Privacy Policy

We strive to uphold the privacy of individuals and abide by all applicable laws and principles of British Virgin Islands.

The purpose of this privacy policy is to inform users of the Adrastea and any associated applications or websites, as to the information we collect, what we do with this information, how your information is protected, and how we process your personal information.

Amalthaea Inc (The “Platform” or “Adrastea”) refers to an ecosystem comprising the website adrastea.fi, any mobile or desktop applications, system of smart contracts, and other applications, products and platforms within the ecosystem, that are developed to offer the Adrastea Services as defined in the Terms and Conditions.

By using our Platform, you consent to the policy and our information administration practices. We may provide additional disclosures in relation to this policy, which will apply supplementary to this policy. These disclosures may expand on information administration practices or provide further clarification for specific practices. If you disagree with or are not comfortable with any aspect of our policy, you should immediately cease accessing and the use of our Platform and our Services.

Changes to the Privacy Policy

We reserve the right to alter and/or modify this policy at any time. Please review this policy periodically in case of any changes. If any significant or substantive amendments are made, we will notify you by email.

Who Does this Privacy Policy Apply To?

This policy applies to users (e.g., individuals, merchants, and legal entities) who use and access our Platform and Services, including.

What Personal Information Do We Collect?

We only collect information that is vital to the provision of our Services. The information that we may collect includes, but is not limited to:

1. Identification Information

Full name, date of birth, age, nationality, gender, signature, phone number, home address, email, utility bills, income statements, passport number, driver’s license details, national identity card details, photograph identification cards, a photographic image of you, social media profile.

2. Financial Information

Transaction history, trading data, payment card numbers, bank account information, credit history information from credit bureaus.

3. Personal Information

Internet protocol (IP) address used to connect your computer to the Internet, login, e-mail address, password and location of your device or computer, criminal record, ethnic origin.

4. Automatically collected information

Device information (including but not limited to, IP address, device ID, device model, network type, OS version, time zone settings, battery status, screen resolution, etc; device event information, (such as crash reports and system activity details); your browsing behaviour while using our Platform and/or Services.

5. User Data

User account details, username, passwords, phone number, purchase history, records of any interactions with our Platform’s specialists, customer service, or support teams (including emails, chat logs, or phone call transcripts), digital wallet and digital asset trading data, frequency and times of Platform usage, and other details necessary for account management.

6. Other Information

Information about your activity and your behaviour, occupation, hobbies, trading experience, interests, preferences, for marketing and advertising purposes.

Why Do We Collect This Information?

1. To Create a Better Experience for Our Users

The collection of data will allow us update and create new services that will better meet our user’s needs. We endeavour to create a more personalised experience for our users.

2. To Protect Our Users

The collection of transaction information will allow us to identify any suspicious activity that may lead to fraud or loss of funds. This may include enhancing security, combating spam and malware devices, and identifying and combating botting programs. As the crypto space is ever changing, we need to combat new risks affiliated with that. Devoid of your personal information, it will be difficult for us to ensure the security of our service.

3. To Comply with Regulatory Requirements

Our Services may be subject to regulations that require us to collect your personal information, which will be used to maintain compliance with Know Your Customer, Anti Money Laundering and Counter Terrorist Financing Regulations, as well as any other regulations that are legislated in the future, whether national or international. Some of the information that is required to be collected pursuant to these regulations include personal identification information, personal usage information, financial information, and employment information.

4. To Enforce our Terms in Our User Agreement

It is important for us to regulate our Services and users relating to the prevention and mitigation any potentially prohibited activities, enforcing our agreements with third parties, and violations of our user agreement or terms and conditions. For these purposes, it is essential for us to collect user data. If we are unable to process user information for these reasons, the consequence is the termination of your access or use of our Platform and Services, as we cannot perform our Services in accordance with our terms.

5. Maintain your Registration as a User

This will allow you to access your account safely and securely whenever and wherever you are.

6. Ensure Quality Control

We store user information for quality control and staff training, to ensure we provide users with accurate information.

7. Marketing Activities

We may send you marketing or promotional offers to inform you of Adrastea’s or our affiliates’ events, to deliver targeted marketing, and to provide you with promotional offers based on your communication preferences. We use information relating to your usage of Adrastea and contact information to provide a better marketing experience.

Who Will We Share Your Information With?

Information that we collect may or may not be used or disclosed to:

• individuals, entities, organisations, as part of Adrastea providing trading services to users and includes, but is not limited to, experts, tribunals, law firms, enforcement agencies, and other associated professionals;

• persons the user has expressly authorised or consented;

• our associated commercial and business partners, which include, but are not limited to, professional advisors, commercial organisations, and business agents;

• comply with legal obligations or requirements;

• develop business and commercial relationships;

• respond to any enquiries where necessary; and

• all other matters, services, engagements, business developments, and commercial enterprises to the maximum extent permitted by law;

• Third-party program restriction providers, fraud prevention vendors and anti-cheating detection providers to block cheating tools and unauthorized programs, and provide a safe and fair trading environment;

• real-time voice transmission platform providers to provide voice chat services;

• Identity verification service providers in order to provide identity

verification services;

• online survey service providers in order to improve Adrastea’s

Services;

• marketing platforms and providers of analytics services relating to trading behaviour, in order to tailor the Services and conduct marketing activities. We may share your information in situations where it is necessary to comply with a legal obligation or a legitimate request for data access. It may also be shared during a merger or acquisition, with our affiliated entities for the purposes outlined in this Policy, or when you have explicitly given your consent or provided instructions.

How Is Your Information

Protected?

We consider our user privacy to be of great importance. That is why we have implemented multiple security measures to ensure that user data is secure, free from unauthorised access, alteration, disclosure, and destruction.

For example, we implement the following security measures:

• Security procedures within our offices;

• IT security procedures including password protection, site monitoring, firewalls; and

• Mandatory confidentiality guidelines for all staff within the business.

However, despite the measures we have in place, data protection is never completely secure. We cannot guarantee the security of your personal information.

Do we use cookies?

Cookies are small files which a platform uses to identify you when you come back to the site and to store details about your use of the site.

Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies, but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our Platform.

Adrastea and our authorised third parties, may use cookies, and/or other tools to store and sometimes track information, such as analysing website traffic to help us provide a better website visitor experience. We may also collect certain information such as browser type, operating system, IP address, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

In addition, cookies may be used to serve relevant ads to website visitors through third party services. These ads may appear on this website or other websites you visit.

Our goal is to ensure a trading environment that is both secure and equitable for every player. By accessing our Platform and Services, you acknowledge that we or third parties may employ cookies and similar technologies, or gather information about your device or machine, to prevent fraud, enhance security, and authenticate your identity. Additionally, we may utilize alternative anti-cheat measures in conjunction with our services.

Obtaining Information

Through Third Party Sources

We will occasionally obtain information about you through third party. Information will only be obtained as required permitted by applicable law. Examples of this include public databases, credit bureaus, resellers and channel partners, and social media platforms.

Automatically Collected Data

We receive and store certain types of data whenever you interact with Our services. Data collected automatically includes any category listed under personal usage information.

Why We Share Personal Information with Other Parties

We will never sell or rent your personal information. We will only share your information in the following circumstances:

• We share your information with third party identity verification services to prevent fraud. We share this information to confirm your identity with relevant public records to prevent fraud. These third-party services will store your information; however, they will only use this information for purposes of identity verification.

• We may share your information with affiliated service providers. These affiliated services providers may include debt collection service agents, marketing firms, and technology services. All affiliated service providers are contracted to solely use this information for purposes that affiliate with us.

• We will share your information with financial institutions which we have partnered with to process payments.

• We may share your information with companies or entities that we purchase or merge with. The new company or entity will uphold this policy.

• We may share your information with law enforcement officials or other entities when required to do so under applicable law.

• We may share your information with law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our terms or any other applicable policies.

How We Protect and Store

Personal Information

We may hold sensitive information in our facilities or service providers located worldwide. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.

We cannot guarantee that loss, misuse, unauthorised acquisition, or alteration of your data will not occur. Please note that the user plays a critical role in ensuring their own personal information.

Furthermore, we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us at the email address, mailing address or telephone number listed at the end of this Privacy Policy.

Personal Information Rights

You have a right to access, correct, object, and delete personal information that we hold about you. You can also require any inaccurate personal information to be corrected or deleted.

You can object to our use of your personal information at any time, and you may have the right to object to our processing of some or all your personal information (and require them to be deleted) in some other circumstances. If you wish to exercise any of these rights, please contact us as set out below.

How You Can Access or Change Personal Information International Data Transfers Our Policy Concerning Children Links and Third-Party Services

You are entitled to review, correct, or amend your personal information, or to delete that information where it is inaccurate. You may do this by contacting us.

If your account is closed or terminated, we will keep your account information in our database for at least seven years for regulatory purposes.

