Privacy Policy
Effective Date: 3 June 2026
1. Introduction
This Privacy Policy (hereinafter – the “Policy”) explains how DynamicOpp Inc (Registration No.: 155779503, address: 55th Street East, SL55 Building, 21st Floor, Office 3, Panama City, Republic of Panama) (hereinafter – the “Company”, “Tronex”, “we”, “us”, “our”) collect, use, store, and protect personal data when accessing the website tronxenergy.com and other related services.
The Company complies with:
-The EU General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) – for users from the European Economic Area (EEA).
-Law No. 81 of 26 March 2019 on Personal Data Protection of the Republic of Panama
By using our services, you confirm that you have read this Policy and agree to its terms.
2. Terms
1) Data Controller – DynamicOpp Inc, which determines the purposes and means of processing your personal data.
2) Data Processor – a natural or legal person which processes personal data on behalf of the Controller (e.g., analytics providers, hosting providers).
3) Personal Data – any information relating to an identified or identifiable natural person, as defined in the GDPR and Law No. 81 of 26 March 2019 on Personal Data Protection of the Republic of Panama.
4) Processing – any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
5) Representative – a natural or legal person established in the Union who, designated by the controller or processor in writing pursuant to Article 27 GDPR, represents the controller or processor with regard to their respective obligations under this Regulation.
6) Consent – freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
7) Cookies – small text files stored in your browser that allow the website to remember your actions and preferences over time.
The use of cookies is governed by a separate Cookie Policy.
3. What Personal Data We Collect
We may collect the following categories of data:
Identification Data
Address(es) of cryptocurrency wallets in supported blockchains;
Transaction hashes and transaction history related to our service.
Contact Data (if voluntarily provided)
Email address;
Nickname or phone number in Telegram (when using the bot).
Technical Data
IP address;
Browser type and version;
Device type, operating system, time zone;
API request log files.
Transaction Data
Information on the purchase of energy, amounts, date, and time;
Payment details (if payment is made via external providers).
Correspondence Data
Requests to customer support, feedback, communication with the team.
Personal data is collected only to the extent necessary for the provision of the service, customer support, prevention of abuse, and fulfilment of legal obligations.
Important: we do not request or store private keys, seed phrases, or other sensitive data for accessing your cryptocurrency wallets.
4. How We Collect Data
The Company may collect your personal data in various ways, namely by processing personal data you provide to us directly and/or collecting information as a result of automated technologies, interactions, and/or from third parties and/or from publicly available sources.
In addition, the Company may collect personal data you voluntarily provide, provided that you are aware of the transfer of such data to the Company.
In particular, information you provide to us directly may include your identification and contact data when contacting customer support via Telegram/email or using the bot.
When using the Company's website, it may automatically collect technical data about your equipment, browsing actions, and behaviour on the website. The Company collects such personal data using cookies and other similar technologies. The Company may also receive technical data about you if you visit other websites using the Company’s cookies.
5. Purposes of Processing and Legal Bases
We use your data for the following purposes:
Where processing is based on consent, you have the right to withdraw it at any time without affecting the lawfulness of processing prior to withdrawal. Withdrawal of consent can be exercised by contacting us at business@tronex.energy.
6. Disclosure of Data to Third Parties
Confidentiality and protection of your personal data are of fundamental importance to us. We take all appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of data and personal information, and to comply with the relevant provisions of applicable data protection laws.
Access to personal information is limited to employees who need it solely to perform their job duties, ensure the operation, development, or improvement of our services. These employees are bound by confidentiality obligations and are responsible for compliance, including possible disciplinary measures and legal liability for any breach of such obligations.
We may transfer Personal Data to our service providers or third parties in connection with the Company's operation of its business. Third-party service providers only have access to Personal Data to perform their functions and may not use it for other purposes.
We do not transfer your personal data to any third parties, except as set out below:
Third Party
Purpose
Legal Basis
Safeguards
Yandex.Metrica
Website analytics
Art. 6(1)(a) –consent
Standard Contractual Clauses (SCCs); DPA: yandex.ru/legal/metrica_agreement/en/
Hosting / infrastructure providers
Website and service operation
Art. 6(1)(b) –contract
Data Processing Agreements (DPA)
AML/compliance providers
AML/KYC checks
Art. 6(1)(c) –legal obligation
Contractual and technical safeguards
Law enforcement / authorities
Where required by law
Art. 6(1)(c) –legal obligation
As required by applicable law
7. International Transfers of Personal Data
We maintain servers hosted by our trusted service providers, and your information may be processed on servers located outside of your country of residence. Additionally, we may transfer your Personal Data to our Affiliates, third-party partners, and service providers located in various countries around the world.
