Privacy Policy

1. INTRODUCTION

Coingalaxy Pty Ltd (“Coingalaxy”, “we”, “our”, or “us”) is committed to protecting your personal information and complying with applicable data protection and privacy laws. In Australia, this includes the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). In Europe, we comply with the General Data Protection Regulation (EU) 2016/679 (GDPR), and in Mexico, we comply with the Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP).

This Privacy Policy sets out our approach to the collection, use, storage, disclosure, and protection of your personal data. It also explains your rights and how you can access or correct your data, or lodge a complaint.

This Policy operates in conjunction with our Terms of Service. Copies of this Policy are available free of charge on our website (coinreserve.net) or by contacting our Privacy Officer.

In this Policy:

2. WHAT KINDS OF PERSONAL INFORMATION DO WE COLLECT AND HOLD?

We may collect a wide range of personal information including:

Failure to provide required data may result in limited access to our services.

3. HOW DO WE COLLECT PERSONAL INFORMATION?

We collect personal data directly from you, including when:

We may also collect information from third-party providers such as:

Where we collect data from third parties, we take reasonable steps to notify you and confirm your consent if required.

Sensitive data will only be collected with your consent unless an exemption applies under applicable law.

4. COOKIES AND ONLINE TRACKING

Our website uses cookies and similar tracking technologies. These help:

You can manage cookie settings via your browser. Disabling cookies may affect your user experience.

5. UNSOLICITED PERSONAL INFORMATION

If we receive personal data that we did not actively request:

6. WHO DO WE COLLECT PERSONAL INFORMATION ABOUT?

We may collect information about:

7. WHY DO WE COLLECT PERSONAL INFORMATION?

We use your personal information for purposes including:

We do not use personal data for purposes inconsistent with the reason it was collected, unless permitted by law or with your explicit consent (as required under GDPR and LFPDPPP).

8. WHO DO WE DISCLOSE PERSONAL INFORMATION TO?

Your data may be disclosed to:

Where disclosure occurs outside Australia, the EU, or Mexico, we take appropriate safeguards (e.g., Standard Contractual Clauses or equivalent agreements) to ensure data protection compliance.

9. INTERNATIONAL DATA TRANSFERS

We may transfer data across jurisdictions, including to Southeast Asia, Europe, and Mexico. When doing so, we ensure:

10. HOW WE SECURE YOUR PERSONAL INFORMATION

We take robust technical and organizational security measures to protect data, including:

11. DIRECT MARKETING

We may contact you for direct marketing only where:

You may also request:

12. MAINTAINING YOUR PERSONAL INFORMATION

We aim to ensure your data is accurate and current. You may:

13. ACCESSING YOUR PERSONAL INFORMATION

You may request access to your personal data at any time. We will:

14. UPDATES TO THIS POLICY

We may amend this Policy in response to changes in law, operations, or data processing practices. We encourage regular review of our privacy practices. Where required by GDPR or LFPDPPP, we will notify you of significant changes and seek your renewed consent where necessary.

15. OUR RESPONSIBILITIES

Management ensures:

16. COMPLAINTS AND CONTACT INFORMATION

For privacy inquiries or complaints, please contact our Privacy Officer at: support@coinreserve.net

If unresolved, you may escalate your complaint to:




Risk Disclosure Statement

Coingalaxy Pty Ltd ("We", "Us", "Our", "Coingalaxy", the "Company") is authorised and registered with the Australian Transaction Reports and Analysis Centre (AUSTRAC). In addition, Coingalaxy complies with regulatory obligations and consumer protection standards in the European Union (under directives such as MiFID II, the GDPR, and EMD2) and Mexico (as required by the Ley Fintech, the Financial Consumer Protection Bureau (CONDUSEF), and relevant CNBV guidelines).

IMPORTANT – PLEASE READ CAREFULLY

This Risk Disclosure Statement ("Statement") is a general overview of risks associated with the financial products and services provided by Coingalaxy. This Statement is not intended to be legal, financial, or investment advice. Coingalaxy makes no representation that the investments or services described herein are appropriate for you. This Statement should not be the sole source of your decision-making.

Before engaging with our platform, services, or products, you should assess the potential risks and obtain independent professional advice appropriate to your circumstances. Investing in financial instruments, including digital assets and derivatives, involves risks that may result in partial or total loss of capital.

GENERAL RISK FACTORS

REGULATORY AND LEGAL RISKS

Different jurisdictions impose varying legal obligations. Regulatory changes, currency controls, and nationalisation can affect investments. In the EU, MiFID II mandates clear risk disclosures and consumer protections. In Mexico, the Ley Fintech and CNBV circulars establish rules for fintech operations and investor protection. Coingalaxy complies with these frameworks to the extent applicable.

TAX RISK

Tax treatment of digital assets and financial products may vary by jurisdiction and change over time. In the EU, local tax laws and DAC7 reporting obligations may apply. In Mexico, SAT regulations govern income reporting. You should consult a qualified tax professional.

SUSPENSIONS OF TRADING

Market volatility may cause delays, halts, or suspensions of trading, limiting your ability to buy or sell assets. Stop-loss orders may not be effective in extreme conditions.

OPERATIONAL AND TECHNOLOGICAL RISKS

System outages, cyberattacks, and technological failures may interrupt access to your account or delay trade execution. Coingalaxy maintains redundancy systems, but risk cannot be entirely eliminated.

INTERNET AND ONLINE ACCOUNT SECURITY

Online platforms carry inherent security risks. You are responsible for securing your account credentials. Any communication or transaction via the internet is at your own risk.

