English

STOCKITY PRIVACY POLICY

INTRODUCTION

This Privacy Policy sets forth how Verte Securities Limited ("Company," "We," "Us," or "Our") collects, uses, discloses, shares, and protects Your personal information (including any personal data) when You access and use the Stockity Trading Platform through the official website app.stockityweb.web.id (referred to herein as the "Website"), the Stockity Mobile Application, and/or any other services provided by Us. For the purposes of this Privacy Policy, all references to the Website and the Stockity Mobile Application are considered equivalent and interchangeable.

We respect your privacy and are committed to protecting the privacy of our users ("user" or "You"). This Privacy Policy outlines our practices with respect to collecting, using, and disclosing your information through your use of Our Website, Stockity Mobile Application, and other online platforms We use to provide Our services (collectively, "the Services").

This Privacy Policy constitutes an integral and legally binding part of the Stockity Client Agreement, and it applies to all users who register on the Website or use the Stockity Mobile Application, regardless of their geographical location. By registering for an Account, logging into the Website or the Stockity Mobile Application, or using any part of Our Services, You confirm that You have carefully read, understood, and fully accepted all the terms and conditions outlined in this Privacy Policy without reservation.

The data that You provide is collected and processed by Verte Securities Limited, a company incorporated and operating under the laws of the Republic of Vanuatu, under Company No. 700726, with its registered address located at Level 1, ICount House, Kumul Highway, Port Vila, Vanuatu, which is the data controller responsible for ensuring that your personal data is processed in accordance with applicable data protection legislation.

We are committed to maintaining the confidentiality, security, and integrity of all personal data that You entrust to Us. We implement all reasonable and necessary technical, organizational, and legal measures to protect Your information against unauthorized access, alteration, disclosure, or destruction.

We strongly encourage You to review this Privacy Policy thoroughly before using the Website, the Stockity Mobile Application, or any of Our Services. If You do not agree with any provision of this Privacy Policy, You should refrain from using the Stockity Trading Platform. However, by continuing to use the Website, the Stockity Mobile Application, or any of Our Services, You acknowledge and consent to the collection, use, and processing of Your data as described herein.

All terms used in this Privacy Policy shall be interpreted based on the definitions provided herein (where available). In the absence of a definition within this Privacy Policy, terms shall be construed in accordance with the definitions and provisions set forth in the Stockity Client Agreement.

1. PROVISION OF INFORMATION ABOUT YOU

1.1. User Registration and Provision of Personal Data: When creating an Account on the Website or accessing the Stockity Mobile Application, You will be prompted to provide an active and valid email address, which is necessary for the initial registration and communication related to the provision of Our Services. Following registration, You may, at Your own discretion, voluntarily supply additional personal details by completing Your profile within the Personal Account section of the Website or Stockity Mobile Application. These details may include Your first and last name, date of birth, gender, contact phone number, and country of residence. This information allows Us to personalize Your user experience, facilitate secure access to the Stockity Trading Platform, and ensure proper identification for both operational and legal compliance purposes.

1.2. Provision of Payment and Identification Data: In order to fund Your Account and access certain services on the Stockity Trading Platform, You will be required to provide specific payment-related information. These information elements include:

- Full legal name;

- Bank card number;

- Card expiration date;

- Card verification code (CVV/CVC);

- Issuing bank or financial institution details;

- Payment system type (e.g., Visa, MasterCard);

- Passport or national ID number;

- Date of birth;

- Residential address;

- Valid email address;

- Active phone number;

- Other data depending on the means of payment.

The information listed above is necessary both for the proper execution of financial operations and to ensure compliance with regulatory requirements, including but not limited to anti-fraud mechanisms, anti-money laundering (AML) obligations, and counter-terrorist financing (CTF) standards. These data must be complete, accurate, and verifiable.

When processing such payment operations, We may also share and verify the necessary payment data through Our authorized and trusted Payment System Providers, who act either as data processors or independent controllers depending on the specific operation. These providers may collect, process, and temporarily retain information associated with Your transaction in accordance with applicable legal requirements, contractual requirements, and applicable privacy standards. Upon explicit request from the payment provider, We may be legally obligated to supply additional information about You, including scanned copies of identity documents and Your contact details. Data retention is strictly limited to the duration necessary for processing the transaction, unless extended retention is required by law. All such partners are obligated to adhere to internationally recognized data protection frameworks and implement robust technical and organizational safeguards to ensure the security and confidentiality of Your personal and financial information.

