SOES Privacy Policy

Last updated: May 5, 2026

SOES respects your privacy. This Privacy Policy explains how SOES collects, uses, shares, and protects information when you visit our website, contact us, participate in a demo, apply for onboarding, or use any SOES account, trading, market data, API, settlement, or support services that link to this Policy.

1. Information We Collect

We may collect:

Contact and business information, such as your name, work email, phone number, company, job title, and communications with us.

Institutional onboarding information, such as legal entity details, ownership and control information, tax or registration numbers, authorized users, identity verification materials, source-of-funds information, sanctions/KYB/KYC results, and related compliance records.

Trading, settlement, and platform information, such as account identifiers, order and trade records, FIX/API logs, market data access, risk and limit information, wallet addresses, Lightning or Taproot Assets settlement details, invoices, payment identifiers, channel-related information, and cryptographic receipts.

Website and device information, such as IP address, browser type, device identifiers, pages visited, cookies, analytics data, log files, and security monitoring data.

SOES does not ask for seed phrases, private keys, or signing keys.

2. How We Use Information

We use information to:

Operate, secure, and improve the SOES website, exchange, APIs, market data, clearing, settlement, and support services.

Onboard institutions, verify authorized users, conduct KYB/KYC, screen for sanctions, monitor activity, prevent fraud, and comply with applicable laws and regulatory obligations.

Process orders, trades, settlement obligations, risk limits, reporting, reconciliations, audits, receipts, and customer support requests.

Maintain system integrity, investigate incidents, enforce our agreements, and protect SOES, participants, and the market.

Send service messages and, where permitted, business updates or marketing communications. You may opt out of marketing at any time.

Create aggregated, anonymized, or de-identified data for analytics, reporting, security, and product improvement.

3. Verifiable Exchange Data

SOES may generate cryptographic receipts, hashes, Merkle roots, and other audit proofs related to exchange activity. Some commitments may be anchored to Bitcoin or another public ledger.

These public commitments are designed to prove integrity without publishing personal information, confidential account details, or private trade details. Public blockchain data may be visible to anyone and may not be removable by SOES.

4. How We Share Information

We may share information with:

Service providers that support hosting, security, analytics, communications, onboarding, identity verification, sanctions screening, transaction monitoring, banking, settlement, professional services, and customer support.

Regulators, law enforcement, courts, auditors, or other parties when required or permitted by law.

Participants or their authorized representatives as needed to provide account, trading, market data, clearing, settlement, reporting, or support services.

Affiliates, successors, or parties involved in a merger, financing, acquisition, restructuring, or sale of assets.

We do not sell personal information. If we use cookies or advertising tools that require an opt-out under applicable law, we will provide the required choice.

5. Cookies

We may use cookies and similar technologies to operate the site, remember preferences, improve performance, understand usage, and protect against fraud or abuse. You can adjust cookie settings through your browser or any cookie tools we provide.

6. Security

We use administrative, technical, and physical safeguards designed to protect information, including access controls, monitoring, encryption where appropriate, and security procedures. No system is completely secure, but we work to protect information against unauthorized access, misuse, loss, or disclosure.

7. Retention

We keep information for as long as needed to provide services, comply with legal and regulatory obligations, maintain audit records, resolve disputes, enforce agreements, and protect our systems and users. Retention periods may be longer for compliance, AML, sanctions, tax, accounting, security, or trading records.

8. Your Choices and Rights

Depending on where you live, you may have the right to request access to, correction of, deletion of, or a copy of certain personal information. You may also have the right to opt out of certain uses.

We may need to verify your identity or authority before responding. We may also retain information where required or permitted by law, including for compliance, security, audit, or dispute-resolution purposes.

9. Children

SOES is intended for institutional and business users. Our website and services are not directed to children under 18, and we do not knowingly collect information from children.

10. Third-Party Sites

Our website or services may link to third-party websites, tools, wallets, networks, or services. Their privacy practices are governed by their own policies.

11. Updates

We may update this Privacy Policy from time to time. The “Last updated” date above shows when it was last revised. Material changes will be posted on our website.

12. Contact Us

For privacy questions or requests, contact: