Privacy Policy

Last Updated: March 2026

1. Introduction and Scope of This Policy

This Privacy Policy ("Policy") has been prepared by CRYPEXCH TECHNOLOGIES PRIVATE LIMITED ("Company," "we," "our," or "us"), the corporate entity that owns, develops, and operates the digital asset trading platform marketed under the brand name Sikkaa Exchange ("Platform"). The Company is incorporated under the laws of the Republic of India bearing Corporate Identification Number U63999PN2025PTC241988, with its registered office at S. No. 14/10, Sai Park, Shop No. 02, Haveli, Nanded, Pune 411041, Maharashtra, India.

The purpose of this Policy is to explain, in clear and comprehensive terms, exactly what personal information we collect from you, the reasons for which we collect it, the legal basis on which we are permitted to collect and use it, how long we retain it, with whom we share it, and what rights you hold over your own data. We believe that transparency about data practices is a fundamental component of building trust with our users, and this Policy reflects our commitment to that principle.

This Policy applies in its entirety to every individual who accesses or uses any part of the Sikkaa Exchange ecosystem. This includes but is not limited to: visitors to our website at sikkaaexchange.com, registered account holders who have completed the Know Your Customer (KYC) verification process, users of our mobile application (whether on iOS or Android platforms), users who access our services via any application programming interface (API), and any individual who communicates with us through our customer support channels, email correspondence, or live chat systems.

This Policy is incorporated by reference into, and forms part of, our Terms of Service and should be read alongside our Risk Disclosure Policy. In the event of any inconsistency or conflict between this Privacy Policy and our Terms of Service with respect to any data protection matter, this Privacy Policy shall take precedence and govern.

By accessing our Platform, creating an account, or transacting with us in any manner, you confirm that you have read, understood, and agreed to the terms of this Privacy Policy. If you do not agree with any part of this Policy, you must immediately discontinue use of the Platform and may request closure of your account by writing to us at support@sikkaaexchange.com.

Governing Legal Framework
This Policy has been drafted to comply with the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011; the Digital Personal Data Protection Act, 2023 (DPDP Act); the Prevention of Money Laundering Act, 2002 (PMLA) and its associated rules and FIU-IND guidelines; and the applicable obligations of a Virtual Digital Asset Service Provider (VDA-SP) registered with the Financial Intelligence Unit of India (FIU-IND).

2. Who We Are — The Data Controller

For the purposes of the Digital Personal Data Protection Act, 2023 and any other applicable data protection legislation, the "Data Fiduciary" or "Data Controller" responsible for your personal data is CRYPEXCH TECHNOLOGIES PRIVATE LIMITED. We are a private limited company incorporated under the Companies Act, 2013, bearing the Corporate Identification Number U63999PN2025PTC241988. Our registered office is situated at S. No. 14/10, Sai Park, Shop No. 02, Haveli, Nanded, Pune 411041, Maharashtra, India.

We operate the Sikkaa Exchange platform, which provides users with the ability to deposit Indian Rupees (INR), convert INR into USDT (Tether) and other Virtual Digital Assets (VDAs) at a fixed spread rate, execute digital asset trades through an API connection to an underlying trading infrastructure, and withdraw the resulting INR amounts back to their registered Indian bank accounts. This model positions us as a broker of digital asset services rather than a direct exchange, and our users interact exclusively with our platform rather than directly with the underlying liquidity infrastructure.

We operate as a Virtual Digital Asset Service Provider (VDA-SP) as defined under the notifications and circulars issued by the Ministry of Finance, Government of India, under the Prevention of Money Laundering Act, 2002. As a VDA-SP, we are in the process of obtaining and maintaining registration with the Financial Intelligence Unit — India (FIU-IND), and our data collection and processing practices are shaped in significant part by the regulatory obligations that flow from that registration, including mandatory KYC, transaction monitoring, and reporting obligations.

