PRIVACY POLICY

Last updated on July 23, 2024

1. INTRODUCTION

GoMining (BVI) Limited (hereinafter also – "GoMining") respects your privacy and is committed to protect your personal data.

This Privacy Policy informs you about how we care about your personal information and tell you about your privacy rights and how the law protects you, when you:

Visit our mobile application available at: https://app.gomining.com/ or its subdomains (collectively “Website”)
Complete surveys and subscribe for the newsletters, communicate with our team ("Voluntary provision of data"); and/or
Use our Services.

2. IMPORTANT INFORMATION AND WHO WE ARE

GoMining (BVI) Limited, a company duly organised and existing under the laws of the British Virgin Islands, BVI company number: 2110978, having its registered address at Trinity Chambers, PO Box 4301, Road Town, Tortola, British Virgin Islands.

We provide Services through the use of our Website, progressive web and mobile applications.

3. PURPOSE OF THIS PRIVACY POLICY

This privacy Policy aims to give you information on how GoMining (BVI) Limited collects and processes your personal data through your use of the Website and/or Services and/or Voluntary provision of data, including any data:

you may provide; and/or
we may collect through your use of the Website and/or the Services; and/or
when you sign up to our newsletters, complete our surveys and/or communicate with our support service.

It is important that you read this privacy policy in conjunction with any other privacy or fair handling policy that we may provide in certain cases where we collect or process personal data about you, so that you are fully aware of how and why we use your data.

This Privacy Policy is in addition to the other policies and is not intended to cancel them. GoMining (BVI) Limited is responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).

4. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US ABOUT THEM

This version was last updated on July 23, 2024. We may update this Privacy policy from time to time. The updated version will be indicated by the date of the last update above. If we make material changes to this privacy policy, we may notify you by posting a Policy on the website and/or the Services, or by sending a Policy directly to you. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

5. THE DATA WE COLLECT ABOUT YOU

Personal data or personal information means any information about a person by which that person can be identified. It does not include data whose identity has been deleted (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows.

The information you provide to us: This is your personal information that you provide to us by filling out forms and all KYC information. We may receive information from you by correspondence with you by mail, phone, e-mail, mobile application(s), and our website available at gomining.com. This includes personal data that you enter on our website, provide to us through Services or through Voluntary Provision of Data, or provide to us in any other way. You provide such information when you:

Use our Website and Services;
Fill out KYC forms and requests;
Subscribe to our newsletters;
Fill out a survey;
Participate in (sign up to) any contest, promotional activity, giveaway, events, education, career, partnership offers;
Communicate with our support service, give us feedback (for example, when you communicate with us by customer support form, e-mail, phone, mail or otherwise).

As a result of these actions, you can provide us with information such as:

Proof of identity in the form of a photo (which will be in the form of a "selfie" in an approved format);
Date and place of birth (if you are an individual);
Date and place of registration or registration (if you are a legal entity) (Please note: using gomining.com, you agree not to hide your real location. You agree not to use a vpn, proxy, tor browser or other methods of hiding your real location);
Primary citizenship;
Email address;
Residential address;
Confirmation of the current residential address or confirmation of the current address of a registered legal entity (for example, a bank statement, electricity or water bill issued within the last three months);
Phone number;
Information about your wallet(s) and crypto tokens that you have;
The nature of the origin of tokens or the origin of funds for the purchase of tokens and other data;
Other data, documents and/or information necessary for compliance with the applicable AML/CFT laws and regulations.

Data for KYC is provided by contractors providing services in the financial sector. All users are checked for compliance with AML/CFT. If you do not pass the AML/CFT check, you will be refused to work with gomining.com.

We also collect payment data such as credit card number, billing address, transaction history. We use this data to process orders and payments, ensure transaction security, and prevent fraud.

Your payment data is stored on secure servers that comply with Payment Card Industry Data Security Standards (PCI-DSS). Access to payment data is limited and is provided only to authorised employees who are required to comply with strict confidentiality and security measures.

All payment data is encrypted using standard encryption methods both during transmission and storage.

We comply with the Payment Card Industry Data Security Standards (PCI-DSS) to ensure the security of your payment data.

Automatic Collection of Information: We receive and store certain types of information automatically whenever you interact with us. As you interact with our Website and/or Services, we may automatically collect technical data about your equipment, browser features, browsing actions and patterns.

For example, like many websites, at the Website and Services we use "cookies" and other similar tools and identifiers for analytics and marketing (like web beacons and pixels), and we obtain certain types of information when you access our Website and/or our Services (access log records such as date, IP address, user agent). However, aggregated data is not considered personal data, as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

Information from Other Sources: We might receive information about you from other sources (such as public databases, marketing partners and other third parties) and add it to our account information (this concerns technical data from the following parties: analytics providers such as Google; advertising networks; and search information providers).

We will inform you about the source of information and the type of information we have collected about you within a reasonable period after obtaining the personal data, but at the latest within a month.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

6. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Your consent. We may process your data when you consented for the use of such data by us
Legitimate Interests. We may process your data where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override them. For instance, for provision of Website and Services to you, for the development of business, to procure compliance with our terms and policies. We can also conduct KYC of each user to counter money laundering and terrorist financing.
Legal obligation. Where we need to comply with a legal or regulatory obligation (for example, to comply with applicable law, governmental requests, a judicial proceeding, court order, legal process, enforcement requirements). We may also disclose your information where it is necessary to investigate, prevent or take action regarding potential or suspected fraud, illegal activities, situations involving potential threats to safety.
Performance of contract. Our processing is necessary for the performance of a contract to which you as a data subject is party or in order to take steps at your request prior to entering into a contract with us;

We are responsible for verifying your identity. For our internal purposes, we identify all persons (whether an individual or a legal entity) with whom we:

(a) establish or intend to establish business relations with;

(b) undertake or intend to make any transaction in GMT.

We undertake to take reasonable measures to verify the identity of the beneficial owners (UBO) of legal entity, including the main investors and/or controllers of the legal entity, or, if the legal entity is a fund, a party that acts as a fund manager.

Our Website uses technologies of our Third-Party Service Providers to help us recognize your device and understand how you use our Website so that we can improve our products and/or services to reflect your interests and serve you advertisements about our products and/or services that are likely to be of more interest to you.

We also utilize services, which may include the collection of hashed identifiers derived from email addresses for cross-device tracking and targeted advertising purposes. By using our services, you acknowledge and consent to this data processing. We may share data, such as hashed email derived from emails or other online identifiers collected on our site(s) with our advertising partners. This allows our partners to recognize and deliver you ads across devices and browsers.

7. CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for a reason compatible with the original purpose. If we need to use your personal data for a purpose not related to the purposes stipulated here, we will notify you and we will explain the legal basis which allows us to do so.

8. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in this Privacy Policy.

Business Transfers. Third Parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

Affiliates. We may share your information with our affiliates (including parties that we control, controlled by or under common control with us). We require all third parties to respect the security of your personal data and to treat it in accordance with the law and this Privacy Policy. We do not allow our third-party service providers to use your personal data for their own purposes, share it with third parties and only permit them to process your personal data for specified purposes and in accordance with our instructions.

9. INTERNATIONAL TRANSFERS

Please note that your information may be transferred, stored and processed by us and by those third parties with whom we may share your information in various countries, including outside BVI. These countries may have less stringent privacy laws than we do, so any information they hold can become subject to their laws and disclosure requirements, including disclosure to governmental bodies, regulatory agencies and private persons. In addition, a number of countries have agreements under which information is exchanged with other countries for law enforcement, tax and other purposes.

We will however take all necessary measures to protect your personal information in accordance with this Privacy Policy and applicable laws and require all our contractors to follow the same rules when processing your personal data. Moreover, we also take into account the best industry standards for securing your data processing.

10. DATA SECURITY

We have put in place appropriate technical and organizational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

We apply modern technical data protection measures, including the use of encryption, antivirus software and firewalls

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

However, please remember that the transmission of data over the Internet (including e-mail) is never completely secure. Therefore, while we use appropriate measures to try to protect your personal data, we cannot guarantee the security of the data transmitted to us or by us. You must access the Website and Services and/or otherwise transmit your data in a secure environment.

11. DATA RETENTION

We will only retain your personal data for as long as is necessary to achieve the purposes for which we collected it, unless a longer retention period is required or permitted by law (for example, any legal, accounting or reporting requirements).

When we do not have an ongoing legitimate business need to process your personal information, we will either delete it or anonymize it, or, if this is not possible (for example, if your data is stored in backup systems), we will securely store it until it is deleted.

If in some circumstances we anonymize your personal data (so that they can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice.

12. YOUR LEGAL RIGHTS

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

request access to your personal data;
request correction of your personal data;
request erasure of your personal data;
object to or restrict processing of your personal data;
request restriction of processing your personal data;
request transfer of your personal data (data portability);
right to withdraw consent.

We must respond to your request within 30 calendar days. We can extend that deadline, but in any case, we will notify you in advance. If you submitted a request to correct and have not received any response within the timeline, make sure you duly submitted your request. Please send all your requests to our DPO to the following e-mail address: [email protected].

If we are relying on your consent to process your personal data you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with certain services.

We will inform you about it when you withdraw your consent. Please note that under certain circumstances it may be lawful for us to continue processing your information even if you have withdrawn your consent if one of the other legal grounds applies. No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights).

13. THIRD-PARTY LINKS

The Website, Services and means of Voluntary provision of data may include links to third-party websites and services, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.

We do not control these third-party websites and services and are not responsible for their privacy statements. When you leave the Website and/or Services and/or use means of Voluntary provision of data ran/built on or hosted by third-party services, we encourage you to read the privacy Policy of every third-party website and service you visit.

13.1 OUR APP AND SUBSCRIPTION: PRIVACY CONDITIONS AND REQUIREMENTS

Our App include a link to our Privacy Policy in the App Store Connect metadata field and within the app in an easily accessible manner.

Our App is offered by developers enrolled as an organization – GoMining (BVI) Limited. We do not use false or inaccurate data. We regularly test Our App for bugs and stability.

Data collected by our App for one purpose may not be repurposed without further consent unless otherwise explicitly permitted by applicable laws.

Our App does not build a user profile based on collected data and may not attempt, facilitate, or encourage others to identify anonymous users or reconstruct user profiles based on data collected from Apple-provided APIs or any data that has been collected in an “anonymized,” “aggregated,” or otherwise non-identifiable way.

Information on what data the app/service collects, as well as how it collects that data, and all uses of that data you can clearly find in our Privacy Policy.

We hereby confirm that any third party with whom our App shares user data will provide the same and equal protection of user data as stated in our Privacy Policy.

Our users can revoke consent and/or request deletion of the user’s data, as stated in this Privacy Policy. Our App provides the customers with an easily accessible and understandable way to withdraw consent, as specified in this Privacy Policy.

Our App collects user or usage data and secure user consent for the collection, even if such data is considered to be anonymous at the time of or immediately following collection.

Our App collects data relying on the terms of the European Union’s General Data Protection Regulation (“GDPR”), and complies with all terms of applicable data protection laws, as well as other best data security standards taking into account our business industry’s specificity.

Our App only requests access to data relevant to the core functionality of our App and only collects and uses such data that is required in accordance with the mandatory applicable laws and regulations.

Our App respects the user’s permission settings and does not manipulate, trick, or force people to consent to unnecessary data access.

Our App supports account creation, and our App also offers account deletion within the App.

Our App does not require users to enter personal information to function, except for cases when directly relevant to the core functionality of the app and/or required by the applicable laws.

Our App does not use SafariViewController to track users without their knowledge and consent.

Our App implements appropriate security measures to ensure proper handling of user collected information and prevent its unauthorised use, disclosure, or access by third parties.

Unless otherwise permitted by law, we will not use, transmit, or share your personal data without first obtaining your permission. We will provide access to information about how and where the data will be used, as it is specified in this Policy.

