Privacy Policy

Last updated: 20th March 2024

Privacy Policy

Welcome to the Privacy Policy (the “Policy”).

This Website and Mobile application are owned by the company by the company Palremit Corporation, incorporated in the State Delaware with a registered number 5480901 and registered office at 8 The Grn Ste A Dover, Delaware 19901-3618, USA (Palremit).

Choise Services UAB, a legal entity duly registered in Lithuania with No. 305964183 with a registered office at Vilnius, Eišiškių Sodų 18-oji g. 11. (the “Choise”) and Charism LLC, is a limited liability company created and existing under the laws of Saint Vincent and Grenadines, with company number 1999 LLC 2022, registered office at Suite 336, Beachmont Business Centre, Kingstown (the “Associated Company”).

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 https://palremit.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:

• visit and use a Website and/or Platform, regardless of where you visit or use them from;
• apply for and register a customer account with us (your “Account”);
• 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

• our obligations to process your data responsibly,
• 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.

Please read the following information carefully to understand our practices regarding your data.

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).

The Websites, the Platform, and the Services are not intended or in any way made available for minors, and we do not knowingly collect data relating to minors.

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. Furthermore, the existence of this contract between you and us will also serve as the legal basis for a number of our processing activities involving your Personal data, as detailed below.

Controllers

Palremit Corporation (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, Associated companies, 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.

Presently, we use the services of the following service providers:

Ondato: https://www.ondato.com for KYC/AML verification;

Vero:  https://www.getvero.com or handling e-mail lists and campaigns; and

Walletto: https://walletto.eu for card-issuing services;

In the course of providing our services to you, we may transfer your personal data to certain third-party legal entities for the purpose of issuing bank cards, facilitating financial transactions, and other related services. Specifically, your personal data will be shared with Reap Technologies Limited and Layer 2 Financial Inc.

These entities have been carefully selected to ensure that your personal data is processed in a manner consistent with our commitment to safeguarding your privacy. Reap Technologies Limited and Layer 2 Financial Inc. will process your personal data in accordance with their established privacy policies, which outline their practices regarding the collection, use, processing, and protection of personal data.

To understand how your personal data will be handled by these entities, you are encouraged to review their privacy policies:

Reap Technologies Limited: https://reap.global/privacy-policy

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: Palremit Corporation

Email address: [email protected]

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.

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. The

term “personal information”, where and when used in this Policy, shall have taken the same meaning as Personal data.

“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, the disposal of such proceedings or the sentence of any court in such proceedings. This type of sensitive data can only be processed under strict conditions.

Note that Personal data does not include information relating to a legal person (such as for example, a company). Therefore, information such as a company name, its company number, registered address, and VAT number, does not amount to Personal data in terms of both the Act and the GDPR. Naturally, we will still treat any such information confidentially and securely.

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 (for purely indicative purposes) we have grouped as follows. For the avoidance of doubt, categories marked in blue do not apply to non-customers (i.e. individuals who do not hold a registered customer account with us).

• 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 the following due diligence documentation and information on you:

copy of your national identity document, passport, and/or driver’s license, (ii) proof of residence (for example, a recently issued utility bill), (iii) a ‘selfie’ (for identity verification), (iv) KYC database checks, (v) fraud database checks and (vi) any documentation or information which we may be from time to time:

required to collect to ensure compliance with any applicable legislation (including applicable foreign laws) and global AML/KYC practices; and/or

otherwise mandated to collect by any competent authority, including, as applicable, any other documentation or information which may be mandated on us from time to time by applicable law and by any other competent authority or related legislation (including overseas authorities and applicable foreign laws).

Enhanced KYC Data applies with respect to payments that exceed a set threshold and includes, at a minimum, the following enhanced customer due diligence documentation and information: source of funds and source of wealth.

Financial Data includes your wallet and private key details.

