Privacy Policy

Privacy Policy

Effective date: February 7, 2026 · Last updated: February 19, 2026

This Privacy Policy constitutes a legally binding agreement between you and Voxum Software Technology FZCO governing the collection, use, disclosure, storage, protection, and processing of your personal information in connection with your access to and use of the Voxum mobile application and all related services, features, content, and functionality. This Privacy Policy is incorporated by reference into our Terms of Use and Investment Risk Disclaimer and forms an integral part of the contractual relationship between you and the Company. By accessing, downloading, installing, or using the Service, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy in its entirety, and you expressly consent to the collection, use, disclosure, and processing of your personal information as described herein. If you do not agree with any provision of this Privacy Policy, you must immediately cease all use of the Service and uninstall the application from your device.

1. Definitions and Interpretation

For the purposes of this Privacy Policy, the following terms shall have the meanings ascribed to them below. The term Company, we, us, or our refers to Voxum Software Technology FZCO, registered with the IFZA (International Free Zone Authority) Free Zone, Dubai, United Arab Emirates, and includes our affiliates, subsidiaries, officers, directors, employees, agents, contractors, and service providers. The term User, you, or your refers to any individual who accesses, downloads, installs, or uses the Service, whether as a registered user or a visitor. The term Service refers to the Voxum mobile application and all related services, features, content, functionality, trading recommendations, analysis tools, a built-in trading journal, position tracking and customization features, educational materials, and any other products or services provided by the Company. The term Personal Information or Personal Data refers to any information relating to an identified or identifiable natural person, including but not limited to name, email address, payment information, device identifiers, usage data, and any other information that can be used to identify, contact, or locate an individual. The term Processing refers to any operation or set of operations performed on personal data, whether or not by automated means, including collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure, dissemination, restriction, erasure, or destruction. The term Third Party refers to any person or entity other than the User or the Company, including service providers, partners, affiliates, regulatory authorities, and other users. The term Applicable Law refers to all laws, regulations, directives, orders, and legal requirements applicable to the processing of personal data, including but not limited to the laws of the United Arab Emirates, the General Data Protection Regulation where applicable, and any other data protection or privacy laws in jurisdictions where the Service is provided or where users are located.

2. Information We Collect

We collect various categories of personal information from and about users of the Service through different means and for different purposes as described in this section. The collection of information is necessary to provide, maintain, improve, and protect the Service, to fulfill our contractual obligations to you, to comply with legal requirements, and to pursue our legitimate business interests. Your provision of certain information may be mandatory for the creation and maintenance of your account and access to certain features of the Service, and failure to provide such information may result in your inability to use the Service or certain features thereof.

2.1 Information You Provide Directly

When you register for an account, configure your trading preferences, interact with the Service, contact our customer support, participate in surveys or promotions, or otherwise communicate with us, you may provide us with the following categories of information.

Account Registration Information includes your email address, which is required for account creation and serves as your unique identifier and primary means of communication, your password, which you create and which is encrypted and hashed using industry-standard cryptographic algorithms and is never stored in plain text or in a manner that would allow us to retrieve your original password, your username or display name if you choose to provide one, and any other information you voluntarily provide during the registration process.

Trading Configuration Information includes your bot deposit amount, which represents a virtual balance used solely for risk calculation and position sizing within the Service and does not represent actual funds deposited with us or any third party, your selected markets for recommendation generation, which may include cryptocurrencies, foreign exchange, commodities, metals, and other financial instruments, your chosen trading strategies from among those offered by the Service, your risk preferences and tolerance levels, your position sizing preferences, and any other trading-related settings or configurations you specify.

Payment and Billing Information: The Company does not directly collect, store, or process your payment card details, bank account numbers, or other sensitive financial payment credentials on its own servers. All payment transactions for subscription fees are processed by third-party payment service providers, which may include Apple Inc. (for subscriptions purchased through Apple App Store), Google LLC (for subscriptions purchased through Google Play Store), Stripe, Inc., or other payment processors designated by the Company from time to time (collectively, "Payment Processors"). When you make a payment, your payment card details and sensitive financial information are collected and processed directly by the applicable Payment Processor in accordance with their own privacy policy and applicable Payment Card Industry Data Security Standards (PCI DSS). The Company receives only limited transaction-related information from Payment Processors, which may include confirmation of successful or failed payment, transaction identifiers and reference numbers, the date, time, and amount of each transaction, the type of payment method used (such as credit card, debit card, or digital wallet) without the full card number or security credentials, your billing address if provided to the Payment Processor, subscription status information including activation, renewal, cancellation, and expiration dates, and any other information necessary for the Company to manage your subscription, issue receipts, process refunds where applicable, and comply with applicable tax and accounting requirements. You acknowledge that your provision of payment information to Payment Processors is subject to the terms of service and privacy policies of those Payment Processors, and the Company shall not be liable for the handling of your payment information by Payment Processors.

Communications and Support Information includes any information you provide when you contact our customer support team via Telegram, email, or other channels, including the content of your messages, attachments, screenshots, or other materials you submit, your feedback, suggestions, reviews, or responses to surveys, any information you provide in connection with disputes, complaints, or requests for assistance, and records of your communications with us.

User Content includes any information, data, text, images, or other materials you upload, submit, post, or transmit through the Service, including trading strategies, comments, notes, or annotations, manually entered trading positions and trade data, trade notes and journal entries, chart screenshots and other user-uploaded images, any content you share with other users if applicable, and any other materials you create or contribute through the Service.

2.2 Information We Collect Automatically

When you access or use the Service, we automatically collect certain information about your device, your usage of the Service, and your interactions with trading recommendations and features. This information is collected through various technologies including software development kits, application programming interfaces, log files, and similar technologies.

Device Information includes your device type, model, and manufacturer, your operating system and version, your device's unique identifiers such as device ID, advertising ID, or other persistent identifiers, your device's hardware specifications including screen size and resolution, your language and region settings, your time zone, your mobile network information including carrier name, and any other technical information about your device that is necessary for the Service to function properly.

Usage Information includes information about how you access and use the Service, including the date and time of your access, the duration of your sessions, the features and functions you use, the screens and pages you view, the actions you take within the Service, your navigation paths through the Service, the frequency and pattern of your use, any errors, crashes, or performance issues you encounter, and any other information about your interaction with the Service.

Recommendation and Trade Interaction Data includes information about the trading recommendations you receive, view, act upon, or dismiss, including which recommendations you mark as entered, skipped, or closed, the timing of your interactions with recommendations, your entry prices, exit prices, and position sizes if you choose to record them, any notes or annotations you add to recommendations or trades, manually entered trading positions including instrument, direction, entry price, stop loss, take profit, risk percentage, and other trade parameters, and user-uploaded images such as chart screenshots attached to trades or journal entries.

Trading Statistics and Performance Data includes aggregated and calculated data about your recommendation and trading performance, including profit and loss calculations based on the information you provide, win rate, risk-reward ratios, and other performance metrics, position history and trade records you maintain within the Service including both recommendation-based and manually entered trades, trade journal entries including notes and attached images, and any other statistical or analytical data generated by the Service based on your usage and interactions.

Network and Technical Information includes your Internet Protocol address, which may be used to identify your general geographic location, information about your internet connection, browser type and version if you access any web-based components of the Service, referral URLs if you access the Service through a link from another site or application, and technical logs and diagnostics information.

Push Notification Data includes your device push notification token, such as a Firebase Cloud Messaging (FCM) registration token or Apple Push Notification service (APNs) device token, which is a unique identifier assigned to your device that enables us to deliver push notifications to you. We collect and store your push notification token for the purpose of delivering trading recommendation alerts, account notifications, service announcements, and other communications related to the operation of the Service. Your push notification token is associated with your account and is used solely for the delivery of notifications through the Service. We may also collect information about your notification preferences, including which types of notifications you have enabled or disabled, the delivery status of notifications sent to your device, and your interactions with notifications such as whether you opened, dismissed, or acted upon a notification. You may disable push notifications at any time through your device operating system settings or through the notification preferences within the Service. Disabling push notifications will prevent you from receiving real-time trading recommendation alerts, which may materially affect your ability to act on time-sensitive trading recommendations provided by the Service. Your push notification token is transmitted to and stored by Firebase Cloud Messaging, a service operated by Google LLC, in accordance with Google's privacy policy and data processing terms.

2.3 Information We Do Not Collect

Transparency: We want to be transparent about the types of information we do not collect to give you confidence in how we handle your data.

We do not collect or request exchange API keys, trading account credentials, or access to your trading accounts on any cryptocurrency exchange, brokerage, or trading platform. We do not have access to, and we do not collect, your actual trading account balances, positions, or transactions on any exchange or trading platform. We do not collect real-time trading data from exchanges or brokerages, and we do not execute trades on your behalf. We do not collect personal identification documents such as passports, driver's licenses, national identification cards, or social security numbers, except as may be required by applicable law for identity verification or anti-money laundering compliance in certain jurisdictions. We do not collect precise geolocation data or track your physical location beyond the general location that may be inferred from your IP address or time zone setting. We do not collect biometric data such as fingerprints, facial recognition data, or voice prints. We do not collect information about your contacts, phonebook, or address book. We do not access your device's camera, microphone, or photo library except when you explicitly grant permission for specific features, and any such access is limited to the scope necessary for the requested feature. We do not collect information about your use of other applications on your device or your browsing history outside of the Service.

3. How We Use Your Information

We process your personal information for various purposes related to providing, maintaining, improving, and protecting the Service, fulfilling our contractual obligations to you, complying with legal requirements, and pursuing our legitimate business interests. The legal bases for our processing of your personal information may include your consent, the necessity of processing for the performance of our contract with you, our legitimate interests in operating and improving the Service, and compliance with legal obligations. Each purpose for which we process your personal information is described below along with the categories of information used and the legal basis for processing.

3.1 Service Provision and Account Management

We use your personal information to provide, deliver, and maintain the Service and to fulfill our contractual obligations to you as a user. This includes creating, maintaining, and managing your account, including authentication and authorization, password reset and account recovery, account settings and preferences management, and account security monitoring. We generate and deliver personalized trading recommendations based on your selected markets, strategies, and risk preferences, calculate position sizes and risk parameters based on your bot deposit amount and risk tolerance, process and display recommendation information including entry levels, stop losses, take profit targets, and market analysis, track and calculate recommendation and trading performance metrics and statistics, maintain your recommendation history, manually entered trades, trade notes, uploaded images, and trading journal within the Service, and provide access to educational content, market analysis, and other features of the Service. We send you push notifications and in-app alerts for new recommendations, important account updates, and service announcements in accordance with your notification preferences. We process your subscription payments and manage your billing, including charging your payment method, issuing invoices or receipts, processing refunds if applicable, managing subscription renewals and cancellations, and maintaining records of your payment history. We provide customer support and respond to your inquiries, complaints, and requests for assistance. The legal basis for this processing is the performance of our contract with you, as this processing is necessary to provide the Service you have requested and agreed to use.

3.2 Service Improvement and Development

We use your personal information to improve, optimize, and develop the Service and to better understand how users interact with our features. This includes analyzing usage patterns, user behavior, and engagement metrics to identify areas for improvement, understand which features are most valuable to users, and prioritize development efforts. We debug technical issues, diagnose errors and crashes, monitor Service performance and reliability, and optimize the Service for different devices and operating systems. We develop, test, and refine trading strategies and recommendation generation algorithms, evaluate the performance and accuracy of recommendations, and enhance our analytical capabilities. We conduct research and analysis to understand user needs and preferences, identify trends in trading behavior and market conditions, and develop new features, services, or products. We create aggregated, anonymized, or de-identified data for statistical analysis, reporting, and research purposes, which may be used or shared without restriction as it does not identify individual users. The legal basis for this processing is our legitimate interest in improving the Service, enhancing user experience, maintaining the security and integrity of the Service, and developing new offerings, provided that such interests are not overridden by your data protection rights and interests.

3.3 Communication and Marketing

We use your contact information to communicate with you about the Service and, with your consent, to send you marketing communications. This includes sending you important Service updates, notifications about changes to our Terms of Use, Privacy Policy, or other policies, security alerts or notices about suspicious activity on your account, and other transactional or administrative communications necessary for the operation of the Service. We respond to your communications, inquiries, feedback, and requests. With your explicit consent, we may send you promotional emails, newsletters, or other marketing communications about new features, special offers, or other information that may be of interest to you, and you may opt out of such communications at any time by following the unsubscribe instructions in the email or by updating your preferences in the Service. We may send you requests for feedback, reviews, or participation in surveys to help us understand user satisfaction and improve the Service. The legal basis for transactional communications is the performance of our contract with you and compliance with legal obligations. The legal basis for marketing communications is your consent, which you may withdraw at any time.

3.4 Legal Compliance and Protection

We use your personal information to comply with legal obligations, protect our legal rights and interests, and ensure the safety and security of the Service and its users. This includes complying with applicable laws, regulations, and legal processes, responding to lawful requests from government authorities, regulators, or law enforcement, fulfilling tax, accounting, and reporting requirements, and complying with court orders, subpoenas, or other legal demands. We prevent, detect, and investigate fraud, abuse, security incidents, and other illegal or unauthorized activities, enforce our Terms of Use and other policies, protect the rights, property, and safety of the Company, our users, and the public, and resolve disputes and enforce our legal agreements. We maintain records and documentation required for legal, regulatory, or audit purposes. The legal basis for this processing is compliance with legal obligations and our legitimate interest in protecting our legal rights, preventing fraud and abuse, and ensuring the security and integrity of the Service.

4. How We Share Your Information

We do not sell, rent, lease, or trade your personal information to third parties for their marketing purposes. However, we may share your personal information with certain third parties in limited circumstances as described in this section. Any sharing of your personal information is conducted in accordance with applicable data protection laws and is subject to appropriate safeguards to protect your privacy and security.

4.1 Service Providers and Business Partners

We may share your personal information with trusted third-party service providers, vendors, contractors, and business partners who perform services on our behalf or assist us in operating the Service. These third parties are authorized to use your personal information only as necessary to provide the specific services they perform for us and are contractually obligated to maintain the confidentiality and security of your information and to comply with applicable data protection laws. Categories of service providers with whom we may share information include payment processors and payment gateway providers who process subscription payments and billing transactions, cloud hosting and infrastructure providers who host our servers, databases, and application infrastructure, push notification services that deliver recommendation alerts and notifications to your device, email service providers who send transactional and marketing emails on our behalf, customer support and helpdesk platforms that assist us in responding to user inquiries and requests, analytics and monitoring services that help us understand usage patterns and Service performance, security and fraud prevention services that protect against unauthorized access and malicious activities, data backup and disaster recovery services, and professional advisors including legal counsel, accountants, and auditors who provide professional services to the Company. When engaging service providers, we implement appropriate contractual and technical safeguards to ensure they process your information only for specified purposes, maintain adequate security measures, and comply with their obligations under applicable data protection laws.

4.2 Legal and Regulatory Disclosures

We may disclose your personal information to government authorities, regulators, law enforcement agencies, courts, or other third parties when we believe in good faith that such disclosure is necessary or appropriate to comply with applicable laws, regulations, legal processes, or governmental requests, respond to subpoenas, court orders, or legal proceedings, establish, exercise, or defend our legal rights or claims, protect the rights, property, safety, or security of the Company, our users, or the public, prevent, detect, or investigate fraud, security incidents, or illegal activities, enforce our Terms of Use or other agreements, or comply with regulatory requirements including anti-money laundering, know-your-customer, sanctions screening, or other financial compliance obligations in jurisdictions where such obligations apply. In such cases, we will disclose only the information that is necessary and relevant to the specific legal or regulatory requirement and will take reasonable steps to ensure that any disclosure is lawful and proportionate.

4.3 Business Transfers and Corporate Transactions

In the event of a merger, acquisition, consolidation, restructuring, reorganization, dissolution, sale of assets, bankruptcy, or other corporate transaction or proceeding involving the Company, your personal information may be transferred, sold, or assigned to the successor entity or third party acquirer as part of the transaction. In such circumstances, we will use reasonable efforts to ensure that the recipient entity agrees to treat your personal information in accordance with this Privacy Policy or will provide you with notice and an opportunity to opt out of the transfer if required by applicable law. If the Company undergoes a change of ownership or control, the new owner may continue to use your personal information as described in this Privacy Policy unless you are provided with notice and an opportunity to make different choices regarding the use of your information.

4.4 Aggregated and Anonymized Information

We may share aggregated, anonymized, or de-identified information that does not identify you personally with third parties for various purposes including research, analysis, marketing, and development of new products or services. Such information is processed in a manner that ensures it cannot reasonably be used to identify you or any individual user, and it is not subject to the restrictions on sharing personal information described in this Privacy Policy. Examples of aggregated information may include statistical data about user demographics, usage patterns, recommendation and trading performance metrics, or market trends.

4.5 With Your Consent

We may share your personal information with third parties when you have provided your explicit consent to such sharing. For example, if you choose to integrate the Service with third-party applications, platforms, or services, you may be asked to authorize the sharing of certain information with those third parties, and such sharing will be subject to the terms of your consent and the privacy policies of those third parties. You may withdraw your consent to such sharing at any time by revoking the integration or authorization, though this will not affect the lawfulness of processing based on consent before its withdrawal.

5. International Data Transfers

The Service is operated globally, and your personal information may be transferred to, stored in, and processed in countries other than the country in which you reside, including the United Arab Emirates, the European Union, the United States, and other jurisdictions where our servers, service providers, or business operations are located. These countries may have data protection laws that differ from the laws of your country of residence and may not provide the same level of data protection. When we transfer your personal information to other countries, we implement appropriate safeguards to ensure that your information receives an adequate level of protection in accordance with applicable data protection laws. These safeguards may include ensuring that the recipient country has been determined to provide an adequate level of protection by relevant data protection authorities, implementing standard contractual clauses or other approved transfer mechanisms, obtaining your explicit consent to the transfer where required by law, or relying on derogations for specific situations as permitted by applicable law. By using the Service and providing your personal information, you acknowledge and consent to the transfer of your information to countries outside your country of residence for the purposes described in this Privacy Policy. If you have questions or concerns about international transfers of your personal information, you may contact us using the contact information provided in this Privacy Policy.

6. Data Security and Protection

We implement and maintain reasonable technical, administrative, and physical security measures designed to protect your personal information from unauthorized access, use, disclosure, alteration, loss, or destruction. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security of your information. You acknowledge and accept the inherent security risks of providing information over the internet and using online services, and you agree that we shall not be liable for any unauthorized access to, use of, or disclosure of your personal information except to the extent such unauthorized access results from our gross negligence or willful misconduct.

6.1 Technical Security Measures

Our technical security measures include encryption of data in transit using Transport Layer Security or other industry-standard encryption protocols to protect information transmitted between your device and our servers, encryption of sensitive data at rest including passwords, payment information, and other sensitive personal data, secure password storage using industry-standard hashing algorithms such as bcrypt with salt to ensure that passwords are never stored in plain text or in a reversible format, regular security updates and patches to our systems, software, and infrastructure to address known vulnerabilities, firewalls, intrusion detection and prevention systems, and other network security controls to protect our systems from unauthorized access and attacks, secure coding practices and security testing including regular vulnerability assessments and penetration testing, data backup and disaster recovery procedures to protect against data loss and ensure business continuity, and monitoring and logging of system access and activities to detect and respond to security incidents.