CONFLICTS OF INTEREST

We may face actual or perceived conflicts of interest. Please refer to our Conflicts of Interest Policy for details on mitigation and management.

PRODUCT-SPECIFIC RISKS

MARKET DISRUPTION EVENTS AND EARLY TERMINATION

Market disruption events may lead to valuation delays, suspension of trading, or early termination of instruments. These are defined under ISDA protocols or as per issuer terms.

FINAL STATEMENT

This Statement is intended to fulfil our disclosure obligations under applicable Australian, European, and Mexican law. We encourage you to read this alongside our Terms of Service, Privacy Policy, and other regulatory documents available on our website.

If you have questions or require clarification, contact us at support@coinreserve.net.




Conflicts of Interest Policy

Coingalaxy Pty Ltd (ABN 50 643 368 496) (“Coingalaxy”, “We”, “Us”, or “Our”) is an AUSTRAC-registered Digital Currency Exchange provider. This Conflicts of Interest Policy (“Policy”) sets out our commitment to the fair treatment of clients and to upholding integrity in all jurisdictions in which we operate.

Purpose

The purpose of this Policy is to outline how Coingalaxy identifies, manages, and discloses any actual or potential conflicts of interest arising during the course of its business activities. The Policy ensures compliance with relevant regulatory requirements in each jurisdiction and preserves the transparency and fairness of our services.

Scope

This Policy applies to Coingalaxy, its directors, officers, employees, contractors, agents, and any other person directly or indirectly linked to the Company. It is applicable across all investment and financial services offered by the Company.

Conflicts may arise:

  • Between Coingalaxy and a client;
  • Between employees and clients;
  • Between one client and another client.

    • Framework for Conflict Management

    Coingalaxy has adopted internal systems and procedures to ensure that conflicts of interest are properly identified, assessed, and mitigated. Where conflicts cannot be entirely prevented, they must be disclosed clearly to affected clients.

    The Company:

  • Maintains effective organisational and administrative arrangements to manage conflicts;
  • Discloses conflicts in a durable medium when mitigation measures are insufficient;
  • Reviews this Policy at least annually and updates it as necessary in response to regulatory, operational, or structural changes.

    • Identification of Conflicts

    Conflicts of interest may include (but are not limited to):

  • A relevant person gaining financial benefit at the client’s expense;
  • Competing interests between services provided and client outcomes;
  • Preferential treatment given to certain clients over others;
  • Insider knowledge being used to inform personal or Company-level trading activities.

    • A “relevant person” includes:

  • Directors, officers, partners, or agents of the Company;
  • Employees or tied agents directly involved in financial or investment services;
  • Contractors or outsourced service providers carrying out regulated functions.

    • All employees and management are required to report actual or potential conflicts to the Compliance Officer (CO) without delay.

    Management and Mitigation Measures

    Coingalaxy applies the following practices to manage conflicts:

  • Independent Compliance function overseeing conflict management;
  • Documentation of identified conflicts and their mitigation;
  • Client interests are always prioritised;
  • Separation of functions and teams where conflicts may occur;
  • Disclosure to clients where full mitigation is not possible;
  • Restriction on personal account dealings and approval requirements;
  • Restrictions on employee accounts at third-party brokers;
  • Enforcement of trading blackout periods where applicable;
  • Mandatory training and annual declarations by staff.

    • Specific Controls

    To prevent and manage conflicts, the Company has implemented:

  • Segregation of duties across conflicting roles;
  • Firewalls and data access restrictions;
  • Prohibition of front-running and insider dealing;
  • Two-person (“four-eyes”) review processes;
  • CO pre-approval of marketing and promotional materials;
  • Restriction on gifts and inducements;
  • Monitoring of personal and proprietary trading;
  • Periodic audits and policy reviews.

    • Segregation of Assets

    To protect client funds and assets, Coingalaxy:

  • Maintains separate records for client and Company funds;
  • Prevents co-mingling and enforces account separation;
  • Ensures client assets are protected in insolvency scenarios;
  • Maintains client-by-client ledgers and accounting controls.

    • Prohibited Business Conduct

    The following conduct is strictly prohibited:

  • Manipulation of financial instruments for benefit of the Company or employee;
  • Misuse or disclosure of confidential client transaction data;
  • Engaging in trades before publication of proprietary research;
  • Preferential treatment of internal parties over clients;
  • Use of inside information for personal gain.

    • Employee Obligations

    All employees must:

  • Avoid engaging in prohibited practices;
  • Promptly report concerns to the CO;
  • Seek guidance when uncertain about potential conflicts;
  • Disclose outside financial interests or personal investments;
  • Submit personal trades for review and approval.

    • Disclosure Requirements

    When organisational arrangements are not sufficient to fully mitigate risks, Coingalaxy will:

  • Provide clear and timely disclosure in a durable medium;
  • Describe the nature, source, and risks associated with the conflict;
  • Allow the client to make an informed decision about proceeding;
  • Decline to proceed with services if the conflict poses unmanageable risk.

    • Disclosures by Employees and Management

    Employees and management must disclose:

  • The opening or closing of personal brokerage accounts;
  • Personal trades within 24 hours of execution;
  • Securities held or conflicts related to Company activity;
  • Any beneficial interest in Company-executed transactions.

    • Compliance Review and Oversight

    The Compliance Officer is responsible for:

  • Reviewing all conflict disclosures;
  • Monitoring adherence to this Policy;
  • Providing conflict training;
  • Advising senior management and the Board on issues;
  • Ensuring international compliance obligations are met.

    • This Policy remains subject to regulatory updates and guidance issued by AUSTRAC, the European Securities and Markets Authority (ESMA), and the financial authorities in each relevant operating jurisdiction.