END USER LICENSE AGREEMENT FOR COINPLUG MOBILE APPLICATION

Last modified 01.17.2020

This End User License Agreement for Coinplug Mobile Application (this "Agreement") is a legal agreement between you ("You" or the "User") and Coinplug, Inc. ("Coinplug", and together with User, the "Parties", and each, a "Party") related to your use of the Coinplug mobile application associated with this Agreement (the "Application").

BY CLICKING "ACCEPT" OR DOWNLOADING, ACCESSING AND/OR USING THE APPLICATION, YOU AGREE TO BE BOUND BY THIS AGREEMENT. IF YOU DO NOT AGREE TO BE BOUND BY THIS AGREEMENT, DO NOT DOWNLOAD, ACCESS AND/OR USE THE APPLICATION. IF THE PERSON ACCEPTING THIS AGREEMENT IS DOING SO ON BEHALF OF A USER WHICH IS A CORPORATION OR OTHER FORM OF BUSINESS ENTITY, THE PERSON ACCEPTING THIS AGREEMENT CONFIRMS THAT THEY ARE AUTHORIZED TO ENTER INTO THIS AGREEMENT ON THE USER'S BEHALF AND TO BIND THE USER TO THE TERMS AND CONDITIONS OF THIS AGREEMENT. COINPLUG RESERVES THE RIGHT, AT ITS SOLE DISCRETION, TO MODIFY OR REPLACE THIS AGREEMENT AT ANY TIME. YOU SHALL BE RESPONSIBLE FOR REVIEWING ANY SUCH MODIFICATIONS TO THE AGREEMENT. USE OF THE APPLICATION BY YOU AFTER ANY MODIFICATION OR REPLACEMENT OF THIS AGREEMENT CONSTITUTES YOUR ACCEPTANCE OF SUCH MODIFICATIONS OR REPLACEMENT.

1. LICENSE AND USE RESTRICTIONS; USER REQUIREMENTS

Subject to the terms and conditions of this Agreement and the payment by User of any applicable fees, Coinplug hereby grants to the User a limited, nonexclusive, nontransferable, non-assignable, non-sublicensable, revocable, royalty free license (the "License") to use the Application for personal, non-commercial purposes on any User mobile phone and/or other IT hardware device ("Device") that User owns or controls. Coinplug shall be solely responsible for the Application. For clarity, the License does not include any right to: make and/or distribute copies of the Application; use the Application for the benefit of any third party; or monetize the use of, or otherwise commercially exploit, the Application. Without limiting the generality of the foregoing, any and all access to the Application by automated inquiry devices, robots or repetitive data gathering and extraction tools, routines, scripts or other mechanisms with similar functionality is expressly prohibited.
User agrees that User will not use the Application to: (i) violate any law or regulation; (ii) associate, input or upload to or through any Application any virus, Trojan horse, worm, time bomb or other computer programming routine that may damage, interfere with, intercept or expropriate the Application and/or any other Coinplug software, system, technology or other intellectual property; and/or (iii) infringe any intellectual property right or any other right of any third party. User represents and warrants that: (i) User is not located in a country that is subject to a South Korea Government embargo, or that that has been designated by the South Korea Government as a "terrorist supporting" country; and (ii) User is not listed on any South Korea Government list of prohibited or restricted parties. User agrees that User's use of the Application is subject to the then-current versions of the Coinplug Terms of Use and the Coinplug Privacy Policy.

Sophistication and Risk of Cryptographic Systems
By utilizing the Application, User represents and warrants that User understands the inherent risks associated with cryptographic systems and that User has an understanding of the usage and intricacies of key cryptography, native cryptographic tokens, and blockchain-based software systems. Risk of Weaknesses or Exploits in the Field of Cryptography

USER ACKNOWLEDGES AND AGREES THAT CRYPTOGRAPHY IS A PROGRESSING FIELD. ADVANCES IN CODE CRACKING OR TECHNICAL ADVANCES SUCH AS THE DEVELOPMENT OF QUANTUM COMPUTERS MAY PRESENT RISKS TO CRYPTOGRAPHIC SYSTEMS AND THE APPLICATION, WHICH COULD RESULT IN THE THEFT OR LOSS OF YOUR CRYPTOGRAPHIC TOKENS OR PROPERTY. TO THE EXTENT POSSIBLE, COINPLUG INTENDS TO UPDATE THE APPLICATION TO ACCOUNT FOR ANY ADVANCES IN CRYPTOGRAPHY AND TO INCORPORATE ADDITIONAL SECURITY MEASURES BUT DOES NOT GUARANTEE OR OTHERWISE REPRESENT AND/OR WARRANT SECURITY OF THE APPLICATION. BY USING THE APPLICATION, USER ACKNOWLEDGES THESE INHERENT RISKS
USER ACKNOWLEDGES AND AGREES THAT DATA THAT MAY BE INVOLVED IN CONNECTION WITH ANY SERVICE ACCESSIBLE THROUGH USE OF THE APPLICATION IS STORED ON USER'S DEVICE. USER FURTHER ACKNOWLEDGES AND AGREES THAT USER IS SOLELY RESPONSIBLE FOR SECURELY MAINTAINING:
USER'S TOKENS (INCLUDING CRYPTOGRAPHIC TOKENS);
USERNAME, PASSWORD AND OTHER IDENTITY-RELATED CREDENTIALS;
THE SECURITY OF USER'S DEVICE;
AND SEPARATE BACKUP COPIES OF ANY DATA STORED ON ITS DEVICE INCLUDING WITHOUT LIMITATION ENCRYPTED DATA THAT MAY BE INVOLVED IN CONNECTION WITH ANY SERVICE ACCESSIBLE THROUGH USE OF THE APPLICATION.

