PRIVACY POLICY
1. INTRODUCTION
This Privacy Policy (“Policy”) explains how Alteumx Internacional, S.A. (“Alteumx Internacional,” “we,” “our,” or “us”), in connection with the AlteumX and Waltrex brands, collects, uses, stores, discloses, and protects personal information when you access or use our websites, platforms, applications, APIs, products, or services (collectively, the “Services”).
AlteumX and Waltrex are brands within the same business ecosystem. This Policy applies to the Services offered under both brands, unless a separate privacy notice expressly applies to a particular service. Where another legal entity is responsible for a specific Service or acts as an independent controller, its identity and applicable privacy terms will be disclosed where required by law.
For purposes of this Policy, “you” or “your” refers to any individual whose personal information we process, including website visitors, prospective customers, representatives of business customers, account holders, and authorized users.
This Policy should be read together with any applicable service terms and cookie notice. Where consent is legally required, we will obtain it before carrying out the relevant processing.
2. PERSONAL INFORMATION WE COLLECT
The information we collect depends on how you interact with us and which Services you use. It may include:
a. Identification and contact information
Full legal name, business contact details, email address, telephone number, business address, date of birth where necessary, and information relating to your role or relationship with a business customer.
b. Account and verification information
Account registration and profile details; identity verification information and supporting documents where required; business registration, ownership, and authorized representative information; and information required for applicable customer due diligence, compliance, and risk assessment procedures.
c. Transaction and payment information
Transaction records, payment instructions, amounts, currencies, timestamps, and status information; relevant bank account details, payment identifiers, and beneficiary information; and digital asset wallet addresses, blockchain transaction identifiers, and related transaction data where applicable to the Services.
Payment information may be processed directly by us or by third-party providers involved in delivering the relevant Services.
d. Technical and usage information
IP address, browser type, device information, operating system, website pages visited, access times, referral URLs, interaction data, log files, diagnostic information, and information collected through cookies or similar technologies.
e. Communications and support information
Messages, inquiries, support requests, feedback, information provided during commercial discussions or account management, and records of communications where necessary for service delivery, security, or legal compliance.
We seek to collect only information that is relevant and necessary for the purposes described in this Policy.
3. HOW WE COLLECT PERSONAL INFORMATION
We may collect personal information directly from you when you contact us, complete a form, register an account, or use our Services; from the business or organization you represent; through identity verification, payment processing, compliance, and technology providers; through third-party platforms or integrations that you authorize us to access; automatically through website logs, cookies, and similar technologies; and from public or legally available sources where appropriate and permitted by applicable law.
Where we rely on information provided by another party, we take reasonable steps to use it for legitimate and authorized purposes.
4. PURPOSES AND LEGAL BASES FOR PROCESSING
We may process personal information to:
1. Create, administer, and maintain accounts and user profiles.
2. Provide, operate, and support our Services under the AlteumX and Waltrex brands.
3. Process service requests, payment instructions, transactions, and related business operations.
4. Verify identities, assess business relationships, and conduct applicable due diligence.
5. Prevent fraud, detect suspicious activity, protect our systems, and manage operational risks.
6. Communicate with users, respond to inquiries, and provide customer support.
7. Monitor, analyze, and improve the performance, security, and functionality of our Services.
8. Maintain business, operational, accounting, and transaction records.
9. Comply with applicable laws, regulations, court orders, and lawful requests from competent authorities.
10. Send service announcements and, where permitted, marketing communications about our products and services.
Depending on applicable law, our legal basis for processing may include your consent, the performance of a contract or pre-contractual steps, compliance with legal obligations, or our legitimate interests, provided those interests do not override your applicable rights.
Where processing is based on consent, you may withdraw that consent subject to applicable legal requirements. Withdrawal does not affect processing lawfully carried out before withdrawal.
5. COOKIES AND SIMILAR TECHNOLOGIES
Our websites may use cookies and similar technologies to operate properly, remember preferences, analyze traffic, improve functionality, and support security.
Where required by law, we will request your consent before using non-essential cookies or similar technologies. You may manage cookies through available website settings or your browser. Disabling certain cookies may affect website functionality.
Additional information about specific cookies and their purposes may be provided in a separate Cookies Policy.