1.3. Verification of Identity and Compliance with AML/CTF Requirements: To meet legal obligations related to anti-money laundering (AML), counter-terrorist financing (CTF), and Know Your Customer (KYC) requirements, We require You to complete a verification process. This process involves the mandatory submission of the following documents and data:

- A clear and legible photograph or scanned copy of a valid identity document (passport or national ID card);

- A photograph of the front and back sides of the payment card used for transactions and/or screenshot of Your e-wallet;

- A selfie of You holding the identity document and payment card in Your hands;

In certain cases, and where required by applicable law, You must also provide additional documentation, including but not limited to:

- A recent utility bill containing Your name and address;

- A reference letter from a licensed banking institution;

- A bank account statement showing Your name and transaction history;

- Official documents verifying the origin of Your funds or assets (such as an employment contract, property sale agreement, loan agreement, or inheritance documents);

- A secondary identity document (e.g., driver’s license or government-issued ID).

All information and documentation submitted for verification purposes must be authentic, up-to-date, and verifiable. The collection and processing of these data are strictly limited to what is necessary to fulfill Our legal obligations under applicable AML/CTF legislation, as well as to safeguard the integrity of the Stockity Trading Platform.

1.4. Collection of Activity Data and User Interactions: In the course of using the Stockity Trading Platform, We collect and retain various types of activity-related data that help Us operate, secure, and improve Our Services. These include, but are not limited to:

- Records of Your login attempts and session activity;

- Your registration date and account category;

- IP address history and device type used to access the Stockity Trading Platform;

- Your interface preferences, selected language, and time zone;

- Browser type and version;

- Frequency and nature of Your interactions within the Stockity Trading Platform, including trading activity and use of tools or services.

We also collect statistical and diagnostic information that includes:

- Error logs and performance data;

- Clickstream behavior and in-app interactions;

- Transactional and complaint history;

- Communication records with Our support team.

This information is used to maintain the functional stability of the Stockity Trading Platform, resolve technical issues, prevent unauthorized access or fraudulent behavior, enhance user experience, and comply with legal and regulatory obligations.

1.4.1 Additionally, if You participate in promotional campaigns or gift-based activities, You are required to provide Your full name, postal address, and phone number for the delivery of any prizes or rewards. We also reserve the right to send You promotional gifts or branded merchandise as part of Our marketing activities, loyalty programs, or user engagement strategies. In such cases, You will be required to provide the same set of data: Your full name, valid delivery address, and contact phone number. These data are used strictly for the purpose of accurate and timely delivery of the items and are processed in accordance with this Privacy Policy.

We may carry out the delivery of such gifts directly or through selected logistics providers. When applicable, only the minimum necessary personal data will be transferred to these partners to enable shipment. You acknowledge and consent to such limited disclosure as essential to the execution of marketing and customer retention activities.

1.4.2. We may invite You to complete voluntary surveys or service evaluations, which may request Your name and contact details for feedback purposes.

1.4.3. If You contact Our Support Service, You will be asked to supply Your full name and a valid email address to enable Our team to provide timely and accurate responses. All such communications may be recorded and stored for quality assurance, dispute resolution, and compliance purposes.

1.5. In line with standard industry practices, We use Cookies and similar tracking technologies to support the functionality and performance of the Website and Stockity Mobile Application. “Cookies” are small data files stored on Your device when You visit or interact with Our Services. These technologies allow Us to recognize Your device, remember Your preferences, and enhance Your overall experience on the Stockity Trading Platform.

Some Cookies are strictly necessary for the Website to function properly and are used without requiring Your prior consent. These include:

- Cookies necessary for the identification of the source from which You accessed the Website;

- Cookies used to maintain Your session identity during navigation;

- Cookies that preserve technical preferences, such as language and time zone.

