimate interests in meeting the requirements of liquidity providers that need it to quote or execute your order and in preventing fraud (Art. 6(1)(f) GDPR).

6. Data Sharing and Disclosure

We may share your personal information with:

• Liquidity Providers: Third-party exchanges, namely our partners, who execute your swap
• Third-Party Providers: Services such as block explorers, so that Kotova can display the transaction details of your swap
• IP Address for Liquidity Providers: Where a liquidity provider requires your IP address to quote or execute an exchange, for example to apply its own geographic restrictions, we pass it to that liquidity provider only (currently SideShift). That liquidity provider receives your IP address with each quote request, even if your order is then executed by another liquidity provider or no order is placed. For quotes and orders requested through the Kotova X API, this is the IP address provided by the Integrator, if any.
• Integrators: The Integrator through which you placed an order via the Kotova X API receives from us the order's status, amounts, addresses and transaction details, including any refund address or memo that you enter on the order page, for 90 days after the order is created. The Integrator may keep its own record of the order; it processes that data as a separate controller under its own privacy policy.

We do not sell your personal information to third parties for marketing purposes.

7. International Data Transfers

Your information may be transferred to and processed in countries outside of the European Economic Area (EEA). When we transfer data outside the EEA, we ensure appropriate safeguards are in place, such as:

• Standard Contractual Clauses approved by the European Commission
• Transfers to countries with adequate data protection laws
• Other legally approved transfer mechanisms

8. Data Retention

We retain your personal data only as long as necessary to provide our services and resolve disputes.

• Transaction records (wallet addresses, timestamps, amounts) become inaccessible in the interface and through the Kotova X API 90 days after the order is created and are permanently deleted from our database after 12 months. This does not apply to transaction records that are tied to a Kotova user account: they remain visible in the order history of that account, and are retained, for as long as the account exists. When the account is deleted, its transaction records are no longer tied to it and are treated like any other transaction record.
• Email addresses provided for order notifications are deleted together with the transaction record they belong to. The email address of a Kotova account is kept until the account is deleted.
• Technical data (IP addresses, device information) is not stored beyond the time needed to process the request that generated it, except that the IP address and browser of an active sign-in session are stored with that session, that our security records of certain actions, such as adding an email address to an order or saving an order to a Kotova account, contain the IP address and browser used, and as described below for the Kotova X API.
• API keys and API access requests are kept as a permanent record, including revoked keys and decided requests. The IP addresses and browser information stored with them are deleted when the account is deleted. Security records of the creation, regeneration and deletion of API keys and of API access requests, including the IP address and browser used, are kept as long as necessary to protect the account and to investigate abuse. Daily counts of API requests are kept for 35 days. The IP address of an end user received through the API is stored with the order's transaction record and deleted together with it.

You may request deletion of your transaction records at any time by contacting us at [Enable JavaScript]. Your privacy matters — we permanently erase all information that could identify you or connect your crypto address to other activities within 48 hours after you request its deletion.

9. Your Rights (GDPR)

Under the GDPR, you have the following rights:

• Right of Access: Request a copy of your personal data
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your data (subject to legal retention requirements)
• Right to Restrict Processing: Request limitation of data processing
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent

To exercise these rights, please contact us at [Enable JavaScript].

10. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Ensure proper functioning of our website
• Remember your preferences
• Analyze website traffic and usage patterns
• Enhance security

You can control cookie preferences through your browser settings. Note that disabling certain cookies may affect website functionality.

11. Security Measures

We implement appropriate technical and organizational measures to protect your personal data, including:

• Encryption of data in transit and at rest
• Secure access controls and authentication
• Regular security assessments and audits
• Employee training on data protection

While we strive to protect your data, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security.

12. Children's Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe we have collected data from a minor, please contact us immediately.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last updated" date. We encourage you to review this policy periodically.

14. Contact Us

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

15. Supervisory Authority

You have the right to lodge a complaint with a supervisory authority. In Hamburg, this is: