Privacy Policy

Welcome to the Privacy Policy (the "Policy").

The Website and Mobile Applications are owned by the company Neo Blockchain FIn Software TEC LLC, incorporated in Dubai, United Arab Emirates with a registered number 1446170 and registered office at Happiness Business Centre, Building Plot 128-246, Al Khabeesi-50819 ("Neo Blockchain Bank").

Vault Fintech Solutions s.r.o., a legal entity duly registered in Czech Republic with No. 216 27 002 with a registered office at Frydlantská 1312/19, Kobylisy, 182 00 Praha 8, Czech Republic. (the "Vault").

As a high-level summary, we are an evolving cryptocurrency-focused financial institution providing various cryptocurrency-related financial services (the "Services"). We provide all this employing the website http://www.neobcb.com/ (the "Website") and the related mobile application and crypto-platforms that we may operate from time to time (each of which, is a "Platform") and which may be accessible via the Website or otherwise.

Accordingly, the purpose of this Policy is to set out the basis on which we will process your data when you:

1. visit and use a Website and/or Platform, regardless of where you visit or use them from;
2. apply for and register a customer account with us (your "Account");
3. apply for, receive, pay, and/or use any of our Services.

This also includes any data that you may provide to us for our events, newsletters, and other marketing items.

This Policy informs you about the items of Personal data that we may collect about you and how we will handle it, and in turn, also tells you about (i) our obligations to process your data responsibly, (ii) your data protection rights as a data subject, and (iii) how the law protects you.

It should be read in conjunction with our Cookie Policy.

1. Important Information and Who We Are

General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR) regulations shall be implemented for EU users (the "Regulation" or the "GDPR").

This Policy aims to ensure that you are fully informed on how we will collect and process your Personal data in the circumstances and scenarios outlined in the 'Introduction' (namely, through your token subscriptions and purchases, your use of the Website, and any of the related Services).

You must read this Policy together with any other privacy or fair processing notice we may provide on specific occasions when we are collecting or processing Personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.

The opening and registration of a customer account will give rise to the existence of a contractual relationship with us, as regulated by our Terms of Use, and all matters between you and us relating to Services will be deemed to fall within the subject matter of that same contractual relationship.

Controllers

Neo Blockchain Bank (as defined) above is the controller and is responsible for your Personal data. There may be other controllers of your Personal data, such as, for example, electronic identification verification service providers, or other service providers engaged by us for purposes of processing and storing your Personal data. They will be so-called "joint controllers" of your Personal data and as such, will share responsibility for such control with us.

By agreeing to this Privacy Policy, you consent to the transfer of your personal data to Reap Technologies Limited and for the purposes outlined above. We ensure that such transfers are conducted in compliance with applicable data protection laws and regulations and that adequate safeguards are in place to protect your personal data.

Please familiarize yourself with these providers and their privacy and liability policies. If you find any of these may not work for you, please do not access any of the Websites and do not use any of our Services.

As a general rule, we always seek to minimize the amount of your Personal data that we collect and store.

Contact Details

Full name of legal entity: Neo Blockchain FIn Software TEC LLC

Email address: privacy@neobcb.com

Please use the words 'Data Protection Matter' in the subject line.

Changes to the Policy and Your Duty to Inform Us of Changes

It is imperative that the Personal data we hold about you is accurate and current at all times. Otherwise, this will impair our ability to process your token purchases and/or our ability to provide you with the Services that you may request from us (amongst other salient issues).

Please keep us informed if any of your Personal data changes during your relationship with us.

Third-Party Links

Our Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notice or policies. We strongly encourage you to read the privacy notice of every website you visit, particularly when leaving our Website.

2. Glossary

Set out below are key definitions of certain data protection terms that appear in this Policy.

• "Consent Form" refers to separate documents that we might from time to time provide you where we ask for your explicit consent for any processing that is not for purposes set out in this Policy.
• "Data subjects" means living individuals (i.e. natural persons) about whom we collect and process Personal data.
• "Data controller" or "controller" means any entity or individual who determines the purposes for which, and how, any Personal data is processed.
• "Data processor" or "processor" means any entity or individual that processes data on our behalf and on our instructions (we being the data controller).
• "Personal data" means data relating to a living individual (i.e. natural person) who can be identified from the data (information) we hold or possess. This includes but is not limited to, your name and surname (including maiden name where applicable), address, date of birth, nationality, gender, civil status, tax status, identity card number & passport number, contact details (including mobile and home phone number and personal email address), photographic image, bank account details, emergency contact information as well as online identifiers.
• "Processing" means any activity that involves the use of Personal data. It includes obtaining, recording, or holding the data, or carrying out any operation or set of operations on the data including, organizing, amending, retrieving, using, disclosing, erasing, or destroying it. Processing also includes transferring Personal data to third parties.
• "Sensitive Personal data", "sensitive data" or "special categories of Personal data" includes information about a person's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offense committed or alleged to have been committed by that person.

3. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, share, and disclose different kinds of Personal data about you which we have grouped as follows:

• Identity Data includes your first name, maiden name (where applicable), last name, username or similar identifier, marital status, title, nationality, date of birth, gender, identity card, and/or passport number.
• Contact Data includes address, billing address, email address, and contact number (telephone and/or mobile).
• AML and KYC Data includes due diligence documentation and information including: copy of your national identity document, passport, and/or driver's license, proof of residence, a 'selfie' (for identity verification), KYC database checks, fraud database checks, and any documentation required for compliance with applicable legislation.
• Enhanced KYC Data applies with respect to payments that exceed a set threshold and includes source of funds and source of wealth.
• Financial Data includes your wallet and private key details.
• Transaction Data includes details about your subscriptions, purchases, transactional activity, transactional history on the Platform, use of the Services, and payments made to and from you.
• Portfolio Data includes details about the tokens credited to your account.
• Usage Data includes details about how you use our Platform and the Websites.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.
• Website Visit Data includes the full Uniform Resource Locators (URL), clickstream to, through, and from the Website, products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information.
• Marketing and Communications Data includes your preferences in receiving marketing from us or our third parties and your communication preferences.

If You Fail to Provide Personal Data

Where we need to collect Personal data about you by law, under the terms of our contract with you, or as part of our legitimate business interests, and you either fail to provide that data when requested, or provide incomplete or insufficient data, we may not be able to perform or conclude the contract that we have or are otherwise trying to enter into with you.

Special Categories of Personal Data

We do not knowingly collect Special Categories of Personal data (or Sensitive Personal data) about you. Should we receive sensitive Personal data about you, we will only process that data when there is a legitimate basis to do so and, in all circumstances, in accordance with our obligations at law and under the appropriate safeguards.

4. How Is Your Personal Data Collected?

We generally use different methods to collect data from and about you including through:

Account Registration

We will ask you to provide us with your Identity, Contact AML, and Risk Data when you apply to open a customer account with us.

Direct Interactions

You may give us your data by filling in our forms or by corresponding with us by post, phone, email, or otherwise. This includes Personal data you provide when you:

• contact us in the context of opening and registering a customer account;
• apply to open a customer account;
• subscribe to, purchase, and/or use our Services;
• discuss with us the particular Services that you require;
• request and receive our Services;
• contact us with complaints or queries;
• complete an inquiry form;
• request marketing to be sent to you;
• express interest and/or attend any of our seminars or other hosted events;
• participate in a survey or our webinars;
• subscribe to our newsletters;
• give us some feedback.

Automated Technologies or Interactions

When you interact with our Website, we may automatically collect Technical and Usage Data about your equipment, browsing actions, and patterns. We may collect this Personal data by using cookies, server logs, and other similar technologies. Please see our Cookie Policy for further details.

Third Parties or Publicly Available Sources

We may receive Personal data about you from various third parties and public sources including analytics providers, advertising networks, search information providers, and publicly available sources such as public court documents and company registers.

5. How We Use Your Personal Data

We will only use your Personal data when the law allows us to. Most commonly, we will use your Personal data in the following circumstances:

• Where you wish to enter into a customer relationship with us.
• Where we need to perform the contract we have or which are about to enter into with you as a customer.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

You have the right to withdraw consent to such marketing at any time by contacting us at privacy@neobcb.com.

6. Purposes for Which We Will Use Your Personal Data

We use your Personal data for the following purposes:

• To conduct customer due diligence measures on you following your application to enter into a customer relationship with us.
• To determine whether we want to enter into a customer relationship with you and, if positive, to register your customer account and onboard you as a customer.
• To establish and verify your identity and fulfill our internal KYC policies and requirements.
• To enable your use of the Platform, process your token subscriptions, purchases, and trading activity, and provide you with the Services.
• To keep your account portfolio accurate and updated.
• To manage transactions and generate transaction reports and records.
• For tax and accounting purposes.
• For billing and invoice purposes.
• To collect and recover money which is owed to us.
• To manage our customer relationship with you.
• To detect, prevent, and/or report fraud or any other potentially illegal or prohibited activity.
• To administer and protect our business, the Website, and our Platform.
• To carry out market research campaigns and deliver relevant content and advertisements.

7. Marketing

We strive to provide you with choices regarding certain Personal data uses, particularly around advertising and marketing. Through your Identity, Contact, Usage, Technical, and Website Visit Data, we can form a view of what we think you may want or need.

You may receive marketing communications from us where:

• you have entered into an ongoing commercial or contractual relationship with us; and
• provided you have not opted out of receiving marketing from us.

Third-Party Marketing

We will get your express opt-in consent before we share your Personal data with any third parties (including our affiliated entities) for marketing purposes.

Opting Out

You can ask us to stop sending you marketing communications (unsubscribe) at any time by following the opt-out (unsubscribe) links on any marketing communication sent to you.