Our App does not include content that is offensive, insensitive, upsetting, intended to disgust, in exceptionally poor taste, or just plain creepy.

We ensure that our users know how to reach us with questions and support issues. Our App include an easy way to contact us.

We ensure that our users should know what they are getting when they download or buy our App. All our App metadata, including privacy information, our App description, screenshots, and previews accurately reflect the App’s core experience, and we keep them up-to-date with new versions.

Our App does not include any hidden, dormant, or undocumented features. Our App’s functionality is clear to end users and App Review.

We are responsible for securing the rights to use all materials in our App icons, screenshots, and previews, and we will display fictional account information instead of data from a real person.

Our App metadata is focused on the App itself and its experience. We do not include irrelevant information.

Our App includes content that we created or that we have a license to use. We do not use protected third-party material such as trademarks, copyrighted works, or patented ideas in our App without permission, and we do not include misleading, false, or copycat representations, names, or metadata in our App bundle or developer name.

We comply with developer code of conduct. We ensure the highest quality of our App, and maintain high quality content, services, and experiences that promote user trust.

All other conditions and requirements specified in the Apple’s App Review Guidelines, and not mentioned in this Privacy Policy, shall apply on the basis of mutatis mutandis principle.

14. COOKIES

We may use cookies and similar tracking technologies (like web beacons and pixels) to access and store information.

Cookies are files placed on your computer by certain websites that you visit or emails that you open. Using the website https://gomining.com, you consent to our use of cookies to collect and use your personal data in order to collect data about the use of the website, as well as to provide you with a personalized and more convenient online interaction.

We use cookies to enhance your experience, personalize content, analyse site traffic, and provide social media features. Cookies help us understand how you interact with our website, allowing us to improve its functionality. Cookies make it easier for you to navigate our website and help to remember the preferences of your language and country.

We can place cookies and other similar technology on your device, including mobile device, in accordance with your preferences set on our cookie preference. Depending on your settings in our cookie consent on your mobile device, the following information may be collected through cookies or similar technology: your unique device identifier, mobile device IP address, information about your device’s operating system, mobile carrier and your location information (to the extent permissible under applicable law).

The personal data we collect may include information about how you use our website, your choice of Internet browser, the type of device from which you access our website, and where you are in the world in accordance with applicable laws. If any information we collect through cookies qualifies as personal data, our Privacy Policy applies to the collection and use of such personal data.

This Privacy Policy provides clarity on how and why cookies are used, the types of cookies implemented, and user options for managing cookies. GoMining closely follows the developments in the Privacy-related laws and regulations. When we make any changes, we will update this Privacy Policy accordingly. You can always find the latest version on our website.

14.1. WHAT ARE COOKIES

Cookies are small text files that are stored on your device when you visit websites. They help websites remember your actions and preferences over time. Cookies stores information about the user’s visit, which may include content viewed, language preference, time and duration of each visit and advertisement accessed.

Cookies are unique to your browser, device or account. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire. The time until expiration of the cookie is referred to as the retention period. GoMining sets specific retention periods for each cookie type depending on its functions.

More useful information about Cookies you can be found at: https://www.allaboutcookies.org/

14.2. HOW WE USE COOKIES

We use cookies and similar tracking technologies (such as web beacons and pixels) to access and store information when you use our website, enhance your experience, personalize content, analyse website traffic, and provide social media features. Cookies help us understand how you interact with our website, enabling us to improve its functionality and provide a personalized and convenient online interaction.

We collect and use cookies on our website for the following purposes:

