1. Introduction
MSX FinTech Holding Limited ("MSX," "Company," "we," "us," or "our") respects your privacy and is committed to protecting your personal information.
This Privacy Policy describes how we collect, use, process, store, share, and protect personal information when you access or use the MSX Pro mobile application, website, and related products and services (collectively, the "Services").
MSX Pro is a financial technology platform that provides access to digital asset-related services, financial market information, trading functionality, account management, and related features, subject to applicable laws and geographic restrictions.
By accessing or using our Services, you acknowledge that you have been provided with this Privacy Policy. Where required by applicable law, we will obtain your consent before processing personal information for specific purposes.
We encourage you to read this Privacy Policy carefully.
2. Geographic Restrictions
MSX Pro does not offer or provide Services to persons located in or residing in:
Mainland China
Hong Kong Special Administrative Region
Countries or territories subject to applicable economic or financial sanctions
Other jurisdictions where the provision of our Services would violate applicable laws or regulatory requirements
Our Services are available only in jurisdictions where we are legally permitted to provide them.
We may use identity verification, geographic information, IP address analysis, and other compliance measures to enforce these restrictions.
We reserve the right to restrict, suspend, or terminate access to our Services where necessary to comply with applicable laws, regulatory obligations, or our internal compliance policies.
3. Information We Collect
We may collect personal information directly from you, automatically through your use of our Services, or from authorized third-party service providers.
3.1 Personal Identification Information
We may collect:
Full legal name
Date of birth
Nationality and country of residence
Residential or mailing address
Email address
Telephone number
Government-issued identification information
Account registration and authentication information
This information is used to establish and maintain user accounts, verify identities, provide Services, and satisfy applicable legal and regulatory requirements.
3.2 Identity Verification and KYC Information
To comply with applicable Know Your Customer (KYC), Anti-Money Laundering (AML), sanctions screening, fraud prevention, and other compliance requirements, we may collect and process:
Passport or government-issued identification documents
Identification numbers and document details
Photographs of identification documents
Selfies and facial images
Identity verification results
Biometric information used for identity verification, where applicable
Information concerning the source of funds or source of wealth, where required
Other information reasonably necessary for regulatory compliance
We use Sumsub, a third-party identity verification provider, to assist with identity verification, document authentication, facial verification, and compliance screening.
Sumsub may process personal information and biometric information as necessary to perform identity verification services, subject to applicable data protection laws and contractual safeguards.
Where required by law, we will provide appropriate notices and obtain any necessary consent before collecting or processing biometric information.
3.3 Financial and Transaction Information
When you use our financial or trading-related Services, we may collect:
Account balances
Digital asset holdings
Deposit and withdrawal information
Trading orders and transaction history
Blockchain wallet addresses
Blockchain transaction identifiers
Payment and settlement information
Transaction monitoring information
Other financial information necessary to provide our Services
This information is processed to facilitate transactions, maintain accurate records, manage financial and operational risks, and comply with applicable laws.
3.4 Device and Technical Information
When you access our Services, we and our authorized service providers may collect:
Device identifiers
Device model and operating system
Application version
IP address
Network connection information
Device security information
Application usage information
Session information
Crash reports
Performance and diagnostic data
Technical information relevant to fraud prevention and account security
We may use third-party technologies, including Adjust and DXRisk, to support analytics, application performance monitoring, device risk assessment, fraud detection, and security-related functions.
3.5 Location Information
We may collect or derive approximate geographic location information through IP addresses, network information, or other technical signals.
We use this information to:
Determine whether our Services are available in a particular jurisdiction
Enforce geographic restrictions
Prevent unauthorized access
Identify suspicious activity
Comply with applicable laws and regulations
We do not require precise GPS location information for ordinary account access unless a specific feature requires such information and the appropriate permission has been obtained.
3.6 Communications and Customer Support
When you contact our customer support team or communicate with us, we may collect:
Your contact information
Customer support inquiries
Messages and correspondence
Account-related requests
Complaints and dispute information
Information necessary to investigate and resolve reported issues
We use this information to provide customer support, maintain service quality, and resolve disputes.
3.7 Analytics and Usage Information
We may collect information about how users interact with our Services, including:
Application launches
Session activity
Feature usage
Navigation and interaction events
Application performance
Technical errors
Aggregated usage statistics
This information helps us understand application performance, maintain security, troubleshoot issues, and improve our Services.
4. How We Use Your Information
We may use personal information for the following purposes.
4.1 Providing and Maintaining Services
To create and manage accounts, authenticate users, process transactions, provide market information, maintain balances, and deliver requested features.
4.2 Identity Verification and Compliance
To verify user identities, perform KYC and AML checks, conduct sanctions screening, monitor transactions, and satisfy applicable regulatory requirements.