All queries, complaints, and requests relating to your personal data and privacy rights should be directed to our designated Grievance Officer at support@sikkaaexchange.com. We are committed to responding to all data-related queries within thirty (30) business days of receipt, and to acknowledging receipt of your communication within three (3) business days.

3. What Personal Data We Collect

We collect different categories of personal data depending on the nature and depth of your engagement with our Platform. The breadth of data we collect is shaped by our obligation to operate a compliant digital asset trading environment in India, and specifically by the requirements of the Prevention of Money Laundering Act, 2002, the Income Tax Act, 1961 (Section 194S — TDS deduction obligations), and the guidelines of FIU-IND. Below we describe each category of data in detail.

3.1 Identity and Know Your Customer (KYC) Data
We collect comprehensive identity information from every user as a mandatory precondition to account activation. This is not discretionary — Indian law requires us to verify the identity of every individual who transacts on our platform. The identity data we collect includes your full legal name exactly as it appears on your government-issued identity document; your date of birth; your nationality and country of residence; your Permanent Account Number (PAN), which is mandatory for all Indian residents and is used for TDS reporting purposes; your Aadhaar number, of which we store only the last four digits after masking — we do not store the full twelve-digit Aadhaar number under any circumstance; a live selfie photograph taken through our KYC interface, used for facial liveness verification and identity matching, and which is not retained in our systems after the verification is complete; and, for users who are required to complete enhanced KYC, a copy of a passport or Voter Identification Card.

3.2 Contact and Account Credentials
When you register on our Platform, we collect your email address, your mobile phone number, and the residential address you provide. Your email address is used for all transactional communications including deposit confirmations, withdrawal notifications, TDS certificates, and regulatory alerts. Your mobile number is used for one-time password (OTP) authentication during login and for high-security actions such as withdrawal initiation. We store your password exclusively in an irreversibly hashed format using industry-standard bcrypt hashing — we never store or have access to your plain-text password. We also collect and store your security configuration, including your two-factor authentication (2FA) settings, backup verification options, and the history of devices and IP addresses used to access your account.

3.3 Financial and Transaction Data
To process deposits and withdrawals, we collect and store your Indian bank account number and IFSC code, and where applicable your UPI Virtual Payment Address (VPA). Every financial transaction conducted on or through our Platform is recorded comprehensively in our systems. This includes the INR amount deposited and the corresponding USDT amount credited, the conversion rate applied at the time of the transaction, the USDT amount withdrawn and the corresponding INR amount paid out, the date and time of each transaction, the unique transaction reference number (UTR) provided by the banking system, the USDT wallet address to which or from which any external transfer was made, and the current and historical balance of your USDT wallet on our Platform. This transaction data is essential for our statutory TDS deduction and reporting obligations, our AML transaction monitoring obligations, and our own reconciliation and fraud prevention processes.

3.4 Technical and Device Data
Each time you access our Platform — whether through the website or the mobile application — our systems automatically collect certain technical data. This includes your Internet Protocol (IP) address, which we use to determine your approximate geographic location for fraud detection and sanctions screening purposes; the type of device you are using to access the Platform, including the device model, operating system version, and hardware identifiers; the browser you are using, including its version and configuration; a device fingerprint, which is a composite identifier derived from the technical characteristics of your device; the date and time of every login; the duration of your sessions; and navigation patterns within the application. We also collect crash reports and error logs automatically when the application encounters a fault, which help us diagnose and correct technical issues.

3.5 Compliance and Risk Assessment Data
As a regulated financial services provider, we generate and maintain an internal risk profile for every user. This includes the result of the sanctions and watchlist screening conducted at the time of account opening and periodically thereafter; the AML risk score and risk tier assigned to your account based on your transaction behaviour, geography, and other risk indicators; any source-of-funds declarations you provide when required; your status as a Politically Exposed Person (PEP) or close associate of a PEP; records of any suspicious activity flags generated by our transaction monitoring systems; and the history of your KYC tier, including any upgrades or downgrades and the reasons for those changes.