6. SHARING AND DISCLOSURE OF PERSONAL INFORMATION
We may disclose personal information to the following categories of recipients, where necessary and legally permitted:
a. Within the AlteumX and Waltrex business ecosystem
We may share information between the applicable entities, affiliates, subsidiaries, and teams responsible for operating, administering, securing, and supporting the Services offered under the AlteumX and Waltrex brands. Such sharing will be limited to legitimate business purposes and subject to applicable privacy requirements.
b. Service Providers and Business Partners
We may share information with providers supporting our technology infrastructure, hosting, analytics, customer support, identity verification, compliance, payment processing, security, and other operational functions. These providers may process information on our behalf or, where applicable, act as independent controllers under their own privacy policies.
c. Financial Institutions and Transaction Counterparties
Where necessary to provide a requested service or process a transaction, we may share relevant information with banks, payment processors, liquidity providers, digital asset service providers, blockchain analytics providers, and other participating institutions or counterparties.
d. Legal and Regulatory Authorities
We may disclose information where required by applicable law, regulation, legal proceedings, or a lawful request from a competent authority, or where disclosure is otherwise legally permitted to protect our rights, users, or operations.
e. Corporate Transactions
Information may be disclosed in connection with a merger, restructuring, acquisition, financing, or sale of all or part of our business, subject to applicable confidentiality and data protection requirements.
We do not authorize third parties to use personal information entrusted to them on our behalf for purposes unrelated to their authorized services, except as permitted by law.
7. INTERNATIONAL DATA TRANSFERS
Because our Services may involve technology providers, financial institutions, and business partners operating in different countries, personal information may be transferred to or accessed from jurisdictions other than the country in which it was collected.
Where required by applicable law, we will implement appropriate safeguards and satisfy the relevant requirements for international data transfers.
8. DATA SECURITY
We maintain administrative, technical, and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, loss, or misuse. These measures are intended to reflect the nature of the information processed and the risks associated with our Services.
However, no method of electronic transmission or storage can be guaranteed to be completely secure.
9. DATA RETENTION
We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Policy, provide our Services, maintain appropriate business and transaction records, resolve disputes, enforce agreements, and comply with applicable legal or regulatory obligations.
Retention periods may vary depending on the type of information, the nature of the relevant service, and applicable legal requirements.
When information is no longer required, we will take appropriate steps to delete it, anonymize it, or otherwise dispose of it securely, subject to applicable retention obligations.
10. YOUR PRIVACY RIGHTS
Depending on your location and applicable law, you may have the right to request access to your personal information; request correction or updating of inaccurate or incomplete information; request deletion, subject to legal retention requirements; object to or request restrictions on certain processing activities; request a copy of your information in a portable format where applicable; withdraw consent where processing is based on consent; opt out of marketing communications; and lodge a complaint with the competent data protection authority.
To exercise your rights, please contact us using the details provided in Section 14. We may request reasonable information to verify your identity before responding. We will handle requests within the time limits and in accordance with the procedures established by applicable law.
11. MARKETING COMMUNICATIONS
We may send information about our products, services, updates, or business activities where permitted by applicable law. Where prior consent is required, we will obtain it before sending marketing communications.
You may opt out of marketing emails at any time by following the unsubscribe instructions included in the communication or contacting us directly. Opting out of marketing will not prevent us from sending necessary service-related or transactional communications.
12. THIRD-PARTY WEBSITES AND SERVICES
Our websites or Services may contain links to third-party websites, platforms, or integrations. Those third parties may collect and process information under their own privacy policies and terms.
We are not responsible for the privacy practices of third-party services that we do not control. We encourage you to review their applicable privacy notices before providing personal information.
13. CHANGES TO THIS POLICY
We may update this Policy from time to time to reflect changes in our Services, business operations, technology, or legal requirements.
The revised Policy will be published on the applicable website with an updated “Last Updated” date. Where required by law, we will provide additional notice or obtain consent before implementing material changes.
14. CONTACT US
If you have questions about this Policy or wish to exercise your privacy rights, please contact us:
Legal Entity:
Alteumx Internacional, S.A.
Email:
support@alteumx.com
Registered Address:
P.H. Proconsa 1, Corregimiento de Bella Vista, Distrito y Provincia de Panamá, 8709
Please include sufficient information for us to understand your request. We may contact you to verify your identity or clarify the scope of your inquiry.
15. GOVERNING LAW
This Policy shall be interpreted in accordance with the laws of the Republic of Panama, subject to any mandatory data protection laws that apply to the processing of your personal information.
Nothing in this Policy limits any privacy rights that cannot lawfully be excluded or waived under applicable law.
Last Updated: October 2026