FINAURA PRIVACY POLICY

FINAURA OÜ, a legal person incorporated under the laws of Estonia with a

registry code 14696643 with a registered address at Roosikrantsi 2-768K, 10119

Tallinn, Estonia, its subsidiaries and affiliated parties (the "Company") is

committed to protecting the privacy of your personal information. The

Company is the controller and responsible for your personal data. This Privacy

Policy applies to Your use of the website www.finaura.eu (the "Site") and

governs data collection and usage in relation to the services provided on the

Site (the "Services"). This Privacy Policy and Cookie Policy constitute an

integral part of the Terms of Use. Unless otherwise specified, the terms used

in this document shall have the same meaning as in the Terms of Use.

This Privacy Policy, together with Terms of Use, provides an explanation as to

the treatment of the personal data which You provide us or that is collected

from You in the course of Your use of the Site or any third-party websites, and

describes when and how we may change this Privacy Policy, and tells You

how to contact us with any questions or comments. By using the Site, You

consent to the data practices described in this Privacy Policy.

We collect Personal Information about You and the device You use when You

use our Services on the Site or otherwise interact with the Company.

Personal Information

"Personal Information" means information that we directly associate with a

specific person or entity, which may include without limitations, name,

addresses, telephone numbers, email address, payment information, unique

device ID (the "UDID"), device location, IP address, Site usage data, etc.

"You" and "Your" refers to you, the person accessing the Site, and which by

doing so, accepts this Privacy Policy. Any use of the above terminology or

other words in the singular, plural, capitalization is taken as interchangeable

and therefore as referring to the same.

How Personal Information About You is Collected

We collect information about You in three primary ways:

a. Information You Provide. We collect information that You provide to us

when You register for or use the Site, or otherwise communicate with

us. Without limitations, provision of information by You may include the

following: information provided when You contact us or register (e-

mail, password) to participate in our affiliated products, KYC

information (as set forth in the AML/KYC Policy and Verification Levels),

the Company may collect personal contact information, billing

information and any information shared with payment processors, all

as may be necessary for the provision of the Company Services or the

interaction executed by You.

b. Upon the establishment or modification of an account with the

Company, We may collect user identification information, passwords,

security question responses, or other elements related to account

security, or any other means of identification, which You will use for the

future sign-on.

c. Upon interaction with our Customer Service representatives or anyone

acting on behalf of the Company, or once You enter information on the

Site, submit survey responses, we may also collect Personal Information

and other data. We may monitor and record phone calls, e-mails, live

chats, or other communications between You and our Customer

Service representatives or other employees or representative

Information We Collect Automatically

We automatically collect a variety of Personal Information associated with

Your use of the Site or the Services. Each time You visit the Site Personal

Information is automatically gathered, which in general, does not identify.

You personally and may include without limitations: UDID, IP address,

Country, City (if available), Connection Speed, Publisher Name, Collection

Date, Day of Week, Time of Day (hour), Language settings in addition to any

information provided directly by You, all of which allows the Company to

evaluate Your use of the Site for the purpose of improving the Site and the

Services.

The Use of Cookies

The Company uses cookies to appropriately run the Website, analysis of the

Website traffic, and marketing purposes. To learn more about the cookies,

please read the Cookie Policy.

The Use of Web Beacons

The Company may use web beacons (or "pixels"), which are small graphic

images on a web page or an HTML, for the purpose of monitoring interaction

with the Site or e-mails.

Site Use Activity

Through Your access to the Site, we automatically collect certain Personal

Information about Your use of the Site, such as Your IP address, browser type,

date and time, the web pages You visited before visiting the Site, Your

activities and downloads on the Site, and additional analytical information

associated with the Site.

Information from Other Sources

The Company may collect information about You from other sources. For

example, the Company may receive certain credit information from third-

party sources before initiating any service to You. The Company may also

purchase or obtain Personal Information (for example, e-mail lists, postal mail

lists, demographic and marketing data) from third parties.

Cryptographic Hashes

Members sending Virtual Currency to the Site through the use of

cryptographic hashes and keys take full responsibility for the risks involved.

By using the Services you will automatically accept liability of any loss,

damages, or implications incurred through the use of this Site and the

Company will not be held liable for any loss of Your Virtual Currencies.

If You do not agree you can request the return of Your Virtual Currencies

through the use of a withdrawal once logged in.

Security

No cryptographic private keys are held on the Site servers. Virtual Currencies

sent to cryptographic public keys displayed on the Site are immediately

forwarded to offline vaults.

The Company’s Use of the Personal Information Collected About You

The Company may use the Personal Information collected about You for a

variety of business purposes, including the following:

● For providing customer services to You;

● For identifying and suggesting products or services that might interest

You;

● For verifying Your identity and maintaining a record of Your

transactions and interactions with us;

● For processing any transaction as applicable;

● For making internal business decisions about current and future

service offerings;

● For creating, modifying, improving, enhancing, removing, or fixing our

Services and their performance;

● For providing You customized user experiences, including personalized

services offerings;

● For protecting our rights, interests, safety and property and that of our

customers, service providers, and other third parties and affiliates;

● The Company may use third-party vendors, subcontractors, network

advertisers, and other businesses to deliver various services to You on

the Company’s behalf. These providers may be supplied with or have

access to Your information, including Your non-personally identifiable

information (such as Your IP address and Your UDID) for the purposes

of performing the functions for which the Company has engaged them.

Provided that such providers have access to your personally identifiable

information, they are bound by a confidentiality obligation; and

● The Company may disclose and use personally identifiable information

in the course of resolving disputes, problems troubleshoot,

enforcement of the Terms of Use or other legal rights (for example,

when necessary to protect the Company or a third party's intellectual

property or proprietary rights), or to alert You to changes in our policies

or Terms of Use that may affect Your use of the Site.

Use for Marketing

The Company may use the information the Company collects to contact You

with regards to our and/or third-party services, products, and offers, which

the Company believes might serve Your interests. In doing so, the Company

may contact You by telephone, postal mail, e-mail, or other methods after

receiving your consent to do so.

In addition, the Company uses Your UDID and information about third parties

websites that You have visited through the Services to report on the number

of users who click through the websites or who accessed third parties

websites as a result of certain ads.

Use for Advertising

Upon the use of the Site, You may be exposed to advertisements. The

Company may assist advertisers to better reach our users by providing

certain customer information, including geographic information, language

preferences, or demographic information obtained from other companies.

The information provided as aforementioned may then be used by

advertisers to determine which ads may be more relevant to You. However,

the Company does not share Personal Information outside of our corporate-

related entities for advertising purposes without Your consent.

Links to Other Content and Third Party Websites

The Company may make content or services from other websites available to

You through links located on the Site. These other sources are not subject to

this Privacy Policy, and the Company has no control over how such sources

may use the personal information collected on their websites. Similarly, the

websites You choose to access through the use of the Site are owned by third

parties and we have no control over what information is collected or used by

such third parties as a result of Your use of third parties’ websites. We

recommend that You review the privacy policy and users’ terms associated

with each of these third-party websites to determine their privacy policies. In

any event, the Company will not be held responsible for the privacy-related

practices, use of Your information by third parties, or the content of third

party providers.

Furthermore, the payment processing services on the Site are provided by

third party payment processing providers, which may also provide fraud

management services and are disclosed of Your information once You

execute a Transaction. Such a payment processing service provider may

further collect additional information and documents from You for the

assessment of fraud risks. You should make yourself aware of any third-party

such third-party provider. The Company will not be held liable or responsible

for such third party practices and use of Your information.

Use for any Fraud Prevention

We may use Personal Information for investigations or for prevention of

fraud, AML, CTF, for Consumer Protection or network abuse and to protect

our users.

When We Share Information Collected About You

Except as detailed herein this Policy, the Company does not sell, license, or

otherwise provide Your Personal Information to unaffiliated third parties,

which are outside our corporate family without Your consent. The Company

may, however, disclose Your information to unaffiliated third-parties with

Your Consent obtained in either writing, online, through "click-through"

agreements and downloads, upon acceptance by You of the terms of

disclosures for certain Services, in writing (including without limitations by

chat or email) or orally, when You interact with our customer service

representatives.

Access to Third-Parties

Should You be required to choose a username or password while using the

Site or the Company’s products, You should refrain from sharing Your login

information with any third party. If You provide any of Your login information

to third parties, such third parties will gain access to all Your Personal

Information upon accessing Your Account with Your login information.

Furthermore, sharing Your login information with third parties is forbidden

under AML restrictions, CTF, Fraud, and identity theft provisions.

