Privacy Policy

Updated May 2022


This Privacy Policy concerns any personal information of yours which is provided to us.

Personal information is any information about an identified individual or an individual who is reasonably identifiable, whether the information is true or not and whether the information is recorded in a material form or not.


What personal information do we collect and why?

The types of personal information we may collect include:

§  from users who sign up for a Kurdex account – email addresses, full names, trade activity (such as amounts and local currencies), phone numbers, and information about a user’s response time. For transparency purposes and also as Kurdex P2P and Direct Exchanges exclusively work in Iraq and Kurdistan region, we will also collect information about whether you are an Iraqi resident;

§  from website visitors – IP addresses, website preferences, traffic sources and device information;

§  if you contact us with a query – your contact details.

§  If we are not provided with the information that we request, then we may not be able to provide services to you or respond to your query.


We do not collect the content of your communications with other Kurdex users, unless required to do so to resolve a dispute or investigate an abuse report. These communications are end-to-end encrypted so we cannot decipher or read them without an involved user's consent.


The personal information you provide us may be used for a number of purposes connected with our business operations, which include to:

§ provide the Kurdex services, including facilitating communications between Kurdex users;

§ respond to any requests from you;

§ better understand your needs in relation to cryptocurrency trading;

§ develop and improve the quality and scope of the services we provide, and seek your feedback;

§ store choices you previously have made on the site, including when you are not logged in, to improve your experience;

§ better understand our how website visitors use the website and how Kurdex users use the service; and

§ to send you marketing messages about our products and services.

We may send you messages by email, SMS, or push notification, with updates about our services, news related to cryptocurrency or decentralized finance, and marketing messages. You always have the right to opt-out of receiving such information. You may exercise that right by clicking the "unsubscribe" link in a message we send you, or contacting us.


We will not use your information for purposes other than those described above unless we have your consent or as permitted by law (including for law enforcement or public health and safety reasons).


Passive information collection

As you navigate through this website, certain information can be passively collected (that is, gathered without you actively providing the information) through various technologies, such as cookies, internet tags or web beacons and navigational data collection. You can manage passive information collection settings in the settings of your browser.

This website may use and combine such passively collected information to provide better services to website visitors, customize the website based on your preferences, compile and analyze statistics and trends and otherwise administer and improve the website for your use.


How we collect your personal information

We generally collect personal information directly from you, for example through online forms or when you contact us. We may also collect personal information through trade activity, server log files and passive information collection technologies.


Sharing your personal information

We also may disclose your personal information to:

§ others in accordance with a request made by you – for example, if your username is your real name, then we will list this when you ask to be listed on the Kurdex marketplace;

§ our third-party service providers engaged by us to perform business and technology services, when reasonably required;

§ law enforcement bodies – both if required by a warrant or voluntarily if we suspect you have engaged in fraud or misuse; and

§ persons to whom we are required by law to disclose information.

When making disclosures to our service providers, we take reasonable steps to ensure that they are bound by privacy obligations.

Unless you consent, we otherwise do not disclose your personal information to third parties.


How long is my personal information kept?

You can request to delete your personal information by using the "delete account" feature.

After you delete your account, most information we have collected about you will be deleted or anonymized within 180 days, however we may retain some information for up to 5 years following the date of your request.

We may retain your personal information for a longer period only if there is a legal obligation for us to do so.


Access and correction

You may request access to any of the personal information we hold about you by contacting us as specified below. We reserve the right to charge a reasonable fee for the costs of retrieval and supply of any requested information.

We will take all reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up to date. To ensure your personal information is accurate, please notify us of any errors or changes to your personal information and we will take appropriate steps to update or correct such information in our possession.


Storage and security

We will take all reasonable precautions to safeguard your information from loss, misuse, unauthorized access, modification, disclosure or destruction. We may store your files as electronic records. We implement a range of electronic security measures to protect the personal information that we hold, including using secured databases using industry-standard network security practices.

You should keep in mind that no internet transmission is ever completely secure or error-free.


Links to other websites

This website may contain links or references to other websites to which this Privacy Policy may not apply. You should check their own privacy policies before providing your personal information.


Notifiable data breaches scheme

In the event of any loss or unauthorized access or disclosure of your personal information that is likely to result in serious harm to you, we will investigate and notify you.



If you have any questions or concerns about our collection, use or disclosure of personal information, or if you believe we have not complied with this Privacy Policy, please contact us as set out below. We will investigate the complaint and determine whether a breach has occurred and what action, if any, to take.