1.5.1. As part of Our use of these technologies, We also collect and analyze Usage Data, including:

- IP address;

- Session identifiers;

- Device type and operating system;

- Browser type and version;

- Time zone and language settings;

- Timestamps of access;

- Referring URLs or sources that led You to Our Website.

This data is critical for ensuring a secure, stable, and personalized user experience, detecting anomalies, improving service responsiveness, and optimizing performance. If You choose to disable or restrict Cookies in Your browser settings, certain features of the Stockity Trading Platform may become inaccessible or function improperly.

2. LEGAL GROUNDS FOR PROCESSING YOUR INFORMATION

2.1. We collect and process Your personal data only when there is a valid legal basis for doing so, in full compliance with applicable data protection laws and regulations. The lawful bases on which We rely include the following:

- Agreement Performance: The processing is necessary for the conclusion and execution of agreements between You and Us, including but not limited to the Stockity Client Agreement, and for delivering Our Services to You as requested through Your registration or continued use of the Stockity Trading Platform.

- Consent: You have explicitly given Your informed consent to the collection and use of Your personal data. This consent is obtained during the registration process, including through the acceptance of the Stockity Client Agreement and this Privacy Policy.

- Legal Compliance: The processing is required for Us to comply with legal or regulatory obligations imposed by applicable law, including anti-money laundering (AML), counter-terrorist financing (CTF), tax, accounting, or financial regulations.

- Legitimate Interests: The processing is necessary for the pursuit of Our legitimate business interests, such as fraud prevention, Stockity Trading Platform optimization, service improvement, or internal reporting. In all such cases, We ensure that Your rights and freedoms are not overridden and that a fair balance is maintained between Our interests and Your data privacy.

2.2. Please note that if You choose not to provide certain essential personal data or withdraw previously granted consent where that is the sole legal basis for processing, We may be unable to deliver the requested services or maintain Your Personal Account functionality. We will inform You of any such implications at the relevant time.

3. RETENTION OF YOUR INFORMATION

3.1. We retain Your personal data only for as long as is strictly necessary to fulfill the purposes for which it was collected, as outlined in this Privacy Policy, including compliance with legal, regulatory, and agreement performance. The specific retention period may vary depending on the nature of the data, the context in which it was collected, and the applicable legal requirements.

Your personal data may be retained for the following reasons:

- To comply with obligations arising from applicable legislation and regulatory frameworks (e.g., anti-money laundering laws, financial reporting, tax law);

- To support the performance and enforcement of agreements entered into with You, including the Stockity Client Agreement;

- To resolve disputes, investigate incidents, or address user complaints;

- To maintain historical business and operational records, where legally permissible;

- To safeguard Our legitimate interests, including fraud prevention and security monitoring.

Once the data is no longer required for the purposes stated above, or if retention is no longer necessary under applicable laws, it will be securely deleted, anonymized, or otherwise disposed of in a manner consistent with recognized data protection standards.

If a statutory retention obligation exists or if the data is needed to assert, exercise, or defend legal claims, We will retain the data accordingly and restrict its processing to only those specific purposes.

4. PURPOSES OF PROCESSING YOUR INFORMATION

4.1. The personal data that We collect is used to ensure the proper operation of the Stockity Trading Platform, improve the quality of Our existing services, and develop new ones. The key purposes for which We process Your data include, but are not limited to, the following:

(i) Providing You with high-quality and secure services on the Stockity Trading Platform, which includes supporting uninterrupted technical functionality, monitoring system performance, identifying technical errors, and enhancing the stability and responsiveness of Our Services across all devices;

(ii) Improving the convenience and efficiency of the Stockity Trading Platform through the application of Cookies and similar technologies that track interface usage, device type, IP address, session data, and language preferences, thereby helping Us deliver content in a format and language most appropriate for Your region and device;

(iii) Storing and utilizing data collected from Your initial visit and each subsequent session on the Website to support the continuity of Your interaction with the Stockity Trading Platform, including remembering login credentials, preselected options, and personalized interface settings;

(iv) Using registration and identity verification data (such as Your first and last name, middle name if applicable, gender, date of birth, nationality, and contact information) to verify Your identity, maintain the accuracy of Your Personal Account, and ensure that the services We provide are tailored to Your needs and comply with applicable regulations;