For Legal Process & Protection

The Company may disclose Personal Information, and other information

about You, or Your communications, where disclosure of such information is

reasonably necessary: (i) In order to satisfy any applicable law, regulation,

legal process or enforceable governmental request, including AML, CTF, Anti-

Fraud and Consumer Protection requirements; or (ii) In order to enforce or

apply agreements, or initiate, render, bill, and collect for services and

products (including to collection agencies in order to obtain payment for our

products and services); (iii) In order to protect our rights or interests, property

or safety or that of others; or (iv) In order to assist with claims, disputes, or

litigation – in court or elsewhere; or (v) In order to facilitate or verify the

appropriate calculation of taxes, fees, or other obligations or in an emergency

situation.

How We Store and Protect Personal Information

The Company uses a variety of physical, electronic, and procedural safeguards

to protect Personal Information from unauthorized access, use, or disclosure

while it is under our control. Unfortunately, no data transmission over the

internet can be guaranteed to be completely secure. As a result, although the

Company utilizes security measures, the Company may not guarantee You

against the loss, misuse, or alteration of Personal Information under our

control, and You provide Personal Information to us at Your own risk. You

should always take care of how You handle and disclose your Personal

Information and should avoid sending Personal Information through insecure

email, social networks, or other internet channels.

Retention and Disposal. The Company retains information for as long as we

have a business or tax need or as required under the applicable laws,

regulations, and/or government orders from time to time. Following

termination of the Account, the Company endeavors to erase and discard

Your data subject to the limitations and requirements under the applicable

laws and regulations.

Transfer to other countries

For the purpose of providing You with the Services, the Company transfers

Your information to different countries outside Your country where the

Company has facilities. By using the Site, You consent to the transfer of Your

information outside of Your country.

The Company may amend this Privacy Policy at any time. You should always

refer to this Policy posted on the Site for the latest information and the

effective date of any changes. By continuing to access or use the Services

after those changes become effective, you agree to be bound by the revised

Your rights

You have the right to access Your Personal Information and to require the

correction, updating, and blocking of inaccurate and/or incorrect data by

sending an email to the Company at [support email] or where possible, you

can do these actions in Your account profile page Yourself.

Upon your written request, the Company will inform You of the Personal

Information relating to You that the Company holds and the use and general

disclosure of Your Personal Information. The Company will also give You a

copy of the Personal Information the Company has retained. There may be a

minimal charge for providing you additional copies of Your Personal

Information to cover administrative costs.

You may also request the deletion or destruction of both the Account and

Personal Information by sending an email to us at [support email]. The

Company will action your request immediately, except, where this is not

consistent with its legal and regulatory obligations.

You have the right to ask us to transfer your Personal Information to another

controller of your choice by sending an email to us at [support email].

You have the right to withdraw the consent if you previously gave the

consent to the processing of your Personal Information, for example, for

marketing purposes by sending an email to us at [support email].

If we process your Personal Information in our legitimate interests you have

the right to object against it by sending an email to us at [support email]. If

there are no legal grounds to refuse it, we shall stop processing your Personal

Information for such purposes.

You have the right to request to temporarily stop the processing of your

Personal Information (when contenting its accuracy or when you think we

process it unlawfully).

You can learn more and complete your requests to exercise data rights by

contacting the Company at [support email].

If you believe that the Company violates your data rights, you have the right

to file a complaint with your national data protection authority.

To ensure the confidentiality, integrity, and availability of Your information to

Yourself, the Company may request You to confirm Your identity by providing

identification documentation and/or other methods prior to assisting you in

exercising any of Your rights.

If You refuse to prove your identity, the Company may decline to take actions

in respect of Your data, save restricting processing, until the Company can

ensure that such actions are the true wish of the data subject.

In the carrying out of the Services, the Company may use automated

processing and profiling to reduce the risks of fraud, money laundering, and

abuse of our services. Through this automated processing, the Company

carries out an analysis of Your identification, transactional, and behavioral

patterns.

The Company may not able to provide you with some or all the Services if you

do not wish this automated processing to be carried out. If You feel that this

processing might be detrimental to You, we can provide You with further

information about this automated processing by contacting us at [support

email].

Contact

The Company has appointed a data protection manager who is responsible

for overseeing questions in relation to this Privacy Policy. If you have any

questions about this Privacy Policy, including any requests to exercise your

legal rights, please contact the data privacy manager using the details set out

below.

Email address: support@finaura.eu.