Necessary Cookies:
- Enable basic features like page navigation and access to secure areas;
- Balance website traffic to ensure that all our users can enjoy consistent and reliable access;
- Limit traffic to key sections of our website to maintain stable performance;
- Maintain our users’ consent to our Terms of Use and Privacy Policy;
- Please note: the website cannot function properly without these cookies, as they are essential for the functioning of our website. Placing such cookies does not require your consent. Other cookies are only activated after you provide your consent via our cookie banner. The majority of cookies are activated upon your consent.
Preferences Cookies:
- Remember information that changes the way the website behaves or looks, such as your preferred language or region.
- Remember the preferences of your language and country.
Statistics Cookies:
- Collect statistical data to understand how you navigate our website.
- Understand, improve, and research products, features, and services, including to create logs and record when you access our websites and Services from different devices.
- Include feedback on your satisfaction through surveys and anonymous data collection for website improvements.
- Collect statistics about how you move and make transactions on our website,
- Collect feedback on your satisfaction through surveys;
- Get information about how you navigate and make transactions on our website, so that improvements can be made.
Targeting Cookies:
- Provide you with relevant ads based on your interests;
- Conduct online behavioural advertising (interest-based advertising);
- Allow our website to serve different versions of the page for marketing purposes;
- Allow us and/or third parties to display relevant messages and/or advertisements that offer a selection of products based on your browsing behaviour on our website and some other websites.

We also use web analytics services such as Google Analytics. Google may use the collected data to contextualize and personalize ads on its own network. If you want to opt out of Google Analytics cookies, you can use the browser add-on offered by Google. Please check compatibility with the browser of your choice before installing it. You can find the instructions here: https://tools.google.com/dlpage/gaoptout.

14.3. WHAT COOKIES DO WE COLLECT AND HOW DO THEY WORK FOR US

The Cookie banner, placed on our Website, works only on the basis of “Gtag” (Google tag).

Google tag is connected to our Website, checks your consent and only afterwards begin to collect your cookies.

Google Analytics, Google Ads and other integrations starts working only in case of transfer of your consent based on necessary parameters.

More details about technical implementation procedure you can find at the following link: https://developers.google.com/tag-platform/security/concepts/consent-mode

The mapping of cookies are as follows:

necessary:
security_storage
preferences:
functionality_storage
statistics:
analytics_storage
targeting:
ad_storage
ad_user_data
ad_personalization

More details about gtag (Google tag) setting you can find at the following link: https://developers.google.com/tag-platform/security/concepts/consent-mode#consent-types

14.4. WHO MANAGES THE COOKIES PLACED ON YOUR COMPUTER OR DEVICE

Cookies placed on your computer or device may be first-party or third-party Cookies.

First-party Cookies are sent to your computer or device from a computer or domain that is managed by GoMining.

Third-party Cookies are sent to your computer or device from a computer or domain that may or may not be managed by GoMining. In these cases, a third party will process the data obtained by the Cookies.

Please note: We do not share cookies with any third party, and we do not collect any personalized information, unless otherwise provided in this Privacy Policy. Any communications with third-party services (including advertising networks) are communicated through Google data.

14.5. HOW PERSONAL DATA COLLECTION TAKES PLACE

The personal data we collect through Cookies may include information about how you use our website, your choice of internet browser, the type of device from which you access our website, and your geographic location.

All location data will be anonymous. The location of individual users will not be tracked in an identifiable way.

14.6. RETENTION PERIOD

We use cookies with varying retention periods on our website. The specific retention periods for each type of cookie are as follows:

Necessary Cookies:
- Session Cookies: These are temporary and last only while your browser is open. They are automatically deleted when you close your browser.
- Persistent Cookies: These cookies remain on your device for up to 12 months to remember your preferences and settings. They are activated each time you visit the website that created that particular cookie.
Preferences Cookies: These cookies store your preferences (such as language or region) and remain on your device for up to 24 months to provide you with a consistent experience.
Statistics Cookies: These cookies help us understand how you use our website and can remain on your device for up to 24 months for analytical purposes.
Targeting Cookies: These cookies track your browsing habits to deliver personalized advertising and have a retention period of up to 12 months.

14.7. SECURITY MEASURES

We implemented enhanced measures to safeguard its users’ data. This Privacy Policy ensures that user’s privacy and security remain our top priorities.

We understand the importance of safeguarding the user’s data and ensuring its privacy. In the course of its operations, we want to reassure you that all user data collected by our services is anonymized, ensuring that no personally identifiable information is disclosed to the extent permitted by applicable laws. We committed to maintaining the privacy and confidentiality of our user’s information.

