1.Introduction

This document (hereinafter –PP) constitutes Cryptology Key LabsLTD (hereinafter – KL, or us)policy in regard to gathering, storing, processing and transferring of yourpersonal data for the purposes of proper and full provision of our marketmaking services to you via appropriate legal instrument.

It is an integral part of the Termsand conditions of KL (hereinafter – T&C).

We really appreciate yourprivacy, and, with implementation of this policy, we are addressing the following:

·      we do understand, and we have addressed, all the processes related to the personaldata we ask you to provide explicitly, and those that we collect about youthrough the operation of our services;

·      we store personal data only for the limited amount of time, in no case longerthan we need to keep it, or up to the moment when cease of storage is requiredby law;

·      we ensure that you control what information on this website is sharedpublicly, or kept private, indexed by search engines, and permanently deleted;

·      we construct our activities in a such manner, which ensures fulltransparency of all of our processes related to your personal data.

We have a person who is incharge of the privacy matters – data privacy officer (DPO), whom you can reachin order to ask any question in regard to your personal data, or other relatedmatters via this email [support@keylabs.trade]].

2. Ourrole and activities related to the personal data

We, KL, are the datacontroller in relation to your personal data for the purposes of this PP.

This PP applies to the datawhich we collect from you when you are using either (a) our Website, (b) our Service,available on or through our Website.

We deem personal data as aninformation which can directly, or indirectly via publicly availableopen-source intelligence instruments, refer to you as a natural person, and weshall protect such according to the standards envisaged by the applicable law.

This PP shall, to the extentpossible with such written instrument, explain to you all of our processesrelated to your personal data (collection, use, storage, share/transfer) withthe choices that you have with respect to such information.

We, of course, understand thatyou can have additional question in regard to the aforementioned, and weencourage you to contact us in case of need.

We can gather your personaldata directly from you, or our partners, through bargains (agreements), orother legal instruments which you have with us or our partners on behalf of us,in order to fulfill the obligations provisioned by such instruments.

Your permission and consentcan be collected by us directly, or we may receive your personal data fromthird parties to whom you have given explicit consent to pass this informationto us.

3. Data we collect about you

If you visit our website, wemay automatically collect information about you, such as (a) technicalinformation, (b) IP addresses, (c) information about what type of device youused to connect to our website, or (d) how you interact with our website, butnot only (for more information refer to our CP).

Types of personal data wecollect from you are:

·      name and surname (to your discretion);

·      email.

Purposes of the collection are,but not limited to:

·      contact or communication with you;

·      conclusion of agreement with you;

·      provision of marketing and promotional materials;

·      billing/invoice issuance;

·      customer support.

4. Reasons to collect personal data

We collect information forsome or all of the following reasons:

·      to provide you the Service – after you have ordered and purchased it throughour Website;

·      to provide you information on our Service within the reasonable amount oftime after you concluded bargain with us;

·      to provide you additional information about the Service you have purchasedfrom us, or related products or services of our partners/affiliates;

·      to fulfill our obligations on provision of the Service to you in accordancewith our bargain;

·      for other legal reasons;

·      to provide information to you about our future, or other, Services – if youhave explicitly consented to receive it.

5. Legalgrounds of our activities in regard to your personal data

The legal grounds to collectpersonal data from you are as follows: (a) a legal reason to collect theinformation – envisaged by the applicable law or our bargain, (b) your explicitunambiguous consent to do so for a specific purpose (e.g. Service provision ornewsletters).

The legal grounds to process your personal data are as follows: (a) we have a duly concludedbargain with you (constructive or else), (b) you have explicitly given uspermission to do so, (c) we must provide services to you because you haveordered and purchased them, (d) you have explicitly asked us to do so, (e) tocomply with the applicable law.

6. Methods of provision of personal data to us

You may give us informationabout you with your consent by either (a) filling in a form or e-mailing us,(b) completing an order on our website, (c) posting reviews and feedbacks on ourwebsite (if applicable), (d) contacting us through the designatedmessengers (if such option is provided to you).

