PRIVACY AND DATA PROTECTION STATEMENT

last update on (April 2024)

1. PRIVACY POLICY

1.1. Altrady BV (“Company,” “we,” “us,” “our”), a Dutch limited liability company with company number 64465284 and registration address: Finnenburg 132 in (2591XT CA) The Hague, the Netherlands ( “Company”, “we”, “our”, or “us”). We respect your rights to personal data protection when we process, collect, store, transfer or access your personal information.

1.2. This Statement outlines the Company’s practices in connection to the storage, collection, use, processing and disclosure of personal data as defined under the EU General Data Personal Regulation (“GDPR”) through our URL at https://www.altrady.com/privacy (“Website”), as well as through our services, and dashboard.

1.3. By visiting our Website or accessing and using our services, you (“User”, “you”, or “your”) have indicated that you are at least eighteen (18) years of age, have the legal capacity to agree to this Statement, and to be bound by the policies and practices of our Company concerning privacy and data protection.

1.4. This Statement outlines the following aspects regarding privacy and data protection: (i) The types of personal data being collected and the sources from which we collect such personal data; (ii) the purposes for collection, use and disclosure of personal data; (iii) disclosure of personal data; and (iv) care of personal data.

1.5. This Statement may be amended from time to time, and we will provide notice of such changes by publishing the most recent version on our Website or by notifying you by email.

1.6. We will comply with any applicable privacy laws and other applicable data protection regulations, including but not limited to the European Union General Data Protection Regulation (“GDPR”).

2. COLLECTION OF PERSONAL AND OTHER INFORMATION

2.1. Non-Personal Data: If you use our Website or services as a User, you allow the Company to collect information about your activities in relation to our services. Such information may include:

(a) Device Information: Data that is automatically collected about your device, such as your browser’s name and other technical information about your device (e.g., hardware, browser, operating system, among other information);

(b) Location Information: Data that is automatically collected via analytics service providers to determine your location, including your IP address or domain name, and any external page you have visited before us;

(c) Log Information: Data that is generated by your use of our Website is automatically collected and stored in our server logs. This may include, but is not limited to, device-specific information, location information and/or other activities;

(d) Account Information: Data that is generated by your account activity on our platform including, but not limited to, trading activity, purchase activity, withdrawals, deposits, and account balances. This information may be aggregated to provide statistical data, and patterns anonymously. We shall never use account information to identify individuals personally.

2.2. The User agrees and acknowledges that the Company shall collect, process and store the User’s personal data (whether you are an EU resident or not) from which that User can be identified (“User Information”). Such User Information does not include data where the identity of the Users has been removed (anonymous data).

2.3. User Information may include but is not limited to the following: User’s name, email address, transaction data on the blockchain, and details about payments and crypto trading and transfers.

2.4. The User Information mentioned in this Section 2 may fall under the scope of “personal data” as defined in the GDPR and as used in this Statement. The User acknowledges that the Company may use your User Information to provide services and offer features targeted at you that will most likely meet your needs in connection to our services.

2.5. In addition, the definition of personal data under the GDPR may be broader than under other privacy laws, and may include sensitive financial information.

2.6. The User expressly consents to the Company’s collection and compilation of all user-related information, irrespective of the method of collection, including personal communications, emails, service-related instructions, and user interactions, for purposes including but not limited to customer support.

2.7. The Company employs Cookies to collect data, enhancing website administration and user experience. These small files, stored on the User’s device, capture non-personal data to analyze website usage and trends without accessing personal files. The use of cookies, which the User consents to by using the Website, facilitates personalized services and website improvement efforts. Cookies enable access to specific website features and services. Users can manage cookie settings through their browsers or devices, though restricting cookies may affect website functionality.

3. USE OF INFORMATION COLLECTED

3.1. We may use personal information to:

(a) Provide the User with the use of the Website and the services offered on the Website, including customer support and marketing materials and dashboard access;

(b) Optimize and enhance the Website or platform operated by the Company or its affiliates for all Users; and

3.2. The Company will handle personal data appropriately and adequately, in line with the circumstances and in accordance with the applicable law. If the Company plans to use personal data beyond initial collection purposes, it will inform Users and request their consent for the new use of their personal information.