Kurdex takes all privacy complaints seriously and will aim to resolve any such complaint in a timely and efficient manner.




[email protected]

Textphone: +964 750 950 6070





Website Terms of Use

Updated May 2022


This page sets out the terms of use of this website. By using this website, you accept all of its terms (including these Terms of Use and the Privacy Policy). A reference in these Terms of Use to ‘we’, ‘us’ or ‘our’ means Kurdex Ltd.


Separate terms of use apply if you create a Kurdex account. These website Terms of Use just apply to visitors to our website. In the event of conflict between these website Terms of Use and the Service Terms, the Service Terms prevail.


We reserve the right to update or amend these Terms of Use at any time. You should check this page from time to time to make sure you are aware of any changes.


Website content

The content provided by us on this website is owned or controlled by us and may be protected by copyright laws. You may only use the content for your own personal purposes, and may not otherwise use, copy, reproduce, modify, publish, or transmit the content without our prior written consent.


We use reasonable endeavors to ensure that the information we include on this website is accurate and up-to-date. However, to the extent permitted by law, we cannot guarantee the accuracy, currency or completeness of the information provided and we accept no responsibility for errors in the content at any time.


We do not guarantee that use of our website will be uninterrupted or error-free.


To the extent permitted by law, all liability is excluded for any loss (including indirect loss), damages or injury resulting from your access to (or inability to access) or use of this website, or as a consequence of any content or information obtained from or through this website.


You may link to this website provided you do so in a way that accurately indicates that the link is to a Kurdex website and is not misleading.


Third party sites

This website may contain links or references to third party sites. We are not responsible or liable for the content of those sites and your access to and use of those sites is at your own risk. Any links are provided for convenience only, and do not indicate any endorsement or recommendation by us.


Misuse of website

You agree to only use this website in accordance with its terms and applicable laws. You may be held personally liable for any unlawful use of this website.


If you think any content on this website is inappropriate or unlawful or infringes your rights, please contact us at [email protected].



Any personal information collected by us through your use of this website will be dealt with in accordance with our Privacy Policy.


Kurdex trades and cryptocurrency transactions currently work in Iraq and Kurdistan region only. Although Iraqi websites may be accessed outside of Iraq, we make no representation that the content complies with the laws of any other country than of the Iraq. If you access this website from outside Iraq, you are solely responsible for ensuring compliance with your local laws and for any reliance on our website content. If your local laws do not permit you to access services provided by Kurdex, then you must not access this website.






Service Terms

Updated May 2022


1. Introduction

This page sets out the service terms for Kurdex account-holders. By signing up for a Kurdex account, you accept all of these terms. A reference in these Service Terms to ‘we’, ‘us’ or ‘our’ means Kurdex Ltd and its directors and officers.


Separate terms of use apply to website visitors. These Service Terms apply if you create a Kurdex account. The website Terms of Use also apply to the use of the services. In the event of conflict between these Service Terms and the website Terms of Use, the Service Terms prevail.


Kurdex is a service that enables its users to find others interested in trading cryptocurrencies for local currencies and vice versa. We do not facilitate the exchange of fiat currency for a digital currency, and we do not provide a digital currency exchange service.


Nothing on our website is intended to constitute legal or financial advice. The information on our website, and the posting and viewing of any the information on our website, should not be construed as, and should not be relied upon for, legal, financial or taxation advice in any circumstance.


2. Your account

You will need to register and create an account in order to access the Kurdex platform as a user. When you register as a member and create your profile, you will need to provide us with your email address, phone number and pick a username and password. You must log in using your username and password to access the services.


You must maintain the confidentiality of your password and you are responsible for all activities that are conducted through your account, whether or not you have authorized such use.


After signing up, you will be asked to verify your identity (KYC) in order to use Kurdex services. For more information about how personal information is used, read the Privacy Policy.


If you lose your password, you can recover it using “password forgotten” feature. 

We do not allow usernames to be changed.


4. Posting offers

Kurdex users may post offers to buy or sell cryptocurrencies in exchange for local currencies. Offers on the marketplace are made publicly available and can be viewed by anyone who accesses the website.


When an offer is displayed, we may also display symbols next to the offeror’s username such as a symbol to indicate the offeror’s trade activity, response rate, or standard hours.