14.8. ONLINE BEHAVIORAL ADVERTISING

Online behavioural advertising is also known as interest-based advertising. It is a way of serving advertisements that are more relevant to your interests on websites visited by you.

Shared interests are grouped together based on your previous web browsing activity. This allows us to display advertising that is relevant and useful to you.

Advertising can also be delivered to you based on the website content you’ve just been viewing. This is called retargeting.

When you visit our website and navigate to other websites, we may leverage the cookies we have in place and our partnerships with online advertisers and social media networks in order to serve you with targeted advertising and/or to limit the number of times you see a particular advertisement.

We collect the following information about you for such purposes: IP address or other unique identifiers, mobile carrier, time zone setting, operating system and platform.

You may opt out of the use of cookies if you do not want to be retargeted or your advertising to be tailored.

Please note: Opting out, however, does not mean that you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer serve you advertising that is tailored to your web preferences and usage patterns. You may instead see more advertising that is not as relevant to your preferences.

14.9. OUR PARTNERSHIP WITH ADVERTISING NETWORKS

We only share your data with advertising networks in the strictest confidence for the unique purpose of serving more relevant advertising.

We have established standards to ensure that you'll only be served appropriate advertising.

You may opt out of such advertising from the advertising networks at any time by visiting their websites or be referring to the section titled "Managing cookie preferences".

14.10. MANAGING COOKIE PREFERENCES

You may refuse to accept cookies by changing the settings of your Internet browser. You can also choose to accept only necessary cookies or accept all cookies on our website. If you do not want cookies to be placed on your device, you can control this through your browser’s settings.

Please note that if you disable or refuse cookies, some parts of the website or services may become inaccessible or not function properly.

Please note that if you delete your cookies, we won’t be able to know that you have opted out of behavioural advertising on our website; recognize that you have agreed to our Terms of Use and Privacy Policy; or remember your language and country preferences. This means that banners from our third-party websites will appear. You will need to accept the use of cookies and provide other cookie-related information again.

14.11. BROWSER SETTINGS

You may block, restrict, disable, or delete Cookies through your browser’s setting. However, if you use your browser settings to block all Cookies, you may not be able to access all or parts of our Website. These settings are usually found in the 'options' or 'preferences' menu of your internet browser.

14.12. THIRD PARTY TOOLS

You may also use third party cookie management tools to manage Cookies. Please note GoMining does not provide or support third party cookie management tools, unless otherwise provided in this Privacy Policy.

14.13. CLICKSTREAM DATA

A clickstream records which parts of a website you click on when you use it. We may collect clickstream data when you use our website and track referrals from other websites to improve your online experience with us. This data will not be stored as part of your customer record, and will only be used for statistical analyses.

14.14. CONTACT US

If you have any questions about our use of cookies, please contact us at [email protected].

15. OPT-OUT MECHANISMS

You have the right to opt out of targeted advertising. You can manage your preferences by visiting the opt-out pages like the Digital Advertising Alliance (DAA), Network Advertising Initiative (NAI), and the European Interactive Digital Advertising Alliance (EDAA). Our partners may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. For this reason, you can use the following third-party tools to decline the collection and use of information for the purpose of serving your interest based advertising. Links to these opt-out tools are provided below for your convenience:

Third-party opt-out tools such as the Digital Advertising Alliance (DAA), the Network Advertising Initiative (NAI), and the European Interactive Digital Advertising Alliance (EDAA) allow users to opt out of interest-based advertising. Please note that opting out through these mechanisms may not entirely stop all targeted ads, as it relies on cookies and similar technologies. The Opt-Out mechanisms are as follows:

1) Digital Advertising Alliance (DAA):

You can visit the DAA's WebChoices tool (https://optout.aboutads.info/) where you can see which participating companies are collecting data for interest-based advertising on your browser.

You can select specific companies or opt out of all participating companies. This sets an opt-out cookie in the browser, signaling those companies to stop collecting data for interest-based advertising.

2) Network Advertising Initiative (NAI):

You can visit the NAI's opt-out page (https://optout.networkadvertising.org/) to view which member companies are tailoring ads based on your data.