(v) Ensuring legal and secure transactions by verifying the accuracy of financial documents You submit, checking consistency between registration information and payment instruments, and screening for fraudulent or unlawful activities in compliance with international standards and Our internal compliance procedures;

(vi) Facilitating deposits and other financial transactions by retaining non-sensitive data (excluding Your card number, expiration date, CVC/CVV code, or any confidential banking credentials), and using this data to streamline Your future interactions with the Stockity Trading Platform by autofilling previously provided payment details, where permitted and applicable;

(vii) Collecting and reviewing records of Your financial and operational activity on the Stockity Trading Platform, including transaction logs, IP addresses, access timestamps, and device/browser details, in order to ensure fund safety, enforce fraud detection mechanisms, and comply with anti-money laundering (AML) policies;

(viii) Sending system-generated notifications about important operational matters (such as maintenance windows, Stockity Trading Platform updates, or modifications to service features), and distributing personalized advertising and promotional content to You via email, SMS, phone calls, and other communication channels permitted by law. You retain full control over the receipt of such messages and may opt out of promotional communications at any time via Your Personal Account settings or by contacting Support;

(ix) Communicating with You regarding changes to the Website’s operation, updates to Our Services, amendments to this Privacy Policy or the Stockity Client Agreement, or the introduction of new regulatory obligations. These messages are considered essential communications and may not always be subject to opt-out;

(x) Delivering a personalized user experience by adapting the Website content and marketing campaigns based on Your activity, preferences, behavioral patterns, and device data in order to show You more relevant offers and improve Your satisfaction with Our Services;

(xi) Responding effectively to Your support requests, inquiries, or complaints by collecting, storing, and reviewing relevant communication logs and data to ensure proper documentation and timely resolution.

4.2. If We intend to use Your personal data for a purpose not explicitly described above, We will seek Your explicit and informed consent in advance. Moreover, where automated processing of personal data is performed, We guarantee that such processing does not result in any decisions that produce legal effects concerning You or similarly significantly affect You, unless this is done with appropriate safeguards in place.

5. DISCLOSURE OF YOUR INFORMATION

5.1. We may disclose Your personal data only when necessary and strictly in accordance with this Privacy Policy and applicable legal frameworks. The disclosure of personal data may occur under the following circumstances:

- Business Transfers: If the Company is involved in any corporate transaction, including but not limited to a merger, acquisition, restructuring, or sale of assets, Your personal data may be disclosed or transferred to another entity as part of that transaction. In such cases, We will take reasonable steps to ensure that the acquiring party upholds data protection standards consistent with this Privacy Policy. Prior to such a transfer, You will be notified if Your data will become subject to a different privacy policy.

- Legal Obligations and Law Enforcement: We may disclose Your personal data where required to do so by applicable laws or in response to lawful requests by governmental authorities, courts, regulatory bodies, or law enforcement agencies. This includes fulfilling obligations imposed under anti-money laundering (AML), financial crime, or counter-terrorism financing (CTF) laws.

- Protection of Legal Interests and Safety: We may disclose personal data when such action is necessary, in Our reasonable judgment and in good faith, to:

(i) Comply with a legal obligation or enforce applicable laws or regulations;

(ii) Protect and defend the legal rights, property, or interests of the Company, Our users, or affiliates;

(iii) Prevent or investigate suspected violations of the Stockity Client Agreement or other unlawful conduct;

(iv) Protect the personal safety and interests of Our clients, employees, or the general public;

(v) Prevent legal liability or respond to claims raised against the Company.

5.2. We ensure that any third party receiving such data is legally bound to maintain confidentiality and process personal data in strict accordance with applicable privacy and data protection regulations.

6. TRANSFER OF YOUR INFORMATION

6.1. Given the international nature of Our operations and service infrastructure, Your personal data may be transferred to, stored in, and processed in jurisdictions other than the one in which You reside. These jurisdictions may not offer the same level of data protection as the laws in Your home country.

6.2. By accepting this Privacy Policy and submitting Your personal data through the Website or Stockity Mobile Application, You acknowledge and expressly agree to such cross-border transfers. These transfers are performed only where necessary for the execution of the Stockity Client Agreement, the fulfillment of Our Services, or as otherwise permitted under applicable law.

