1. Introduction

Nummularius (“Nummularius,” “we,” “us,” or “our”) operates a cryptocurrency exchange platform that enables users to trade digital tokens backed by earth minerals. The Services include websites, mobile applications, APIs, wallets, and trading systems (collectively, the “Services”).

By using the Services, you agree to this Privacy Policy.

2. Overview of Nummularius Tokens

The Platform supports trading of the following asset-backed digital tokens:

• Nummu Gold (NGT) — Price reference: COMEX Gold
• Nummu Oil (NOT) — Price reference: WTI Crude Oil
• Nummu Cell (NCT) — Price reference: Lithium Carbonate Spot Market

These reference benchmarks are used for pricing guidance only and do not constitute a guarantee of value.

3. Information We Collect

3.1 Information You Provide

• Full legal name
• Date of birth
• Address and proof of residence
• Government-issued identification (passport, driver’s license, national ID)
• Email address and mobile number
• Wallet addresses and transaction data
• Banking and payment information
• Customer support communications

3.2 Automatically Collected Data

• IP address and device identifiers
• Browser type and operating system
• Login timestamps and usage activity
• Transaction metadata
• Cookies and analytics identifiers

3.3 Third-Party Sources

We may receive information from:

• Identity verification providers
• Blockchain analytics tools
• Payment processors
• Sanctions and fraud databases

4. How We Use Information

We use your information to:

• Provide exchange and wallet services
• Perform KYC/AML compliance
• Process transactions and settlements
• Prevent fraud and unauthorized access
• Comply with legal obligations
• Improve platform functionality
• Provide customer support

5. Legal Basis for Processing

We process data based on:

• Contract performance
• Legal and regulatory obligations
• Legitimate interests
• User consent (where required)

6. Sharing of Information

We may share data with:

• Compliance and verification providers
• Banking and payment partners
• Cloud and infrastructure providers
• Legal and regulatory authorities

We do not sell personal data.

7. Blockchain Transparency

Blockchain transactions are public and immutable. Wallet addresses and transaction details may be visible on public networks.

8. Cookies and Tracking

We use cookies for:

• Authentication
• Security
• Analytics
• Performance improvements

Users may disable cookies via browser settings.

9. Data Retention

We retain data for as long as necessary to:

• Provide Services
• Comply with regulations (typically 5–10 years)
• Resolve disputes
• Enforce agreements

10. Data Security

We implement industry-standard safeguards including:

• Encryption (in transit and at rest)
• Multi-factor authentication
• Access control systems
• Continuous monitoring

11. Opt-In Text Messaging (SMS) Policy

11.1 Consent to Receive Text Messages

By providing your mobile number and opting in, you consent to receive recurring automated and non-automated SMS messages from Nummularius, including account alerts, security notifications, transaction updates, verification codes, and service communications.

Consent is not required as a condition of using the Services.

11.2 Mobile Number Non-Sharing Statement

We respect your privacy. We do not sell, rent, lease, or share your mobile phone number with third parties for their marketing purposes.

We may share your number only with trusted service providers who assist in:

• SMS delivery and messaging infrastructure
• Identity verification and fraud prevention
• Regulatory compliance

These providers are contractually obligated to protect your data.

11.3 Message Frequency

Message frequency varies based on account activity and may include:

• Security alerts
• Transaction confirmations
• Account notifications
• System updates
• Optional promotional messages (if opted in)

11.4 Message and Data Rates

Message and data rates may apply. Charges depend on your mobile carrier plan. Nummularius is not responsible for carrier fees.

11.5 Opt-Out Instructions

You may opt out at any time by replying:

• STOP to cancel SMS messages

You may still receive essential service or legally required communications.

11.6 Help

Reply HELP or contact support at support@nummularius.us

12. Your Privacy Rights

Depending on jurisdiction, you may have rights to:

• Access personal data
• Correct inaccurate data
• Request deletion
• Restrict processing
• Data portability

13. International Data Transfers

Your data may be transferred and processed in jurisdictions outside your country of residence.

14. Changes to This Policy

We may update this Privacy Policy periodically. Continued use constitutes acceptance of changes.

15. Acceptance of Terms

By accessing or using Nummularius, you agree to these Terms of Use and all related policies.

16. Nature of the Platform

Nummularius is a digital asset trading platform that facilitates the exchange of tokenized commodities:

• NGT (Nummu Gold) — benchmarked to COMEX Gold
• NOT (Nummu Oil) — benchmarked to WTI Crude Oil
• NCT (Nummu Cell) — benchmarked to Lithium Carbonate spot prices

These tokens represent digital representations of reference-linked value systems and are not legal tender.

17. No Investment Advice

Nummularius does not provide:

• Investment advice
• Financial advice
• Trading recommendations

All trading decisions are made independently by users.

18. Market Pricing Disclaimer

Token prices are influenced by external benchmark markets:

• COMEX Gold (NGT)
• WTI Crude Oil (NOT)
• Lithium Carbonate Spot Prices (NCT)

However:

• Prices may diverge from benchmarks due to liquidity, volatility, and exchange dynamics
• Nummularius does not guarantee parity or stability with reference markets

19. Trading Risks

Users acknowledge risks including:

• Market volatility
• Liquidity limitations
• Technology failures
• Regulatory changes
• Loss of funds due to trading decisions

You may lose all funds invested in digital assets.

20. Eligibility

Users must:

• Be at least 18 years old (or legal age in jurisdiction)
• Pass identity verification (KYC)
• Not be subject to sanctions or restrictions

21. Account Responsibilities

Users are responsible for:

• Account security
• Password protection
• Transaction authorization
• All activity under their account

22. Prohibited Activities

Users may not:

• Engage in market manipulation
• Use insider information
• Conduct illicit financial activity
• Circumvent compliance controls
• Use the platform for fraud or terrorism financing

23. Compliance & AML

Nummularius complies with applicable:

• Anti-Money Laundering (AML) laws
• Counter-Terrorist Financing (CTF) regulations
• Sanctions enforcement rules

We may freeze or terminate accounts for compliance reasons.

24. Suspension and Termination

We reserve the right to suspend or terminate accounts:

• For violations of these Terms
• For regulatory compliance
• For suspicious activity

25. Limitation of Liability

Nummularius is not liable for:

• Market losses
• Trading decisions
• Service interruptions
• Third-party failures

26. Amendments

We may update these Terms at any time. Continued use constitutes acceptance.

27. Governing Law

These Terms are governed by applicable laws of the jurisdiction in which Nummularius is registered.

Contact Information

For privacy-related inquiries, requests, or concerns, please contact:

Nummularius – Privacy Office
📧 privacy@nummularius.com
🌐 www.nummularius.com