I. Introduction

For Clients from the European Union member states and EEA Walleexer s.r.o. (identification number 179 89 124) is the company incorporated under the law of the Czech Republic and have registered office at Perštýně 342/1, Old Town, 110 00, Prague is the responsible party for the processing of Personal Data (Data Controller) collected through your access of our Website, Apps and use the Services.

Capitalised terms used in this Privacy Policy have the same meanings as those defined in Service Terms of Use and in EU General Data Protection Regulation ("GDPR").

This privacy Policy ("Privacy Policy") describes how and why we collect, store, use, and manage the information, and data, including Personal Data, that you provide or we collect when you visit our Website, Apps and use the Services. It also tells you how you can access and update data and make certain choices about how information that you provide to us is used.

Privacy Policy is an integral part of Holders Service Terms of Use. By accessing our Website, Apps and using the Services, you accept the terms of this Privacy Policy. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access to our Website, Apps or use of the Services.

We reserve the right to update or modify this Privacy Policy from time to time. Such updated or modified versions shall apply from the date of publication on Website and/or in Apps, unless otherwise expressly stated, and you waive any right you may have to receive specific Policy of such changes or modifications. Your continued access to the Website and Apps or use of the Service shall constitute your acceptance of such updates or modifications.

Some of the Services or parts of the Services may be provided by our Partners. They have their own privacy policies which govern the processing of your data when using such Services. You are required to review and accept the privacy policies of those Partners before using their Services. Please note that their policies may differ from this Privacy Policy.

II. How we process your Personal Data

1. Scope

We only process your Personal Data if this is necessary to ensure functioning of the Website, Apps or to provide you with our Services. The processing of Personal Data only takes place based on the appropriate legal basis and as permitted by law.

We collect information that you voluntarily provide to us when you express an interest in obtaining information about us or our products, in using our Services, when you register and participate in activities on the Website, Apps or otherwise when you contact us.

The personal information we may collect is described below:

• general personal data: full name, sex, personal identification code or number, date of birth, legal capacity, nationality and citizenship, location (street, city, country, postcode);
• facial image data; photos of a face (including selfie images) and photo or scan of a face on the identification document, videos, and sound recordings;
• biometrical data: facial scan(s);
• identity document data: document type, issuing country, number, expiry date, MRZ, information embedded into document barcodes (may vary depending on the document), security features;
• banking details: cardholder name, expiry date, first 6 and last 4 digits of the card number, data extracted from documents provided as proof of source of funds/wealth;
• contact details: address, e-mail address, phone number, IP address;
• unique identifier (Applicant ID) created only for the association Data Subject and its personal data inside the Informational System;
• relevant publicly available data: information regarding a person being a Politically Exposed Person (PEP) or included in sanctions lists;
• personal information additionally provided by Data Subjects, such as data obtained during their communications with the Data Processor (e.g., requests, reports).

You hereby acknowledge and agree that facial images of yourself are processed to confirm the liveliness of your face and/or to confirm that a given identity document is presented by you, its legitimate owner.

We may automatically collect the following information:

• a) technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, information regarding the date, time and activity in the Services, domain name, software and hardware attributes (camera name and type), general geographic location (e.g., city, country) from your device;
• b) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website; 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), and methods used to browse away from the page and any phone number used to call our customer support number.

Information collected from other sources.

We may receive information about you if you use any of the other websites we operate or the other Services we provide. We are also working closely with third parties and may receive information about you from them. For example:

• a) The banks or payment card issuers you use in the Service will provide us with your basic personal information, such as your name and address, as well as your financial information such as your bank account details;
• b) Partners may provide us with your data;
• c) Analytics providers and search information providers may provide us with pseudonymised information about you, such as confirming how you found our Website;
• d) We may engage a Partner, who will act as Data Processor, to carry out KYC ("Know Your Customer) procedures and fulfill AML/CTF Requirements, including information and documentation collection and processing.
• e) We may collect and process information about you from publicly accessible sources or governmental and other databases.

2. Legal basis for processing under GDPR

We use the following legal bases when processing your Personal Data.

Processing necessary for the performance of the contract between you and us or in order to take steps at your request prior to entering into a contract with us.

We process data on this basis for the following purposes:

• To create and manage Accounts, ensuring access to the Website, Apps and Services;
• To facilitate operations in the scope of Services provided;
• To send necessary updates or notifications regarding Services, Account activities, or any changes to Terms of Use;
• To provide customer support and address Client inquiries related to Website, Apps and Services usage.

Processing necessary for compliance with legal obligations.

We process data on this basis for the following purposes:

• To ensure compliance with applicable AML/CFT Requirements;
• To implement age restrictions in accordance with applicable laws;
• To comply with other relevant laws, regulations, and legal obligations as required;
• To conduct customer due diligence procedures as mandated by laws governing the intended business relationship;
• To respond to lawful requests, such as subpoenas or court orders, and cooperate with regulatory investigations;
• To maintain records for audit, compliance, and regulatory reporting purposes.

Processing necessary to protect our legitimate interests.

We may process data on this basis for the following purposes:

• To identify and prevent fraudulent activities;
• To implement security measures that protect Client's funds and sensitive information;
• For analytics to improve the Website, App and Services functionality and Client experience;
• To analyze and improve the functionality and performance of the Website, Apps, and Services;
• To measure the effectiveness of marketing campaigns and refine strategies to enhance engagement and retention.

Processing based on your consent

We may process data on this basis for the following purposes:

• To conduct surveys, feedback requests, and other research to understand Client preferences and improve Services;
• To personalize and optimize the Client experience across different marketing channels, such as email, social media, and in-app notifications;
• To provide newsletter and other information feed;
• To measure the effectiveness of marketing campaigns and refine strategies to enhance engagement and retention;
• To organize and manage promotional events, contests, and loyalty programs;
• To conduct targeted advertising based on anonymized or aggregated data that aligns with Client preferences;
• To offer personalized Services, content, and recommendations based on Client interactions and preferences;
• To share specific information with third-party Partners for integrated services;
• To process biometric data in the scope of KYC in order to fulfill AML/CFT Requirements.

III. Automated Data Processing and Decision Making, Cookies

3. Automated Data Processing

Every time you visit our Website, our system automatically collects data and information about the computer system you used to access our Website.

The following data may be collected:

• Internet Protocol (IP) address used to connect your device to the Internet;
• Login information;
• Browser type and version;
• Time zone setting;
• Browser plug-in types and versions;
• Operating system and platform;
• Date, time, and activity in the Services;
• Domain name;
• Software and hardware attributes (e.g., camera name and type);
• General geographic location (e.g., city, country) from your device;
• Websites from which your system reaches our Website;
• Websites accessed by the Client's system via our Website.

The data is also stored in the log files of our system. This data is not stored together with your other Personal Data.

The data stored in log files serves the purpose of ensuring the functionality of the Website. In addition, the data serves us to optimize the Website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.

For data processing subject to GDPR, the legal basis for the temporary storage of data and log files is our legitimate interests.

4. Automated Decision Making

We may use technology that can evaluate your personal circumstances and other factors to predict risks or outcomes. This is sometimes known as profiling. We do this for the efficient running of our services and to ensure decisions are fair, consistent and based on the right information.

We may make automated decisions about you that relate to:

• Opening Accounts;
• KYC, anti-money laundering and sanctions checks;
• Identity and address checks;
• Detecting fraud;
• Monitoring your Account to detect fraud and financial crime.

Our legal basis is one or more of the following:

• a) entering into, or performance of contracts and agreements between you and us;
• b) legal obligations;
• c) legitimate interests (to develop and improve how we deal with financial crime and meet our legal responsibilities).

Where only legal bases in points "b" and "c" are applied you have the right not to be subject to a decision based solely on automated processing. In any case where we make an automated decision about you, you have the right to ask that a human review it manually.

5. Cookies

In order to guarantee an optimal level of usability and performance and to ensure relevance of promoted Service, we use cookies and similar technologies in order to track the interaction of Clients with the Website and Apps. This section explains the different types of cookies that may be set when the Client uses the Website and Apps, helping to understand and manage them as he/she wishes.

A cookie is a small file that is stored locally at the Client's technical device as soon as the App is being used and/or the Website being visited.

Cookies function by saving particular sets of data, such as, for example, the Client's language selection, version of browser, the type of operating system used, device characteristics and the IP address of the connected device used. Should the Client visit the Website and/or open the App again later, a cookie will transmit this data back to the Website and App. The cookies don't store personal information like the Client's name or address.

Types of Cookies

We use different types of cookies:

Session cookies only last only while the Client is visiting the Website and/or using the App and help the Website and the App to learn more about Client's behavior during a single session and to help the Client to use the Website and the App more efficiently. Session cookies are deleted when you close your browser. Legal basis for processing is legitimate interest and performance of the contract, as these cookies are essential for providing the service you request.

Persistent cookies have a longer lifespan and aren't automatically deleted when the Client leaves the Website or closes the App. These cookies are primarily used to help the Client to sign-in again quickly, for security and analytical purposes. The Website and the App do not use any information whilst the Client is logged off. Legal basis for processing is consent for analytics purposes, legitimate interest for security purposes. Persistent cookies remain on your device after you leave the Website or App and can last for up to 12 months unless deleted manually.

We use first-party cookies that is when the cookies are placed on the Client's device directly by the service. For example, first-party cookies are used to adapt the App to the language preferences and analyze user experience of the Client. Legal basis for processing is legitimate interest for improving user experience and providing tailored services. These cookies may last up to 12 months.

Third-party cookies are placed on the Client's device by our partners and service providers. Legal basis for processing is consent for advertising and social media functionalities. The retention period for third-party cookies is determined by our partners and service providers and may last up to 24 months.

Necessary cookies. These cookies are strictly necessary to provide the Client App's services. Legal basis for processing is legitimate interest and performance of the contract, as these cookies are crucial to providing the requested services. The retention period for necessary cookies is session duration, deleted after closing the browser or app.

Authentication cookies. These persistent cookies help the Service to identify the Clients so that the Client could log in automatically. Legal basis for processing is legitimate interest to enhance user convenience and security. The retention period for authentication cookies remains active for up to 12 months.

Analytics cookies. These cookies help us to understand how the App is being used, and help to customise and improve the service. Legal basis for processing is consent, as analytics cookies are only used when users provide explicit consent. Retention period for analytics cookies is 24 months.

The Client can at any time reset device identifiers by activating the appropriate setting on his/her mobile device. The procedure for managing device identifiers is slightly different for each device.

The data processed by cookies for the aforementioned purposes, when this data is recognized as a personal, is processed for the purposes of performance of the contract between Walleexer and the Client, Walleexer's legitimate interests and compliance with legal obligations.

IV. Data Sharing

6. Disclosure of Your Data

We may disclose your personal information with selected third parties including:

• a) Partners, involved in Service provision for the performance and execution of any agreement we enter into with them or you.
• b) KYC providers. We may engage third party providers in order to carry out Client's identification and verification. In most cases they act as Data Processors on the basis of the processing agreement.

We also may disclose your personal information to third parties:

• a) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• b) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply Holders Service Terms of Use and other applicable agreements, or to protect the rights, property, or safety of Walleexer, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
• c) to assist us in conducting or co-operating in investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so;
• e) in response to a subpoena, warrant, court order, or as otherwise required by law;
• f) to assess financial and insurance risks;
• g) to recover debt or in relation to your insolvency; and
• h) to develop customer relationships, services and systems.

