This statement of privacy (“Privacy Policy”) describes how BitLipa (“we”, “us”, “our”, the “Company”) or the BitLipa app (the “App”) collects, uses, and disclose your information. This Privacy Policy is incorporated into and subject to our Terms of Use (“Terms of Use”).

By using the App, you give us consent to collect and process your information listed below.If you disclose any personal information relating to other people to us, you represent thatyou have the authority to do so and to permit us to use the information in accordance withthis Privacy Policy

We collect your information listed under clause 5.2 to provide you a safe, efficient, andcustomized experience. Some of the information may identify you personally.

We use personal information to provide the services you request. To the extent we use your personal information to advertise to you, we will provide you the ability to opt-out of such uses. We retain any information as necessary to contact you and provide support as permitted by law.

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We may share personal information with our affiliates. We do not disclose your personalinformation to third parties for their marketing and advertising purposes without yourexplicit consent.We may disclose personal information if required to do so by law or in the good faithbelief that such disclosure is reasonably necessary to respond to subpoenas, court orders,or other legal process. We may disclose personal information to law enforcement offices,third party rights owners, or others in the good faith belief that such disclosure isreasonably necessary to: enforce our Terms of Use or Privacy Policy; respond to claimsthat an advertisement, posting or other content violates the rights of a third party; orprotect the rights, property or personal safety of our users or the general public.We and our affiliates will share some or all of your personal information with anotherbusiness entity should we (or our assets) plan to merge with, or be acquired by thatbusiness entity, or re-organization, amalgamation, restructuring of business. Should such atransaction occur that other business entity (or the new combined entity) will be requiredto follow this Privacy Policy with respect to your personal information.

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Personal information is any information which can identify an individual or throughwhich an individual’s identity can be deduced, and which is disclosed to us or which wecreate within the context of our relationship with the individual.

We collect several types of information from and about users of the App, includinginformation:

• by which you may be personally identified, such as name, postal address, e-mailaddress, telephone number, social security number, passport number, date ofbirth, taxpayer or government identification number, or any other identifier bywhich you may be contacted online or offline ("personal information");
• that is about you but individually does not identify you, such as gender, salary,and job;
• about your crypto-wallet address, bank account and routing numbers and/orcredit card numbers that you link to your account on the App; and/or
• about your internet connection, and app usage details.

• Directly from you when you provide it to us through sales and supplyagreements or otherwise;
• Discussions with our employees, contractors and service providers;
• Automatically as you navigate through the site. Information collectedautomatically may include usage details, IP addresses, device informationincluding, but not limited to, identifier, device name and type, operatingsystem, location, mobile network information, and information collectedthrough cookies, web beacons, and other tracking technologies.
• From third parties; for example, credit bureaus, identity verificationservices, and our business partners.

In serving the needs of the Company and its employees, contractors and customers, it isimportant that the Company have accurate information. The Company may collect personalinformation in order to:

• Establish your identity;
• Understand your needs for, and determine your suitability for, productsand services;
• Provide services to you and process payments for your account;
• Inform you of new products and services;
• Establish and maintain an employment or contractor relationship;
• Adhere to legal requirements.

The Company may use Personal Information in order to:

• To present the App and its contents to you;
• Administer and maintain the relationship;
• Administer and maintain benefits;
• Comply with legal, regulatory and other obligations;
• To provide you with notices about your dashboard and account;
• Resolve disputes, collect fees and troubleshoot issues and tickets;
• For any other purposes with your consent;
• Carry out our business operations.

We may disclose aggregated personal information about our users and information thatdoes not identify any individual without restriction. We may disclose information asdescribed in this privacy policy:

• Administer and maintain the employment/contractor relationship;
• To employees, contractors, service providers and other parties we use tosupport our business - and who will always be bound by contractualobligations to keep personal information confidential and use it only for thepurposes for which we disclose it to them;
• Make hiring decisions;
• To our subsidiaries and affiliates;
• To fulfil the purpose for which you provide it;
• Enable employees/contractors to access client/customer facilities or that ofthe Company (i.e. security clearances);
• To comply with any court order, law, or legal process - including, but notlimited to, responding to any government or regulatory request.

Safeguards, security systems and processes are in place to protect your information againstunauthorized access, disclosure, use, or modification whether on-site or off-site.The safety and security of your information also depends on you. Where we have givenyou (or where you have chosen) a password for access to certain parts of the App, you areresponsible for keeping this password confidential. We ask you not to share your passwordwith anyone.

The company( and/ or its affiliates/subsidiaries) shall retain your information for aminimum of seven (7) years or for as long as necessary for the purposes for which it hasbeen collected - and to comply with any legal obligations. Your personal information willbe destroyed once it is no longer needed by us and once all requirements at law havebeen met.

You have the following rights, which can be exercised by contacting us at support@bitlipa.com

You have the right to access your personal data in our use at any time and ask us toprovide you with a copy of your personal data in case the right to obtain the copy doesnot adversely affect the rights and freedoms of others. You are also entitled to receiveinformation regarding data processing objectives, categories of personal data collected,recipients or categories of recipients to whom the personal data have been or will bedisclosed, source of the personal data and retention periods.