4.3 Security and Fraud Prevention
To detect and prevent unauthorized access, fraudulent transactions, account takeovers, suspicious activity, and other security threats.
4.4 Customer Support
To respond to inquiries, investigate complaints, resolve disputes, and provide technical assistance.
4.5 Analytics and Service Improvement
To analyze application performance, diagnose technical issues, evaluate product functionality, and improve the reliability and usability of our Services.
4.6 Marketing and Communications
Where permitted by applicable law, we may use contact information to communicate product updates, service announcements, promotional offers, and other relevant information.
Users may opt out of non-essential marketing communications.
4.7 Legal and Regulatory Compliance
To comply with applicable laws, regulations, lawful requests, court orders, financial recordkeeping requirements, and regulatory obligations.
We will not use personal information for materially incompatible purposes without an appropriate legal basis or additional consent where required.
5. Third-Party Service Providers
We may engage third-party service providers to support our operations.
These providers may process personal information only as necessary for the relevant services and subject to applicable legal and contractual requirements.
5.1 Sumsub — Identity Verification
We use Sumsub to assist with:
Identity verification
Government document authentication
Facial verification and liveness checks
KYC and AML compliance
Fraud prevention and sanctions screening
Sumsub may process identification documents, facial images, biometric information, and related verification data.
5.2 Adjust — Analytics and Attribution
We use Adjust to support application analytics, installation attribution, performance measurement, and related analytical functions.
Adjust may process certain technical information and application interaction data, depending on the configuration of the Services.
MSX does not currently use Apple's Identifier for Advertisers (IDFA) for cross-application tracking through Adjust.
If our practices change in the future, we will update our privacy disclosures and obtain any required permissions before enabling tracking activities.
5.3 DXRisk — Security and Risk Management
We use DXRisk to support device risk assessment, security monitoring, fraud prevention, and identification of suspicious activities.
DXRisk may process device-related and technical information necessary to support these security functions.
5.4 Other Service Providers
We may also engage providers for:
Cloud infrastructure and hosting
Cybersecurity
Transaction processing
Communications
Customer support
Application diagnostics
Financial compliance
Professional and legal services
We take reasonable measures to ensure that service providers maintain appropriate security and confidentiality protections.
6. Advertising, Analytics, and App Tracking Transparency
We respect your choices regarding advertising and tracking.
Our Services may incorporate analytics and attribution technologies to measure application performance, understand usage, and evaluate marketing effectiveness.
On Apple devices, certain tracking activities are subject to Apple's App Tracking Transparency (ATT) framework.
Where required, we will request your permission before accessing IDFA or conducting tracking activities as defined by Apple's policies.
You may grant or deny such permission through the operating system's authorization prompt.
You may also manage tracking permissions through your device settings:
Settings → Privacy & Security → Tracking
If you decline permission, we will not engage in tracking activities that require that permission.
We may continue to process information necessary for essential functionality, security, fraud prevention, and legal compliance, subject to applicable law.
We do not currently use IDFA-based cross-app tracking through Adjust.
If advertising or tracking practices change, we will update this Privacy Policy and implement applicable consent requirements.
7. Sharing and Disclosure of Information
We may share personal information in the following circumstances.
7.1 Service Providers
With authorized third-party providers performing services on our behalf, including identity verification, infrastructure, security, analytics, and customer support.
7.2 Legal and Regulatory Requirements
With regulators, law enforcement agencies, courts, or other competent authorities where disclosure is required or permitted by applicable law.
7.3 Fraud Prevention and Security
With authorized partners where necessary to investigate or prevent fraud, unauthorized access, financial crime, or security incidents.
7.4 Business Transactions
In connection with a merger, acquisition, restructuring, financing, or transfer of business assets, subject to applicable legal requirements.
7.5 With Your Consent
With third parties where you have provided valid consent or otherwise authorized disclosure.
We do not sell personal information to third parties for monetary consideration as part of our current business practices.
We do not authorize service providers to use personal information for purposes inconsistent with applicable contractual and legal obligations.
8. Legal Bases for Processing
Where applicable data protection laws require a legal basis, we may process personal information based on:
Contractual Necessity
To provide the Services requested by users and perform our contractual obligations.
Legal Obligations
To satisfy KYC, AML, sanctions screening, financial recordkeeping, and other applicable legal requirements.
Legitimate Interests
To maintain security, prevent fraud, improve Services, and conduct legitimate business operations, subject to applicable legal limitations.
Consent
Where required for specific processing activities, including certain biometric verification, marketing, or advertising tracking activities.
Where processing is based on consent, you may withdraw your consent in accordance with applicable law.
9. International Data Transfers
MSX FinTech Holding Limited may process personal information through service providers or infrastructure located in different jurisdictions.
As a result, personal information may be transferred to, stored in, or processed in countries outside your country of residence.