3.3. If you are a resident of the EU, we are required to disclose the legal basis for collecting and processing your data under the GDPR. We will use your personal information as described in the following paragraphs.

3.4. To ensure that our services function properly, we may utilize your data in the following ways:

(a) Enhance the Website’s performance and the proper functioning of your device;

(b) Manage the Website, including troubleshooting, performing data analysis, testing, and conducting research for statistical and survey purposes;

(d) Customize our products and services to meet your preferences and needs;

(e) Answer and address promptly your inquiries, requests, or feedback;

(f) Send surveys via email or other communications, including social media notifications. You can opt out of these surveys at any time by contacting us;

(g) Enforce our terms, conditions, and policies to maintain the integrity of our services; and

(h) Provide opportunities for you to engage with experimental features of our services (e.g., paper trading), subject to your interests and participation.

4. SUBMISSIONS

You are reminded that the Company does not guarantee confidentiality for any unsolicited information submitted by Users, regardless of the submission method. Such information will not be considered confidential or proprietary. Additionally, the Company’s systems are not designed to transmit private or confidential electronic communications through the Website. Please be aware that all messages and content shared with us or submitted through the Website may be accessible to the Company. We discourage Users from using our services for private communications.

5. SECURITY AND RETENTION OF PERSONAL INFORMATION

5.1. We implement reasonable and practical security measures to protect personal information from unauthorized access, use, disclosure, and other risks. Despite these efforts, we cannot guarantee complete security for data transmitted over the internet or stored in our systems. Users acknowledge these limitations by using our services and agree to assume the risk of potential personal information disclosure due to any security breaches. You understand that given the inherent limitations of internet and data storage systems, complete data security can never be guaranteed.

5.2. The Company shall review the security measures from time to time in light of new and relevant legal and technical developments and maintain industry-standard security measures.

5.3. The User is aware that personal data may continue to be stored and retained by the Company for the period necessary to carry out the purposes outlined in this Statement unless longer retention is required under applicable law or until data retention is no longer necessary for any other legal or purposes.

6. DISCLOSURE OF PERSONAL INFORMATION

6.1. In general, the Company will not disclose personal data except in accordance with the following:

(a) in order to carry out the purposes for which such personal data was collected;

(b) where the User has consented;

(d) if required by applicable law, including reporting suspicious transactions to the authorities in any jurisdiction.

7. THIRD PARTY SERVICES

7.1. The Company employs third-party services, such as applications from cryptocurrency exchanges, to facilitate user interactions with our services. You agree that your personal data may be shared with these third parties, both within and outside the EU, and as required for the purposes disclosed by us. Your engagement with these third parties, including data collection permissions and restrictions, is separate from your relationship with us. You acknowledge and have read the privacy policies of these third-parties.

7.2. If you are an EU resident and we store any of your data in the European Economic Area (“EEA”), the transfer of data outside the EEA is governed by this Section 7. Such transfers are carried out either because they are necessary for the performance of services the Company provides to you, or they comply with the laws applicable under the GDPR.

8. THIRD PARTY AUTHENTICATION SERVICES

8.1. To enhance security and for the purpose of User verification, the Company may engage third-party authentication services. This allows us to gain access to, be granted permissions for, and sometimes store particular pieces of data these third-parties hold. Such data is crucial for carrying out registration and identification procedures effectively, ensuring that Users’ interactions with our services are both secure and personalized.

8.2. For EU residents whose data we store within the EEA, transferring data outside the EEA is governed by this Section 8 and involves specific considerations. Such transfers occur only if they are essential for the services the Company offers you or if they comply with the GDPR and other relevant privacy laws.

9. THIRD-PARTY LINKS

9.1. We may, at our discretion, include third party products or services on the Website that we do not operate. Third-party sites operate under their respective privacy policies. You understand that we have no influence or control over them. Consequently, we cannot be held responsible or liable for the content and actions on external websites. We highly recommend that you examine the privacy policies of any such third-party service.