Offerors can write their own terms and conditions of sale, which may be published with the offer or negotiated with the other party to the transaction. However, all terms and conditions of sale must include the mandatory terms specified in these Service Terms regarding Kurdex’s fee and the process for resolving disputes.


Offers displayed on the Kurdex website have Kurdex’s fee (see section 7) priced into them by default, which is why buyers and sellers will see a different rate for the same trade. The prices you see are what you should expect to receive after Kurdex's fee has been charged, however they are not inclusive of cryptocurrency network transaction fees.


Kurdex reserves the right to delete offers from the marketplace at its discretion. Generally, it will delete offers if they appear to be unlawful, non-genuine, fraudulent, spam or are otherwise incorrect.


5. Communications between parties

Kurdex users can communicate over the Kurdex platform.


All communication made between buyers and sellers on Kurdex is end-to-end encrypted. No third parties, including us, have the technical ability to decipher and/or read these messages unless we are given the shared secret to do so by one party.


It is the responsibility of a user to make and keep adequate records of communications, details of transactions and financial history to the extent that they are required to do so in their jurisdiction.


Once the shared secret used to encrypt the messages is destroyed, that conversation is gone forever and cannot be recovered.


You must not be engaging in communication with other Kurdex users which is offensive, abusive, unlawful, defamatory, indecent or inappropriate.


You acknowledge that we are unable to provide you with any other information about the identity of another Kurdex user other than what is made available to you on our website.


6. Trades of cryptocurrency

The parties of a trade are referred to as "buyers" (those who are interested in trading local currency for cryptocurrency) and "sellers" (those who are interested in trading cryptocurrency for local currency).


When trading with a user located with the aid of Kurdex's services, cryptocurrency payments can only happen directly between the buyer and seller. We do not have any wallets or accounts that hold users' cryptocurrencies. At no point during the course of a trade does the buyers' or sellers' cryptocurrency enter our control, unless the buyers use the Fast (Express) Buy or Sell which is a feature on Kurdex to directly trade fiat-to-cryptocurrency with Kurdex.


Tether (USDT) trades are conducted via the Ethereum (ERC20), Tron (TRC20), BSC (BEP20) distributed computing network, which we cannot and do not control. When a seller sends USDT to a buyer during the course of a trade, the seller transfers USDT directly to the user’s address on the mentioned blockchains. Kurdex cannot access USDT sent by seller. It is impossible for us to have USDT directed to anyone other than the seller or the buyer. After the seller sends the USDT, he or she is required to proceed the process by submitting the transaction hash (TXID) and a screenshot of the transaction to prove the USDT has been sent to the buyer. Once this is confirmed by Kurdex team, the locked balance of the buyer will be transferred to the seller’s account.


Bitcoin, Ethereum, Binance Coin, Litecoin, Dash, and Bitcoin Cash, Cardano, Polygon and any other cryptocurrency trades operate in a same or similar manner as Tether trades, except that they are operated on their respective public blockchains or blockchain forks.


We hold users’ fiat currency in our local payment accounts. A digital number with the ratio of 1:1 to the US Dollar is provided to the Kurdex users which act the fiat currency and is deducted when the users trade or withdraw. Users can withdraw their balance in fiat currency from the Kurdex pool at any time of their convenient if confirmed that they have no open orders or offers.


Buyers must have enough balance in their Kurdex account to make a request. Once a request is made by the buyer and is processed by the seller, an amount of the buyer’s balance equal to the request will be locked until the trade is processed or cancelled.  



7. Terms of the transaction

7.1. Peer-to-peer transactions:

Once a buyer proceeds to buy an available bid, an amount of fiat currency of the buyer’s balance equal to the trade amount including the Kurdex fees will be locked until the transaction is completed or cancelled.


If the seller approves the buyers offer, the buyer is moved to the next step in which the buyer must either confirm or cancel the transaction.


If confirmed, the seller must send the requested amount of the requested cryptocurrency to the buyers chosen address and submit the proof of the transaction by submitting the transaction hash, also known as Transaction ID or TXID, and a screenshot of the transaction. Once the transaction is confirmed and verified by Kurdex, the locked amount in the buyer’s account will be transferred to the seller’s account.


In case if the buyer cancels the transaction before the sellers turn to send the cryptocurrency, the locked amount in the buyer’s account will be unlocked. However, the buyer cannot cancel an offer approved by the seller and confirmed by the buyer.



