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Privacy Policy

Last Updated: 27 September 2026

This Privacy Policy explains how Proxima Labs Inc., a company incorporated in Panama ("Proxima", "we", "us", or "our") collects, uses, shares, and protects personal information in connection with your use of the Proxima marketing website (https://proxima.tools), the web application (https://app.proxima.tools), the documentation site (https://docs.proxima.tools), the Proxima API, and related services (collectively, the "Platform"). This Policy should be read together with our Terms of Service and AML Policy.

By using the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree, you must stop using the Platform.

1. Information We Collect

We collect only the information necessary to provide the Platform, secure it, and comply with our legal obligations.

1.1 Account and Authentication Data

Authentication is provided through Turnkey and may involve email one-time passcodes, passkeys, or an external wallet. In connection with your account we may collect and store:

  • Your email address (where provided) and Turnkey user and sub-organization identifiers
  • Your username, license key(s), and referral codes, together with your referrer and referral relationships
  • Session information, including authentication tokens and session activity

1.2 Session, Device, and Location Data

When you access the Platform, we automatically collect

  • Your IP address
  • Approximate geolocation derived from your IP address (country, region, and city), using a geolocation database (MaxMind GeoLite)
  • Device and browser information, including your user agent

1.3 Wallet and Transaction Data

To provide launch, trading, and market-operations functionality, we collect and store:

  • Wallet addresses (public keys) for managed, imported, and watched wallets
  • Private keys for managed wallets and, where you import them, for imported wallets, held on Proxima-controlled systems so the Platform can sign transactions on your instructions. On your request to support@proxima.tools, and after we verify that the request comes from the account holder, we may disclose the private keys of your managed wallets to you. We do not guarantee that a request will succeed. We do not release keys while the account or wallets are restricted or frozen (see the Terms of Service and the Risk Disclosure)
  • Launch and token metadata (such as token names, descriptions, images, and social links you provide)
  • Trading, funding, withdrawal, routing, activity, balance, profit-and-loss, and fee records
  • For CEX funding and withdrawals routed through third parties, information necessary to process those orders, which may include your IP address

1.4 Compliance Data

Where we apply the measures described in the AML Policy, we (or a verification provider we appoint) may collect identity documents, selfie and liveness data, and source-of-funds documentation.

1.5 Support and Diagnostics Data

  • Content you submit through bug reports and support requests, protected against automated abuse using Cloudflare Turnstile
  • Error and performance diagnostics collected through Sentry (frontend) and OpenTelemetry (backend), which may include technical event data and identifiers

2. How We Use Your Information

We use personal information to

  • Provide, operate, maintain, and improve the Platform and its features
  • Authenticate you, manage sessions, licenses, and referrals, and secure your account
  • Generate managed wallets and execute the launches, trades, transfers, withdrawals, and automated strategies you initiate
  • Calculate and collect fees and referral or affiliate rewards
  • Detect, investigate, and prevent fraud, abuse, security incidents, and prohibited or unlawful activity
  • Comply with legal obligations, including AML, CTF, sanctions, and record-keeping requirements
  • Provide support, respond to requests, and communicate with you about the Platform

Proxima Labs Inc. is the controller of the personal information described in this Policy.

Where applicable law (such as the GDPR) requires a legal basis, we rely on: the performance of our contract with you (to provide the Platform); our legitimate interests (to secure, improve, and operate the Platform and prevent abuse); compliance with legal obligations (including AML and record-keeping); and, where required, your consent (which you may withdraw at any time).

4. How We Share Information

We do not sell your personal information. We share it only as necessary:

  • Service providers and processors, including Turnkey (authentication and key infrastructure), Husher and its exchange service providers (CEX funding, withdrawals, and privacy routing), Hushxima (aged-wallet Marketplace), Jupiter (swap routing), Streamflow (locks), blockchain RPC and infrastructure providers, hosting providers, Cloudflare (abuse prevention), MaxMind (geolocation), and Sentry (diagnostics), each processing data on our behalf or under their own terms as applicable
  • Verification providers, if we appoint them for identity verification or other checks described in the AML Policy
  • Authorities, where we are required or permitted by law to disclose information to competent governmental authorities, law enforcement agencies, regulatory bodies, or investigative authorities, upon lawful request
  • Corporate transactions, in connection with a merger, acquisition, financing, or sale of assets, subject to appropriate confidentiality protections

When you use a third-party feature (for example, a CEX funding or withdrawal route through Husher, or an external launchpad), that third party may collect and process information under its own privacy policy, which we do not control.

5. Public Blockchain Data

Blockchain transactions are inherently public and permanent. Wallet addresses, transactions, launches, and related activity conducted through the Platform are recorded on public blockchains and can be viewed, analyzed, and linked by anyone, including law enforcement. Privacy-enhancing features reduce but do not guarantee unlinkability, and we cannot remove or alter information recorded on a blockchain.

6. Data Retention

We retain personal information for as long as necessary to provide the Platform and for legitimate business purposes, and thereafter as required to comply with our legal obligations. Compliance and identity records, when collected, are retained for at least five years after the end of our relationship, or longer where required by law or ongoing investigation.

7. Security

We implement technical and organizational measures designed to protect personal information against misuse, unauthorized access, and disclosure. Those measures do not eliminate risk. A compromise of first-party systems, including the systems that store managed-wallet keys, or of the support channel used to deliver keys, may result in loss. You are responsible for safeguarding your credentials, authentication factors, and any private keys you receive.

8. International Transfers

Your information may be processed and stored in countries other than the one in which you reside. Where personal information is transferred internationally, we take steps to ensure it is protected in accordance with applicable data-protection laws.

9. Your Rights

Depending on your jurisdiction, you may have rights to access, correct, delete, or port your personal information, to restrict or object to certain processing, and to withdraw consent. To exercise these rights, contact us at legal@proxima.tools. We may need to verify your identity before responding, and some rights are subject to limitations, including where we are legally required to retain information (for example, for AML purposes) or where information is recorded on a public blockchain and cannot be altered.

10. Cookies and Local Storage

The Platform uses cookies, local storage, and similar technologies that are necessary to authenticate you, maintain sessions, remember preferences, secure the Platform, and understand and improve performance. You can control cookies through your browser settings, though disabling certain cookies may impair the functionality of the Platform.

11. Children

The Platform is not intended for, and may not be used by, anyone under 18 years of age or the age of legal majority in their jurisdiction. We do not knowingly collect personal information from children.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through the Platform, the documentation site, or by other reasonable means at least 14 days before they take effect, except where a shorter period is required to address legal or security concerns. Your continued use of the Platform after the effective date constitutes acceptance of the updated Policy. If you do not agree, you must stop using the Platform.

13. Contact

For questions about this Privacy Policy or your personal information, contact us at legal@proxima.tools. For general support, contact support@proxima.tools. Proxima Labs Inc. is a company incorporated in Panama. Send formal notices to legal@proxima.tools unless we designate another address in writing.

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