6.3. We take all necessary measures to ensure that any transfer of Your personal data outside of Your jurisdiction is carried out with an adequate level of protection. These measures may include:

- Entering into contractual agreements with recipients of Your data that incorporate standard data protection clauses approved by regulatory authorities;

- Ensuring that third-party service providers (including cloud storage providers and customer support systems) operate in accordance with robust data protection frameworks;

- Requiring that such third parties maintain appropriate technical and organizational safeguards to protect Your data from unauthorized access, use, or disclosure.

6.4. No transfer of Your personal data will take place unless We are satisfied that adequate controls are in place to ensure the security, confidentiality, and lawful treatment of Your information, in accordance with the standards outlined in this Privacy Policy and applicable legislation.

7. YOUR RIGHTS REGARDING YOUR INFORMATION

7.1. We recognize Your rights under applicable data protection legislation and are committed to enabling You to exercise these rights in a transparent and effective manner. Subject to legal and contractual limitations, You have the following principal rights with respect to Your personal data:

- Right of Access: You have the right to request confirmation as to whether or not We process Your personal data, and, where that is the case, to receive a copy of the personal data We hold about You, along with relevant information regarding the processing.

- Right to Rectification: You have the right to request the correction or completion of any inaccurate or incomplete personal data We maintain about You. In certain cases, We may need to verify the accuracy of the new information provided before making updates.

- Right to Erasure ("Right to be Forgotten"): You have the right to request the deletion of Your personal data when there is no longer a valid legal basis for Us to continue processing it. This right may be exercised under specific conditions outlined in applicable laws.

- Right to Restriction or Objection to Processing: You may request the restriction of processing of Your personal data or object to certain types of processing (e.g., direct marketing or profiling based on legitimate interests) under specific circumstances.

- Right to Withdraw Consent: Where We rely on Your consent as the legal basis for processing Your personal data, You have the right to withdraw that consent at any time. Please note that this does not affect the lawfulness of processing carried out before the withdrawal.

7.2. These rights are not absolute and may be subject to limitations under applicable laws and regulations, particularly those related to anti-money laundering (AML), know-your-customer (KYC), financial reporting, or other legal obligations We are bound by. In some situations, exercising certain rights (such as the right to erasure or restriction of processing) may result in Our inability to continue providing You with services or may require the termination of Our contractual relationship.

8. INFORMATION WE SHARE WITH THIRD PARTIES

8.1. We do not disclose or transfer Your personal data to any third party not affiliated with Your use of the Stockity Trading Platform unless such disclosure is necessary to fulfill Our contractual or legal obligations, provide You with Our services, or pursue Our legitimate business interests in accordance with this Privacy Policy.

8.2. Third parties with whom We share Your personal data do so strictly on Our behalf and only in accordance with Our documented instructions. These third parties are contractually bound to maintain the confidentiality and security of Your information and may include the following categories:

(i) A limited number of Our employees or employees of Our affiliated entities who require access to personal data to perform their duties;

(ii) Independent professional auditors for compliance or regulatory audit purposes;

(iii) Dispute resolution organizations or arbitrators handling Your legal claims or complaints;

(iv) Payment systems and financial institutions involved in processing Your transactions;

(v) Payment System Providers who assist with the execution of deposits, withdrawals, and other monetary operations;

(vi) Identity verification and KYC service providers to comply with AML/CTF requirements;

(vii) Infrastructure and IT service providers whose technology is essential for the functionality and reliability of the Stockity Trading Platform.