3.6 Customer Support and Communication Data
When you contact us for any reason — whether to report a problem, query a transaction, request account assistance, or provide feedback — we retain a complete record of that interaction. This includes all messages sent through our in-app support chat, all email correspondence sent to or received from support@sikkaaexchange.com, all documents or screenshots you attach to support tickets, and all notes made by our support team in the course of resolving your query. We retain this data to ensure continuity of support, to detect patterns of fraud or abuse, and to demonstrate the steps taken to resolve your concerns in the event of a regulatory inquiry.

What We Do Not Collect
We do not collect or store your full twelve-digit Aadhaar number (only the last four digits after official masking). We do not collect, store, or have access to your plain-text password under any circumstance. We do not collect credit card or debit card data, as we use only UPI and bank transfers for INR transactions. We do not collect full biometric data — our selfie liveness check is used only for identity verification and is not permanently retained in our biometric database.

4. How We Use Your Personal Data

Every use we make of your personal data has a defined purpose and a corresponding legal basis. We do not use your data for any purpose beyond those described in this Policy, and we do not repurpose data collected for one function for an entirely unrelated function without informing you.

4.1 Account Creation and User Onboarding
We use your identity data, contact data, and KYC documents for the purpose of creating and activating your account on our Platform. This processing is necessary for the performance of a contract between you and us — specifically, the contract constituted by your acceptance of our Terms of Service. Without this processing, we simply cannot provide you with a trading account. The mandatory KYC component of this process is additionally required by law and cannot be waived regardless of the amount you intend to transact.

4.2 Processing Deposits and Withdrawals
Your bank account details, UPI ID, and transaction data are used to process your INR deposits and withdrawals. This processing is necessary for the performance of our contract with you. When you deposit INR, your bank credentials are used to verify the payment and to credit the corresponding USDT amount to your wallet at the applicable conversion rate. When you withdraw, your bank credentials are used to send the INR payout to your account after converting your USDT at the applicable rate and deducting the statutory TDS amount.

4.3 KYC, AML, and Regulatory Compliance
This is one of the most significant data processing activities we undertake, and it is driven entirely by our statutory obligations as a VDA-SP registered under the PMLA. We use your full identity data — including PAN, name, date of birth, address, and nationality — to conduct mandatory Know Your Customer verification, to screen your profile against domestic and international sanctions lists and politically exposed persons databases, and to conduct ongoing monitoring of your transaction behaviour for signs of money laundering, terrorist financing, or other financial crime. This processing is not subject to your consent and cannot be disabled. It is a legal obligation, and your continued use of our Platform constitutes your acknowledgment that this processing will occur.

4.4 Tax Compliance — TDS Deduction and Reporting
We are legally required under Section 194S of the Income Tax Act, 1961, to deduct Tax Deducted at Source (TDS) at the rate of one percent (1%) on the full consideration value of every Virtual Digital Asset (VDA) transaction conducted on our Platform. We use your PAN card number for the purpose of reporting this TDS to the Income Tax Department of India, crediting the deducted amount to your Form 26AS on the income tax portal, and issuing the quarterly TDS certificate (Form 16A) to you. This processing is a direct legal obligation and cannot be opted out of.

4.5 Fraud Prevention and Platform Security
We use your technical data — including your IP address, device fingerprint, login patterns, and session behaviour — for the purpose of detecting and preventing fraud, account takeover, suspicious login attempts, and other threats to platform security. We also use your transaction history to identify patterns that are inconsistent with normal legitimate trading activity. This processing is carried out on the basis of our legitimate interest in maintaining a secure and trustworthy trading environment for all users. We have assessed this legitimate interest against the potential impact on your privacy rights and have determined that the processing is proportionate and necessary.

