Privacy Policy

Last updated: 2025-04-11

This Privacy Policy defines the procedure for processing personal data by ЗАО ОнСикс (also referred to as 'Company', 'we', 'our', 'us') and the measures taken to ensure the security of such data to protect and respect the privacy of users of the site https://onesix.tech/ and/or the Company's products/services. The Policy applies to all information that the Company may obtain from Users. The current Policy does not control and is not responsible for third-party websites that Users may access via links available on the site https://onesix.tech/, where personal information may also be collected or requested from the User.

By continuing to use this Site and/or registering to use the Company's products/services (our services), you confirm that you have read, understood, accepted, and agree to comply with these Terms, Policies, and provisions governing the use of the Site and/or the products/services offered by the Company. The Site's Privacy Policy regulates the provision of personal data by users ('Information').

1. General Information

1.1. In accordance with the Privacy Policy, the Company has the right to collect personal data of individuals visiting the Company's Site, inform about the purposes and methods of using the Information, and the rights to control the Company's use of collected and stored personal information about Site visitors.

1.2. Protecting your personal data is the most important task for the Company, and we guarantee that we will protect your data in accordance with legal requirements.

1.3. The Company is the data processor of the data you provide and is responsible for processing and storing the information.

1.4. The website https://onesix.tech/ and other domains that are periodically updated, as well as related pages ('Site'), are developed and managed by the Company.

1.5. Users of the Site and/or the Company's products/services may be referred to as 'you', 'your', or 'yours' for convenience. Before using the Site or any other product/service of the Company, you must carefully read this Policy, which governs the processing of personal data by the Company. If you disagree with any part of this Policy, we ask you to refrain from using this Site and its services and to leave it.

We recommend carefully reviewing the provisions of this Privacy Policy. By continuing to use this Site and/or registering to use the Company's products/services, you confirm that you have read, understood, accepted, and agree to comply with this Privacy Policy.

2. Definitions

Automated Data Processing
Data processing using information technology.

Data Processor
A public institution, individual, or legal entity that determines, individually or jointly with others, the purposes and means of processing personal data, and directly or through an authorized person carries out data processing.

Regulatory Requirements
Any applicable law, statute, regulation, order, court decision, resolution, recommendation, rule, policy (including but not limited to the KYC/AML/CTF Policy), or guideline adopted or issued by parliament, government, or any competent court or authority, or any payment system (including, but not limited to, banking payment systems, card payment systems such as Visa, MasterCard, or any other payment, clearing, or settlement system, or similar agreement used to provide products/services).

Data Processing
Any action performed on data using automated, semi-automated, or non-automated means, in particular, collection, recording, photography, audio/video recording, organization, storage, alteration, retrieval, use, or disclosure for the purpose of transmission, distribution, or otherwise making the data accessible, grouping or combining, blocking, deletion, or destruction of data.

Personal Data (Information)
Any information related to an identified or identifiable individual. An individual is identifiable when they can be identified directly or indirectly, in particular, by an identification number or specific physical, physiological, psychological, economic, cultural, or social characteristics.

Products, Services, and/or Services
Products, services, and/or services provided to the User on the Site https://onesix.tech/.

Policies / Policy
Policies and provisions governing the provision of products/services, including but not limited to Customer Risk Management Policies, Anti-Money Laundering and Counter-Terrorist Financing, Sanctions, and Country Policies (AML/CTF & KYC & SANCTIONS & COUNTRY POLICY), Privacy Policy, and others.

Semi-Automated Data Processing
Data processing using information technology or non-automated means.

User
An individual visiting the Site https://onesix.tech/ and/or using the products/services of the Site and/or the Company and who is a data subject.

Consent
The voluntary consent of the data subject to the processing of their data for specific purposes, expressed orally, in writing, or in an equivalent form, via telecommunications or other appropriate means after receiving relevant information, allowing clear determination of the data subject's will.

Data Subject
Any individual whose data is processed.

Authorized Person
Any individual or legal entity processing data on behalf of or for the data processor.

User Account
A personal profile or personal account created after registration on the Site https://onesix.tech/.

3. Procedure for Collecting, Storing, and Processing Personal Data and User Information

3.1. In accordance with the Privacy Policy, the Company has the right to process personal data of individuals visiting the Company's Site, inform about the purposes and methods of processing personal data, and the rights to control the Company's use of collected and stored personal information about Site visitors.

3.2. Protecting your personal data is the most important task for the Company, and we guarantee that we will protect your data in accordance with legal requirements.

3.3. The Company may collect information voluntarily provided by you during registration and account creation, including: name, surname, email address, mailing address, country of residence, phone number, date of birth, e-wallet address, taxpayer identification number, bank details, credit card information, personal information for KYC/AML or CTF procedures.

3.4. The Company collects and stores personal data to comply with applicable laws, particularly regarding the prevention of money laundering and terrorist financing, improving and developing the Company's services, studying User requirements, compiling Site statistics, and planning and conducting various marketing activities.

3.5. The Company collects personal information from Users only to the extent necessary to ensure the proper provision of services to Users.

3.6. We store your financial information in our secure systems, and only we have access to your information. However, we may transfer such information to third parties in accordance with legal requirements or this Policy.

3.7. Additional information about your device and use of services (device connection to the network, IP address, geolocation information, etc.) may be collected by methods provided for in this Privacy Policy, with your prior consent. Filling out the registration form when creating an account on the Site and/or using the Company's products/services, after reviewing the Company's Policies, will be considered as your consent to the collection, processing, storage, and transfer of information to third parties in accordance with this Policy and applicable laws.

3.8. If necessary, the Company may request additional information in accordance with legal requirements.

3.9. To verify the data you provide, the Company may perform inquiries through third-party service providers to prevent misidentification, fraud, suspicious activity, money laundering, or any other prohibited activity. The Company may also take additional measures regarding the results of inquiries that we deem necessary. By agreeing to this Policy, you grant us permission to conduct such inquiries, including inquiries about the information specified in your Account.

3.10. Notwithstanding the above, the Company may, at any time and at its sole discretion, refuse to allow you to open an Account, restrict an already created Account, or suspend any transaction pending the results of our review of any information you provide.

3.11. We may permanently close the account of any User who fails to comply with our requests for information verification or otherwise violates the above rules and/or Policies. Such a User may be held liable for losses incurred by the Company or any third party due to violations of the rules for using the Site and/or the Company's products/services.

3.12. We may also collect additional information from you or about you through other lawful means not specified in this Policy. For example, we may collect information related to your communication with our customer support service or retain the results of your responses to surveys, analysis of your activity on the Site and/or the Company's products/services, and others.

3.13. We store and process your personal information on highly secure specialized servers and protect it by maintaining physical, electronic, and procedural safeguards in accordance with applicable laws. We use computer safeguards such as firewalls and data encryption, we implement physical access controls to our media and files, and we permit access to personal information only to employees who require it to perform their job duties.

3.14. During collection and storage, the Company adheres to the following principles:

  • data is processed fairly and lawfully without degrading the dignity of the data subject;
  • data is processed only for specific, clearly defined, lawful purposes, namely for the provision of the Company's services. The Company does not allow subsequent processing of data for purposes incompatible with the original purpose;
  • data is processed only to the extent necessary to achieve the relevant lawful purposes. The data is adequate and proportionate to the purposes for which it is processed;
  • data is accurate and up-to-date and updated when necessary. Data collected without a legal basis and not corresponding to the purpose of processing is blocked and deleted.

3.15. We will store: (a) transaction records for five (5) years from the date of the transaction's completion, or for another minimum period required by applicable law; (b) other information collected by the Company for compliance with anti-money laundering and counter-terrorist financing laws for the entire period of business relations with the User and for five (5) years from the date of termination of business relations with the User, or for such other minimum period as may be required by applicable law.

4. Confidentiality

You acknowledge that you are equally responsible with the Company for maintaining the confidentiality of your Account information, including your password, protecting your digital assets, and for all actions and transactions occurring in your Account. You understand that any disclosure of your registration or other information may expose your Account to unauthorized access by third parties, which may result in the loss or theft of digital assets and funds from your Account, including linked accounts such as withdrawal details.

5. Collection of Information for AML/CTF, KYC/CDD Policy and Procedures

5.1. Use of KYC/CDD, AML, and CTF procedures.

As part of our commitment to combating financial crimes, money laundering, terrorist financing, fraud, sanctions evasion, and other criminal activities, the Company has implemented procedures and systems aimed at identifying and mitigating risks associated with the misuse of our Site, as well as the Company's products/services. These include KYC/CDD, AML, and CTF procedures based on collecting information about our users, assessing AML/CTF risks related to their activities, and continuously monitoring their transactions.

5.2. Your personal data may be used for:

  • processing transactions and sending notifications provided for by the Policies and/or applicable laws regarding your transactions;
  • resolving disputes, collecting payments, and troubleshooting;
  • sending you targeted marketing, service updates, and promotional offers based on your preferences;
  • preventing potentially prohibited or illegal activities and ensuring compliance with our Terms of Use;
  • providing services and customer support at your request/application;
  • configuring, measuring, and improving our services, as well as the content and appearance of our website;
  • verifying information for accuracy and checking it with third parties;
  • confirming or refuting violations of regulatory requirements and/or Policies.