This ensures that those who are attempting to avoid fraud cannot achieve this by simply closing or terminating their account. When your account is closed or terminated, your information will not be used by us for any further purposes, including being shared to third parties.

Our operations span across the globe, and in order to deliver our Services, we may transfer your data to countries and regions beyond your current location. Should your personal information be transferred, stored, or processed by us, we will make reasonable efforts to protect the privacy of your personal information. Specific regions within certain countries where data processing takes place are outlined in further detail below.

Without obtaining verifiable parental consent or as permitted by law, we do not intentionally gather, utilize, or disclose any information about children (the age threshold may vary depending on the country of residence). If you are a parent or guardian and you believe that your child has shared information with us, you can reach out to us and request the deletion of your child's information from our system.

By clicking on a link to a third-party website, which includes advertisements, you will be directed away from our Site to the chosen website. As we lack control over the actions of third parties, we are not accountable for how they utilize your personal information, and we cannot guarantee that they will maintain the same privacy and security measures as we do. We recommend that you thoroughly review the privacy policies of any other service provider you engage with. Prior to sharing any personal information, it is advisable to consult the privacy policy of any linked third-party website associated with our Services.

General Data Protection

Regulations (GDPR)

The General Data Protection Regulations (GDPR) apply to organisations who process data in the EU as well as organisations that offer goods or services to or monitors the behaviour of the people inside the EU. The GDPR applies to all information that can directly or indirectly influence an individual.

We have prepared ourselves for the GDPR by providing information as to when our data is deleted, a transparent overview of our use of the personal information it has collected, and detailed how you can exercise your privacy rights.

European Union Residents have the following rights:

1. Right to Withdraw

You will have the right to withdraw your consent to process your personal information.

2. Right to Request

You have a right to request that we provide you with a copy of your personal information held by us. This information will be provided without undue delay subject to some fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others.

3. Right to Update

You have the right to request that we update any of your personal information that you believe incorrect or inaccurate.

4. Right to Erasure

You have the right to request erasure of your personal information that:

(a) is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (b) was collected in relation to processing that you previously consented, but later withdraw such consent; or (c) was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.

5. Right to Data Portability

If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.

A “controller” Is a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of your personal information.

6. Right to Restriction of or Processing

You have the right to restrict or object to us processing your Jurisdiction - Specific.

Supplemental Terms

In the event of a conflict between the terms of this Privacy Policy and the Jurisdiction-Specific Supplemental Terms which pertain to the jurisdiction from which you access Adrastea, the relevant jurisdictions' Supplemental Terms will prevail.

1. EEA, Switzerland, and the UK

If you are an EEA (European Economic Area), Switzerland, or a UK residents, you may have additional rights:

International Data Transfer: If we move your data outside the European Economic Area (EEA) to a country that does not have a recognized level of data protection as determined by the European Commission, we make every effort to implement appropriate measures to protect your personal data in accordance with relevant data protection and privacy laws. These measures may include using data transfer agreements that incorporate the latest standard contractual clauses, which are pre-approved by the European Commission and offer sufficient safeguards for personal data. If you wish to obtain a copy of these measures, please contact us as specified in this Policy. In other cases, we transfer personal data with your consent, to fulfill a contractual obligation, or based on a legitimate interest that does not override your rights and freedoms.

Your Privacy Rights: You have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.

2. California

If you reside in California you may have additional rights, as listed here:

Privacy Notice for California Residents: This Privacy Notice (“Notice”) for California residents provided pursuant to the California Consumer Privacy Act (“CCPA”) supplements the Privacy Policy of Adrastea and its affiliates (“we”, or “us”) and provides additional information on how your personal information is collected, used, disclosed and processed online or offline. Unless otherwise specified, all terms used within this Notice shall carry the same meaning as they are defined in our Privacy Policy(“Policy”). This Notice and the Policy together constitutes our “California Privacy Policy”.

We will collect the following categories of information that may directly or indirectly identify or describe you or your device, or information that may be reasonably capable of being associated with or reasonably linked to you or your device (“personal information”). We have collected these same categories of personal information from consumers over the past 12 months. Please refer to our Policy concerning the categories of sources from which this personal information is collected.

Also, we may provide service providers or third parties with certain personal information to provide or improve our services. Within the past 12 months, we disclosed or shared each of the following categories of personal information with the following categories of third parties. We do not sell personal information to third parties as that term is defined by the CCPA.

You may exercise the following rights at any point in time in Contact Us If you have an enquiry regarding our Privacy Policy surrounding personal information, you can contact us at [email protected].

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