We are committed to protecting your privacy. In the course of using the Ciphex.io website or the Alpha Centurion Network, also known as Alpha CPX (collectively referred to as “CipheX,” “Site,” “we,” “us,” or “our”), you may be asked to provide certain personal information. This Privacy Policy outlines our privacy practices and explains how we collect, process, use, and disclose your personal information (“Personal Information”). For purposes of this Privacy Policy, the terms “user” or “you” refer to: (i) any visitor to CipheX including those referred by a CipheX affiliate website or agent; (ii) individuals who interact with CipheX services; and (iii) individuals who become community members through their ownership of CipheX Tokens, whether acquired directly from this Site or through a decentralized or centralized exchange (collectively, “Users”). By accessing or using the Site, you acknowledge, agree to, and consent to the collection, use, and disclosure of your Personal Information in accordance with this Privacy Policy and the practices described herein.

1. Service Applicability

The scope of this Privacy Policy applies to CipheX and any of our affiliates with whom we might share Personal Information and encompasses all of our product offerings and services (operated offline, online, or both) including services made available through other agents and partnerships. CipheX products and services shall mean our CipheX website (this Site), the Alpha Centurion Network (Alpha CPX), and any software applications and online services we may offer (collectively, the "Services") and when you interact with us, such as through our social media or any online chat channel where interaction between us may occur. If you engage with us independently of a third party, this Privacy Policy will apply. If your Personal Information is processed by an independent third party such as an identity KYC verification provider, then those third-party providers may be responsible for the privacy of that specific Information.

2. Decentralized Environment

CipheX is a decentralized protocol-based environment. As such, CipheX does not require users to register accounts, nor does it engage in the custody of user assets. All interactions with the protocol are conducted through user-controlled, non-custodial wallets. Users retain sole responsibility and control over their digital assets, in alignment with the foundational principles of decentralization, privacy, and user autonomy. Notwithstanding the foregoing, CipheX may collect and process limited user information as necessary to facilitate participation in governance-related activities, User management of their Alpha CPX Portfolios, and to administer their CipheX Tokens that are subject to lockup, vesting, or similar contractual arrangements (“Limited Personal Information”). Such processing shall be conducted in accordance with applicable data protection and governance policies.

3. Limited Personal Information We Collect

Active Users are persons who connect their digital wallets to the CipheX Community or use its Alpha CPX Services. We will only collect the following Personal Information from Active Users:

• Your email address;

• Your Wallet address if you are signing up via your Wallet service; and

• IP address and geographic location.

4. The Use of Limited Personal Information

We use Active User Information to:

• Operate and provide you with the Services;

• Communicate with you and send you communications; and

• Enforce our Terms of Service, legal rights, and comply with applicable law.

5. Use of Cookies

CipheX uses cookies and similar tracking technologies to enhance your experience, analyze Site traffic, and personalize content and services. Cookies are small text files that are stored on your device when you access the Site. These files allow us to recognize your browser, remember user preferences, and improve the functionality and security of the Site.  We use both session cookies, which expire when you close your browser, and persistent cookies, which remain on your device until deleted or expired. Some cookies are essential for the operation of the Site or its Services, while others are used for analytics, performance monitoring, or to provide customized content. By continuing to use the Site, you consent to the placement and use of cookies as described in this Privacy Policy. You may choose to disable cookies through your browser settings; however, doing so may affect your ability to access certain features or functionality of the Site or its Services. You may manage your cookie preferences in your browser settings.

6. Sharing of Information

We may disclose Personal Information to other parties as needed to provide the Services and operate our business. The categories of other parties with whom we may share Information include:

Service Providers. We may share the Information you provided with third party services such as, payment processors, centralized market exchanges,  web and security service providers, developers, analytic services, and providers we might use to analyze the Services and functionalities.

Government and Legal. We may share Personal Information with regulatory or law enforcement authorities, as may be required by applicable law, regulation, or legal process.