Where required by applicable law, we implement appropriate safeguards for international transfers, including contractual protections or other legally recognized mechanisms.
We take reasonable steps to ensure that personal information receives appropriate protection regardless of where it is processed.
10. Data Security
We implement technical and organizational security measures designed to protect personal information against unauthorized access, alteration, disclosure, misuse, or destruction.
These measures may include:
Encryption of data in transit and at rest
Access controls
Authentication and authorization mechanisms
Security monitoring
Fraud detection and prevention systems
Restricted access to sensitive information
Infrastructure and network security protections
Internal security policies and procedures
Although we take reasonable steps to protect information, no electronic system can be guaranteed to be completely secure.
Users are responsible for protecting their account credentials and promptly reporting suspected unauthorized account activity.
11. Data Retention
We generally retain personal information for a period of up to ten (10) years, where necessary for legitimate business purposes, regulatory compliance, financial recordkeeping, fraud prevention, dispute resolution, or other lawful purposes.
The actual retention period may vary depending on the category of information, the purpose of processing, and applicable legal requirements.
Information may be retained for a longer period where required by law, regulatory obligations, court orders, or the establishment, exercise, or defense of legal claims.
Where applicable law requires shorter retention periods, deletion, or additional restrictions for particular categories of information, including biometric information, we will comply with those requirements.
When personal information is no longer required, we will take reasonable steps to delete, anonymize, or securely dispose of it in accordance with applicable law and our retention procedures.
12. Your Privacy Rights
Depending on your location and applicable law, you may have the right to:
Request access to your personal information
Request correction of inaccurate or incomplete information
Request deletion of personal information
Request a copy of certain information
Request restriction of certain processing activities
Object to certain uses of personal information
Withdraw consent where applicable
Opt out of certain marketing communications
Exercise other rights available under applicable data protection laws
These rights may be subject to legal limitations, including financial regulatory obligations and mandatory recordkeeping requirements.
To exercise your privacy rights, please contact:
We may request reasonable identity verification before processing certain privacy-related requests.
13. Account Deletion
Users may request deletion of their MSX Pro accounts and associated personal information.
Account deletion requests may be initiated through the account deletion process made available through our Services or through our designated privacy support channel.
Requests may also be directed to:
Upon receiving a valid deletion request, we will process the request in accordance with applicable laws and our account closure procedures.
Certain information may need to be retained after account closure to comply with legal, financial, regulatory, fraud prevention, or recordkeeping obligations.
Where information must be retained, we will restrict its use to legally permitted or required purposes.
14. Marketing Communications
Where permitted by law, we may send users information about product updates, new features, service announcements, and promotional activities.
You may opt out of non-essential marketing communications by following unsubscribe instructions or contacting us.
Opting out of marketing communications will not prevent us from sending essential security, transaction, account, or legally required notices.
15. Cookies and Similar Technologies
Our websites and Services may use cookies, SDKs, and similar technologies to support authentication, security, analytics, and application functionality.
Where required by law, we will obtain consent before using non-essential cookies or similar technologies.
You may manage certain preferences through your browser, device settings, or privacy controls made available by our Services.
Disabling certain technologies may affect some functionality.
16. Children's Privacy
MSX Pro is intended only for individuals who are at least 18 years old or who meet the applicable minimum legal age for the relevant Services, whichever is higher.
We do not knowingly provide trading Services to minors who do not satisfy applicable age requirements.
If we become aware that personal information has been collected from an ineligible minor in violation of applicable law, we will take appropriate steps to address the information.
17. Regional Data Protection Rights
We respect applicable privacy and data protection laws in jurisdictions where our Services are legally offered.
Depending on the applicable law, users may have additional rights concerning the collection, processing, disclosure, retention, and deletion of their personal information.
Where applicable, these rights may include:
Access to personal information
Correction of inaccurate information
Deletion of personal information
Data portability
Restriction of processing
Objection to certain processing activities
Withdrawal of consent
Submission of complaints to competent data protection authorities
We will respond to valid privacy requests in accordance with applicable legal requirements.
The geographic restrictions described in Section 2 remain applicable regardless of the availability of privacy rights under particular laws.
18. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our Services, technology, business operations, legal requirements, or privacy practices.
When we make changes, we will update the "Last Updated" date.
Where required by applicable law, we will provide additional notice or obtain consent before implementing material changes.
We encourage users to review this Privacy Policy periodically.
19. Contact Information
If you have questions, concerns, or requests regarding this Privacy Policy or our processing of personal information, please contact:
MSX FinTech Holding Limited
Privacy and Support Email: support@msx.tech
Website: https://msx.tech
Please do not send passwords, private keys, recovery phrases, or other sensitive credentials through email.
© 2026 MSX FinTech Holding Limited. All rights reserved.