Personal Data Processing Policy

“Personal Information” (also referred to as “Personal Data”) means any information relating to the User and that alone or in cumulation with other pieces of information gives the opportunity to the person that collects and processes such information to identify the User as a person. It can be User’s name, identification number, location data, or information related to physical, physiological, genetic, mental, economic, cultural or social life. Processing of the information means any action with User’s personal data, for example, collection, recording, organization, structuring, storage, use, disclosure by any means and so on.

The other terms and notions used in this Policy shall be understood according to the Paypolitan Terms and Conditions, unless other specified in this Privacy Policy.

2.1 We collect the Personal Data from running the Website and use information, provided to us by you, sent to us by your computer, mobile phone, or other access device, which may include your ETH-address or other similar address, IP address, email address, device information including, but not limited to, identifier, name, and type, operating system, mobile network information and standard web log information, such as your browser type, and the pages you accessed on our Website. When you use a location-enabled device with our Website and products, we may collect geographical location data or use various means to determine the location, such as sensor data from your device that may, for instance, provide data on nearby cell towers and wi-fi access spots. However, we will not release your Personal Data of such kind to any third party without your consent, except as set forth herein.

2.2 If you participate as a buyer in our TGE, we may collect and store the following types of Personal Data: contact information – your name, address, phone, email and other similar information. We would also request from you additional information (such as a date of birth, passport number, numbers that You may use or have registered with your local tax authority, or other Personal Data which can be used for personal identification purposes and that may be required to comply with applicable laws), so that we can verify your identity or address before permitting you to use our Website and acquiring the Paypolitan Tokens (PAN). We may also obtain information about you from third parties such as identity verification services and/or KYC service providers.

2.3 We are committed to implementing and maintaining the highest standards of Know Your Customer (KYC) and Anti Money Laundering (AML) compliance and require managers and employees to adhere to these standards to prevent abuse of our Services for money laundering and terrorist financing purposes.

2.4 To assist in the detection, prevention, and reporting of money laundering activities, the Company shall:

 know its customers by obtaining satisfactory evidence of their identity and having effective procedures to verify the authenticity of the information furnished by new customers;

 ensure that its business is conducted in conformity with high ethical standards, that laws and regulations are adhered to, and that service is not provided where there is good reason to believe that transactions are associated with money laundering activities;

 cooperate fully with law enforcement agencies by, among others, taking appropriate measures allowed by law if there are reasonable grounds for suspecting money laundering;

 implement specific procedures for customer identification, record keeping and retention of transaction documents and reporting of covered and suspicious transactions.

2.5 For the above mentioned purposes, described in paragraph 2.4., we would collect including, but not exhaustive information: photo of your passport or other identity card to show proof of identity; documentation that evidences your proof of address; name; telephone number; e-mail address.

2.6 Such documents may be requested by the Company prior to activating your account on the Website and/or any services, available through the Website. Any doubts as to validity, authenticity and genuineness of the documents, provided by you shall be considered a valid reason to refuse you access to our services and Website.

2.7 When you access the Website, or use our products or services we (or Google Analytics or similar service provider on our behalf) may place small data files called cookies on your computer or other device.

2.8 Paypolitan uses the following types of cookies files when entering the website:

Description Name Provider Purpose Expiry Type

Necessary cookies

are used to provide proper functioning of the website CookieConsent

Stores the user's cookie consent state for the current domain 1 year HTTP

Cookie PHPSESSID Preserves user session state across page requests Session HTTP

Cookie Statistics cookies enable us to analyse your preferences and activity on website @@History/@@scroll|# Unclassified Persistent HTML

Local Storage _ga Registers a unique ID that is used to generate statistical data on how the visitor uses the website 2 years HTTP

Cookie _gat Used by Google Analytics to throttle request rate Session HTTP

Cookie _gid Registers a unique ID that is used to generate statistical data on how the visitor uses the website Session HTTP

Cookie collect Used to send data to Google Analytics about the visitor's device and behavior. Tracks the visitor across devices and marketing Session Pixel

Tracker Marketing cookies help us to provide you with relevant information (via emails, ads etc.) GPS Registers a unique ID on mobile devices to enable tracking based on geographical GPS location Session HTTP

Cookie VISITOR_INFO1_LIVE Tries to estimate the users' bandwidth on pages with integrated YouTube videos 179 days HTTP

Cookie YSC Registers a unique ID to keep statistics of what videos from YouTube the user has seen Session HTTP

2.9 You may control the use of cookies within your internet browsers’ settings. The following links might be useful for you to choose the best option of your browser:

For the users of Internet Explorer

For the users of Firefox

For the users of Chrome

For the users of Safari web and iOS .

3.1 We collect from the Users only the Personal Data that we need for their proper use of the Website. In particular, we use your Personal Data to:

 administer our Website and provide services;

 develop new products and services;

 personalize our Website for you;

 provide third parties with statistical information about our Users (but those third parties will not be able to identify any individual User from that information);

 comply with applicable laws, including, but not limited to Anti Money Laundering (AML) laws;

 detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of the Company and others;

 link or combine Personal Data we collect from or about you; and

 verify compliance with the terms and conditions governing the use of our Website (including monitoring private messages sent through the Website private messaging service).

3.2 If Paypolitan decides to change the purposes of processing specified above, we will inform you on such changes prior to use your personal information within the newly set purposes. The notification on such changes will be sent to your account dashboard and/or your email and your personal data will be processed for the amended purposes only on the basis of your consent, unless additional purpose of processing is compatible with those listed above.

