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.

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 Ponzi 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 Ponzi Platform, among other identifiers;
• Other personal data or commercial and/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 Ponzi Platform or when you use the Ponzi 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 Ponzi Platform. In cases where the Ponzi 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 Ponzi Platform. Users who are uncertain about which Personal Data is mandatory may contact us for clarification.

When you visit the Ponzi 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.

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 Ponzi 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 authorization 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.

How to Control and Delete Cookies

Cookies can be controlled, blocked or restricted through your web browser settings. Information on how to do this can be found within the Help section of your browser. All Cookies are browser specific. Therefore, if you use multiple browsers or devices to access websites, you will need to manage your Cookie preferences across these environments.

If you are using a mobile device to access the Site, you will need to refer to your instruction manual or other help/settings resource to find out how you can control Cookies on your device. For more information about cookies, and how to disable cookies, visit https://www.allaboutcookies.org.

Please note that if you restrict, disable or block any or all Cookies from your web browser or mobile or other device, the Site may not operate properly, and you may not have access to our services available through the Site. We are not be responsible for your inability to use our Site or any degraded function you may experience that may be caused by your settings and choices regarding Cookies.

Google Analytics

We may use Google Analytics to help analyze how you use our Site. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated is used to create reports about the use of our Site. Google will store this information.

If you do not want your Site visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit the Google Analytics opt-out page.

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 Ponzi 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.

Data we collect about you is collected to:

• Provide the Site and Ponzi Platform and customer support you request;
• Process transactions and send notices about your transactions on the Ponzi Platform;
• Detect any malicious or fraudulent activity;
• Enable us to monitor and analyze your behaviour ("Analytics");
• Beta test certain features or the Ponzi Platform;
• Contact you;
• Display content from external platforms;
• Handle productivity related activities;
• Provide social features;
• Optimize traffic and performance of the Ponzi Platform;
• Allow us to register you as a user of the Ponzi Platform and authenticate your credentials;
• Comply with legal obligations and respond to enforcement requests;
• Protect the rights and interests of Ponzi and Ponzi 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 Ponzi Platform);
• Engage in traffic optimization and distribution.

We may share your Personal Data with our service providers and vendors to assist us in providing you with the Ponzi 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.

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 an unauthorized user, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and 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 be allowed to retain Personal Data for a longer period whenever you have given consent to such processing, as long as such consent is not withdrawn. Furthermore, we may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

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.

Links to Third-Party Sites

The Ponzi 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. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your Personal Data. 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. The safety and security of your information also depends on you. We ask you not to share any of your personal security information.

Unfortunately, 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 Ponzi 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 or third-party networks which are not controlled or operated by us, we are not able to erase, modify, or alter personal data on such networks.

Overseas Disclosure and Your Privacy Rights

For purposes of relevant data protection legislation, Ponzi is the Personal Data controller. Ponzi 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 of Personal Data shall take place under applicable law and will be protected through international data transfer agreements where necessary that have been recognized by relevant data protection authorities as providing an adequate level of protection to the Personal Data we process. By using the Ponzi Platform you understand that your Personal Data may be processed in the United States and outside of the EEA.

Residents of the EEA and the UK are granted certain rights over their Personal Data, which include:

• The right to obtain confirmation of the Personal Data we process.
• The right to rectify inaccurate Personal Data that we process.
• The right to request erasure of your Personal Data, subject to exceptions provided under the law.
• The right to restrict certain processing of your Personal Data, so long as the processing is not necessary for the performance of or in relation to a contract or service to which you are a party.
• The right to receive your Personal Data in a structured, commonly used and machine readable format
• The right to object to the processing of your Personal Data, including the right to object to automated decision-making and profiling.
• The right to withdraw your consent where you have previously given it for the processing of your Personal Data

You are generally entitled to access Personal Data that we hold about you. If you request access to your Personal Data, in ordinary circumstances we will give you full access to your Personal Data. Depending on the nature of the request, we may charge for providing access to this information, however such charge will not be excessive. However, there may be some legal or administrative reasons to deny access. If we refuse your request to access your Personal Data, we will provide you with reasons for the refusal where we are required by law to give those reasons.

Complaints: If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this Privacy Notice, please contact Support and advise us as soon as possible. We will investigate your queries and privacy complaints within a reasonable period of time depending on the complexity of the complaint. We will notify you of the outcome of our investigation.