4.6 Customer Support
We use your account data and communication records to respond to your support queries, investigate complaints, resolve disputes, and provide you with accurate and helpful assistance. This processing is necessary both for the performance of our contract with you and for our legitimate interest in operating a professional and responsive support function.

4.7 Marketing Communications
We send marketing communications — such as new product announcements, promotional offers, and platform updates — only where you have given us your explicit and informed consent to do so. You may withdraw your consent at any time by clicking the unsubscribe link included in every marketing email, or by sending a written request to support@sikkaaexchange.com. The withdrawal of consent for marketing communications will not affect any other aspect of your account or the services available to you.

6. KYC, AML, and Compliance Data — Special Provisions

The data we collect and process for the purpose of Know Your Customer verification, Anti-Money Laundering monitoring, and compliance with the Prevention of Money Laundering Act, 2002, is subject to a distinct and more stringent set of rules than other categories of personal data. This section describes those rules in detail.

6.1 Mandatory KYC — No Exceptions
Every individual who creates an account on Sikkaa Exchange is required to complete a minimum level of KYC verification before any deposit, trade, or withdrawal can be processed. This requirement is not a matter of our business policy — it is a direct and non-negotiable legal obligation imposed on us as a Reporting Entity under the PMLA. Failure to complete KYC will result in your account remaining in a restricted state with no transactional capabilities. We cannot grant any exceptions to this requirement regardless of the amount being transacted or the duration of your relationship with the Platform.

6.2 Sanctions Screening and Watchlist Checking
At the time of account registration, and on a periodic basis thereafter, we run your name, date of birth, nationality, and PAN number through a range of domestic and international sanctions screening databases. These include the United States Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons (SDN) list; the United Nations Security Council Consolidated Sanctions List; the European Union Consolidated List of Sanctions; the UK HM Treasury's Financial Sanctions List; the Monetary Authority of Singapore (MAS) sanctions list; the FIU-IND designated persons and entities list; and any other list required by applicable law or our risk management framework. If your profile generates a positive match against any of these lists, your account will be suspended pending investigation, and we will take such further action as is required by law, which may include reporting the match to FIU-IND and freezing your account balance.

6.3 Suspicious Transaction Reports
As a registered Reporting Entity under the Prevention of Money Laundering Act, 2002, we are legally obligated to file a Suspicious Transaction Report (STR) with FIU-IND within seven (7) days of becoming aware of any transaction that we have reasonable grounds to suspect is related to money laundering, terrorist financing, or any other predicate offence under the Schedule to the PMLA. Critically, the law prohibits us from informing the user — you — that an STR has been filed about your account or any of your transactions. This is a statutory gag provision, and we cannot override it even if we wished to. The filing of an STR does not constitute an accusation, a finding of guilt, or any formal allegation against you. It is a mandatory regulatory filing that we are required to make whenever specific triggers are met.

6.4 TDS Deduction and Income Tax Reporting
Under Section 194S of the Income Tax Act, 1961, we are designated as the "person responsible for paying" in the context of Virtual Digital Asset transfers, which makes us legally obligated to deduct one percent (1%) TDS on the full consideration received from every VDA transfer conducted on our Platform, deposit that amount with the Income Tax Department of India by the seventh (7th) of the following month, file the quarterly TDS return in Form 26Q by the due dates prescribed by the Income Tax Department, and issue a quarterly TDS certificate in Form 16A to you within fifteen (15) days of filing the TDS return. Your PAN is used specifically for this purpose — to ensure the TDS we deduct is correctly attributed to your income tax account with the government and reflected in your Form 26AS.

6.5 Sharing Data with FIU-IND and Law Enforcement
We may be required to share your personal data, transaction records, KYC documents, and compliance reports with FIU-IND, the Income Tax Department, the Enforcement Directorate, or other law enforcement and regulatory authorities, either proactively as part of our mandatory reporting obligations or in response to a lawful demand, notice, or court order. We are not required to obtain your consent before making such disclosures, and we are not permitted to notify you in advance of any disclosure made in connection with an STR or active investigation.