Cookies

You can set your browser to refuse all or some browser cookies or to alert you when the Website sets or accesses cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly.

8. Disclosures of Your Personal Data

We may have to grant access to, disclose, or share your Personal data with the parties set out below (which may be in or outside your jurisdiction):

• Third-party service providers, including platform integration and infrastructure hosting providers, KYC providers, payment services and payment gateways, and token accounting services.
• Our affiliated entity, such as partner firms involved in the provision of certain Services.
• Affiliated group entities to help detect and prevent potentially illegal acts and violations of our policies.
• Suppliers and external agencies that we engage to process information on our or your behalf.
• Professional advisers such as consultants, bankers, professional indemnity insurers, brokers, and auditors.
• Law enforcement agencies, public authorities, and judicial bodies (local and overseas).
• Other organizations where the exchange of information is for the purpose of fraud protection or credit risk reduction.
• Debt recovery agencies to assist us with the recovery of debts owed to us.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.

We require all affiliated entities and third-party service providers to respect the security of your Personal data and to treat it following the law. Our service providers currently store your Personal data in Germany.

Some of our service providers (including those providing cloud infrastructure, such as Amazon Web Services) may be located or store data in the United States. Where such transfers occur, we ensure that adequate safeguards are in place to protect your personal data in accordance with GDPR requirements.

9. International Transfers

We do not generally transfer your Personal data outside the European Economic Area ("EEA") except as may be necessary to: (i) process your transactions, subscriptions, purchases, and/or trading activity, (ii) provide the requested services, (iii) fulfill our contractual obligations to you, (iv) exercise and enforce our contractual rights and terms of services, (v) comply with our legal and/or regulatory obligations or (vi) assert, file or exercise a legal claim.

Where we do need to transfer your Personal data to outside the EEA, we will ensure a similar degree of protection is afforded to that Personal data by ensuring at least one of the following safeguards applies:

• We will only transfer your Personal data to countries that have been deemed to provide an adequate level of protection for Personal data by the European Commission.
• In the absence of an adequacy decision, we will use specific contracts approved by the European Commission which give Personal data the same protection it has in Europe.
• Where we use providers based in the U.S., we may transfer data to them if they are part of the Privacy Shield.

Please contact us at privacy@neobcb.com if you want further information on the specific mechanism used by us when transferring your Personal data out of the EEA.

10. Data Security

We have put in place appropriate security measures to prevent your Personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We also regularly review and, where practicable, improve upon these security measures.

We also limit access to your Personal data to strictly those employees, agents, contractors, and third parties that have a professional 'need-to-know'. They will only process your Personal data on our instructions and they are subject to a duty of confidentiality. All our employees and agents have received appropriate training on data protection.

We have put in place procedures to deal with any suspected Personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. Data Retention

Please note that we consider our relationship with customers to be an ongoing and continuous customer relationship, until such time that either we or the customer terminates it in accordance with our Terms of Use.

We will only retain your Personal data for as long as necessary to fulfill the purposes for which we collected it and, thereafter:

• for the purpose of satisfying any legal, accounting, tax, anti-money laundering, and regulatory obligations or reporting requirements to which we may be subject; and/or
• to the extent that we may also need to retain your Personal data to be able to assert, exercise or defend possible future legal claims against you or that otherwise involve you.

By and large, our retention of your Personal data shall not exceed the period of six (6) years from the termination of your customer relationship with us. In certain cases, we may need to retain your Personal data for a period of up to ten (10) years in order to comply with applicable accounting and tax laws.

In some circumstances, you can ask us to delete your data. See Request erasure below for further information.

Kindly contact us at privacy@neobcb.com for further details about the retention periods that we apply.

Data Minimization

To the extent possible, we may anonymize the data that we hold about you when it is no longer necessary to identify you from the data that we hold about you. In some circumstances, we may even pseudonymize your Personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

12. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal data:

• Request access to your Personal data (commonly known as a "data subject access request").
• Request correction (rectification) of your Personal data.
• Request erasure of your Personal data.
• Object to processing of your Personal data.
• Request restriction of processing your Personal data.
• Request transfer of your Personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at privacy@neobcb.com.

No Fee Usually Charged

You will not have to pay a fee to access your Personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may simply refuse to comply with your request in such circumstances.

What We May Need from You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal data (or to exercise any of your other rights). This is a security measure to ensure that Personal data is not disclosed to any person who has no right to receive it.

Time Limit to Respond

We try to respond to all legitimate requests within a period of one month from the date of receiving your request. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints

You have the right to complain at any time to a competent supervisory authority on data protection matters, such as (in particular) the supervisory authority in the place of your habitual residence or your place of work.

We would, however, appreciate the opportunity to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance at privacy@neobcb.com.

13. Conclusion

We reserve the right to make changes to this Policy in the future, which will be duly notified to you. If you have any questions regarding this Policy, or if you would like to send us your comments, please contact us today or alternatively write to our data protection team using the details indicated in this Policy.