6.2 Administrative Security Measures

Our administrative security measures include access controls and authorization procedures to limit access to personal information to only those employees, contractors, and service providers who have a legitimate business need to access such information, background checks and security training for employees and contractors who have access to personal information, confidentiality and non-disclosure agreements for employees, contractors, and service providers who handle personal information, security policies, procedures, and standards governing the handling, storage, and disposal of personal information, incident response plans and procedures to address security breaches and data incidents, regular security audits and compliance assessments, and a data protection officer or designated privacy contact responsible for overseeing data protection and privacy matters.

6.3 Your Security Responsibilities

You are responsible for maintaining the security of your account and device. You agree to use a strong, unique password for your account that is not used for any other service or account, not to share your password or account credentials with any other person, to log out of your account when you are finished using the Service, particularly on shared or public devices, to keep your device and operating system up to date with the latest security patches and updates, to use security features such as device passwords, biometric authentication, or device encryption to protect your device from unauthorized access, to be vigilant against phishing attempts, social engineering, or other attempts to obtain your password or personal information, and to notify us immediately if you become aware of any unauthorized access to or use of your account. Any unauthorized use of your account that results from your failure to maintain the security of your credentials may be attributed to you, and you may be liable for any losses or damages resulting from such unauthorized use.

6.4 Security Incident Notification

In the event of a security incident involving your personal information, we will take appropriate steps to investigate the incident, mitigate its effects, and prevent future incidents. If we determine that there has been unauthorized access to, disclosure of, or loss of personal information that poses a risk to your rights and freedoms, we will notify you of the incident without undue delay and in accordance with applicable law. Our notification will include a description of the incident, the categories of personal information affected, the likely consequences of the incident, the measures we have taken or propose to take to address the incident and mitigate its effects, and contact information for further inquiries. We may delay notification if required by law enforcement or if notification would impede a criminal investigation, but we will provide notice as soon as we are permitted to do so.

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, to provide the Service to you, to comply with our legal obligations, to resolve disputes, to enforce our agreements, and to protect our legal rights and interests. The specific retention period for different categories of personal information may vary based on the nature of the information, the purpose for which it was collected, and applicable legal requirements. When determining retention periods, we consider factors such as the duration of your use of the Service, whether you have an active account, the nature and sensitivity of the information, legal and regulatory requirements for record retention, the potential risk of harm from unauthorized use or disclosure of the information, and whether we can achieve the purposes for processing through other means such as anonymization.

7.1 Active Account Data

While your account is active and you continue to use the Service, we retain your account information, trading configuration, usage data, recommendation history, manually entered trades, trade notes, uploaded images, and other information necessary to provide the Service to you and to maintain a complete record of your interactions with the Service. You may access, review, update, or modify certain information in your account at any time through the account settings in the Service.

7.2 Closed or Deleted Account Data

You may request deletion of your account at any time by (a) using the account deletion feature available in the Settings section of the Service, if such feature is available; (b) contacting our support team via email at support@voxum.net; or (c) contacting our support team via Telegram at @Voxum_Co_Support. Upon receiving a valid account deletion request, we will verify your identity to prevent unauthorized deletion of accounts and will process your request in accordance with the timelines set forth below.

If you close or delete your account, we will delete or anonymize your personal information in accordance with the following timeline and procedures:

Important: Account deletion is permanent and irreversible. Once your account has been deleted and the applicable retention periods have expired, we will not be able to recover your account, trading history, performance statistics, configurations, trade notes, uploaded images, or any other data associated with your account. You are advised to export any data you wish to retain prior to submitting an account deletion request. If you wish to use the Service after deleting your account, you will need to create a new account, and your previous trading history and statistics will not be available.

If you subscribed through Apple App Store or Google Play Store, you must separately cancel your subscription through the applicable platform to avoid continued billing after your account is deleted, as the Company does not have the ability to cancel subscriptions managed by third-party platforms on your behalf.

Upon completion of the account deletion process and the expiration of any applicable mandatory retention periods, we will send a confirmation to the last email address associated with your account confirming that your personal information has been deleted in accordance with this Privacy Policy, except where sending such confirmation is not technically feasible due to the deletion of your email address.

7.3 Legal and Compliance Retention

Notwithstanding the above, we may retain personal information for longer periods if required or permitted by applicable law, including to comply with legal obligations, respond to legal processes, establish, exercise, or defend legal claims, comply with audit, tax, accounting, or regulatory requirements, or if retention is necessary for our legitimate interests such as fraud prevention and security. If we retain information for legal or compliance purposes after your account is deleted, such information will be securely stored with restricted access and will be used only for the specific legal or compliance purpose for which it is retained.

