This Privacy Policy explains how Trexilon Technologies S.A. de C.V. ("Trexilon," "Company," "we," "us," or "our") collects, uses, stores, and protects Personal Data in connection with our website and digital asset services. Trexilon is incorporated in El Salvador with address at AVENIDA LA REVOLUCIÓN, COLONIA SAN BENITO, PRESIDENTE PLAZA, NIVEL 6, OFICINA 25, Distrito de SAN SALVADOR, Municipio de SAN SALVADOR CENTRO, Departamento de SAN SALVADOR. We are the Data Controller for the Personal Data described herein.
This website is not intended for use by minors, and we do not knowingly collect Personal Data from individuals under 18 years of age. If we become aware that such data has been collected, we will take reasonable steps to delete it promptly.
For questions or concerns about this Policy, contact us at: general@trexilon.tech. If a complaint is not resolved to your satisfaction, you may contact the Superintendencia del Sistema Financiero (SSF) of El Salvador.
The following definitions apply throughout this Privacy Policy:
| Term | Definition |
|---|---|
| AML/CFT | Anti-Money Laundering and Countering the Financing of Terrorism. |
| CNAD | Comisión Nacional de Activos Digitales (National Commission of Digital Assets) of El Salvador. |
| DASP | Digital Asset Service Provider, as defined under applicable Salvadoran law. |
| Data Controller | The entity that determines the purposes and means of Processing Personal Data. |
| Data Subject | An identified or identifiable natural person whose Personal Data is Processed. |
| KYB/KYC | Know Your Business and Know Your Customer verification procedures. |
| Personal Data | Any information relating to an identified or identifiable natural person. |
| Processing | Any operation performed on Personal Data, including collection, storage, use, disclosure, or deletion. |
| SSF | Superintendencia del Sistema Financiero of El Salvador. |
| UIF | Unidad de Investigación Financiera (Financial Investigation Unit) of El Salvador. |
We may collect the following categories of Personal Data in connection with our services:
| Category | Examples |
|---|---|
| Identity Data | Name, date of birth, nationality, government-issued identification documents, selfie photographs. |
| Contact Data | Address, email address, telephone number. |
| Financial Data | Bank account details, source of funds information. |
| Transaction Data | Digital asset transaction details, payment history, trade records. |
| Technical Data | IP address, browser type, device information, operating system, time zone, login data. |
| Compliance Data | Passport or ID copies, proof of address, source of funds documentation, and other KYB/KYC and AML/CFT records. |
| Communications Data | Correspondence with us, marketing communication preferences. |
We do not collect special categories of Personal Data (such as data concerning race, religion, health, or sexual orientation), except where compliance obligations require collection of information about criminal convictions or offenses.
If you fail to provide Personal Data that we are required to collect by law or under the terms of our agreement with you, we may be unable to provide our services. We will notify you if this situation arises.
We collect Personal Data through the following channels:
We process Personal Data only where a lawful basis exists. The following table maps each lawful basis to its corresponding processing purposes.
| Lawful Basis | Processing Purposes |
|---|---|
| Performance of a contract | Client registration, account management, transaction processing, and delivery of our digital asset services. |
| Legal obligation | Compliance with AML/CFT regulations, KYB/KYC requirements, tax reporting, and responses to requests from the CNAD, SSF, UIF, or other competent authorities. |
| Legitimate interests | Business administration, website protection, service improvement, analytics, and fraud prevention, provided your rights do not override these interests. |
| Consent | Marketing communications. You may withdraw consent at any time by contacting us. |
If we need to process Personal Data for a purpose not originally contemplated, we will notify you and explain the applicable lawful basis before proceeding.
We may share Personal Data with the following categories of recipients:
We do not sell Personal Data to third parties. We do not share Personal Data with third parties for their own marketing purposes without your explicit consent.
Certain service providers engaged by Trexilon may be located outside the Republic of El Salvador. Where Personal Data is transferred to a jurisdiction outside El Salvador, we take reasonable steps to ensure that an adequate level of protection is maintained.
Safeguards applied to cross-border transfers may include:
By providing Personal Data to us, you acknowledge and consent to the transfer of such data outside El Salvador in accordance with the safeguards described above. You may contact us at general@trexilon.tech for further information regarding the specific safeguards applied to any particular transfer.
Trexilon implements appropriate technical and organizational measures to protect Personal Data against unauthorized access, alteration, disclosure, or destruction. These measures are reviewed periodically and updated as necessary to address evolving risks.
Access to Personal Data is restricted to personnel who require it for legitimate business purposes. All such personnel are bound by written confidentiality obligations.
Trexilon maintains documented procedures for identifying, investigating, and responding to suspected data breaches. Where a breach is likely to affect the rights of Data Subjects or where applicable law requires, we will notify the relevant regulator and affected individuals without undue delay.
We retain Personal Data for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, regulatory, tax, and accounting requirements. Where applicable law prescribes minimum retention periods, we will retain data for at least the required duration.
When Personal Data is no longer required for any lawful purpose, we will securely delete or anonymize it in accordance with our internal data retention procedures.
You may request deletion of your Personal Data by contacting us at the address set out in Section 14. Such requests remain subject to our legal retention obligations under applicable law.
Subject to applicable law, you may exercise the following rights with respect to your Personal Data:
To exercise any right, contact us at general@trexilon.tech. We may request information to verify your identity before responding. These rights are not absolute and remain subject to applicable legal exceptions. We may charge a reasonable fee for requests that are clearly unfounded or excessive.
Our website may contain links to websites operated by third parties. These links are provided for convenience only and do not imply endorsement of, or responsibility for, the content, privacy practices, or policies of any third-party website.
Trexilon does not control and is not responsible for the collection, use, or disclosure of Personal Data by third-party websites. We encourage you to review the privacy policy of each external website you visit before providing any Personal Data.
Your use of any third-party website is subject to that website's own terms and privacy policy, and Trexilon accepts no liability arising from such use.
Trexilon reserves the right to update or modify this Privacy Policy at any time. Any changes will be posted on our website with a revised "Last updated" date. We encourage you to review this Policy periodically.
Where changes are material, we will take reasonable steps to notify affected clients prior to the changes taking effect.
It is your responsibility to ensure that the Personal Data we hold about you remains accurate and current. Please inform us promptly of any changes to your Personal Data.
This Privacy Policy, and any dispute or claim arising out of or in connection with it (including non-contractual disputes or claims), shall be governed by and construed in accordance with the laws of the Republic of El Salvador.
Any dispute arising from or related to this Privacy Policy that cannot be resolved amicably shall be submitted to the exclusive jurisdiction of the competent courts of the Republic of El Salvador. The parties irrevocably submit to the jurisdiction of such courts.
If you have any questions, concerns, or complaints regarding this Privacy Policy or our Processing of Personal Data, please contact us at:
Trexilon Technologies S.A. de C.V. Email: general@trexilon.tech
We will endeavor to respond to all inquiries within a reasonable timeframe. If your complaint is not resolved to your satisfaction, you may escalate the matter to the Superintendencia del Sistema Financiero (SSF) of El Salvador.