Such information may bepersonal, financial, educational, or related to your order.

You may give us informationfor legal reasons, such as to enter into a bargain with us – when you arebuying our Service.

7. Information we receive from other sources

We may receive informationabout you if you use any other website we operate, any other services weprovide, or from our business partners/affiliates, entitled to collectinformation on our behalf.

We also work with thirdparties (e.g., business partners, sub-contractors in technical, payment anddelivery services, advertising networks, analytics providers, searchinformation providers, credit reference agencies, background checking agencies)and may receive information about you from them as part of the service weprovide you, or for other legal reasons.

We may collect and store filesyou upload, download, or access with our Website (e.g., homework assignments).Please do not share with us the files you are not permitted to use. Please donot upload or share with us the files that contain your personal data, orpersonal data of third parties without respective permission – we may notguarantee that such personal information will be secured.

8. Share of personal data collected

We may share your personaldata with the third parties, either because you have consented to allow us todo so or for other legal reasons. For example, we may share your personal informationwith (a) our marketing people in order to provide you with promotionalmaterials after you have registered at our Website, (b) our group companies,which means our subsidiaries, or our ultimate holding company and itssubsidiaries, (c) subcontractors and third parties for the purpose of fulfilmentof our respective agreements, which we hold with them or that we hold with you,(d) with third parties because you have given consent.

Thereare other reasons for share of your personal data with the third parties,namely:

·     ifall of our substantial assets will be sold to the third party (statutorymerger), where personal data held by us about the customers is one of thetransferred assets;

·     if weare required to comply with our legal obligations (in certain situations, wemay be required to disclose personal data in response to lawful requests bypublic authorities, including to meet national security or law enforcementrequirements);

·     if itis requested by a governing body in scope of its authority on legally sounduncontested basis

·     toenforce or apply our T&C, or other legally binding bargains;

·     toprotect our rights, property, or safety of our customers or other persons;

·     ifpurpose of sharing is prevention of fraud or reduction of our credit risk.

9. Aggregated data

We may, from time to time,provide third parties with the data aggregated.

This means that your personaldata, which may identify you a certain natural person, has been removed fromthe aggregated one.

Data provided to third partiesin such case does not constitute personal data, but a statistic only, orsimilar.

But, nevertheless, you havethe right to object in regard to such transfer.

10. Territory of storage and processing of personal data

We primarily store andprocess your personal data in the EU/European Economic Area (EEA).

If you are from the EU(meaning, resident), by accepting this PP, you give us the right to store yourpersonal data in the EEA. We assure you that all your data is encrypted in asecure way and no unauthorized persons may access them.

For the EU Citizens, pleasenote, that there are reasons due to which your data may be processed outsidethe EEA, such as (but not limited) to (a) order fulfillment, (b) paymentprocessing, (c) technical support services, (d) client care management.

Ifyour personal data cannot be processed within the territory EEA, we shall (a) complywith all data protection principles, (b) where possible, choose a country thatis on the list of the EU Commissions’ countries that provide adequateprotection for the rights and freedoms of data subjects, and (c) make sure wehave assessed the adequacy of protections in all other cases.

11. Access to personal data

Where we have provided you (orwhere you have chosen) a password that grants you access to certain parts ofour website, namely your account – you are responsible for keeping thispassword confidential. We ask you not to share a password with anyone.

12. Transmission and storage of your personal data

Considering that transmissionof information via the internet is not completely secure, we cannot guaranteethe security of your data as it is transmitted and stored.

We shall use best practice toensure your data is encrypted to the standard required in the GDPR to protectyour personal data.

13. Timeframe of personal data storage

We will not store yourPersonal Data for longer than (a) required by the applicable law, (b) a validreason for kipping it exhausts, or (c) until you request us to stop using anddelete it.

