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Coinastra

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Privacy Policy

Last Updated: April 22, 2026

This Privacy Policy describes how DIRE MONEY TRANSMITTER LLC ("we," "us," or "our"), operating as Coinastra, collects, uses, stores, and shares personal information from individuals who access or use the Coinastra platform at coinastra.co.com. This policy applies to US residents and complies with applicable federal and state privacy laws including the Gramm-Leach-Bliley Act (GLBA), the Bank Secrecy Act (BSA), and the California Consumer Privacy Act (CCPA) where applicable.

1

Scope and Applicability

This Privacy Policy applies to personal information collected through the Coinastra website, mobile applications, account registration processes, customer support channels, and any other interaction between you and DIRE MONEY TRANSMITTER LLC. It does not apply to third-party websites or services linked from our platform.

By accessing Coinastra services, you acknowledge that you have read this Privacy Policy. If you do not agree with these practices, please discontinue use of our services and do not create an account.

2

Information We Collect

Identity Information: As a licensed Money Services Business subject to the Bank Secrecy Act and USA PATRIOT Act, we are required by law to collect and verify identity information. This includes full legal name, date of birth, government-issued identification numbers (such as Social Security Number or Individual Taxpayer Identification Number), and a copy of a valid government-issued photo ID.

Contact Information: Email address, phone number, and physical mailing address as provided during account registration or customer support interactions.

Financial Information: Bank account details, transaction history, wallet addresses, and payment method information used to fund your account or receive withdrawals.

Technical Information: IP address, browser type, operating system, device identifiers, access timestamps, and pages viewed during site sessions. This information is collected automatically through server logs and cookies.

Communications: Records of correspondence with our customer support team, including emails, chat transcripts, and phone call records where permitted by law.

Behavioral Data: Patterns of account activity, trading behavior, and platform usage that help us monitor for security threats and comply with transaction monitoring obligations under the BSA.

3

Legal Basis for Collection

DIRE MONEY TRANSMITTER LLC collects personal information under the following legal bases:

Regulatory Compliance: Federal law requires us to collect identity information, maintain transaction records, file Currency Transaction Reports (CTRs) for transactions over $10,000, file Suspicious Activity Reports (SARs) when required, and retain records for a minimum of five years. These obligations arise under 31 U.S.C. 5318, the Bank Secrecy Act, and FinCEN regulations at 31 C.F.R. Chapter X.

Contractual Necessity: We collect contact and financial information necessary to provide account services, process transactions, and communicate account-related information.

Legitimate Interest: We collect technical and behavioral data to maintain platform security, detect fraud, prevent unauthorized access, and improve service functionality.

Consent: Where we collect information beyond these bases, we obtain your explicit consent, which you may withdraw at any time subject to legal retention obligations.

4

How We Use Your Information

We use collected information for these purposes:

Account Management: Creating, verifying, maintaining, and terminating accounts. Processing KYC verification as required under the USA PATRIOT Act Customer Identification Program requirements.

Transaction Processing: Executing trades, processing deposits and withdrawals, completing crypto-to-fiat conversions, and managing wallet balances.

Regulatory Compliance: Fulfilling BSA obligations including transaction monitoring, CTR filing, SAR filing, and record retention. Responding to lawful government requests and court orders.

Fraud Prevention and Security: Detecting unauthorized access, identifying suspicious activity patterns, protecting account integrity, and investigating potential policy violations.

Customer Support: Responding to inquiries, resolving disputes, processing complaints through our formal complaint resolution process, and managing error resolution claims.

Service Improvement: Analyzing usage patterns to identify technical issues, improve platform performance, and develop new features. We do not sell personal information for marketing purposes.

Legal Proceedings: Preserving and producing records in response to valid legal process, including subpoenas, court orders, and regulatory inquiries.

5

Information Sharing and Disclosure

We do not sell personal information to third parties for commercial marketing purposes.

Regulatory Authorities: We share information with FinCEN, state money transmission regulators, and law enforcement as required by law. This includes mandatory reporting under the BSA and responses to valid legal process.

Identity Verification Providers: We engage third-party KYC verification services to confirm identity documents and check against sanctions lists including the OFAC Specially Designated Nationals list. These providers receive only the minimum information necessary.

Banking Partners: Financial institutions processing fiat deposits and withdrawals receive account and payment information necessary to complete transactions.

Technology Providers: Cloud hosting, security monitoring, and platform infrastructure providers operate under data processing agreements that restrict their use of your information to providing contracted services.

Business Transfers: If DIRE MONEY TRANSMITTER LLC undergoes a merger, acquisition, or asset sale, personal information may be transferred as part of that transaction. We will notify affected users before personal information becomes subject to a different privacy policy.