8. Your Rights and Choices

Depending on your jurisdiction and applicable law, you may have certain rights regarding your personal information. These rights may include the right to access, correct, delete, restrict processing of, object to processing of, or port your personal information, as well as the right to withdraw consent and the right to lodge a complaint with a data protection authority. We respect and will facilitate the exercise of your rights in accordance with applicable law, subject to certain limitations and exceptions provided by law. To exercise any of these rights, please contact us using the contact information provided in this Privacy Policy, and we will respond to your request within the timeframe required by applicable law, typically within thirty days.

8.1 Right to Access

You have the right to request confirmation of whether we process your personal information and to obtain access to your personal information and certain information about how we process it. If you request access to your information, we will provide you with a copy of the personal information we hold about you, along with information about the purposes of processing, the categories of personal information, the recipients or categories of recipients to whom the information has been or will be disclosed, the retention period or criteria for determining the retention period, and the source of the information if it was not collected directly from you. You may exercise this right by submitting a request through the account settings in the Service or by contacting us directly.

8.2 Right to Correction

You have the right to request correction or update of inaccurate or incomplete personal information we hold about you. You may update certain account information directly through the account settings in the Service. For other information that you cannot update yourself, you may submit a request for correction by contacting us, and we will review and process your request in accordance with applicable law. We may request additional information or documentation to verify the accuracy of the corrected information.

8.3 Right to Deletion

You have the right to request deletion or erasure of your personal information in certain circumstances, including when the information is no longer necessary for the purposes for which it was collected, when you withdraw consent on which processing is based and there is no other legal ground for processing, when you object to processing and there are no overriding legitimate grounds for processing, when the information has been unlawfully processed, or when deletion is required to comply with a legal obligation. However, we may deny your deletion request if retention of the information is necessary for compliance with legal obligations, establishment, exercise, or defense of legal claims, or other reasons permitted by applicable law. If we delete your personal information, we will also delete or anonymize any associated data, subject to legal retention requirements.

8.4 Right to Restriction of Processing

You have the right to request restriction of processing of your personal information in certain circumstances, including when you contest the accuracy of the information and we are verifying the accuracy, when processing is unlawful and you request restriction instead of deletion, when we no longer need the information but you need it for legal claims, or when you have objected to processing and we are verifying whether our legitimate grounds override your interests. When processing is restricted, we will store the information but will not otherwise process it except with your consent, for legal claims, to protect the rights of another person, or for important public interest reasons.

8.5 Right to Object

You have the right to object to processing of your personal information that is based on legitimate interests or performed for direct marketing purposes. If you object to processing for direct marketing, we will cease processing your information for such purposes. If you object to processing based on legitimate interests, we will cease processing unless we can demonstrate compelling legitimate grounds for processing that override your interests, rights, and freedoms, or the processing is necessary for establishment, exercise, or defense of legal claims.

8.6 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that information to another controller where technically feasible. This right applies to information you have provided to us and that we process based on consent or for performance of a contract. You may exercise this right by requesting an export of your data through the account settings in the Service or by contacting us directly.

8.7 Right to Withdraw Consent

Where we process your personal information based on your consent, you have the right to withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. You may withdraw consent for certain processing activities through the account settings in the Service, such as by disabling push notifications, opting out of marketing communications, or revoking integrations with third-party services. For other processing activities, you may withdraw consent by contacting us directly.

8.8 Right to Lodge a Complaint

If you believe that our processing of your personal information violates applicable data protection laws or that your rights have been infringed, you have the right to lodge a complaint with a supervisory authority or data protection authority in the jurisdiction where you reside, where you work, or where the alleged infringement occurred. We encourage you to contact us first so that we can attempt to resolve your concerns, but you have the right to contact a supervisory authority at any time.

8.9 Opt-Out Rights

You have the right to opt out of certain types of communications and data processing. You may opt out of marketing emails by clicking the unsubscribe link in any marketing email or by updating your preferences in the account settings. You may opt out of push notifications by disabling notifications in your device settings or in the Service settings. You may opt out of certain analytics or tracking by adjusting your device settings or by contacting us, though some analytics are necessary for the operation of the Service and cannot be disabled. Opting out of communications or analytics will not affect transactional or administrative messages that are necessary for the operation of the Service.

9. Children's Privacy

The Service is not intended for, and we do not knowingly collect personal information from, individuals under the age of eighteen or the age of majority in their jurisdiction, whichever is greater. We do not knowingly solicit, collect, or maintain personal information from children, and we do not knowingly allow children to register for accounts or use the Service. If we become aware that we have collected personal information from a child without parental consent, we will take steps to delete such information as soon as possible. If you believe that we may have collected personal information from a child, please contact us immediately using the contact information provided in this Privacy Policy, and we will investigate and take appropriate action. Parents and legal guardians are responsible for monitoring their children's use of devices and internet services and should ensure that children do not access or use the Service.