We may keep just enough ofyour Personal Data to ensure that we comply with your requests not to use yourpersonal information or comply with your right to erasure (meaning, that wemust keep your request to be erased even if it includes your personal datauntil such time as you are no longer our customer, or for tax purposes, etc.).

14. Refusal to provide personal data

Incase if you choose not to provide your personal data to us, we shall refuse toprovide our Services to you because lack of your personal data will constituteinability to enter into legally binding bargain with you under the applicablelaw.

15. Your rights in regard to personal data

Due to the provisions of theapplicable law and the nature of the privacy rights you possess in regard toyour personal data, you have certain rights in regard to such subject matter,and our efforts to uphold them, as follows:

·      the right to be informed – we are publishing this PP to keep you informedas to what we do with your personal information, and our DPO is opened to yourquestions in regard to the handling of your personal data;

·      the right to access personal data – you have the right to access yourinformation via contacting our DPO on such;

·      the right to rectification of the personal data – if the information wehold about you is inaccurate or incomplete, you have the right to ask us torectify it via contacting our DPO;

·      the right to erasure of the personal data – this is sometimes called ‘theright to be forgotten’, meaning that if you want us to erase all your personaldata and we do not have any legal reason to continue to process and hold it,you can do that via contacting our DPO on such;

·      the right to restrict processing of the personal data – you have the rightto ask us to restrict how we process your data, meaning that we are permittedto store the data but not further process it, you can do that via contactingour DPO on such;

·      the right to object – you have the right to object to us processing yourdata even if it is based on our legitimate interests, such as the exercise ofofficial authority, direct marketing (including data aggregation), andprocessing for purposeless statistics, and you can do that via contacting ourDPO on such;

·      the right to withdraw consent – if you have given us your consent toprocess your data but have changed your mind later, you have the right towithdraw your consent at any time, you can do that via contacting our DPO onsuch;

·      the right to complain to the governing body in sphere of privacy – you havethe right to complain to the relevant governing body in sphere of DP in yourrespective country if you feel that we have not responded to your requests tosolve a problem.

16. Links to the third-party websites

From time to time, our websitemay contain links to and from websites of our partner networks, advertisers andaffiliates. If you follow a link to any of these websites, please note thatthese websites may have their own rules/policies in regard to handling thematters of personal data, and that we do not accept any responsibility/liabilityfor any such.

Please, make sure to get familiarwith such rules/policies, where available, before you submit any personal datato these websites.

17. Age limitations

To the extent prohibited byapplicable law, we do not allow the use of our Services and Websites by anyoneyounger than 18 years old, however, other may be provided by the applicable lawof sovereign country of your citizenship/residency. If you learn that anyoneyounger than 18 has unlawfully provided us with personal data, please contactus and we will take steps to delete such information.

18. Changes to this PP

We may change this PP fromtime to time due to the necessity to keep up with the updates in applicable lawand industry standards, or due to the changes to our business.

We will post the changes tothis page and encourage you to review them to stay informed. If we make changesthat materially alter your privacy rights, we will provide additional notice,such as via email or through the Website. If you disagree with the changes tothis PP, you should cease usage of our website, delete your account, or takeany other step necessary to alienate yourself to us.

19. Applicable law

The laws that govern personaldata in EU is REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THECOUNCIL of 27 April 2016 on the protection of natural persons with regard tothe processing of personal data and on the free movement of such data andrepealing General Data Protection Regulation (“GDPR”).

In other countries – therelevant data protection laws are applied. Also, where applicable, theinternational treaties on protection and transfer of personal data areapplicable (e.g., Trans-Atlantic Data Privacy Framework when entered intoforce).

20. Our contact details

Sendus an email to the following address [support@keylabs.trade]with the subject matter ofyour concern (any of the aforementioned or else), and we shall answer you atour first convenience.

Cryptology Key Labs LTD

Registrycode: 15893692

Address:128, City Road, London,

EC1V2NX, England, United Kingdom

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