With Your Consent: We share information with third parties only when you have provided explicit consent for a specific sharing purpose.

6

Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this policy, subject to the following minimum retention periods imposed by law:

BSA Records: Transaction records, identity verification documents, and account files are retained for a minimum of five years following the account closure date or the date of the relevant transaction, as required under 31 C.F.R. 1010.430.

SAR Records: Suspicious Activity Reports and supporting documentation are retained for five years from the date of filing, pursuant to 31 C.F.R. 1023.320(d).

General Account Data: Account information is retained for a minimum of five years after account closure for regulatory and dispute resolution purposes.

Technical Logs: Server logs and access records are retained for 90 days for security purposes, then deleted unless required for an active investigation.

After applicable retention periods expire, we securely destroy personal information using industry-standard deletion methods.

7

Data Security

DIRE MONEY TRANSMITTER LLC implements technical and organizational measures to protect personal information against unauthorized access, loss, alteration, and disclosure. These measures include:

Encryption of personal data in transit using TLS 1.2 or higher. Encryption of personal data at rest using AES-256 or equivalent standards. Access controls limiting employee access to personal information on a need-to-know basis. Multi-factor authentication requirements for administrative system access. Regular security assessments and penetration testing of platform infrastructure. Incident response procedures for detecting, containing, and reporting data security events.

No security system is impenetrable. We cannot guarantee absolute security of information transmitted over the internet. We encourage users to maintain strong, unique passwords and to report any suspected unauthorized account access immediately.

8

Your Rights and Choices

Subject to applicable law and our legal obligations, you have the following rights regarding your personal information:

Access: You may request a copy of personal information we hold about you. We will respond within 45 days of a verified request.

Correction: You may request correction of inaccurate personal information. Some corrections may require re-verification under our KYC procedures.

Deletion: You may request deletion of personal information. Note that we are legally required to retain certain information under the BSA and cannot fulfill deletion requests that conflict with mandatory retention obligations.

Portability: You may request a structured, machine-readable copy of personal information you provided to us.

Opt-Out of Marketing: You may opt out of non-essential communications at any time by contacting us at support@coinastra.org. Transactional and regulatory communications are not subject to opt-out.

To exercise any of these rights, contact us at support@coinastra.org with "Privacy Request" in the subject line. We may require identity verification before processing requests.

9

California Residents - CCPA Rights

California residents have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

Right to Know: You have the right to know what categories of personal information we collect, the purposes for collection, and the categories of third parties with whom we share information.

Right to Delete: Subject to exceptions for legal compliance, you may request deletion of personal information we have collected.

Right to Correct: You may request correction of inaccurate personal information we maintain about you.

Right to Opt-Out of Sale/Sharing: We do not sell or share personal information for cross-context behavioral advertising. This right does not apply to our current practices.

Right to Limit Sensitive Information Use: You may limit our use of sensitive personal information to purposes permitted by the CPRA.

Non-Discrimination: We will not discriminate against you for exercising CCPA rights. We will not deny services, charge different prices, or provide different service quality based on your exercise of privacy rights.

California residents may submit requests through our privacy contact at support@coinastra.org or by calling +1 (813) 280-9999. We will verify your identity before processing requests.

10

Cookies and Tracking Technologies

Coinastra uses cookies and similar tracking technologies to operate the platform, maintain session security, and analyze usage patterns. For detailed information about our use of cookies, please review our Cookie Policy.

You may manage cookie preferences through our cookie consent tool, accessible via the notification icon in the bottom-right corner of any page. Disabling certain cookies may affect platform functionality.

11

Children's Privacy

Coinastra services are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that personal information has been collected from an individual under 18, we will take steps to delete that information promptly. If you believe a minor has submitted personal information to us, contact us at support@coinastra.org.

12

Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will post the updated policy on this page with a revised "Last Updated" date and, where required by law, notify affected account holders directly.

Continued use of Coinastra services after a policy update constitutes acknowledgment of the revised policy. We encourage you to review this page periodically.

13

Contact Information

Direct privacy-related questions, requests, or complaints to:

DIRE MONEY TRANSMITTER LLC
Attn: Privacy Officer
3811 S Cooper St K6525
Arlington, TX 76015

Email: support@coinastra.org
Phone: +1 (813) 280-9999

We will acknowledge privacy requests within 10 business days and provide a substantive response within 45 days, subject to identity verification requirements.

Coinastra is operated by DIRE MONEY TRANSMITTER LLC, registered with FinCEN as a Money Services Business. Cryptocurrency products involve risk including possible loss of principal. Not FDIC insured. This is not investment advice. Services not available in all states.

© 2026 Coinastra / DIRE MONEY TRANSMITTER LLC. All rights reserved.

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