Privacy Notice

This "Privacy Notice" describes the privacy practices of Coinbook and Coinbook Affiliates (collectively, "Coinbook", "our","us" or "we"), in connection with the Sites and the Coinbook Platform (collectively, "Services"). This Privacy Notice also explains the rights and choices available to individuals with respect to their information.

Please read this Privacy Notice carefully to understand our policies and practices regarding your information. If you do not agree with our policies and practices, please do not use the Coinbook Platform. By accessing or using the Coinbook Platform, you acknowledge and agree to the terms of this Privacy Notice.

We may update this Privacy Notice based upon evolving laws, regulations and industry standards, or as we may make changes to the Coinbook Platform. If we make changes that materially alter your privacy rights, we will take appropriate measures to inform you, consistent with the significance of the changes we make. If you disagree with the changes to this Privacy Notice, you should discontinue your access and use of the Coinbook Platform.

Our Site and the Coinbook Platform are not directed to, and we do not knowingly collect Personal Data from, anyone under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information, they should contact us. We will delete such information from our files as soon as reasonably practicable.

Personal Data Controller

The term "Personal Data" as used in this policy describes information that can be associated with a specific person and can identify that person. Personal Data does not include information that has been aggregated or anonymized so that a specific person can no longer be identified. Any reference to "Personal Data" in this Privacy Notice includes without limitation "Personal Data" as defined by the Data Protection Act 2018.

A Personal Data controller is a person or organisation who controls the collection, holding, processing or use of Personal Data, including a person or organisation who instructs another person or organisation to collect, hold, process, use, transfer or disclose Personal Data on his or her behalf.

Types of Personal Data Collected

The types of Personal Data that we may collect from you or through third parties will depend on our interactions with you and may include:

• Financial information such as your wallet addresses;
• Transaction information such as the wallet addresses of senders and recipients of Digital Assets, activities on the Coinbook Platform, your inquiries and our responses;
• Usage Data which can include your IP address, your country of origin, the features of the browser or operating system utilised by you, how you use the Coinbook Platform, among other identifiers;
• Other personal data or commercial and/or identification information that we, in our sole discretion, may deem necessary to comply with various applicable anti-money laundering laws and regulations.

We may also collect Personal Data about you from third parties and other sources such as publicly available sources of information.

We collect this information from you when you freely provide it on the Coinbook Platform or when you use the Coinbook Platform. We may also collect your Personal Data from third parties or publicly available sources as noted above.

Unless specified otherwise, all Personal Data requested by us is mandatory and failure to provide this Personal Data may make it impossible for you to access or use the Coinbook Platform. In cases where the Coinbook Platform specifically states that some Personal Data is not mandatory, users are free not to communicate this Personal Data without consequences to the availability or the functioning of the Coinbook Platform. Users who are uncertain about which Personal Data is mandatory may contact us for clarification.

Information We Automatically Collect

When you visit the Coinbook Platform, we may automatically collect certain information about your device, including information about your web browser, IP address and/or domain name, IMEI or other device information, your login information, browser type and version, timezone setting, browser plug-in types and versions, operating systems and platforms, location information, and some of the cookies that are installed on your device using cookies and similar technologies. Additionally, as you browse the Site, we may collect information about the individual web pages or services that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site.

Cookies & Similar Technologies

We use cookies (small, often encrypted, text files that are stored on your computer or mobile device) and similar technologies ("Cookies") to provide you with certain functions on our Site and help collect data. This section explains how we use Cookies to collect information about the way you use our Site and how you can control them.

How We Use Cookies

We use Cookies to track how you use the Coinbook Platform by providing usage statistics. Cookies are also used to deliver our information (including updates) and allow account authentication to you based upon your browsing history and previous visits to the Site.

For the avoidance of doubt, we do not combine or link data or information gathered from Cookies with third party data for targeted advertising or advertising measurement purposes or sharing data collected about a particular end-user or device with a data broker.

Types of Cookies

We use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your device until you delete them). To make it easier for you to understand why we need them, the Cookies we use on our Site can be grouped into the following categories:

• Strictly Necessary: These Cookies are necessary for the Site to work properly. They include any essential authentication and authorisation Cookies for our Site.
• Functionality: These Cookies enable technical performance and allow us to remember the choices you make while browsing our Site, including any preferences you set. They also include sign-in and authentication Cookies and IDs that enable you to return without additional sign-in.
• Performance/Analytical: These Cookies allow us to collect certain information about how you navigate the Site and services running on your device. They help us understand which areas you use and what we can do to improve them.
• Targeting: These Cookies are used to deliver relevant information related to our Site to an identified machine or other device (not a named or otherwise identifiable person) which has previously been used to visit our Site. Some of these types of Cookies on our Site are operated by third parties with our permission and are used to identify advertising sources that are effectively driving customers to our Site.

Method and Basis of Processing Data

Methods of Processing

We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Personal Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. Data may be accessible to you and in some cases, to certain types of persons in charge, involved with the operation of the Coinbook Platform (administration, legal, system administration) or external parties (such as third-party technical service providers, hosting providers, IT companies) appointed, if necessary, as Data Processors by us. You may request a list of these parties at any time.