Anonymized Data. Anonymization involves the application of techniques that modifies personally identifiable Information. This process results in anonymized data that cannot be associated with any one individual. By anonymising your data, we can provide a safe environment for our users while protecting user identities and other information such as on-chain transaction history and digital wallet identification,

No Sell Policy. We do not sell any of your Information to any third party.   

7. Data Retention of Limited Personal Information

CipheX is committed to protecting the privacy and personal data of its users in accordance with applicable privacy laws, including the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and the Personal Information Protection and Electronic Documents Act (PIPEDA). CipheX retains only the minimum necessary personal data for the limited and specific purposes outlined above. Limited Personal information is: (a) Stored securely using appropriate technical and organizational safeguards; (b) Retained only as long as necessary to fulfill the purpose for which it was collected, or to meet legal and regulatory obligations; and (c) Deleted, anonymized, or aggregated once it is no longer required, unless further retention is legally mandated.

8. Data Retention Compliance of Limited Personal Information

• GDPR (EU/EEA Users): Under the GDPR, users have the right to access, correct, delete, or restrict the processing of their personal data. CipheX processes personal data based on user consent, legitimate interest, or legal obligation, and ensures compliance with data minimization and purpose limitation principles.

  
  

• PIPEDA (Canadian Users): CipheX adheres to the principles of accountability, transparency, and consent under PIPEDA. Users have the right to access their personal information and challenge its accuracy. CipheX does not disclose personal information to third parties without consent, except where legally required.

  
  

• CCPA (California Users): CipheX does not sell user personal information. Under the CCPA, California residents have the right to request access to, or deletion of, their personal data and to opt out of any potential data "sales" (which CipheX does not engage in). Requests can be submitted through our designated contact channels.

Users may exercise their data rights under GDPR, CCPA, or PIPEDA by contacting CipheX through the official communication channels provided on our website. All verified requests will be handled in accordance with applicable privacy laws.

9. Communications and Marketing

CipheX may, from time to time, send you email or other communications regarding the Services, including updates, feature announcements, and information about new offerings that may be of interest to you. If you have subscribed to our newsletters or promotional communications, you may opt out at any time by following the unsubscribe instructions included in each message. Please note that opting out of promotional communications does not affect our ability to send you important administrative or transactional messages related to your use of the CipheX Services, participation in community governance, or other legally required communications. These communications are necessary to ensure compliance with applicable laws and to maintain the integrity of the CipheX protocol.

10. Third-Party Sites, and Social Media

Our website may contain links to external websites with privacy practices that differ from ours. When you navigate to a third-party site, their privacy policy will govern your activity, and any data collected. Additionally, certain areas of our Site might include social media features and widgets (e.g., "Like" or "Share" buttons), which may collect your IP address, record the pages you visit, and place cookies to enable proper functionality. These features are hosted by third parties, and your interactions with them are subject to their respective privacy policies.

11. General Data Protection

CipheX does not operate from a centralized business location. Contributors who support and develop the Services are located across multiple jurisdictions. As a result, your Limited Personal Information may be collected, stored, and processed on servers located outside your country of residence. All cross-border data transfers are conducted in accordance with applicable data protection laws and subject to appropriate safeguards and transfer mechanisms to ensure your information remains protected.

12. Information Security

We implement technical, administrative, and organizational safeguards to protect the confidentiality, integrity, and availability of your Personal Information. These measures are supported by the infrastructure of our service providers and CipheX community contributors. Our controls are designed to prevent unauthorized access, disclosure, alteration, or destruction of data, whether accidental or unlawful. In the event of a data breach involving your Personal Information, we will take appropriate remedial actions and provide timely notice in accordance with applicable legal and regulatory requirements.

For more information:

Cipherion Capital SA
CipheX Capital Ecosystem
50th Street PH Plaza 2000
17th Floor, Panama City, Panama
privacypolicy@cipherion.co