Privacy Policy
Effective Date: May 15, 2026 Last Updated: May 15, 2026
This Privacy Policy explains how NMT Offchain L.L.C-FZ ("NMT," "we," "us," or "our") collects, uses, shares, and protects information about you when you visit newmarkettrading.com (the "Site") or otherwise interact with us as a prospective or existing client of our onchain execution services (the "Service").
NMT is a Limited Liability Company incorporated in the Dubai Meydan Free Zone, United Arab Emirates, with its registered address at Meydan Grandstand, 6th Floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E. The Service we offer is non-custodial, software-enabled onchain execution assistance and consulting. We never hold or take custody of your crypto assets or private keys.
This Privacy Policy applies to the Site only. Separate terms and notices may apply to your use of our web application or platform. If you have signed an Onchain Execution Services Agreement with us, that agreement also contains confidentiality and data-use provisions that apply to you.
1. Scope and Who This Policy Covers
This Policy covers visitors to newmarkettrading.com, individuals who submit information through forms on the Site, subscribers to our marketing communications, and prospective or existing clients who provide identification documents during onboarding.
If you do not agree with this Privacy Policy, please do not use the Site or provide information to us.
2. Information We Collect
We collect information in three ways: information you give us directly, information collected automatically when you use the Site, and information we receive from third parties.
2.1 Information You Provide Directly
Contact information. Name, email address, phone number, and country, when you fill out a contact form, request a consultation, or sign up for marketing communications.
Account information. If you create an account on the Site, your username, password (stored in hashed form), and any profile details you choose to provide.
Marketing email signup data. Your email address and any preferences you provide when subscribing to our newsletter, product updates, or educational content. Where required by law, we use double opt-in confirmation and retain records of your consent.
Onboarding and Know-Your-Customer ("KYC") information. If you proceed to become a client, we (or a third-party identity verification provider acting on our behalf) collect government-issued identification documents (such as a passport or driver's license), proof of address, date of birth, nationality, and a selfie or other biometric verification image. We collect this information to comply with applicable anti-money-laundering ("AML"), counter-terrorist-financing ("CTF"), and sanctions-screening obligations, and to confirm that you are not located in a restricted jurisdiction.
Communications. Any information you choose to share when you email, message, or call us, including the content of those communications.
Wallet address. A public blockchain wallet address you provide for the purpose of receiving information about the Service. A wallet address by itself is pseudonymous, but it may be linked to you through other information you provide.
2.2 Information Collected Automatically
When you visit the Site, we and our service providers automatically collect:
Device and browser data. IP address, browser type and version, operating system, device identifiers, screen resolution, and language settings.
Usage data. Pages visited, time spent on pages, referring and exit URLs, links clicked, and approximate geographic location derived from IP address.
Cookies and similar technologies. As described in Section 4.
Analytics data. Aggregated usage statistics collected through analytics providers (such as Google Analytics, Mixpanel, or similar tools).
2.3 Information From Third Parties
Identity verification providers. When you submit KYC documents, our identity verification vendor returns a verification result and may share extracted document data with us.
Marketing and advertising partners. We may receive information from advertising or referral partners about how you arrived at our Site.
Public blockchain data. Blockchain transaction data associated with a wallet address you have shared with us is, by its nature, publicly visible on the relevant chain. We may view, index, or analyze this data in connection with providing the Service.
Service providers. We may receive information from vendors who help us operate the Site and the Service.
2.4 Information We Do Not Collect
We do not collect or request your private keys, seed phrases, recovery credentials, or signing-device information at any time, through the Site or otherwise. Any communication or page asking you to disclose this information is fraudulent and should be reported to us immediately.
3. How We Use Information
We use the information we collect for the following purposes:
To operate and improve the Site. Including hosting, securing, troubleshooting, and analyzing how visitors interact with the Site.
To manage Site accounts. Including authentication, password reset, and securing your account.
To respond to inquiries. Including consultation requests, support questions, and other communications you initiate.
To send marketing communications. Including newsletters, product updates, and educational content, where you have signed up or where otherwise permitted by law. You may unsubscribe at any time using the link in any marketing email or by contacting us.
To onboard prospective clients. Including identity verification, AML/CTF screening, sanctions screening, and determining eligibility to use the Service.
To comply with legal obligations. Including record-keeping under UAE law and responding to lawful requests from regulators, courts, or government authorities.
To protect our rights and the integrity of the Service. Including fraud prevention, abuse detection, and enforcement of our agreements.
To analyze and improve our offerings. Including aggregated and anonymized usage analytics. As stated in our Onchain Execution Services Agreement, we may use aggregated or anonymized data derived from client activity to improve the Service, provided such data cannot reasonably be used to identify you.
We do not sell your personal information for money.
4. Cookies and Similar Technologies
We use cookies, web beacons, pixel tags, and similar technologies to operate the Site, remember your preferences, measure performance, and (where permitted) deliver marketing.
We use the following categories of cookies:
Strictly necessary cookies. Required for the Site to function, including login and security.
Analytics and performance cookies. Help us understand how visitors use the Site (for example, through Google Analytics, Mixpanel, or similar tools).
Functional cookies. Remember your preferences, such as language or region.
Marketing and advertising cookies. Used to measure the effectiveness of marketing campaigns and, where applicable, to show you relevant ads on other websites.