2. TERM AND TERMINATION

This Agreement shall be effective upon User's acceptance hereof by downloading, accessing, using and/or clicking "Accept" and shall remain in full force and effect thereafter until terminated as provided herein (the "Term"). User may terminate this Agreement for convenience at any time by deleting the Application from all Devices that User owns or controls. Coinplug may terminate this Agreement for convenience at any time with or without notice to User. Notwithstanding the foregoing, with respect to any User, this Agreement shall terminate without any further action needing to be taken by Coinplug upon a material breach by such User of this Agreement. Upon the termination of this Agreement for any reason whatsoever all licenses granted hereunder shall immediately terminate and the affected User shall immediately cease and desist from all access to and use of the Application and shall immediately purge from such User's mobile devices all copies of the Application. The terms set forth in the following paragraphs of this Agreement shall survive the termination of this Agreement for any reason: "INTELLECTUAL PROPERTY"; "DISCLAIMER OF WARRANTIES"; "LIMITATION OF LIABILITY"; "CHOICE OF LAW; VENUE"; "NO CLASS ACTIONS; JURY TRIAL WAIVER", "INDEMNITY AND RELEASE"; and "GENERAL."

3. SUSPENSION AND TERMINATION OF RIGHTS

Coinplug may in Coinplug's sole discretion suspend or terminate User's rights in and to the Application accessible through the Application including, without limitation, if a newer version of the Application is available; to improve the Application or any functionality therein; to add or remove access to any service accessible through the Application; to improve ease of use for the User or Coinplug; to correct an error or bug; to prevent or discontinue harmful, improper or unauthorized access to the Application or a service therein; to comply with any governmental request; and/or to comply with a law, regulation, statute and/or judicial order.

4. INTELLECTUAL PROPERTY

A. User acknowledges and agrees that the Application contains proprietary and confidential information that is protected by applicable copyright, trademark, trade secret and other intellectual property laws including without limitation the software and other code contained in the Application. The trademarks, service marks and logos used and displayed on this Application are registered and unregistered trademarks of Coinplug and others. Nothing in this Application should be construed as granting, by implication, estoppel or otherwise, any license or right to use any trademark displayed in the Application without the written permission of the trademark owner. Coinplug and its licensors reserve the right to enforce its and their intellectual property rights to the fullest extent of the law. All images on the Application are legally protected and are not to be used, reproduced, modified or distributed without written consent of Coinplug or its licensors.
B. User and Coinplug acknowledge that, in the event of any third-party claim that User's possession and use of the Application infringes that third party's intellectual property rights, Coinplug will be solely responsible for the investigation, defense, settlement and discharge of any such intellectual property infringement claim.
C. The Application and all improvements, additions, derivatives and other modifications thereto and any information pertaining to the foregoing are and shall remain the exclusive property of Coinplug and/or its licensors and shall be considered and treated by Licensee as the proprietary information of Coinplug (the "Coinplug Proprietary Information"). User acknowledges and agrees that Coinplug is the owner of the Coinplug Proprietary Information and User agrees that User has no right, title or interest in any of the Coinplug Proprietary Information except the right to use the Application in accordance with and subject to this Agreement. User agrees not to, directly or indirectly, disclose, sell or otherwise transfer or exploit the Coinplug Proprietary Information, or any portion thereof, to any other person or entity or allow any other person or entity to use the Coinplug Proprietary Information, or any portion thereof, without the prior written consent of Coinplug, which may be withheld in Coinplug's sole discretion. User further agrees not to challenge or assist with or participate in any challenge, directly or indirectly, of Coinplug's ownership of the Coinplug Proprietary Information or any right, title or interest therein or any portion thereof.
D. User acknowledges and agrees that Coinplug is the owner of or has rights to the trade names, trademarks and service marks "Coinplug", "connect.me" and such other names, marks, and logos and other intellectual property Coinplug used, uses or may in the future use in or related to its business, products or services, including, without limitation, all improvements, additions, derivatives and other modifications thereof (the "Coinplug Marks"). User agrees that User has no right, title or interest in any of the Coinplug Marks. User further agrees not to challenge or assist with or participate in any challenge, directly or indirectly, of Coinplug's ownership of or right to the Coinplug Marks and the Proprietary Information or any right, title or interest therein or any portion thereof.
E. User agrees to not remove, obscure or alter any copyright, trademark or other proprietary rights notice affixed to, contained within or accessed in conjunction with or through the Application. The User further agrees not to modify, adapt, translate, prepare derivative works from, transmit, decompile, reverse engineer, disassemble or otherwise attempt to derive source code from any portion of the Application.
F. User agrees that Coinplug and/or its Representatives may (a) collect and use technical data and related information including, without limitation, technical information about your Device (including, without limitation, system and application software, and peripherals) that is gathered periodically to facilitate the provision of software updates, product support and other services to you (if any) related to the Application and (b) use this information, as long as it is in a form that does not personally identify you, to evaluate or improve the Application, its products and/or to provide services or technologies.

5. SUPPORT AND MAINTENANCE

Coinplug is not obligated to provide any support or maintenance services to User related to the Application. Any complaints related to the Application can be addressed to our Customer Service Department per the contact information provided below.

6. EXPORT CONTROL LAWS

User agrees to comply with all South Korea and all other applicable laws, rules, and regulations relating to the export, re-export, or transshipment of the Application.

7. DISCLAIMER OF WARRANTIES

THE USER HEREBY ACKNOWLEDGES AND AGREES THAT THE USE OF THE APPLICATION IS ENTIRELY AT THE USER'S OWN RISK. THE APPLICATION IS PROVIDED FREE OF CHARGE ON AN "AS IS" BASIS WITHOUT ANY WARRANTIES OF ANY KIND. ALL EXPRESS, IMPLIED AND STATUTORY WARRANTIES, INCLUDING, WITHOUT LIMITATION, THE WARRANTIES OF MERCHANTABILITY, SATISFACTORY QUALITY, FITNESS FOR A PARTICULAR PURPOSE, ACCURACY, RELIABILITY, ACCESSIBILITY AND NON-INFRINGEMENT OF INTELLECTUAL PROPERTY RIGHTS OR OTHER PROPRIETARY RIGHTS ("ALL WARRANTIES"), ARE EXPRESSLY DISCLAIMED BY COINPLUG TO THE FULLEST EXTENT PERMITTED BY LAW. COINPLUG MAKES NO WARRANTY WITH RESPECT TO THE SECURITY, TIMELINESS, CONTENT OR PERFORMANCE OF THE APPLICATION. COINPLUG FURTHER DISCLAIMS ALL WARRANTIES AND ANY RESPONSIBILITY AND/OR OTHER OBLIGATION FOR STORING, MAINTAINING AND/OR OTHERWISE MANAGING ANY USER TOKENS, USERNAME AND/OR PASSWORD CREDENTIALS; THE SECURITY OF USER'S DEVICE; AND ANY DATA STORED ON USER'S DEVICE INCLUDING WITHOUT LIMITATION ENCRYPTED DATA THAT MAY BE INVOLVED IN CONNECTION WITH ANY SERVICE ACCESSIBLE THROUGH USE OF THE APPLICATION. SOME JURISDICTIONS DO NOT ALLOW LIMITATIONS ON IMPLIED WARRANTY, SO THE LIMITATIONS AND EXCLUSIONS IN THIS SECTION MAY NOT APPLY TO EVERY USER. THIS AGREEMENT GIVES USER SPECIFIC LEGAL RIGHTS. USER MAY ALSO HAVE OTHER RIGHTS WHICH VARY FROM JURISDICTION TO JURISDICTION. USER AGREES AND ACKNOWLEDGES THAT THE LIMITATIONS AND EXCLUSIONS OF LIABILITY AND WARRANTY PROVIDED IN THIS AGREEMENT ARE FAIR AND REASONABLE. IF USER IS AN INDIVIDUAL ACTING AS A CONSUMER, USER MAY HAVE CERTAIN STATUTORY RIGHTS WHICH MAY NOT BE WAIVED, AND SUCH STATUTORY RIGHTS ARE NOT AFFECTED BY THE FOREGOING.

