1. Our approach

EXCHANGE SAMODEX LIMITED cooperates with legitimate requests from law-enforcement and government authorities, consistent with our Terms of Use, Privacy Policy and applicable law. We also work to protect our users' data from requests that are overbroad, improperly issued, or not legally valid.

2. What we require

We require a valid legal process appropriate to the request and jurisdiction, for example a subpoena, court order, search warrant, or an equivalent instrument recognised under Panamanian law or through a mutual legal assistance treaty (MLAT) channel for foreign authorities. Requests must be in writing, on official letterhead, identify the requesting authority and the legal basis, and be sufficiently specific about the account(s) or data sought — we do not respond to broad, non-specific requests.

3. What data may be disclosed

Depending on the legal basis and scope of a validated request, we may be able to provide account registration details, KYC/identification records, IP and login history, transaction and balance history, and correspondence with support. We do not hold users' private keys for self-custody wallets and cannot disclose data we do not possess.

4. Emergency requests

Where there is a good-faith belief of imminent risk of death or serious physical harm, we may voluntarily disclose limited information necessary to prevent that harm, even absent formal legal process, consistent with applicable law. Emergency requests should clearly state the nature of the emergency and be sent through the channel below.

5. User notification

Where legally permitted, it is our practice to notify the affected user before disclosing their data, so they have the opportunity to seek legal counsel or challenge the request. We may delay or withhold notice where we are prohibited by law or court order from providing it, or where notice would genuinely endanger an investigation or a person's safety.

6. Preservation requests

We can preserve account data pending receipt of formal legal process, for a limited period as permitted by law, upon a written preservation request from an authorised authority.

7. Costs

We reserve the right to seek reimbursement of reasonable costs associated with responding to unusually burdensome requests, to the extent permitted by applicable law.

8. How to submit a request

Send requests, on official letterhead and including the legal basis for the request, to legal@tosodex.com. Include the specific account identifier(s), the data sought, and a return contact for follow-up.

9. Contact

General questions about this policy can be directed to compliance@tosodex.com or via Support.