10. THIRD PARTY STORAGE

10.1. The Company may use international web hosting facilities and cloud server services, which are maintained in accordance with industry-standard security standards.

11. TRANSFER OF PERSONAL DATA OUTSIDE THE EU

11.1. Data may be stored and processed in data centers around the world, wherever third-parties and service providers are located. As such, we may transfer your personal data outside the Netherlands or the EU. Storage and processing of personal information shall always be in accordance with applicable laws and regulatory obligations.

12. COMPANY TRANSITIONS

12.1. The User understands that should the Company undergo a merger, become acquired by another organization, or sell all or a portion of its assets, your personal data may be transferred as part of such a transaction. We represent that the transfer of data to the legal successor shall adhere to the strictest data security standards and comply with any applicable privacy laws.

13. RIGHTS IN RELATION TO YOUR PERSONAL DATA

13.1. Under the GDPR, you may, by a written request to us, ascertain whether the information we hold about you is current and accurate, and you may also receive a copy of the personal information we hold. You have the right to know whether we process data about you, and, if we do so, to access data we hold about you and information about how we use it and who we share it with.

13.2. When we receive your data access or correction request, we will first check the identity of the requesting party to ensure that he or she is entitled to make such request and receive personal data. We may charge you a reasonable fee for the administrative costs incurred in complying with your request.

13.3. You understand that certain circumstances may lead to our refusal to comply with your request under section 13.2. These include (to the extent allowable under applicable law) the following situations:

(a) If a government agency or any regulatory authority overseeing our operations instructs us not to fulfill such a request from a User; or

(b) Should the information, at our discretion, pose a risk to any individual’s safety or be pertinent to regulatory or official investigations concerning possible criminal activities or other legal violations.

13.4. The right to correction or rectification: You may request us to correct any inaccurate data held about you.

13.5. Withdrawal of Consent to Use Your Personal Information: You may withdraw your consent to the use of your personal data at any time by contacting us. We shall comply with your request, and stop processing your data. If you wish to stop receiving communications from us, please contact us.

13.6. If you reside in the EU, you are entitled to specific rights under the GDPR regarding your personal data:

(a) the right to be informed about our use of your information as outlined in this Statement;

(b) the right to data portability;

(d) the right to limit processing of your data; and

(e) the right to object to the processing of your data.

13.7. The right to data portability allows you to receive your information we collected in a structured, commonly used, and machine-readable format and this data to be transferred to another entity. This only includes data you have consented to provide.

13.8. To transfer your personal data to another entity, please provide the necessary details for the transfer. While we strive to ensure technical safeguards, we are not liable for the data’s security once transferred. Some data may not be provided if it poses a risk to another individual’s rights.

13.9. The right to be forgotten: You can request data deletion if:

(a) storing your data becomes unnecessary, or does not match its original purpose(s);

(b) you withdraw your previously given consent, and no other legal basis for processing your data exists; or

13.10. Despite the requests mentioned in this Section, legal grounds may require us to retain your data, about which we will inform you. You agree that the deletion of your data means that we cannot offer personalized services to you.

13.11. The right to restrict processing: You may ask us to cease processing your data. However, we may resume processing your data if legal reasons arise, including in case of a legal duty of adherence to compliance laws.

13.12. A request to stop processing your data applies in the following situations:

(a) you dispute the accuracy of your data held by us;

(b) you believe our processing of your data is unlawful; or

13.13. To exercise any data privacy request, contact us using our email address with specific details of your request. We aim to respond promptly, but at least within seven business days.

14. UPDATE TO THIS POLICY

14.1. The Company reserves the right to revise, modify and update this Statement at any time, without prior notice, and at the sole discretion of the Company.

14.2. Users may check the date of the most updated version of this Statement by referring to the top of this page.

15. CONTACT AND ENQUIRIES.

Please send any questions or requests in relation to this Statement to: privacy@altrady.com. To facilitate any request regarding your personal data, you should indicate “Privacy Request” in your email subject.