Legal Basis of Processing

We may process Personal Data relating to you if one of the following applies:

You have given your consent for one or more specific purposes. Note: Under some legislation we may be allowed to process Personal Data until you object to such processing ("opt-out"), without having to rely on consent or any other of the following legal bases:

• Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;
• Processing is necessary for compliance with a legal obligation to which we are subject;
• Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us;
• Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

How We Use Personal Data

Data we collect about you is collected to:

• Provide the Site and Coinbook Platform and customer support you request;
• Process transactions and send notices about your transactions on the Coinbook Platform;
• Detect any malicious or fraudulent activity;
• Enable us to monitor and analyze your behavior ("Analytics");
• Beta test certain features or the Coinbook Platform;
• Contact you;
• Display content from external platforms;
• Handle productivity related activities;
• Provide social features;
• Optimize traffic and performance of the Coinbook Platform;
• Allow us to register you as a user of the Coinbook Platform and authenticate your credentials;
• Comply with legal obligations and respond to enforcement requests;
• Protect the rights and interests of Coinbook and Coinbook Affiliates (or those of our users and third parties);
• Infrastructure monitoring;
• Interaction with external social networks and platforms;
• Location-based interactions;
• Tag management (tags are pieces of code that allow us to better analyze and track activities on the Coinbook Platform);
• Engage in traffic optimization and distribution.

How We Share Personal Data

We may share your Personal Data with our service providers and vendors to assist us in providing you with the Coinbook Platform. We do not share your Personal Data with third parties without your consent, except as described in this Privacy Notice or as otherwise required or permitted by applicable law. We may share your Personal Data within our group, and with affiliates, for purposes consistent with this Privacy Notice.

We may share your Personal Data with third-party companies and individuals that provide services on our behalf or help us operate the Site or our business. These third parties may use your Personal Data only as directed or authorized by us and in a manner consistent with this Privacy Notice, and are prohibited from using or disclosing your information for any other purpose. We may also share your Personal Data for compliance purposes.

We may sell, transfer or otherwise share some or all of our business or assets, including your Personal Data, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization, or sale of assets, or in the event of bankruptcy or dissolution

Retention of Personal Data

We will retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. We determine data retention based on:

• The amount, nature, and sensitivity of the Personal Data
• The potential risk of harm from unauthorized use or disclosure
• The purposes for which we process your Personal Data
• Whether we can achieve those purposes through other means
• Applicable legal requirements

Personal Data collected for purposes related to the performance of a contract between you and us will be retained until such contract has been fully performed. Personal Data collected for our legitimate interests will be retained as long as needed to fulfill such purposes.

We may retain Personal Data for longer if you have given consent or where required to do so by law. Once the retention period expires, Personal Data will be deleted (or, where permitted under applicable law, may be de-identified instead).

Once the retention period expires, Personal Data will be deleted (or, where permitted under applicable law, may be de-identified instead). Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability (where relevant under applicable law) cannot be enforced after expiration of the retention period.

However, not all your Personal Data may be able to be deleted or de-identified; see the section of this Privacy Notice on "Blockchain Transactions" below.

Privacy Technology Practices

Links to Third-Party Sites

The Coinbook Platform may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party.

We do not control third-party websites, mobile applications, or online services and are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.

Data Security

The security of your Personal Data is important to us. We employ a number of administrative, technical, and physical safeguards designed to protect the Personal Data we collect.

However, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to the Coinbook Platform. Any transmission of Personal Data is at your own risk.

Blockchain Transactions

Your use of digital assets may be recorded on a public blockchain, in particular the settlement of your trades in digital assets.

Public blockchains are distributed ledgers intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to re-identification of transacting individuals and the revelation of personal data, especially when blockchain data is combined with other data.

As blockchains are decentralized networks not controlled by us, we cannot erase, modify, or alter personal data on blockchain networks.

Overseas Disclosure and Your Privacy Rights

For purposes of relevant data protection legislation, Coinbook is the Personal Data controller.

Coinbook is a company with operations throughout the world. As a result, Personal Data may be transferred outside the country in which you reside for the purposes identified. Any such transfer will take place under applicable law and protected through international data transfer agreements where necessary.

Residents of the EEA and UK have certain rights over their Personal Data, including:

• Right to obtain confirmation of the Personal Data we process
• Right to rectify inaccuracies
• Right to request erasure
• Right to restrict processing
• Right to object to processing
• Right to receive Personal Data in a machine-readable format
• Right to withdraw consent

You can access your Personal Data or request to exercise your rights by contacting Support.

Complaints can be directed to us or to your local data protection authority.

General

If you would like to exercise any rights listed above, or if you have questions about your Personal Data, please contact Support with:

• Enough information to identify you
• A description of the information to which your request relates

Any Personal Data we collect from you to verify your identity will be used solely for the purposes of verification.