7. International Transfers

We confirm that all Personal Data is stored on servers located within the European Union (EU) and/or in compliance with any national data localization requirements of the respective countries, where such requirements exist. Furthermore, we confirm that all Personal Data is transferred within the EU or the European Economic Area (EEA). No Personal Data from EEA is transferred to third countries that are not subject to an adequacy decision by the European Commission, or that do not provide a level of data protection equivalent to that of the EEA.

V. Your Rights

You have the following rights under the applicable data protection laws:

Information and Access. The right to know whether your Personal Data is being processed, right to get information regarding processing of Personal Data, right to request a copy of Personal Data being processed. The right to information about public and private entities with which we have shared data.

Rectification (correction). The right to correct your Personal Data in a situation when such data available to us or disclosed to third parties is inaccurate or incomplete.

Erasure. The right to request deletion of your Personal Data from our database so that the Service is not able to continue processing and storing of such data, with exceptions, provided in applicable law. We may not be able to agree to your request where we need your data for compliance with our legal obligations. As a regulated financial services provider, we must keep certain Client Personal Data. If you've closed your Account, we may not be able to delete your entire file because these regulatory responsibilities take priority. We'll always let you know if we can't delete your personal data.

Restrict processing. The right to introduce the restriction regime on the processing of Your Personal Data, so that in each case the data may be processed only upon your separate consent.

Data portability. The right to request for the Personal Data to be given in a machine-readable format so that it could be transferred to another service provider or transfer directly to a third party designated by you.

Object. You have the right to object to processing of your Personal Data. However, if there are legitimate grounds for the processing in place, which override your interests, rights and freedoms, we will not accept your request. If you object to us using Personal Data that we need to provide our services, we may need to close your Account as we won't be able to provide the services.

Withdraw consent. Right to withdraw consent to processing of your Personal Data by us or third parties to which we have previously disclosed your Personal Data.

Automated decision. If we make an automated decision about you that significantly affects you, you can ask us to carry out a manual review of this decision.

Lodge a complaint. If you wish to raise a complaint about how we are using your information, exercise any of the rights set out above, or if you have any questions or comments about privacy issues, you can contact us by:

For data subjects who are from the European Union member states and EEA:

• writing to Data Protection Officer, Walleexer s.r.o, Czech Republic at Perštýně 342/1, Old Town, 110 00, Prague; or
• sending an email to privacy@walleexer.com.

You can also complain to the Office for Personal Data Protection, which regulates and supervises the use of personal data in the Czech Republic, on +420 234 665 800 or send an email to posta@uoou.gov.cz.

VI. Duration of processing and security

We only store your Personal Data for as long as necessary to serve the purpose of the processing and we delete Personal Data or block access to it as soon as such purpose ceases to apply.

Furthermore, Personal Data may be stored if this has been provided for by the applicable law (for example for book keeping or mandatory archiving purposes). The data will also be blocked or deleted if a storage period prescribed by the applicable law expires, unless there is a need for further storage of the data for the conclusion or fulfilment of a contract.

We have implemented reasonable technical and organisational precautions to protect the confidentiality, security and integrity of your personal information from accidental or unlawful destruction, loss, alteration, disclosure, or unauthorised access. We cannot guarantee the security of information transmitted to us over the internet.

VII. Retention period of personal data

We seek to ensure that we only keep your personal data for the longest of:

• the period necessary for the relevant activity or services;
• any retention period that is required by law; or
• the period in which litigation or investigations might arise in respect of the services.

We are required to keep certain personal data for specified periods by KYC, anti-money laundering, banking and e-money laws. In line with such laws, regulated financial companies are obliged to store the Client's data up to ten years after the termination of the Client's relationship with the Client or the date of the occasional transaction.

Where we independently define the compatible purposes or are under a legal obligation, Personal Data will be destroyed after our purposes for collecting the personal data have been satisfied or after three (5) years from the provision of data to our system, whichever occurs first.

VII. Changes to our Privacy Policy

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated Privacy Policy on the Website as part of Privacy Policy. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

VIII. How to contact us

If you have any questions about this Privacy Policy or implement your rights, you can contact us by email: privacy@walleexer.com.