Privacy policy

Privacy Policy

Last Revised: April 2024

1. Comprehensive Data Collection

We collect data at various stages of your journey:

  • Directly: During registration (SSN/Tax ID, Passport copies, residential address).

  • Automated: Through cookies and pixels (Device fingerprinting, browser metadata, geolocation).

  • External: From credit bureaus and public blockchains (to verify the source of funds).

2. Purpose of Processing

Your data is used to:

  1. Facilitate Transactions: Processing buy/sell orders and recovery claims.

  2. Legal Compliance: Reporting to tax authorities (IRS/HMRC) and financial regulators (SEC).

  3. Forensic Analysis: Using your data to map transaction chains in recovery cases.

  4. Platform Optimization: A/B testing features to improve the "Excel" user experience.

3. Data Retention and Erasure

Under financial regulations, we are required to retain certain "Financial Records" for a period of 7 years after an account is closed. However, you may request the deletion of non-essential marketing data at any time.

4. Advanced Security Architecture

  • Encryption: All data in transit is protected via TLS 1.3 encryption.

  • Cold Storage: 98% of digital assets are held in geo-distributed, air-gapped cold vaults.

  • Internal Controls: Employees must pass multi-factor biometric authentication to access sensitive user databases.

5. International Data Transfers

As a global firm, your data may be processed in secure facilities located in the United States, UK, and EU. We utilize Standard Contractual Clauses (SCCs) to ensure your data receives equivalent protection across borders.


3. Asset Recovery & Refund Policy

1. Forensic Investigation Phase

Upon payment of the Retainer/Audit Fee, our team initiates a "Deep Trace." This involves:

  • Cluster analysis of the offending wallet addresses.

  • Deanonymization efforts via "Know Your Transaction" (KYT) tools.

  • Coordination with the legal departments of centralized exchanges (CEXs).

2. Success-Based Compensation

If Excel Coin Market successfully freezes and returns assets to the User:

  • A success fee of 10% of the recovered value will be applied.

  • This fee is calculated based on the market price of the asset at the moment of successful recovery.

3. Non-Refundable Nature of Work

The initial audit fee covers the high cost of forensic software licenses and expert labor hours. Consequently:

  • No Refunds will be issued if the assets are found to have been moved into "Tumbling/Mixing" services that render them untraceable except additional charges has been paid for such services.

  • No Refunds if the user provides incorrect wallet information that leads to an unsuccessful trace.

4. Refund Process for Standard Accounts

For regular investment deposits (not recovery):

  • Cancellations: Users can withdraw uninvested cash at any time.

  • Processing Time: Withdrawals are processed within 24–72 hours, depending on bank clearing cycles and blockchain congestion.

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