You can opt out of tracking by selecting individual companies or opting out of all at once. An opt-out cookie is placed in the browser to notify companies of your preference.

3) European Interactive Digital Advertising Alliance (EDAA):

If you are a user in EEA, please visit the EDAA's Your Online Choices website (https://www.youronlinechoices.eu/) to manage your preferences.

You can see which companies are using your data for interest-based advertising and opt out by setting preferences. Opt-out cookies are placed to enforce these choices.

4) Other possibilities

You may also control the collection of data by web browsers and mobile devices. To control the collection of data by web browsers and mobile devices, visitors can follow these instructions:

For information on how to manage your privacy settings within your web browser, please refer to the help or support section of your browser.

This may include instructions on how to control cookies, manage website permissions, clear browsing data, and other privacy-related configurations. Please note that instructions may vary depending on the browser you are using (e.g., Chrome, Firefox, Safari, etc.).

For information on how to control your privacy settings related to hardware or software products you are using, please consult with your respective vendor.

This may include guidance on adjusting settings, managing data collection preferences, and implementing privacy controls specific to your device or software configuration.

In any case, if you have any concerns regarding our data processing activities, do not hesitate to contact our DPO to the following e-mail address: [email protected].

16. JURISDICTION-SPECIFIC DISCLOSURES (EUROPE - GDPR):

If you are located in the European Economic Area (EEA), Switzerland, or the United Kingdom (UK), the General Data Protection Regulation (GDPR) may apply to the processing of your personal data. We comply with GDPR requirements regarding data processing, including lawful bases for processing, data subject rights, and international data transfers.

We process your personal data only when we have a lawful basis to do so (Art. 6 of the GDPR). This includes:

Consent: Where you have given clear consent for us to process your personal data for a specific purpose.
Contract: Where the processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
Legal Obligation: Where the processing is necessary for us to comply with the law.
Legitimate Interests: Where the processing is necessary for our legitimate interests or the legitimate interests of a third party, provided these interests are not overridden by your rights and interests.

As a data subject under GDPR, you have the following rights:

Right to Access: You have the right to request access to your personal data.
Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data.
Right to Erasure: You have the right to request the deletion of your personal data under certain conditions.
Right to Restriction of Processing: You have the right to request the restriction of processing your personal data under certain conditions.
Right to Data Portability: You have the right to request the transfer of your personal data to another organization, or directly to you, under certain conditions.
Right to Object: You have the right to object to the processing of your personal data under certain conditions, including processing for direct marketing purposes.
Rights Related to Automated Decision-Making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or significantly affects you.

If we transfer your personal data outside the EEA, Switzerland, or the UK, we ensure that appropriate safeguards are in place to protect your data. These safeguards may include:

Standard Contractual Clauses (SCCs): We use standard data protection clauses approved by the European Commission.
Adequacy Decisions: We transfer your data to countries that have been recognized by the European Commission as providing an adequate level of data protection.

We retain your personal data only for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We implement appropriate technical and organizational measures to protect your personal data against any unauthorized access, loss, or destruction.

If you believe that your data protection rights have been violated, you have the right to lodge a complaint with your national data protection authority (DPA). The list of DPAs and their contact details you can find at the following link: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.

17. DATA USAGE AND SHARING CLARITY

We collect and process personal data for specific purposes, such as providing our services, conducting AML/KYC checks, performing contracts and complying with legal obligations. This may include information such as your identity, contact details, and browsing behaviour. We may share this information with third-party service providers and affiliates strictly for the purposes outlined in this Privacy Policy.

18. POLICY UPDATES AND NOTIFICATIONS

We may update this Privacy Policy periodically to reflect changes in our data practices or legal requirements. We will notify you of any material changes by posting the updated Privacy Policy on our website or through other appropriate means (for example, by e-mail). We encourage you to review this Privacy Policy regularly to stay informed about how we are protecting your information.

19. CONTACT US

If you have any other questions, comments or requests about this Privacy Policy or the handling of your personal data by us, email us at: [email protected].