10. Third-Party Services and Links

The Service may contain links to, or may integrate with, third-party websites, applications, platforms, services, or resources that are not owned or controlled by the Company. This Privacy Policy applies only to the Service and does not apply to any third-party services. We are not responsible for the privacy practices, data collection, or content of any third-party services, and we do not endorse or make any representations about third-party services. When you access third-party services through links in the Service or when you grant the Service permission to integrate with third-party services, you do so at your own risk and subject to the terms of use and privacy policies of those third-party services. We encourage you to review the privacy policies of any third-party services before providing them with your personal information or granting them access to your data. Third-party services may have their own policies regarding data collection, use, and sharing, and we have no control over how they process your information. If you choose to use third-party payment services to process subscription payments, those services will collect and process your payment information in accordance with their own privacy policies and applicable law, and we will receive only limited information necessary to process your subscription, such as confirmation of payment and transaction identifiers. We are not responsible for the security or privacy practices of third-party payment processors, and you should review their policies before providing payment information.

11. Cookies and Tracking Technologies

The Voxum mobile application does not use browser cookies as it is a native mobile application and not a web-based service. However, we may use other tracking technologies and identifiers within the mobile application to provide functionality, enhance user experience, analyze usage, and improve the Service. These technologies may include device identifiers such as unique device IDs, advertising identifiers, or other persistent identifiers that are used to recognize your device and associate your usage with your account. We use device identifiers for purposes such as authentication and session management, push notification delivery, analytics and usage tracking, fraud prevention and security, and personalization of the Service. Session data and temporary identifiers may be used to maintain your login session and preferences during a single use of the Service.

Analytics Software Development Kits: The Service may integrate third-party analytics software development kits (SDKs) or tools to collect usage statistics, performance metrics, error diagnostics, and other analytical information to help the Company understand how users interact with the Service and to improve its features and performance. As of the effective date of this Privacy Policy, the Company plans to integrate Firebase Analytics, a mobile analytics service provided by Google LLC, to collect and analyze usage data including but not limited to session frequency and duration, feature engagement metrics, user retention and conversion data, application crashes and error reports, device and operating system distribution, subscription lifecycle events, and recommendation and trade interaction analytics. Firebase Analytics may use device identifiers, instance IDs, and other tracking technologies to collect and process this information. Data collected through Firebase Analytics is processed by Google LLC in accordance with Google's privacy policy and data processing terms. The Company may integrate additional analytics tools in the future, and any such integration will be disclosed through an update to this Privacy Policy in accordance with Section 12. You may have options to control or limit analytics tracking through your device settings, such as disabling advertising identifiers, enabling "Limit Ad Tracking" or equivalent settings on your device, or resetting device identifiers. However, some analytics functionality is necessary for the operation, security, and maintenance of the Service and cannot be fully disabled without affecting the functionality or availability of the Service. If we operate a website or web-based components of the Service in the future, those components may use cookies and similar web-based tracking technologies, and we will provide notice and obtain consent as required by applicable law.

12. Changes to This Privacy Policy

We reserve the right to modify, amend, or update this Privacy Policy at any time in our sole discretion to reflect changes in our practices, technology, legal requirements, or for other operational, legal, or regulatory reasons. If we make material changes to this Privacy Policy that affect how we collect, use, or share your personal information, we will provide notice of such changes by posting the updated Privacy Policy on the Service with a revised effective date, sending you an email notification to the address associated with your account, displaying a prominent notice within the Service, or by other reasonable means of notification. Material changes will be effective thirty (30) days after we provide notice of such changes, or immediately upon your acceptance of the modified Privacy Policy, whichever is earlier, unless applicable law requires a different notice period or method. Changes that are not material, such as clarifications, corrections, or administrative changes, may be effective immediately upon posting the updated Privacy Policy. Your continued use of the Service following the effective date of any changes constitutes your acceptance of the modified Privacy Policy. If you do not agree to the modified Privacy Policy, you must cease using the Service and may delete your account. We recommend that you review this Privacy Policy periodically to stay informed of any updates. The most current version of this Privacy Policy will always be available through the Service and will supersede all previous versions. If required by applicable law, we will obtain your explicit consent to material changes that expand the scope of processing or introduce new purposes for processing your personal information.

13. California Privacy Rights

If you are a resident of California, you may have additional rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act or other California privacy laws. These rights may include the right to know what personal information we collect, use, disclose, or sell, the right to delete personal information subject to certain exceptions, the right to opt out of the sale or sharing of personal information, the right to correct inaccurate personal information, the right to limit the use and disclosure of sensitive personal information, and the right not to be discriminated against for exercising your privacy rights. We do not sell personal information as defined by California law, and we do not share personal information for cross-context behavioral advertising. If you wish to exercise your California privacy rights, you may submit a request by contacting us using the contact information provided in this Privacy Policy. We will verify your identity before processing your request and will respond within the timeframe required by California law. You may designate an authorized agent to submit requests on your behalf, provided that you provide written authorization or a power of attorney and the agent provides proof of authorization. We may deny requests from authorized agents who cannot provide proof of authorization. For more information about our privacy practices and how we handle California residents' personal information, please review this Privacy Policy in its entirety.

14. European Economic Area and United Kingdom Rights

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you may have additional rights under the General Data Protection Regulation, the UK General Data Protection Regulation, or other applicable data protection laws. The rights described in this Privacy Policy, including the rights to access, correction, deletion, restriction, objection, portability, and withdrawal of consent, are based on these laws. You also have the right to lodge a complaint with a supervisory authority in the country where you reside, where you work, or where an alleged infringement of data protection law occurred. For users in the European Economic Area or the United Kingdom, the data controller responsible for your personal information is Voxum Software Technology FZCO, registered with the IFZA Free Zone, Dubai, United Arab Emirates. If we appoint a representative in the European Union or United Kingdom as required by law, we will provide their contact information in this Privacy Policy. When we process your personal information, we rely on one or more of the following legal bases: your consent for specific processing activities, performance of the contract between you and us, compliance with our legal obligations, protection of your vital interests or those of another person, performance of a task carried out in the public interest, or our legitimate interests or those of a third party, provided that your interests and fundamental rights do not override those interests. If you have questions about the legal basis for processing your personal information or wish to exercise your rights under European data protection law, please contact us using the contact information provided in this Privacy Policy.

15. Data Protection Officer and Contact Information

If you have any questions, concerns, comments, or requests regarding this Privacy Policy, our privacy practices, or the processing of your personal information, or if you wish to exercise any of your rights under applicable data protection laws, please contact us using the following information. You may contact our support team via Telegram Support at @Voxum_Co_Support, and we will direct your inquiry to the appropriate personnel. For privacy-specific inquiries, you may request to speak with our Data Protection Officer or privacy contact. For legal inquiries and data protection matters, you may contact us at support@voxum.net.

16. Governing Law and Dispute Resolution

This Privacy Policy and any disputes arising out of or relating to the privacy, collection, use, or disclosure of personal information shall be governed by and construed in accordance with the laws of the United Arab Emirates and the regulations applicable within the IFZA (International Free Zone Authority) Free Zone, Dubai, without regard to conflict of law principles. Any dispute, claim, or controversy arising out of or relating to this Privacy Policy, or the breach, termination, enforcement, interpretation, or validity thereof, shall be subject to the exclusive jurisdiction of the competent courts of Dubai, United Arab Emirates, and you hereby irrevocably consent to the personal jurisdiction and venue of such courts. To the extent permitted by applicable law, any claims or causes of action arising out of or related to our privacy practices or the processing of your personal information must be filed within one (1) year after such claim or cause of action arose, or they shall be forever barred. Notwithstanding the foregoing, if you are located in a jurisdiction that provides mandatory consumer protection rights or data protection rights that cannot be waived by agreement, such rights shall remain in effect and this provision shall not limit your ability to exercise such rights or bring claims under applicable consumer protection or data protection laws.

17. Severability and Waiver

If any provision of this Privacy Policy is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be modified to the minimum extent necessary to make it valid and enforceable while preserving its intent, or if such modification is not possible, such provision shall be severed from this Privacy Policy, and the remaining provisions shall remain in full force and effect. The invalidity or unenforceability of any provision shall not affect the validity or enforceability of any other provision. Our failure to enforce any provision of this Privacy Policy or to exercise any right shall not constitute a waiver of that provision or right, nor shall it prevent us from enforcing such provision or exercising such right in the future. Any waiver must be in writing and signed by an authorized representative of the Company.

18. Entire Agreement

This Privacy Policy, together with our Terms of Use and Investment Risk Disclaimer, constitutes the entire agreement between you and the Company regarding the privacy, collection, use, disclosure, and processing of your personal information in connection with the Service and supersedes all prior or contemporaneous agreements, understandings, representations, warranties, or communications, whether written or oral, relating to such subject matter. In the event of any conflict or inconsistency between this Privacy Policy and our Terms of Use or other policies, this Privacy Policy shall control with respect to privacy and data protection matters, except where the Terms of Use expressly impose additional obligations or restrictions related to data protection.

19. Language

This Privacy Policy is drafted in the English language. If this Privacy Policy is translated into any other language, the English language version shall be controlling in all respects and shall prevail in the event of any inconsistencies or discrepancies between the English version and any translated version. You acknowledge that you have read and understood the English version of this Privacy Policy, or that you have had the opportunity to have it translated and explained to you in a language you understand.

20. Acknowledgment and Acceptance

By accessing, downloading, installing, or using the Service, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy in its entirety. You acknowledge that you have been informed of how we collect, use, disclose, and protect your personal information, and you consent to such collection, use, disclosure, and protection in accordance with this Privacy Policy. You acknowledge that you have been informed of your rights under applicable data protection laws and the means by which you may exercise those rights. If you do not agree with any provision of this Privacy Policy, you must not use the Service and must delete the application from your device.

Effective Date: February 7, 2026. Last Updated: February 19, 2026.