5.3. If we have any suspicions that our business relationship with you or a specific transaction you wish to conduct involves any risk of money laundering, terrorist financing, or any other financial crime or prohibited activity, we may, at our sole discretion, refuse to accept you as a client, terminate any interaction with you, refuse to process any transaction, and take any other actions we deem necessary, including reporting our suspicions to the competent authorities. We will not inform you of any such actions we decide to take, nor are we obligated to provide you with any explanations for such decisions or our suspicions.

5.4. For the purpose of conducting the above checks, we may collect certain personal information not only from you but also from external sources. Any such information about you will be stored and used in accordance with the Privacy Policy.

6. Sharing Information with Other Parties

6.1. We may share your personal data with:

  • Related and affiliated entities of the Company;
  • Banking partners and/or payment processing service providers for processing payments;
  • Companies with which we merge or which acquire us. In such cases, we will require the new combined entity to follow this Privacy Policy regarding your personal data. If your personal data is used contrary to this policy, you will receive prior notice and may opt out of the new combined entity's use of your personal data;
  • Other cases provided for by applicable law.

6.2. The Company will not sell or allow third parties to use your personal data for their personal marketing purposes and undertakes to share your personal data with third parties as described in this Policy.

7. Processing of Personal Data

7.1. By registering on the Site and using its services without registration, in accordance with this Policy, the User:

  • Consents to the use of their personal data, as well as its processing: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of any information directly or indirectly related to the User, their transactions, and payments;
  • Confirms that they are aware that the processing of personal data will be carried out by the Service in the interests of the User and for the purpose of providing/offering the User any consultations (explanations) and/or for the purpose of offering the User services provided by the Service, and/or services provided by persons on whose behalf the Service operates, and/or for conducting surveys, questionnaires, advertising, and marketing research regarding services provided by the Service and/or the aforementioned persons, as well as for informing about advertising and/or marketing campaigns conducted by the Service and/or the aforementioned persons regarding services provided by the Service, as well as persons on whose behalf the Service operates, by contacting Users directly or by phone, mail, fax, email, or other means of communication, as well as for preparing to conclude, for the purpose of concluding, executing, amending, terminating agreements (contracts) between Users and the Service or persons on whose behalf the Service operates, including proper identification of the User, as well as for preparing forms of applications, notices, agreements, contracts that do not directly entail the conclusion, termination, or amendment of the relevant agreement, contract, and for other purposes consistent with the focus of the above objectives.

7.2. The User confirms that they have been properly informed about the purposes of processing their personal data.

7.3. The User confirms that they are aware that the processing of personal data is carried out by the Service in any manner, including both using automation tools (including software) and without using automation tools (using various material carriers, including paper carriers).

7.4. The User confirms that the processing of personal data may be carried out both by the Service and by other persons who have entered into an agreement with the Service under confidentiality and liability terms for the disclosure of personal data.

7.5. This right (consent) is valid for 10 (ten) years and may be revoked by sending a written notice to the Service. This consent is considered revoked after 30 (thirty) days from the date the Service receives the written notice of revocation. The day of receipt of the notice is not included in the thirty-day period.

7.6. The User understands that the Company also uses and processes cookies in accordance with the Cookies Usage Policy.

8. User Rights

8.1. In connection with the provision of your personal information, the Company guarantees your rights regarding personal data, in particular:

  • the right to request the Company to update and correct incomplete, incorrect, or outdated information;
  • other actions within the requirements of information protection laws.

8.2. During data processing, you have the right to restrict the processing of your personal data in the manner provided by applicable law. However, based on our legitimate interests, we may continue processing your data within a reasonable balance between your interests and the interests of the Company, as well as in the manner provided by applicable law.

8.3. The data subject has the right at any time, without explanation, to withdraw their consent and demand the termination of data processing and/or the destruction of processed data. In this case, the Company undertakes, in accordance with the data subject's request, to block the User's Account and cease processing the data or (and) destroy the processed data within 5 days after the application is submitted, unless there is another basis for processing the data.

8.4. The provisions of clause 7.3 do not apply to personal data related to completed transactions and personal data collected by the Company for compliance with laws on anti-money laundering and counter-terrorist financing. In this case, the Company has the right to retain such personal data and use it in the manner provided for in clause 5.1 of this Policy, as well as other Policies of the Company.

9. Protection of Personal Data

The Company takes the necessary technical and organizational measures to protect your personal data to prevent unauthorized access and processing, damage, loss, misuse, and other unlawful forms of processing personal data provided to the Company.

10. Final Provisions

10.1. The Company reserves the right to amend this Privacy Policy without prior notice or consent from the User. The current version of the AML/KYC Policy is published on the website https://onesix.tech/. The Company recommends that you periodically review this Policy for updates. If you disagree with the changes, you should refrain from accessing the Site and cease using the Company's products/services.

10.2. All clarifications, suggestions, or questions regarding this Policy should be sent to the following address: support@onesix.tech.