8. LIMITATION OF LIABILITY

NEITHER COINPLUG NOR ANY OF ITS REPRESENTATIVES SHALL BE LIABLE TO USER AND/OR ANY THIRD PARTY, TO THE EXTENT PERMITTED UNDER APPLICABLE LAW, FOR ANY DIRECT, INDIRECT, CONSEQUENTIAL, EXEMPLARY, PUNITIVE, MULTIPLE, INCIDENTAL, AND/OR SPECIAL DAMAGES, LOST PROFITS, LOSS OF DATA OR DATA USE, LOST SAVINGS, OR COSTS OF PROCURING SUBSTITUTE GOODS ARISING OUT OF THIS AGREEMENT, DUE TO BREACH OF CONTRACT, TORT (INCLUDING, WITHOUT LIMITATION, NEGLIGENCE), USE OF THE APPLICATION OR OTHERWISE, EVEN IF COINPLUG OR ANY OF ITS REPRESENTATIVES HAVE BEEN ADVISED OF THE LIKELIHOOD OF SUCH DAMAGES OCCURRING. THE ABOVE LIMITATIONS AND EXCLUSIONS OF LIABILITY SHALL BE APPLICABLE ONLY TO THE EXTENT PERMITTED BY LAW IN THE EVENT OF THE GROSS NEGLIGENCE OR WILLFUL MISCONDUCT OF COINPLUG OR IN THE EVENT OF PERSONAL INJURY OR DEATH OR IN RESPECT OF ANY OTHER LIABILITY THAT MAY NOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW. IF USER IS AN INDIVIDUAL ACTING AS A CONSUMER, USER MAY HAVE CERTAIN STATUTORY RIGHTS WHICH MAY NOT BE WAIVED, AND SUCH STATUTORY RIGHTS ARE NOT AFFECTED BY THE FOREGOING. IN NO EVENT SHALL COINPLUG AND/OR ANY OF ITS REPRESENTATIVES' TOTAL CUMULATIVE LIABILITY TO USER FOR ANY AND ALL DAMAGES EXCEED THE AMOUNT OF US$50.00 (OR ITS EQUIVALENT).

9. CHOICE OF LAW; VENUE

This Agreement and the relationship between User and Coinplug will be governed by the laws of South Korea, excluding its conflicts of law provisions. User irrevocably agrees to submit to the personal and exclusive jurisdiction of the courts located in South Korea to resolve any dispute or claim arising from this Agreement. As to intellectual property rights, User specifically agrees that Coinplug may file an action in any jurisdiction to protect or enforce its rights. The United Nations Convention on Contracts for the International Sale of Goods will not apply to this Agreement.

10. NO CLASS ACTIONS; JURY TRIAL WAIVER

USER AND COINPLUG AGREE THAT ALL CLAIMS BETWEEN US WILL BE RESOLVED IN AN INDIVIDUAL ARBITRATION. WE BOTH AGREE THAT THERE WILL BE NO CLASS, REPRESENTATIVE OR CONSOLIDATED ACTIONS IN ARBITRATION. In addition, neither User, nor Coinplug may participate in a class or representative action in court as a class member if the claims asserted in the arbitration would fall within the scope of this Agreement or the arbitration agreement paragraph if asserted directly by you or Coinplug. To be clear, the User and Coinplug both waive any right to participate in any class action involving disputes between us.
You and Coinplug expressly and knowingly WAIVE THE RIGHT TO TRIAL BY JURY.
User agrees that any claim and/or cause of action related to this Agreement or the use of the Software must be filed within one (1) year after the cause of action arose or be forever barred.

11. INDEMNITY AND RELEASE

When the User downloads, accesses, and/or uses the Application, the User shall indemnify, defend and hold harmless Coinplug and its owners, shareholders, subsidiaries, affiliates, officers, employees, partners, successors, assigns, licensors, advisors, contractors and other representatives ("Representatives") from any and all claims and expenses including, without limitation, attorney's fees arising from the use of the Application. By using the Application, the User is agreeing to release Coinplug and its Representatives from any and all claims, fees, costs, damages and obligations of any kind whatsoever that the User may have against any of them directly or indirectly arising out of or in any way related to such claims and/or obligations and/or to any disputes regarding the Application. YOU HEREBY AGREE TO WAIVE ALL LAWS THAT MAY LIMIT SUCH RELEASES. FOR EXAMPLE, YOU SPECIFICALLY AGREE TO WAIVE THE PROVISIONS OF CALIFORNIA CIVIL CODE SECTION 1542, WHICH PROVIDES:
"A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE CREDITOR DOES NOT KNOW OR SUSPECT TO EXIST IN HIS FAVOR AT THE TIME OF EXECUTING THE RELEASE, WHICH IS KNOWN BY HIM MUST HAVE MATERIALLY AFFECTED HIS SETTLEMENT WITH THE DEBTOR."

12. GENERAL

User may not assign or transfer any of your rights or obligations under this Agreement to a third party without the prior written consent of Coinplug. Coinplug may freely assign this Agreement. Any waiver of any provision of this Agreement will be effective only if in writing and signed by or on behalf of Coinplug. This Agreement constitutes the entire and only agreement between the Parties in relation to its subject matter and replaces and supersedes all prior or simultaneous agreements, undertakings, arrangements, understandings and/or statements of any nature made by the Parties or any of them, whether oral or written (and, if written, whether or not in draft form) with respect to such subject matter. Each of the Parties acknowledge that they are not relying on any representations, warranties and/or any other statements given or made by any of them in relation to the subject matter of this Agreement and that neither Party nor any of their Representatives shall have any right or remedy with respect to any such subject matter otherwise than under this Agreement. No modification or amendment of this Agreement shall be effective unless it is in writing and signed by a duly authorized representative of Coinplug. If a court of competent jurisdiction finds any provision or portion of this Agreement to be unenforceable, the remainder of this Agreement will continue in full force and effect.

13. CONTACTING COINPLUG

If User has any questions, complaints and/or claims with respect to the Application, please contact Coinplug via email at [email protected].

Coinplug, Inc. PRIVACY POLICY

Last modified 01.17.2020

ATTENTION

PLEASE READ THIS COINPLUG, INC. ("COINPLUG", "COMPANY", "WE", OR "US") PRIVACY POLICY ("PRIVACY POLICY") CAREFULLY, WHICH IS PART OF THE COINPLUG TERMS OF USE AT WWW.COINPLUG.COM/TERMS-OF-USE/ (COLLECTIVELY "TERMS OF USE"), BEFORE YOU ("YOU") ACCESS, DOWNLOAD OR OTHERWISE USE THE http://coinplug.com/en/mykeepin/terms-and-policy WEBSITE; MOBILE APPLICATIONS; OTHER ONLINE SERVICES; OUR PRODUCTS AND SERVICES INCLUDING OUR IDENTITY OWNER AND DIGITAL CREDENTIAL-RELATED TECHNOLOGY AND ASSOCIATED SERVICES SUCH AS DATA HOSTING SERVICES (THE "IDENTITY-RELATED SERVICES"); OTHER INTERACTIONS (INCLUDING EMAIL, ONLINE, OFFLINE AND BY PHONE OR MAIL) BETWEEN YOU AND US; AND/OR OUR SOCIAL MEDIA ACCOUNTS INCLUDING ALL CONTENT AVAILABLE THROUGH THESE PLATFORMS (COLLECTIVELY, THE "DIGITAL CHANNELS" AND, TOGETHER WITH OUR IDENTITY-RELATED SERVICES. THE "SERVICES").

INTRODUCTION

We respect your privacy. This Privacy Policy describes how we collect, use, and share your personal data in connection with the provision of our Services and when you use our Digital Channels.

The purpose of this Policy is to inform you about our privacy practices and to ensure that you understand the purposes for which We collect and process your personal data. The following is a brief summary of the manner and purposes for which We process your personal data.

ACCESSING, DOWNLOADING OR OTHERWISE USING OUR DIGITAL CHANNELS OR SERVICES INDICATES THAT YOU ACCEPT AND AGREE TO BE BOUND BY THIS PRIVACY POLICY IN FULL. IF YOU DO NOT ACCEPT THIS PRIVACY POLICY, DO NOT ACCESS, DOWNLOAD OR OTHERWISE USE THE SERVICES. YOU ACKNOWLEDGE (A) THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY; AND (B) THIS PRIVACY POLICY SHALL HAVE THE SAME FORCE AND EFFECT AS A SIGNED AGREEMENT.

APPLICATION

This Privacy Policy relates to your personal data (i.e., data about you, an individual, from which you can be identified). This Privacy Policy therefore does not apply to any data insofar as it is held, processed, disclosed or published in a form which cannot be linked to a living individual (such as anonymized data or aggregated data, which, in a given form, cannot directly or indirectly be used to identify you as an individual) ("Anonymized and Aggregated Data"). We reserve the right to generate Anonymized and Aggregated Data extracted out of any databases containing your personal data and to make use of any such Anonymized and Aggregated Data as we see fit (including publishing such data and sharing it with third parties).

CHANGES TO THIS PRIVACY POLICY

Please review this Privacy Policy each time You use the Services. We reserve the right to update or change our Privacy Policy at any time in our sole discretion, and the updated version of this Policy will be effective upon posting on the Digital Channels. Please check this page to review the most up-to-date version of this Policy. Your continued use of the Services after We post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

BY USING THE SERVICES, YOU AGREE TO BE BOUND BY THE MOST RECENT VERSION OF THIS PRIVACY POLICY.

RESPONSIBILITY FOR DATA PROCESSING

In the course of providing our technology services to our enterprise clients ("clients"), including data hosting, back-up and data processing services in connection with our digital wallets and identity verification technology, We process personal data records of individuals who are our clients' customers or otherwise associated with our clients. In those circumstances, We act as processors of data on behalf of our client and on our client's instructions and the client is ultimately responsible for the processing of your personal data. If you are a customer of one of our clients and believe that We process your data on behalf of one of our clients, please refer to the client's privacy policy for information regarding the processing of your data.

Coinplug collects and processes personal data on its own behalf where the data is collected in connection with the administration of Our business and the promotion and marketing of our technology services, including in the operation of our Digital Channels. We may also collect personal data from end-users of our technologies if We market and offer our technologies directly to end-users. In those circumstances, Coinplug is the entity which is responsible for the processing of personal data. If you have any questions or concerns about Coinplug's use of your personal data, please contact us at [email protected].

COUNTRIES OF PROCESSING

We operate data hosting services for our clients primarily from South Korea and our data collection and processing activities take place predominantly in the South Korea. However, We also operate data centers in other jurisdictions through local subsidiaries or affiliates including in the European Union. We store and otherwise process data (including personal data) through third-party cloud service providers and other IT service providers which may be located or operate in other countries, including countries which do not guarantee the same level of protection to privacy as South Korea.

When transferring personal data records from the EU to a country outside the EU which does not provide an adequate level of protection to privacy rights, we put in place appropriate safeguards including data transfer agreements on the terms approved by the EU Commission. Where appropriate, We may also rely on your consent for the transfer of your personal data for processing outside the EU.

HOW WE COLLECT AND USE YOUR PERSONAL DATA

Your digital credentials: Our digital identity technology and digital wallets are designed to provide a secure method for consumers to access and exchange identity-related information ("digital credentials") when dealing with various organisations including when they use financial and other services and when purchasing goods and services. These digital credentials are stored on the end-user's device. Where the end-user chooses to upload his or her data to the cloud (for example for back-up purposes), We may host the data on our servers or through third-party cloud service providers. We may also hold encryption keys relating to your encrypted data. Where We provide the data hosting service, users' data is held on our servers in an encrypted form that does not enable the identification of specific individuals, even by Coinplug itself.

Data that we receive from our client: When providing data hosting services for our clients, We receive encoded data from our clients relating to their customers. That data enables our clients to identify its customers when using our services.

Information That You Provide Directly or Authorize Someone Else to Give Us: We may ask you to provide certain information including, but not limited to your name, email address, and any other information You choose to provide to Us. For example, We may collect information from You when You register for and/or use our Digital Channels, contact or interact with Us, fill out a form, apply for employment, respond to a survey, and voluntarily provide Us with Your comments and/or questions and other content in connection with using our Digital Channels. When You submit a "Contact Coinplug" form, We may collect Your name, phone number, email address and any other information You choose to provide to Us.

Analytics information: We collect, measure and analyze traffic and usage trends in connection with our website and other Digital Channels, and We use third-party analytics tools to help us. We use Google Analytics to provide analytics services. This allows us to understand, among other things, who is using the Digital Channels, how they are using them, and ways to improve the Services. Such third-party analytics tools and services may use cookies and persistent device identifiers to collect and store information including, but not limited to time of visit, pages visited, time spent on each page, IP address, unique device ID, advertising tags and type of operating system used.

Cookies: When you use our Digital Channels, We sometimes send one or more cookies (small text files containing a string of alphanumeric characters) to your computer or mobile device that uniquely identify your browser and enhance your navigation on the Digital Channel. A cookie may also convey information to us about how you use the Digital Channels (e.g., the pages you view, the links you click and other actions you take) and allow us or our third-party analytics tools We use to track your usage of the Digital Channels. There are at least two different types of cookies: persistent and session cookies. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent use of the Digital Channels. Persistent cookies can be removed by following your Web browser's directions for removal of cookies. A session cookie is temporary and disappears after you close your browser. You can reset your Web browser to refuse all cookies or to notify you when a cookie is being sent. However, some features of the Digital Channels may not function properly if cookies are disabled.

Log File: Log file information is automatically reported by your browser each time you access a Web page. When you access or use the website, our servers may automatically record certain log file information, including but not limited to your Web request, Internet Protocol address, browser type, referring/exit pages and URLs, number of clicks and how you interact with links on the website, domain names, landing pages, and pages viewed.

Device Identifiers: When you access or use our Digital Channels using a mobile device, We may access, collect, monitor and/or remotely store one or more "device identifiers," such as a universally unique identifier. Device identifiers are small data files or similar data structures stored on or associated with your device that uniquely identify your device. A device identifier may consist of data stored in connection with the device hardware, operating system or other software, or data sent to the device by us. A device identifier may convey information to us about how you browse and use the Digital Channel. A device identifier may remain persistently on your device to enhance your navigation on the Digital Channel. Some features of our Digital Channels may not function properly if use or availability of device identifiers is impaired or disabled.

Commercial Communications: To the extent permitted under applicable law, We may use the information We collect or receive from you (specifically through the "connect.me" functionality) to communicate directly with you in relation to our services and technologies. Subject, where necessary, to obtaining your consent to receiving such communications, We may use the information to communicate with you in relation to other services that We and our affiliates offer. We may also use the information to send you service-related notices (e.g., account verification, technical and security notices).

Use of Certain Service-Type information: We may use information from cookies, log files, device identifiers, location data, clear GIFs and other tools to: (i) remember information so that you will not have to re-enter it during your visit or the next time you use the Services; (ii) provide custom, personalized content or information to you or others; (iii) monitor the use of our Digital Channels; (iv) monitor aggregate metrics, such as total number of visitors, traffic and demographic patterns; (v) diagnose or fix technology problems; (vi) provide advertising to your browser or device; and (vii) conduct research or surveys.

Use of information with Your Consent: We may use your personal data for any other purpose for which you specifically provide Us with your consent.

THE PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA

The purposes for which We collect and store your personal data are the following:
Personal data records that We receive in providing data hosting and back-up services are processed on behalf of our clients for the purpose of supporting the client in delivering identity credential-related services and digital wallet services that the client provides to you;
Personal data that We receive from you enables Us to deliver services that We offer to you (including use of our Digital Channels) and to enable you to use them efficiently; Insofar as permitted under applicable law, to communicate with you in relation to our services and technologies and other services that We or our affiliates offer;
To personalize, test, monitor, improve and upgrade our Digital Channels;
To meet our legal obligations and the regulatory requirements to which We may be subject, for loss prevention purposes and to protect and enforce our rights and meet our obligations to third parties;
And for our internal business purposes, such as compiling and analyzing usage information of our Digital Channels, for general operational, statistical and business purposes.

YOUR RESPONSIBILITIES

It is important that the personal data We hold about you is accurate and current. If you provided us with any details of personal data, please keep us informed if such details change.

LEGAL BASIS FOR PROCESSING YOUR DATA

Insofar as it concerns our operations in the European Union or services that We offer to individuals in the European Union, We rely on the following lawful bases for the processing of your personal data:

Our legitimate interests in (among other things) delivering our services (including our Digital Channels), conducting commercial research, improving and maintaining our Services, personalising and tailoring content made available to you through our Digital Channels, protecting the security or integrity of our databases, protecting our business or reputation, taking precautions against legal liability, dealing with our assets in the event of a business change (see further below), protecting and defending our legal rights or property, or for resolving disputes, investigating and attending to inquiries or complaints with respect to your use of our Services;
Where relevant, your express consent, for example, if you use Our services to send your digital credentials to a third- party);
Where relevant, the fulfilment of our contractual obligations to you under our terms and conditions of service; and Where relevant, for compliance with legal obligations to which we are subject.

HOW WE SHARE YOUR INFORMATION

Service Providers: We may share your personal data with third-party service providers that perform services on our behalf in connection with our Digital Channels or with our data hosting services, such as cloud service providers that we may use or third-party analytical service providers. Where your information is shared with such third parties, We ensure that the third-party service provider will deal with your information only on our behalf and on our written instructions and solely for Our benefit (and not for its own benefit).

Business Change: If We become involved in a merger, consolidation, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution or other transaction, or if the ownership of all or substantially all of our business otherwise changes, We may share or transfer databases containing personal data of users including your personal data to a successor party or parties in connection with such transaction or change in ownership or legal structure.

Necessary Disclosure: Regardless of the choices you make regarding your information and to the extent permitted or required by applicable law, We may disclose information about you to third parties to: (i) enforce or apply the terms and conditions of our Services; (ii) comply with laws, subpoenas, warrants, court orders, legal processes or requests of government or law enforcement officials; (iii) protect our rights, reputation, safety or property, or that of our users or others; (iv) protect against legal liability; (v) establish or exercise our rights to defend against legal claims; or (vi) investigate, prevent or take action regarding known or suspected illegal activities; fraud; our rights, reputation, safety or property, or those of our users or others; violation of the Terms of Use, our policies or agreements; or as otherwise required by law.

Sharing information: We may share certain service-type information, including information obtained through tools such as cookies, log files, device identifiers or location data (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with our third-party service providers who may use such information for the purposes described in the section titled "How We Collect and Use Your Information."

Aggregated data: As mentioned above, We may also aggregate or otherwise strip information of all personally identifying characteristics and may share that Anonymized and Aggregated Data with third parties or publish it. This Anonymized and Aggregated Data does not personally identify you and helps us to measure the success of the Services and its features and to improve your experience. We reserve the right to make use of any such Anonymized and Aggregated Data in our sole discretion.