7. Sharing and Disclosure of Your Personal Data

We wish to be completely transparent about every instance in which your personal data is shared with a party outside of our organisation. We do not sell your personal data, we do not rent your personal data, and we do not provide your personal data to advertisers or data brokers under any circumstances. The only disclosures we make are those described below, each of which has a clear and legitimate purpose.

7.1 FIU-IND and Regulatory Authorities
We share your identity, transaction, and compliance data with the Financial Intelligence Unit of India as part of our mandatory reporting obligations under the PMLA. This includes Suspicious Transaction Reports (STRs), Cash Transaction Reports (CTRs) for transactions above INR ten lakhs, and any other reports required by FIU-IND's guidelines for VDA-SPs. We may also be required to provide data to the Income Tax Department in connection with TDS filings and audits, to the Enforcement Directorate in connection with any investigation under FEMA or PMLA, and to any other regulatory body with jurisdiction over our operations.

7.2 Banking and Payment Service Providers
To process your INR deposits and withdrawals, we necessarily share your bank account number, IFSC code, name, and transaction amounts with our banking infrastructure provider. This is the Banking-as-a-Service (BaaS) provider through whom we process INR collections and payouts — such as Neocred or any equivalent licensed payment infrastructure provider. These providers are licensed by the Reserve Bank of India and are bound by their own regulatory obligations and data processing agreements with us.

7.3 KYC Verification Service Providers
We use third-party KYC technology providers — such as Hyperverge or an UIDAI-authorised Aadhaar verification API — to conduct the technical aspects of identity verification. Your PAN, masked Aadhaar, and selfie are transmitted to these providers for the purpose of verification. These providers do not retain your data after the verification is completed, and they are contractually bound to handle your data in accordance with our data processing instructions and applicable law.

7.4 Cloud Infrastructure Providers
Our platform data — including your personal information, transaction history, and account data — is stored on enterprise-grade cloud infrastructure operated by providers such as Amazon Web Services (AWS) or Google Cloud Platform (GCP), hosted in the Mumbai (India) region or equivalent compliant infrastructure within India. All data at rest on these systems is encrypted, and access is tightly controlled. These infrastructure providers operate under data processing agreements that bind them to strict confidentiality and security obligations.

7.5 Trading Infrastructure — KuCoin API
Our Platform executes trades through an API connection to KuCoin (operated by Peken Global Limited, incorporated in the Turks and Caicos Islands). In the course of routing trade instructions through this API, anonymised trade data including order type, quantity, and direction is transmitted to KuCoin's servers. Critically, however, your personal identity data — including your name, PAN, Aadhaar, address, email, and phone number — is never transmitted to KuCoin. Your identity is known only to us; KuCoin sees only the sub-account identifier associated with your orders.

7.6 Auditors and Legal Advisors
We may share specific personal data or anonymised datasets with our statutory auditors, internal auditors, legal counsel, or compliance consultants in the course of audits, legal proceedings, or regulatory submissions. All such parties are bound by professional confidentiality obligations and, where required, by explicit non-disclosure agreements.

7.7 Law Enforcement and Court Orders
We will disclose your personal data to law enforcement agencies, courts, or other government bodies where we are legally required to do so under a valid court order, summons, search and seizure warrant, or other lawful legal process. We will, to the extent permitted by law, endeavour to notify you of any such disclosure before it is made. Where we are legally prohibited from providing such advance notice — as is typically the case with PMLA-related disclosures — we will notify you as soon as the prohibition is lifted.

8. Data Retention — How Long We Keep Your Data

We retain different categories of personal data for different periods, determined by a combination of statutory requirements, contractual obligations, and our legitimate operational needs. We do not retain data for longer than is necessary for the purpose for which it was collected, subject always to the minimum retention periods imposed by Indian law.