Transaction Data includes details about:

• your subscriptions, purchases, and transactional activity;
• your transactional history on the Platform;
• your use of the Services (including your service requests);
• the 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, and other technology on the devices which you (whether a client or otherwise) use to access and browse the Websites.
• Website Visit Data includes the full Uniform Resource Locators (URL), clickstream to, through, and from the Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.
• Marketing and Communications Data includes your preferences in receiving marketing from us or our third parties and your communication preferences. This may include information on whether you have subscribed or unsubscribed from any of our mailing lists, attended any of our events, or accepted any of our invitations.

We will also collect, use, and process any other information that you voluntarily choose to provide or disclose to us where relevant for processing your token requests and/or providing you with your requested Services. Any such information that we receive from you would fall under the ‘Transaction Data’ category.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal data but is not considered Personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Website Visit Data to calculate the percentage of users accessing a specific feature of the Website. However, if we combine or connect Aggregated Data with your Personal data so that it can directly or indirectly identify you, we treat the combined data as Personal data which will be used following this Policy.

If you fail to provide Personal data

• Where we need to collect Personal data about you:
• by law, or
• under the terms of, or in connection with, the contract that we have with you (as discussed above); or
• as part of our legitimate (business) interests to verify the identity of our applicants and customers, mitigate against risks (such as potential or suspected fraud), and, in particular, assess and take a decision on whether we want to enter into a customer relationship with you (as subject to our customer acceptance criteria and policies),

and you either fail to provide that data when requested, or else 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 (namely regarding your account opening, token subscriptions and purchases, and provision of the Services).

In certain cases, particularly where it relates to KYC due diligence data (both standard and enhanced), we may even need to exercise our prerogative to terminate our contract with you following the terms thereof, or else, if still at the application stage, we may have to decline to enter into a customer relationship with you.

We will however notify you if this is the case at the time.

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.

As set out below in Section 5, we collect and process AML and KYC Data and, if applicable, Enhanced KYC Data in order to (i) conduct our AML and KYC checks, and other due diligence checks, on you, (ii) verify your identity or claimed identity and, in those instance of enhanced due diligence, your source of funds and source of wealth, (iii) take an informed decision on whether we want to enter into a customer relationship with you, and, if positive, to conduct initial and ongoing screening and monitoring and (iv) to comply with any legal or regulatory obligation that we may have and/or any Court, regulatory or enforcement order that may be issued upon us.

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. You provide this information, which will then be collected and processed when you fill in and submit your account application form (together with other related forms) and complete the required application steps.

Direct Interactions. You may give us your Identity, Contact AML and Risk Data, Enhanced KYC Data, and Marketing and Communications Data by filling in our forms (such as our ‘Contact Form’) 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;
• contact us for further information about our products and services;
• submit the AML and KYC Data and/or Enhanced KYC Data that we request;
• 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.

Through our provision of the Services. This may encompass all of the data categories listed in Clause 3 (namely, Identity, Contact, AML and Risk Data, Enhanced KYC Data, and Transaction Data).

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 as set out below:

Technical Data from the following parties:

• analytics providers;
• advertising networks; and
• search information providers.

Identity, Contact, AML, and Risk Data and Enhanced KYC Data from publicly available sources such as public court documents, the RoC, and the company houses and registers of other jurisdictions, and from electronic data searches, online KYC search tools (which may be subscription or license-based), anti-fraud databases and other third party databases, sanctions lists, outsourced third-party KYC providers and from general searches carried out via online search engines (e.g. Google).

We may also receive customer due diligence reports about our applicants from our outsourced third-party KYC provider. These reports may encompass identity checks, document integrity checks, checks against global sanctions lists, and related screening and monitoring measures. In such cases, this third-party provider will conduct the requested customer due diligence checks autonomously and will generally amount to a controller of the Personal data that it collects in connection with those checks. It also has its data policies and practices, which will be duly notified and communicated to the applicant.

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 (including in respect of your token purchases and subscriptions, and use of the Services).

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, as indicated above under ‘Contact Details’.

6. Purposes for which we will use your Personal data

We have set out below, in a table format, a description of all the ways we plan to use your Personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your Personal data according to more than one lawful ground or basis, depending on the specific purpose for which we are using your data. Please contact us at [email protected] if you need details about the specific lawful basis we are relying on to process your Personal data where more than one lawful basis has been set out in the table below.