3.3 We would like to additionally point at the processing of your personal data for marketing purposes that include:

 monitor and analyse trends, usage and activities in connection with our Website and services;

 send you technical notices and support and administrative messages; and

 communicate with you about products, services, promotions, events and other news and information we think will be of interest to you.

3.4 Please note that when the information is collected for these purposes you will be additionally asked for consent such information is processed for the marketing purposes. Furthermore, you will at any time have the possibility to withdraw your consent free of charge by the clicking on a separate “Unsubscribe button” in the email sent.

4. The Company is the only data controller and processor, except for the cases when there is an objective Company’s need to store or further process information at Company’s counterparties or agents.

4.2 We will not share your Personal Data with any third parties other than our respective identity verification partners. We also reserve the right to share your Personal Data with:

 our banking partners;

 companies that we plan to merge with or be acquired by (should such a combination occur, we will require that the newly combined entity follow these terms with respect to your Personal Data);

 third party identification service providers for fraud prevention purposes;

 law enforcement, government officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure; or we believe in good faith that the disclosure of Personal Data is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of any of our policies;

 our Personal Data processing counterparties or agents, hired by or cooperating with us, whose services are required by us from the practical point of view;

 other third parties only with your prior consent or direction to do so.

4.3 The Company is the only data controller and processor, except for the cases when there is an objective Company’s need to store or further process information at Company’s counterparties or agents.

4.4 In all cases we pass the information to other persons we ensure that your information is being protected and used only within the purposes specified in Section 4 of this Privacy Policy. This is achieved by using only certified services and products, signing agreements on protection of personal data with contractors as well as taking technical measures to ensure the information is protected when stored, used and while being transferred.

4.5 We may also contain information about you from other sources according to applicable law and combine that with the information we collect about you. This information will be protected not less favourable than the information you provide to us.

4.6 Our services may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates (including, but not limited to, websites on which the Website is advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any Personal Data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any Personal Data to these websites or use these services.

4.7 Paypolitan may disclose your personal information to enforce and comply with the law. In other words, Paypolitan may disclose information necessary for the investigation or legal process on official request or the official bodies acting within their powers.

According to applicable laws and as needed to provide services to our Users, we may hold your Personal Data. This requirement is conditioned by the need of complying with legal obligations and resolving possible disputes. We may retain your Personal Data for as long as your account is active. Moreover, your Personal Data may be hold beyond the above-mentioned period till it is indispensable for us to have relevant information to respond to any issues that may arise later.

6.1 We use relevant electronic and procedural safeguards to protect the privacy of the information you provide to the Platform from loss, misuse, disclosure, alteration and destruction.

6.2 We will also do any and all efforts and actions prescribed by Applicable Law to store any of your Personal Data in secrecy by means of, including but not limited to firewalls and data encryption, physical access controls to Our data centers, and information access authorization controls (which are designed to comply with Applicable Law and regulations), authorization of access to Personal Data only for those employees or contractors who require it to fulfill their job or service responsibilities.

We store and process your information using cloud services in various jurisdictions. As such, the information that we collect from you may be transferred to, and stored in various jurisdictions outside of your country of residence and outside the European Economic Area ("EEA"). The laws on processing such information, including where such information is classed as “personal data”, in these locations may be less stringent than in your country. It may also be processed by staff operating outside of your country or the EEA who work for us, for one of our service providers or one of our business partners. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Policy.

8.1 The Users may have the following right regarding Personal Data Paypolitan collects and processes:

8.1.1. To request Paypolitan to access to your Personal Data

This means that you can ask Paypolitan what personal information of yours is being processed, as well as for the clarifications on the information described above, i.e. purpose of collecting and processing, period of processing, third parties that have access to information.

8.1.2. To request Paypolitan to rectify your Personal Data

This means you can ask all the inaccurate personal information concerning you being corrected. You can also complete the personal information, if you feel there is a need to do so.

8.1.3. To request Paypolitan to erase Personal Data

You can request Paypolitan to erase such data, if its processing is no longer necessary in relation to the purposes for which it was collected, as well as if there are no legal grounds for the processing. In most cases, Paypolitan will erase it, unless otherwise will be required by legislation.

8.1.4. To request Paypolitan to restrict the processing of your Personal Data

In some cases, prescribed by law you will be able to restrict the processing of your personal data, for example, if you contest the accuracy of your personal information being processed or in case Paypolitan will not be interested to process your personal information any longer, but if you want Paypolitan to do this on different reasons, for example, to bring some claim for somebody and instead of the erasure of information, its processing will be just restricted.

8.1.5. To withdraw consent

You can withdraw your consent for the collection and processing of your personal information by Paypolitan at any time, without affecting the lawfulness of processing based on consent before its withdrawal. After we at Paypolitan receive such withdrawal from you we will process it in a timely manner and no longer process such information, unless the obligation to proceed is set by law.

8.2 Paypolitan will provide information on action taken on your request related to your rights specified above within one month of receipt of the request for the longest. That period may be extended by two further months, if Paypolitan is overwhelmed by the number of requests. Paypolitan will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.

8.3 The User also have the right to lodge a complaint with a supervisory authority that is empowered to process such complaints in your country.

The privacy of children is one of our concerns as well. Paypolitan can provide services only in case you as the User is aged 18 or older and is fully able and legally competent to use the Website according to the applicable laws.

We hope this Privacy Policy helped you to understand how your personal information will be dealt with here at Paypolitan. If you have questions concerning this Policy, please feel free to email us at