Your KYC documents and identity verification records — including PAN, Aadhaar details, selfie verification data, and address proof — are retained for a minimum period of five years from the date of account closure. This is a mandatory statutory obligation under Section 12 of the PMLA. Even if you request deletion of your account, this category of data cannot be erased until the five-year statutory period has elapsed.

Your complete transaction history — every deposit, withdrawal, trade, and internal transfer — is similarly retained for a minimum of five years from the date of each transaction under the PMLA. In addition, TDS-related records including the details of every TDS deduction and the corresponding Form 26Q filing and Form 16A issued are retained for a minimum of seven years from the end of the financial year in which the transaction occurred, in accordance with the income tax record-keeping obligations.

Any Suspicious Transaction Reports or Cash Transaction Reports filed with FIU-IND are retained for the period required by FIU-IND guidelines, which is a minimum of five years from the date of the report, and remain accessible to FIU-IND throughout that period.

Your account data — including login history, session records, 2FA configuration, and account preferences — is retained for the duration of your account and for a further two years following account closure, to enable us to respond to any post-closure disputes, fraud investigations, or regulatory inquiries.

Customer support communications, including all emails, chat messages, and ticket records, are retained for a period of three years from the date the support interaction was closed. Server access logs and technical security logs are retained on a rolling twelve-month basis. Marketing preference records are retained until you withdraw your consent, at which point they are deleted within thirty days.

9. Your Rights Over Your Personal Data

The Digital Personal Data Protection Act, 2023 (DPDP Act) confers a number of important rights upon you as a "Data Principal" (i.e., the individual whose data is being processed). We are committed to enabling you to exercise these rights in a straightforward and timely manner. All requests to exercise your data rights should be sent to support@sikkaaexchange.com.

9.1 Right to Access Your Personal Data
You have the right to request a copy of the personal data that we hold about you. Upon receiving a verified request, we will provide you with a summary of the categories of data we hold, the purposes for which it is being processed, and a copy of the data itself in a readable format. We will respond to access requests within thirty (30) days. We may ask you to verify your identity before processing your request to ensure that we do not inadvertently disclose your data to an unauthorised party.

9.2 Right to Correction
If you believe that any personal data we hold about you is inaccurate, incomplete, or out of date, you have the right to request that we correct it. Requests to correct identity-related data (such as name or date of birth) may require you to submit updated official documentation as part of the KYC re-verification process. We will complete the correction within thirty days of receiving sufficient documentation.

9.3 Right to Erasure
You have the right to request that we delete your personal data. However, this right is expressly subject to our legal obligations under the PMLA, the Income Tax Act, and other applicable laws. We cannot delete your KYC documents, your transaction history, or your TDS records before the statutory minimum retention periods have elapsed. We can, however, delete operational data (such as marketing preferences, non-essential cookies, and support tickets beyond our standard retention period) upon request, subject to any overriding legitimate interest.

9.4 Right to Data Portability
You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to have that data transmitted to another controller where technically feasible. We will fulfil portability requests within thirty days of a verified request.

9.5 Right to Withdraw Consent
Where our processing is based on your consent — specifically for marketing communications — you may withdraw that consent at any time with immediate effect. You can do this by clicking the unsubscribe link in any marketing email, adjusting your notification preferences in the app settings, or writing to us at support@sikkaaexchange.com. Withdrawal of consent will not affect the lawfulness of any processing carried out before the withdrawal.

9.6 Right to Grievance Redressal
If you have a complaint about how we are handling your personal data, or believe we are in breach of our data protection obligations, you have the right to lodge a formal grievance with our designated Grievance Officer at support@sikkaaexchange.com. We will acknowledge your grievance within three business days and provide a substantive response within thirty days. If you remain unsatisfied with our response, you may escalate your complaint to the Data Protection Board of India, once the Board is operationally constituted under the DPDP Act, 2023.