You may always correct your data on your account or request us to rectify or update anyof your personal data that is inaccurate.

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

• is no longer necessary in relation to the purposes for which it was collectedor otherwise processed;
• was collected in relation to processing that you previously consented, but laterthe consent was withdrawn;
• there is no longer legal ground for processing;
• was collected in relation to processing activities to which you objected, andthere are no overriding legitimate grounds for our processing; ord. the personal data has been unlawfully processed.

If we have made your personal data public and are obliged to erase the personal data,we will, taking into account of available technology and the cost of implementation, takereasonable steps to inform other parties that are processing your personal data that youhave requested the erasure of any links to, or copy or replication of your personal data.The above is subject to limitations by relevant data protection laws.

Where the processing of your personal data is based on consent or legitimate interests, you
may object, at any time, to the processing of your personal data as permitted by
applicable law. We can continue to process your personal data based on legitimate
interests if it is necessary for the defense of legal claims, or for any other exceptions
permitted by applicable law.

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If we process your personal data based on a contract with you or based on your consent
and the processing is carried out by automated means, you may request to receive your
personal data in a structured, commonly used and machine-readable format to transmit
the data to another “controller” or have us transfer your personal data 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 data.

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You have the right to restrict processing your personal data where one of the following applies:

1. you contest the accuracy of your personal data that we processed. In such instances, we will restrict processing during the period necessary for us to verify the accuracy of your personal data;
2. the processing is unlawful and you oppose to the erasure of your personal data and request the restriction of its use instead;
3. we no longer need your personal data for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims; or
4. you have objected to processing of your personal data and the verification is pending to determine whether our legitimate grounds override yours.

With the exception of storing, your restricted personal data shall only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest.

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If you feel that your personal data has been processed in a way that does not comply with the applicable laws of the countries where BitLipa operates, you have a specific right to lodge a complaint with a supervisory authority. If you wish to raise a complaint on how we have handled your personal data, you can contact us and we will investigate the matter. We hope that we can address any of your concerns.

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Where requests from you are manifestly unfounded or excessive, in particular because of
their repetitive character, we may either:

• charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or
• refuse to act on the request.

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When we transfer personal data outside of the jurisdictions where we operate, we ensure an adequate level of protection for the rights of data subjects based on the adequacy of the receiving country’s data protection laws or contractual obligations placed on the recipient of the data.

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Personal Data Security Breach shall mean:

• the loss or misuse (by any means) of any subscriber’s Personal Data;

the inadvertent, unauthorized and/or unlawful processing, destruction,
disclosure, corruption, modification, sale or rental of any subscriber’s Personal Data; or

• any other act or omission that compromises the security, confidentiality, or integrity
  of a subscriber’s personal data.

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We agree and warrant that we will promptly notify you by email if we become aware of a
breach of security leading to the accidental or unlawful destruction, loss, alteration,
unauthorized disclosure of, or access to your personal data arising from any act or
omission by us or our sub-processors. Such notice shall summarize in reasonable detail
the impact of the personal data security breach.

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We will cooperate reasonably with you regarding such personal data breach. You will keep
any such received information confidential, unless disclosure of such is obligatory under any
applicable legislation.

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If ownership of all or substantially all of our business changes, or we undertake a corporate
reorganization (including a merger or consolidation), you expressly consent to BitLipa
transferring your information to the new owner or successor entity so that we can continue
providing our services. If required, BitLipa will notify the applicable data protection agency in
each jurisdiction of such a transfer in accordance with the notification procedures under
applicable data protection laws.

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We may send you Service and administrative emails and messages. We may also contact you to inform you about changes in our Services, our Service offering, and important Service related notices, such as security and fraud notices. These emails and messages are considered part of the Services and you may not opt-out of them. In addition, we sometimes send emails about new product features or other news about BitLipa. By subscribing to our services, you consent to us sending messages for marketing purposes. You can opt out of these at any time by contacting us at support@bitlipa.com

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The App and services are not intended for minors and we do not knowingly collect personal information from minors. If you are under the age of 18, do not use or provide any information on the App or on or through our services. If we learn that we have collected personal information from a minor, we will delete it. If you believe we might have any personal information from or about a minor, please contact us at support@bitlipa.com

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‍Links to Other Sites‍

The App may contain links to other sites that may collect personally identifiable information about you. We are not responsible for the privacy practices or the content of those linked sites.‍

Security Precautions

The App has stringent security measures in place to protect the loss, misuse, and alteration of the information under our control. Once your information is in our possession, we adhere to strict security guidelines, protecting it against unauthorized access.

Choice/Opt-Out

We provide all users with the opportunity to opt-out of receiving non-essential (promotional, marketing-related) communications from us or on behalf of our partners.

Advertisements

We may use third-party advertising companies to serve ads on the App. These companies may use information (not including your name, address, email address, or telephone number) about your use of this App and other apps in order to provide advertisements about goods and services of interest to you.‍

Questions?

To ask questions or comments or comments about this privacy policy and our practices, contact us at support@bitlipa.com

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