In instances where we process your Personal Data on servers outside your country or transfer it to third countries or international organizations beyond your country of residence, we implement appropriate technical, organizational, and contractual safeguards to ensure that your Personal Data remains protected. This includes, but is not limited to, the use of Standard Contractual Clauses. These measures ensure that any such transfers comply with applicable data protection laws and maintain an adequate level of protection for your Personal Data as outlined in this Policy.
8. Data Retention Periods
We retain different types of personal data for specific periods.
Contact and communication data – until deletion upon request or after 2 years of inactivity;
Transaction logs – up to 7 years (for legal compliance and audit purposes);
Technical logs – up to 12 months (for security purposes).
Upon expiration of these periods, the data will be deleted or anonymized.
9. Data Subject Rights
You have the following rights regarding your personal data:
Right of access: you have the right to be informed whether the Company processes your personal data, and, if so, to obtain a copy of such data.
Right to rectification: you may request amendments to your personal data to correct or supplement them.
Right to erasure: you may send the Company a written request to delete specific personal data by emailing business@tronex.energy. Such request will be considered taking into account data retention requirements we are obliged to comply with under applicable laws and regulations, as well as our data retention policy. In some cases, deletion of data may be impossible if it is required for the Company to fulfil its legal obligations.
Right to restriction of processing: you have the right to restrict the processing of your personal data in certain cases. This means you may limit the ways the Company uses your data. This is an alternative to data deletion. Restriction is possible, for example, iif you object to the content of the information held by the Company or to the way it is processed.
Right to data portability: you may request that your personal data be provided in a readable electronic format.
Right to object to processing: you may request that the Company stop processing your personal data, and the Company will do so if:
a) it cannot demonstrate compelling legitimate grounds for the processing;
b) the processing is carried out for marketing purposes.Right to transfer data to you or a third party: the Company will provide you or a third party chosen by you with your personal data in a structured, commonly used, machine-readable format. This right applies only to automated information that you provided with your consent to its use or that is necessary for the performance of a contract with the Company.
Right to lodge a complaint: if you believe the Company is unlawfully using your personal data, you may file a complaint.
Right to withdraw consent: as stated above, you have the right to withdraw your consent. However, in such a case, the Company may be unable to provide you with certain products or services. The Company will inform you of the consequences of withdrawal at the time such a request is received.
Alternatively, to exercise your rights, you can contact us at business@tronex.energy.
We will respond as quickly as possible. If we are unable to respond, we will inform you in writing of the timeline for our response. If you have any questions or concerns about how we collect and process your Personal Data, or if you wish to withdraw your consent for any processing, please contact us.
Age Restrictions
Our Services are intended exclusively for individuals who are at least 18 years of age. We do not knowingly collect personal data from minors. If we become aware that personal data of a person under 18 has been collected, we will promptly delete such data. If you are a parent or guardian and believe your child has provided us with personal data, please contact us using the contact information.
11. Data Security
The Company builds an information security management system in accordance with the requirements of ISO/IEC 27001. We implement technical, physical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction.
Technical measures include:
Data encryption during transmission (TLS/HTTPS) and storage;
Role-based access control and mandatory multi-factor authentication for administrative access;
Centralized log collection, automated anomaly detection, and 24/7 security monitoring via a dedicated Security Operations Center (SOC);
Regular vulnerability management, patch management, and periodic penetration testing;
Technical measures include:
Restricted physical access to workspaces, devices, and storage media;
Clean desk / clean screen policy for all employees and contractors;
Secure disposal of media and devices containing confidential data;
Use of data centers with physical security, video surveillance, and power redundancy.
Organisational measures include:
Owners of information systems-are responsible for security within their trusted systems and services;
All employees and contractors are required to comply with the Policy, receive training, and report possible incidents immediately.
The Company's security measures are implemented and maintained in accordance with its ICT risk management framework under Regulation (EU) 2022/2554 on Digital Operational Resilience for the Financial Sector (DORA), applicable from 17 January 2025.
12. Cookies
Our website uses cookies for operation, analytics, and service improvement. Details are provided in a separate Cookie Policy.
13. Policy Updates
We may amend this Policy to comply with new laws or technologies. The updated version will be published on the website with the effective date indicated. In the event of significant changes, we will notify users via the website or by email.
14. Contact Information
If you have any requests, questions, or complaints, you may contact us at: business@tronex.energy.