9.7 Right to Nominate
Under the DPDP Act, 2023, you have the right to nominate another individual to exercise your data rights on your behalf in the event of your death or incapacity. You may designate a nominee at any time by submitting a nomination form through our support portal or by writing to support@sikkaaexchange.com.

10. Data Security — How We Protect Your Information

The security of your personal data is a matter of paramount importance to us. We have implemented a comprehensive suite of technical and organisational security measures designed to protect your data against unauthorised access, accidental loss, destruction, or disclosure. These measures are reviewed and updated regularly to keep pace with evolving threats and best practices.

All data transmitted between your device and our servers is encrypted in transit using Transport Layer Security (TLS) version 1.2 or higher, which is the industry-standard protocol for securing data in transit over the internet. All data stored on our servers — including your personal information, transaction records, and KYC documents — is encrypted at rest using AES-256 encryption, which is the highest-grade symmetric encryption standard currently available. Your password is never stored in any recoverable format; we use the bcrypt hashing algorithm with an appropriate cost factor to store a one-way hash of your password, meaning that even our own technical staff cannot determine your password from what is stored in our systems. Sensitive fields such as Aadhaar details and bank account numbers are additionally encrypted at the database level using field-level encryption.

Access to your personal data within our organisation is strictly limited to employees and contractors who have a genuine operational need for that access. We operate a role-based access control (RBAC) system, which means that each team member is granted only the minimum level of access necessary for their specific job function. All internal access to user data is logged, and these logs are reviewed regularly for anomalies. Our team members are required to sign confidentiality agreements and undergo regular training on data protection obligations.

We require all users to enable two-factor authentication (2FA) for any high-security action on the Platform, including initiating withdrawals, changing linked bank accounts, modifying 2FA settings, and requesting password resets. We strongly recommend using an authenticator application — such as Google Authenticator or Authy — rather than SMS-based 2FA, as authenticator apps are not vulnerable to SIM-swap attacks, which are a known attack vector in the cryptocurrency industry.

We conduct regular third-party penetration testing and vulnerability assessments of our platform. Identified vulnerabilities are assigned a severity rating and remediated within Service Level Agreement (SLA) timelines proportionate to their severity — critical vulnerabilities are addressed on an emergency basis, while lower-severity issues are tracked and resolved within defined timelines. We also operate a responsible disclosure programme through which security researchers can report vulnerabilities they discover.

Your Responsibility in Account Security
Your account security depends not only on our technical measures but also on the steps you take to protect your own credentials. You should use a strong, unique password for your Sikkaa Exchange account that is not used for any other service. You should never share your password, 2FA codes, or OTPs with any person under any circumstances — including individuals who claim to be Sikkaa Exchange staff, who will never ask for these credentials. If you receive a suspicious communication purporting to be from Sikkaa Exchange, please report it to us immediately at support@sikkaaexchange.com. You should also verify that you are always accessing the Platform through the correct URL: sikkaaexchange.com.

11. Cookies and Tracking Technologies

Our website and mobile application use cookies and similar tracking technologies to ensure the Platform functions correctly, to maintain your security session, and to understand how users interact with our services.

Essential and Strictly Necessary Cookies are used by our Platform for functions that are integral to the operation of the service. These include session authentication cookies that keep you securely logged in throughout your session, security tokens that protect against cross-site request forgery (CSRF) attacks, and state-management cookies used by the 2FA and OTP verification process. These cookies are not optional — they are required for the Platform to work, and they cannot be disabled without disrupting your ability to use the service.

Functional Cookies are used to remember your personal preferences on the Platform, such as your preferred language, display settings, default trading pair, and last-viewed sections of the application. These cookies improve your experience by reducing the need to reconfigure your preferences each time you log in. They are not strictly necessary for the Platform to function, and you may disable them through your browser settings or our in-app preferences panel, though doing so may result in a diminished user experience.

Analytics Cookies collect aggregated, anonymised information about how users navigate and interact with our Platform. We use this data to identify pages or features that are difficult to use, to understand the most common paths users take through the application, and to inform our product development priorities. No personally identifiable information is associated with analytics cookie data. You may opt out of analytics tracking through our cookie preferences panel.