HOW WE PROTECT YOUR INFORMATION

We take measures to protect personal data you provide through the Services against loss, theft, and unauthorized access, use, disclosure or modification. These include physical, technological and administrative measures. However, We cannot ensure or warrant the security of any information you transmit to us or guarantee that information on the Services may not be accessed, disclosed, altered or destroyed. Email sent to or from the Services may not be secure. You should use caution whenever submitting information online and take special care in deciding what information you send to us via email.

We cannot guarantee that transmissions of your personal data will be fully secure and that third parties will never be able to defeat our security measures or the security measures of our partners. WE ASSUME NO LIABILITY FOR DISCLOSURE OF YOUR INFORMATION DUE TO TRANSMISSION ERRORS, THIRD-PARTY ACCESS OR CAUSES BEYOND OUR CONTROL.

YOUR CHOICES ABOUT YOUR INFORMATION

Controlling Your Settings. You can limit your browser or mobile device from providing certain information by adjusting the settings in the browser, operating system or device. Please consult the documentation for the applicable browser, operating system or device for the controls available to you. You can also stop receiving promotional emails from us by following the unsubscribe instructions in those emails.

Changing Your Information. To change Your information, please contact Us at [email protected].

Email Communications. You can make changes regarding opting out of or otherwise receiving email communications from Us by contacting Us at [email protected].

Do Not Track. At this time, We do not recognize "do not track" signals sent from Web browsers. In some cases, your browser may offer a "Do Not Track" option, which allows you to signal to operators of Websites, mobile applications, and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and/or across different Websites and mobile applications and services. Disabling tracking mechanisms may disable certain features of the Services. To disable tracking, please consult the documentation for you browser, operating system or mobile device. For some devices, it may not be possible to disable tracking mechanisms. You may also disable tracking by certain third-party services by opting out:

HOW LONG WE KEEP YOUR INFORMATION

We will only retain your personal data 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.

To determine the appropriate retention period for personal data, We consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which We process your personal data and whether We can achieve those purposes through other means, and the applicable legal requirements.

EU PRIVACY RIGHTS

Users based in the European Union have the following legal rights in respect of their information:

(a) The right to require the data controller to confirm whether or not their information is being processed, the purpose of any such processing, the recipients of any information that has been disclosed, the period for which their information is to be stored and whether any automated decision-making processes are used in relation to their information;

(b) The right to require the data controller to rectify inaccurate information without undue delay;

(c) Where the data controller has relied on the 'consent' basis for processing that information (see paragraph 9(b) above), the right to withdraw their consent at any time. This right to withdraw consent does not affect the lawfulness of processing based on consent before its withdrawal;

(d) The right to request the erasure of their information in certain circumstances. You can make a request for erasure where:

(i) the information is no longer necessary in relation to the purpose for which it was collected;

(ii) where the processing of the information is based on the user's consent (and the other circumstances described in the 'Legal Basis for Processing Your information' and 'How We May Share Your information' sections above no longer apply), if the user withdraws his or her consent;

(iii) or where the personal data is processed by the data controller solely on the basis of our 'legitimate interest' referred to in paragraph 9(a) (and the other legal basis set out in paragraph do not apply), if the user objects to the processing of his or her personal data and there are no overriding legitimate grounds for the processing (such as, for example, where the processing of the data is required to meet statutory obligations or for the defence of legal claims).

Where the data controller has disclosed the information of a European Union user to a third-party and the user requests the erasure or rectification of the data, the data controller should take all reasonable steps to inform the third- party of such request;

(e) The right to require the data controller to restrict its processing of a user's personal data in certain circumstances, such as where the accuracy of that data is disputed or an objection has been raised. In such circumstances, the data controller should only process that information with the express consent of the user, or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest;

(f) Where data is processed based on user's consent or to fulfil a contractual obligation, the user has the right to receive his or her personal data from the data controller in a structured, commonly used and machine-readable format;

(g) The right to object to the processing of personal data where:

(i) the data controller relies solely on the 'legitimate interest' basis for processing that data, in which case we will be legally required to stop processing the user's information unless we have compelling legitimate grounds for the processing which override the user's privacy rights and interests;

(ii) or the information is used for direct marketing purposes, in which case we will immediately stop processing the user's information for such purposes;

(h) Users have the right to lodge a complaint with the data protection supervisory authority of the EU member state where the user resides.

The above legal rights are subject to various conditions and exceptions including where the data is used for statistical or scientific research purposes and the exercise of the right would prevent such purposes from being attained or would seriously impair their attainment.

THIRD-PARTY SITES AND SERVICES

Our Digital Channels may reference or provide links to other websites, applications, or resources. If you access any website, application, or resources provided by a third-party, our Privacy Policy will not apply. Your interactions with such websites, applications, and resources are subject to the privacy policies of the third parties that operate them. Please review those policies carefully to understand how those parties will treat your information.

QUESTIONS/CONTACTING US

If you have any questions regarding this Privacy Policy, you may email us at [email protected].