Privacy Policy
Last Updated: April 7, 2026 · Olympus Capital AD
1. Introduction
This Privacy Policy ("Policy") describes how Olympus Capital AD, a company registered in the Republic of Bulgaria under EIK 206820199, with its registered office at bul. Simeonovsko Shose 33, floor 1, 1700 Sofia, Bulgaria ("Olympus Capital", "we", "us", or "our"), collects, uses, and protects personal data in connection with the Changex website at https://changex.io (the "Website").
Important Notice: The Changex mobile application (the "Changex App") is powered by Holyheld Digital Limited ("Holyheld"), registered in Bulgaria under registration number 204937129. All personal data collected and processed within the Changex App — including KYC/AML verification data, transaction data, wallet data, and financial information — is collected and processed by Holyheld as an independent data controller, in accordance with Holyheld's Privacy Policy. This Policy does not govern data processing performed by Holyheld.
By using the Website, you confirm that you have read and understood this Policy.
2. Data Controller
For the purposes of the General Data Protection Regulation (EU) 2016/679 ("GDPR"):
Olympus Capital AD is the data controller for personal data collected through the Website (e.g., website analytics, cookies, contact form submissions, newsletter subscriptions).
Holyheld Digital Limited is the independent data controller for all personal data collected and processed within the Changex App in connection with the crypto-asset services. For details on how Holyheld processes your data, please refer to Holyheld's Privacy Policy.
3. What Personal Data We Collect
3.1. Data Collected Through the Website
We may collect the following categories of personal data when you visit or interact with the Website:
Technical Data: IP address, browser type and version, operating system, device type, screen resolution, language preferences, referring URL, and pages visited.
Usage Data: Date and time of visits, pages viewed, time spent on pages, click patterns, and navigation paths.
Contact Data: Name and email address, if you voluntarily submit them through a contact form or newsletter subscription.
Cookie Data: Information collected through cookies and similar tracking technologies (see Section 7 below).
3.2. Data We Do Not Collect
Olympus Capital does not collect, through the Website:
• KYC/AML identification documents or verification data;
• Financial information, bank account details, or payment card data;
• Crypto-asset wallet addresses, private keys, or transaction data;
• Biometric data.
All such data is collected and processed exclusively by Holyheld through the Changex App, subject to Holyheld's Privacy Policy.
4. How We Use Your Data
We use the personal data collected through the Website for the following purposes:
| Purpose | Lawful Basis (GDPR) |
|---|---|
| Operating and maintaining the Website | Legitimate interest |
| Analyzing website traffic and usage patterns | Legitimate interest |
| Responding to inquiries submitted via contact forms | Performance of a contract / Consent |
| Sending newsletters or marketing communications (if opted in) | Consent |
| Ensuring the security and integrity of the Website | Legitimate interest |
| Complying with legal obligations | Legal obligation |
5. How We Share Your Data
We may share your personal data with the following categories of recipients:
Analytics Providers: Such as Google Analytics, for website traffic analysis (data is anonymized/pseudonymized where possible).
Hosting and Infrastructure Providers: Third-party services that host and maintain the Website.
Holyheld Digital Limited: If you navigate from the Website to the Changex App, any data you subsequently provide is collected by Holyheld under its own Privacy Policy.
Legal and Regulatory Authorities: Where required by law or in response to valid legal process.
We do not sell your personal data to third parties.
6. International Data Transfers
Your personal data may be processed within the European Economic Area (EEA). If any transfer outside the EEA is necessary, we will ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.
8. Data Retention
We retain personal data collected through the Website only for as long as necessary to fulfill the purposes described in this Policy, or as required by applicable law.
Website analytics data is retained in anonymized/aggregated form and does not identify individual users after the retention period.
9. Your Rights Under GDPR
As a data subject, you have the following rights with respect to personal data we hold about you:
Right of Access: Request a copy of your personal data.
Right to Rectification: Request correction of inaccurate or incomplete data.
Right to Erasure: Request deletion of your personal data (subject to legal retention obligations).
Right to Restriction: Request restriction of processing in certain circumstances.
Right to Data Portability: Receive your data in a structured, commonly used format.
Right to Object: Object to processing based on legitimate interest.
Right to Withdraw Consent: Where processing is based on consent, withdraw at any time.
To exercise any of these rights, contact us at [email protected].
For rights relating to personal data processed by Holyheld within the Changex App, please contact Holyheld's Data Protection Officer at [email protected].
10. Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or electronic storage is completely secure.
11. Children
The Website is not directed at individuals under 18 years of age. We do not knowingly collect personal data from children under 18. If we become aware that we have collected data from a child under 18, we will take steps to delete it.
12. Third-Party Links
The Website may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites. We encourage you to review the privacy policies of any third-party websites you visit.
13. Changes to This Policy
We may update this Policy from time to time. Any changes will be posted on the Website with a revised "Last Updated" date. We encourage you to review this Policy periodically.
14. Contact Information
For questions about this Privacy Policy or to exercise your data protection rights:
Olympus Capital AD
bul. Simeonovsko Shose 33, floor 1
1700 Sofia, Bulgaria
Email: [email protected]
For questions about personal data processed within the Changex App:
Holyheld Digital Limited
Data Protection Officer: [email protected]
You also have the right to lodge a complaint with the Commission for Personal Data Protection (CPDP) of the Republic of Bulgaria or with the supervisory authority of the EU Member State where you reside.
Copyright © 2026, Olympus Capital AD. All rights reserved.