Security Cookies are used by our fraud detection and bot-mitigation systems to distinguish human users from automated scripts, to detect unusual access patterns that may indicate account takeover attempts, and to flag suspicious login activity. These cookies are required for the integrity and security of the Platform and cannot be disabled without potentially compromising the security of your account.

12. Children's Privacy

The Sikkaa Exchange Platform is strictly designed for and intended to be used by individuals who are at least eighteen (18) years of age. We do not knowingly collect, process, or store personal data belonging to children or minors under the age of eighteen. Our KYC verification process, which requires a valid PAN card, acts as an effective age gate — PAN cards cannot be issued to individuals below the age of eighteen, ensuring that minors are screened out at the point of registration.

This restriction is also expressly required by our broker agreement with our underlying trading infrastructure provider, which mandates that every end client must be at least eighteen years of age. If we become aware, or have reasonable cause to believe, that a minor has successfully created an account on our Platform or has had personal data submitted to our systems, we will take immediate steps to close that account, remove all associated personal data from our systems to the fullest extent permitted by law, and where appropriate, notify the relevant guardians or authorities.

If you are a parent or legal guardian and believe that your child has provided personal information to Sikkaa Exchange without your consent, we ask you to contact us immediately at support@sikkaaexchange.com. We will investigate promptly and take appropriate remedial action.

13. Changes to This Privacy Policy

We may update or revise this Privacy Policy from time to time to reflect changes in applicable law, changes in our business operations, the introduction of new features or services on the Platform, or in response to guidance issued by data protection authorities. We are committed to keeping you informed of any changes that materially affect how we process your personal data.

When we make changes to this Policy, we will take the following steps to ensure you are informed. We will update the "Version" number and "Effective Date" shown at the top of this document to reflect the revised version. For material changes — that is, changes that significantly affect your rights or our use of your data — we will notify you by email to the registered email address on your account at least fourteen (14) days before the new version takes effect, and we will display a prominent notification banner on the Platform's homepage and within the application.

Your continued use of the Platform after the effective date of any updated version of this Policy will be treated as your acceptance of the revised terms. If you do not agree with the changes, you must stop using the Platform and may request account closure before the effective date by contacting us at support@sikkaaexchange.com. For changes that are required by law — such as changes mandated by new regulations, court orders, or FIU-IND guidelines — we may implement those changes immediately and provide notice as soon as is reasonably practicable.

14. Contact Us — Grievance Officer Details

We take our privacy obligations seriously and are committed to resolving any concerns you may have about how we handle your personal data. If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or have a complaint about our data practices, please contact our designated Grievance Officer using the details below. Please note that by law, we are required to designate a Grievance Officer under the Information Technology Act, 2000, and the DPDP Act, 2023.

Grievance Officer Contact Details

Designation: Grievance Officer and Data Protection Officer

Company: CRYPEXCH TECHNOLOGIES PRIVATE LIMITED

Brand: Sikkaa Exchange

Registered Office: S. No. 14/10, Sai Park, Shop No. 02, Haveli, Nanded, Pune 411041, Maharashtra, India

Email: support@sikkaaexchange.com

Response Time: Acknowledgement within 3 business days; substantive response within 30 days.

Governing Law: This Policy is governed by the laws of the Republic of India. Disputes shall be subject to the exclusive jurisdiction of the courts at Pune, Maharashtra.

Last Updated: March 2026 — Version 1.0

If you are dissatisfied with the outcome of your grievance, you may escalate the matter to the Data Protection Board of India, once it is operational under the DPDP Act, 2023, or to such other authority as may be designated under applicable law. For matters specifically relating to AML reporting or suspicious activity, the relevant regulatory authority is the Financial Intelligence Unit — India (FIU-IND), accessible at fiuindia.gov.in.