You can manage cookies through your browser settings. Most browsers allow you to refuse new cookies, delete existing cookies, or be notified when cookies are set. You can also opt out of specific analytics and advertising cookies by visiting the opt-out pages of the providers we use, including the Google Analytics opt-out (https://tools.google.com/dlpage/gaoptout) and the Digital Advertising Alliance opt-out tool (https://optout.aboutads.info). Blocking cookies may affect how the Site functions.
Do Not Track. Some browsers transmit a "Do Not Track" signal. Because there is no industry standard for how to respond, our Site does not currently respond to these signals.
5. How We Share Information
We share information only as described below. We do not sell your personal information for money.
Service providers. We share information with vendors who perform services on our behalf, such as web hosting, email delivery, analytics, customer relationship management, identity verification, and marketing automation. These vendors are contractually required to use the information only to perform services for us.
Identity verification and compliance partners. We share KYC information with regulated identity verification vendors and, where required, with screening providers that check global sanctions and politically-exposed-persons lists.
Legal and regulatory disclosures. We may disclose information when we believe in good faith that disclosure is required by law, regulation, court order, or governmental request, or is necessary to protect the rights, property, or safety of NMT, our clients, or others.
Business transfers. If NMT is involved in a merger, acquisition, reorganization, financing, or sale of assets, your information may be transferred as part of that transaction, subject to confidentiality obligations.
With your consent. We share information for any other purpose with your consent or at your direction.
A non-exhaustive list of the categories of third-party services that may receive information includes hosting and infrastructure providers, analytics providers, marketing automation platforms, identity verification providers, communications platforms, and security and monitoring tools.
6. Marketing Email Signups
If you subscribe to our marketing emails, we will send you content such as newsletters, product updates, educational material, and information about the Service. Where required by law and as a matter of good practice, we use a double opt-in process: after you provide your email, we send a confirmation email and only add you to our list after you confirm. We retain records of the date, source, and IP address associated with your opt-in.
You may unsubscribe at any time by clicking the "unsubscribe" link at the bottom of any marketing email or by contacting us at the address in Section 15. Transactional and account-related emails (for example, replies to a question you have asked or notices about your account) are not marketing emails and you will continue to receive those as needed.
We comply with the U.S. CAN-SPAM Act with respect to U.S. recipients.
7. KYC, AML, and Sanctions Screening
To onboard you as a client of the Service, we are required to verify your identity and screen you against applicable sanctions and watchlists. The KYC information described in Section 2.1 is used for these purposes and is retained for as long as required by applicable AML, CTF, and record-keeping rules, which is typically a minimum of five (5) years following the end of our client relationship.
We do not use KYC information for marketing purposes. We do not disclose KYC information to advertisers or analytics providers.
If we determine that we cannot onboard you (for example, because you are located in a restricted jurisdiction or appear on a sanctions list), we will retain a record of the verification result to support our compliance obligations.
8. Data Retention
We retain information for as long as necessary to fulfill the purposes described in this Policy, including to provide the Service, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements. Specifically:
Account data: retained while your account is active and for a reasonable period thereafter to handle account-related matters.
Marketing data: retained until you unsubscribe or request deletion, subject to a reasonable suppression-list retention to honor your opt-out.
KYC and AML records: retained for the period required by applicable law (typically at least five years following the end of the client relationship).
Site analytics data: retained in aggregated or pseudonymized form for as long as needed for product and business analysis.
Communications: retained for as long as needed to respond to and document the matter discussed.
When information is no longer needed, we delete, anonymize, or securely destroy it. Where you exercise a right of deletion, we may continue to retain a minimum set of records as required to comply with AML, tax, and other legal record-keeping obligations.
9. Security
We use reasonable administrative, technical, and physical safeguards designed to protect information from unauthorized access, disclosure, alteration, and destruction. No internet transmission or storage system is fully secure, however, and we cannot guarantee absolute security. You are responsible for safeguarding any credentials you use to interact with us and, especially, for safeguarding your private keys, seed phrases, and signing devices, which we never collect.
10. International Data Transfers
NMT is based in the United Arab Emirates. If you access the Site from the United States or any other country outside the UAE, your information will be transferred to, processed in, and stored in the UAE and in any other country where we or our service providers operate. The data-protection laws of these countries may differ from those of your country of residence. By using the Site, you understand that your information may be transferred internationally as described in this Policy.
11. Your U.S. Privacy Rights
Residents of certain U.S. states may have rights under applicable privacy laws, including the right to access, correct, delete, or receive a copy of certain personal information. Some state laws may also provide rights to object to or opt out of certain processing activities. To exercise these rights, contact us at the address in Section 15. We will respond as required by applicable law.
12. Children's Privacy
The Site is not directed to children under the age of 18, and the Service is not available to minors. We do not knowingly collect personal information from children under 18. If you believe a child has provided personal information to us, please contact us and we will take appropriate steps to delete it.
13. Accessibility
NMT is committed to making the Site accessible to all visitors, including those with disabilities. If you encounter an accessibility barrier or need information from the Site in an alternative format, please contact us at [email protected] and we will work in good faith to provide the information or assistance you need.
14. Changes to This Policy
We may update this Privacy Policy from time to time. When we do, we will update the "Last Updated" date at the top of the Policy. If changes are material, we will provide additional notice (for example, by email or a notice on the Site). Your continued use of the Site after a change becomes effective constitutes acceptance of the updated Policy.
15. Contact Us
If you have questions about this Privacy Policy, wish to exercise your rights, or need to report a concern, contact us at:
NMT Offchain L.L.C-FZ Meydan Grandstand, 6th Floor Meydan Road, Nad Al Sheba Dubai, U.A.E.
Email: [email protected]