Sales between buyers and sellers are subject to:

§ the payment of Kurdex’s fee;

§ the process for resolving disputes set out in these Service Terms; and

§ the seller’s terms and conditions, or any other terms and conditions agreed between the buyer and the seller. In the event of inconsistency, the higher in the list of terms prevails.


7. 2. Fast (Express) Transactions:

The transactions in the Fast (Express) Transactions’ category are subject to the same term and conditions of the peer-to-peer transactions, except it is a peer-to-Kurdex transaction, therefore, a party of the trade is Kurdex.


8. Security

You must comply with all reasonable security requirements prescribed from time to time by Kurdex.


9. Disputes

A dispute may arise about a trade if:


§ a party to a trade transfers local currency but the locked balance isn’t released,

§ the cryptocurrency is not sent to the buyer but confirmed by the seller, or

§ the cryptocurrency is only partially paid.


The contract of sale is between the seller and the buyer. Accordingly, the parties are required to first use best efforts to resolve the dispute between themselves. However, Kurdex verifies all transactions before transferring or releasing the locked balance.


Kurdex is not responsible in cases where the cryptocurrency is sent through the wrong blockchain.


In cases the parties refer disputes to Kurdex, parties must respond to Kurdex’ requests for information promptly (and at least within 24 hours). If a party does not respond to a request within that timeframe, Kurdex may resolve the escrow in favor of the other party to the dispute.


The parties agree that except in cases of gross negligence or fraud, Kurdex’s decision is final and binding on the parties and there is no appeal from such decision.


Kurdex reserves the right to refuse to resolve a dispute where Kurdex, in its sole discretion, considers that:

·       the issue is best resolved through other methods;

·       one or both parties have not provided all required or requested information;

·       the ownership of cryptocurrency is not clear from the information provided;

·       the contract between the parties is unlawful;

·       a party is acting unlawfully or fraudulently;

·       Kurdex has a legal obligation to do so; or

·       directing cryptocurrency to a party would cause Kurdex to breach any law.


Where Kurdex exercises its right to refuse to resolve a dispute, Kurdex will notify both parties of this. Either party may then apply for a court order resolving the dispute.


If a party provides a copy of a court order to Kurdex along with access to a digital signature that allows Kurdex control the parties’ accounts, Kurdex will resolve the issue in accordance with the court order.


This process for resolving disputes is incorporated in all contracts between buyers and sellers arranged through Kurdex.


10. Kurdex fees

For transactions concluded through Kurdex platform, Kurdex charges the seller (the person who placed the offer listing) and the buyer (the person responding to the offer) according to the fee which is already stated in the transaction form. The fee is charged in the users’ Kurdex balance.


11. Other taxes

Though, no taxes apply to Iraqi users of cryptocurrencies yet. In case taxes apply, you are responsible for determining what taxes apply to any trades you conduct with other Kurdex users. You must pay for all taxes applicable to all trades in which you participate.


You indemnify Kurdex for any claim, loss or damage arising from your failure to pay applicable taxes.


12. Suspending and deleting your account

We may suspend or delete your account if:

·       we consider that you are using the Kurdex platform to scam other users or for any other unlawful purpose;

·       we receive reports that you are communicating offensive, abusive, unlawful, defamatory, indecent or inappropriate messages to other users;

·       we know or suspect that you have completed the residency declaration dishonestly;

·       Kurdex is required by law to do so;

·       there is any change in law that adversely affects Kurdex’ operating model or would make it unlawful to continue the service without materially changing the Kurdex platform or regulatory license required to operate; and

·       for any other reason in our absolute discretion.


Once your account is deleted, we destroy any information we hold in relation to it after any legal requirement imposed on Kurdex to retain it has expired.

After suspension of your account, you are entitled to limited access for the purpose of managing existing trades however you may not open new trades or post to the marketplace.


13. Compliance with laws

Although our website may be accessed outside of Iraq, we make no representation that the services comply with the laws of any other country than the Iraq. If you use the services from outside Iraq, you are solely responsible for ensuring compliance with your local laws.


14. Risks associated with dealing with other users

Cryptocurrency transfers are irreversible. If you release or send cryptocurrency to somebody else, it is generally not possible for Kurdex, nor yourself, to recover the funds. This also applies to sending cryptocurrency to an incorrect address. You transfer any cryptocurrency at your own risk.


If someone gains access to your account and uses your wallet, we will have no way to recover your funds.


