GDPR Compliance Statement

Version 2.1 · Last Updated: 16 July 2026 · Effective: 16 July 2026

1. Overview

Clearex Market, LLC, a limited liability company organized under the laws of the State of Delaware, United States (operating as "CLEAREX.MARKET" or the "Platform"), recognizes and embraces its data protection responsibilities. We adopt the data protection principles and data subject rights set forth under the General Data Protection Regulation (EU) 2016/679 ("GDPR") and the UK GDPR for users residing in the European Economic Area (EEA) and the United Kingdom.

Although our corporate domicile is in the United States and we operate a global remote model, all Platform data at rest is hosted within the EEA (see Section 6), and we apply uniform technical and organisational standards to protect every user's privacy.

2. Core Data Processing Principles (GDPR Art. 5)

• Lawfulness, fairness, transparency (Art. 5(1)(a)): every data stream is mapped to a verified legal basis, documented in our Privacy Policy.
• Purpose limitation (Art. 5(1)(b)): personal data is used strictly for the services described in our Privacy Policy. Identifiers are never repurposed, cross-profiled, or sold to data brokers.
• Data minimisation (Art. 5(1)(c)): we operate a passwordless, magic-link authentication system; the primary stored identifier is a verified email address.
• Accuracy (Art. 5(1)(d)): self-service profile controls let you correct your data in real time.
• Storage limitation (Art. 5(1)(e)): personal data is kept only for an active account lifecycle. Upon verified account erasure, profile data is permanently deleted. To comply with United States federal tax, accounting, and audit requirements, transactional financial metadata and billing history are segregated and retained for seven (7) years from the transaction date — exactly as stated in our Privacy Policy.
• Integrity and confidentiality (Art. 5(1)(f)): TLS 1.3 in transit and AES-256 encryption at rest.

3. Legal Bases (GDPR Art. 6)

• Contract performance (Art. 6(1)(b)): delivering the services you request — your account, analytical dashboards, membership tiers, the Tools Library, courses, the Trading Journal, and community forums.
• Legal obligation (Art. 6(1)(c)): US federal auditing, tax, and corporate record-keeping requirements.
• Legitimate interests (Art. 6(1)(f)): platform and user security — fraud monitoring, intrusion prevention, credential-stuffing defence, and operating our breach-check security engine.
• Consent (Art. 6(1)(a)): opt-in analytics cookies and optional features, withdrawable at any time.

4. Data Subject Rights (GDPR Chapter III)

You can exercise the following rights free of charge:

• Access (Art. 15): obtain confirmation and a copy of your data — self-service JSON export from your dashboard (GET /api/user/export).
• Rectification (Art. 16): correct your profile data through your dashboard.
• Erasure / "right to be forgotten" (Art. 17): permanently delete your account via account settings (DELETE /api/user), subject to the statutory financial-record retention in Section 2.
• Restriction (Art. 18) and Objection (Art. 21): via our DPO.
• Data portability (Art. 20): structured, machine-readable export from your dashboard.
• Withdrawal of consent: at any time, where consent is the legal basis.

For any request outside the self-service panels, contact privacy@clearex.market. We resolve verified requests within thirty (30) days.

5. Sub-Processors & Recipients

We share specific data categories only with the providers named in Section 7 of our Privacy Policy (AWS EMEA — Stockholm; Resend; NOWPayments; Stripe — card payment processing, where enabled; FastSpring as independent-controller Merchant of Record for card purchases; Anthropic — AI briefing generation; Google Analytics 4 — opt-in only). Every sub-processor operates under a binding Data Processing Agreement incorporating Standard Contractual Clauses or an applicable adequacy mechanism.

6. International Data Transfers & Remote Operations

Platform data at rest is hosted in the EEA: AWS region eu-north-1 (Stockholm, Sweden).

Clearex Market, LLC operates on a global, remote model: administrative access, platform engineering, and technical support are performed by authorised personnel operating remotely, including from our operations centre in Mongolia. To ensure your data receives an equivalent level of protection regardless of where authorised staff work, we implement:

• Standard Contractual Clauses (SCCs) approved by the European Commission for cross-border access;
• Technical access isolation: strict role-based access management preventing local data retention on remote endpoint devices;
• Encryption standards: mandatory TLS 1.3 for all administrative operations.

Where a recipient is located in the United States, we rely on the EU-US Data Privacy Framework adequacy decision or SCCs, as applicable.

7. Contact & Supervisory Authority

Data Protection Officer: privacy@clearex.market Corporate legal: legal@clearex.market Registered office (Delaware): Clearex Market, LLC, 131 Continental Dr, Suite 305, Newark, DE 19713, United States (principal place of business: Ulaanbaatar, Mongolia)

If you are an EEA or UK resident and believe your personal data has been processed in violation of applicable data protection law, you have the right to lodge a complaint with your national supervisory authority. As our hosting infrastructure is located in Sweden, the Swedish Authority for Privacy Protection (IMY) is a relevant EU supervisory authority.

Exercise your rights now: Access (Art. 15) and erasure (Art. 17) are self-service from your account. For rectification, restriction, or any other request, contact our DPO.

CLEAREX.MARKET provides generalized information, data aggregation, and educational software utilities only. Nothing on the Platform constitutes financial, investment, legal, or tax advice, nor a trading recommendation. Trading and investing involve substantial risk of loss and are not suitable for everyone — you may lose some or all of the capital you invest. Past or hypothetical performance is not indicative of future results.

© 2026 Clearex Market, LLC. All rights reserved. · GDPR Compliance Statement v2.1