We strongly recommend that if you do not have a strong understanding of the underlying "blockchain" technology that supports cryptocurrencies such as Ethereum and Bitcoin, you do not use our services. Cryptocurrencies can be subject to extreme price volatility. You should consider your financial circumstances and tolerance to risk before acquiring and trading in cryptocurrencies.


15. Disclaimer of warranties

Kurdex is only an introductory and information service (except in cases where Kurdex acts as a primary party) and, to the maximum extent permissible by law, is not responsible for any actions of its users including, without limitation, representations by any users regarding funds (cryptocurrency or currency) having been transferred or any ownership of cryptocurrency or funds.


To the maximum extent permitted by law, Kurdex does not guarantee the quality or fitness for purpose of its services. Kurdex is provided on an "as is" and “as available” basis and you agree to use it at your sole risk. While we strive to make the services available to you at all times, we do not make any representations as to the availability of the services, or that your access or use of the website will be uninterrupted or timely. There may be delays, failures, errors, omissions or loss of transmitted information.


We make no warranties, claims or guarantees related to any of our users, including but not limited to:

·       the merchantability or fitness of the user;

·       the identity of the user;

·       the location of the user;

·       the reliability and timeliness of the user;

·       the accuracy of any information the user presents; or

·       the accuracy of any information we provide about the user.


16. Third party integrations in the Kurdex wallet (to be implemented soon)

The Kurdex wallet may incorporate, reference or provide access to third-party services. Kurdex is not the owner, operator or licensor of these third-party services, and Kurdex shall not be responsible for any consequences stemming from your use of a third-party service.


You agree that your use of any third-party service is subject to separate terms and conditions issued by the respective third-party service provider. It is your responsibility to review the terms and policies of a third-party service provider before deciding to use such service.


17. Limitation of liability and indemnity

You indemnify Kurdex and hold Kurdex harmless against all loss, claims, actions, liability, damage, costs (including legal fees on a solicitor and client basis), expenses and penalties arising directly or indirectly from any:


1.     breach by you of these Service Terms;

2.     unauthorized use of your Kurdex account;

3.     act or omission (including any negligence, unlawful conduct, wilful misconduct or fraud) by you in relation to your use of Kurdex’ services;

4.     third party claim against us in relation to your use of Kurdex’ services;

5.     any action taken by Kurdex at your request in respect of your account, trade or dispute;

6.     any inaction or delay on your part in respect of any dispute, including any failure by you to respond to a request for information by us within the time required under clause 9 (Disputes);

7.     any failure by you to comply with any reasonable recommendation made by Kurdex;

8.     infringement of intellectual property rights by you; and

9.     any actions or inactions of third-party service providers.


Except in the case of gross negligence or fraud in resulting a dispute, and to the fullest extent permitted by law, Kurdex is not liable for:


1.     any breach of these Service Terms; or

2.     any act or omission (including any negligent act or omission) of Kurdex in connection with these Service Terms or any services supplied by Kurdex.


Under no circumstances, including in cases of gross negligence or fraud, are we liable to you for any consequential loss suffered by you (including any loss of profit).


18. Privacy

Personal information we collect about you through the services (if any) will be dealt with in accordance with our Privacy Policy.


19. Applicable law and language

These Service Terms may be translated into other languages; however the official language of these terms is English. Translations may not accurately represent the information communicated in the English language.


20. Notices

You agree that an email sent to the email address nominated when you created your account is a valid notice under these Service Terms.

You should exercise reasonable caution when reviewing emails and SMSs purporting to originate from Kurdex as emails can be vulnerable to phishing, spoofing and additional viruses.


21. Changes to these terms

We reserve the right, at our sole discretion, to update, change or replace any part of these Service Terms by posting updates and changes to our website. If there is a change which has a material adverse impact on you, we will notify you by emailing you and providing 30 days’ notice. If you do not agree to the changes, your only remedy is to discontinue using the services.

It is your responsibility to check our website periodically for changes. Your continued use of or access to our website or the services following the posting of any changes to these Service Terms constitutes acceptance of those changes.


These Service Terms were last updated in May 2022.


22. Terms that survive account closure

The following terms in these Service Terms continue to apply after the closure of your account:

Clause 9 – Disputes;

Clause 10 – Kurdex fees; and

Clause 17 – Limitation of liability and indemnity.


23. Entire understanding

These Service Terms contain the entire understanding between the parties as to the subject matter of this terms.


24. Contact

Please send any questions, comments, issues, or general correspondence via email to [email protected].

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