8.3. For identity and transaction verification, We engage Sum and Substance Limited (UK Registration No. 09688671). This provider receives personal data You submit during verification procedures. For further information, please consult SumSub's Privacy Policy: https://sumsub.com/privacy-notice/

8.4. We may also provide aggregated, anonymized, or statistical information to third-party analytics and marketing partners that does not directly identify You. These include:

(i) Google Analytics: a tool used to evaluate how users interact with the Stockity Trading Platform. This information helps improve performance and personalize advertising. More information: https://policies.google.com/privacy

(ii) Cloudflare: a network and security platform that processes and protects Your data during transmission and hosting. Data may be stored on servers located in the European Union and the United States. More information: https://www.cloudflare.com/privacypolicy/

(iii) Zendesk: a support service provider that processes communications with Our support team. When You initiate contact, the data You provide (such as Your name, email, and inquiry) is accessible to Zendesk. More information: https://www.zendesk.com/company/agreements-and-terms/privacy-policy/

8.5. For purposes of delivering promotional materials, rewards, and branded gifts (whether in the context of loyalty programs or one-time campaigns), We may share Your full name, delivery address, and phone number with authorized postal or courier service providers, as well as Our promotional partners strictly for the purpose of fulfilling the delivery.

8.6. In the event that the Company is involved in a merger, acquisition, or restructuring, Your personal data may be transferred to the new entity, provided that the receiving party undertakes to continue protecting Your data in a manner consistent with this Privacy Policy.

8.7. We may also transfer Your personal data to countries outside the European Economic Area. When such transfers occur, We ensure that adequate safeguards (such as contractual clauses and technical measures) are in place to guarantee a level of protection comparable to that provided within the EEA.

8.8. Finally, in exceptional circumstances, and only with Your prior express consent, We may share Your personal data with third parties not listed in this Privacy Policy for clearly defined purposes that will be explained at the time such consent is sought.

9. PROTECTING TECHNICAL AND PERSONAL INFORMATION

9.1. We apply a comprehensive set of administrative, technical, and organizational safeguards designed to protect Your personal data and all other information transmitted or stored through the Stockity Trading Platform. These security practices are aimed at maintaining data confidentiality, preventing unauthorized access, and ensuring the integrity of Our systems.

9.2. To safeguard the transfer of data between Your device and Our servers, We use Secure Sockets Layer (SSL) encryption technology. This ensures that all communications, including login credentials, financial transactions, and personal data submissions, are transmitted in an encrypted and secure format, protected from interception or tampering by third parties.

9.3. While We apply industry-standard technologies and practices to protect Your data, it is important to understand that no method of transmission over the Internet or electronic storage is completely secure. We therefore encourage You to exercise caution when sharing sensitive information online and to use strong, unique passwords to secure Your Account.

10. PASSWORDS AND ACCOUNT SECURITY

10.1. When creating an Account on the Stockity Trading Platform, You are required to provide a valid email address and create a strong, confidential password that will be used to access Your Account. This password is known only to You and is not visible to Us or accessible by Our systems in plain text.

10.2. For Your protection, We do not have the ability or right to modify Your password or email credentials. You are solely responsible for maintaining the confidentiality of Your login credentials and for all activities conducted through Your Account.

10.3. We strongly recommend that You:

- Use a unique, complex password that includes a mix of letters, numbers, and symbols;

- Avoid using the same password across multiple services;

- Change Your password regularly and immediately if You suspect any compromise.

10.4. In the event You detect or suspect any unauthorized use of Your Account, or notice any other suspicious activity (such as login attempts from unfamiliar locations or unexpected changes to Your profile), You must notify Our Support Service immediately. Timely reporting enables Us to take swift measures to secure Your Account and investigate any potential breach.

11. USE OF OUR SERVICES BY MINORS

11.1. Our services, including access to the Website, Stockity Mobile Application, and associated features of the Stockity Trading Platform, are intended exclusively for individuals who have reached the legal age of majority as defined by applicable law in their respective jurisdiction. We do not knowingly collect, process, or store personal data from individuals under the age legally required to enter into binding agreements or access financial platforms.

11.2. If We become aware or have reason to believe that a person who does not meet the minimum legal age requirement has attempted to register or provided personal data through any of Our services, We will take immediate steps to delete such information from Our systems and terminate the associated Account.

11.3. We strongly encourage parents and legal guardians to monitor the online activity of minors and to assist Us in enforcing this provision by promptly notifying Our support service if they suspect unauthorized access or registration by a minor.

11.4. By using Our Stockity Trading Platform, You represent and warrant that You are of legal age in accordance with the laws of Your jurisdiction and have full legal capacity to use the services provided by Us.

12. CHANGES TO THIS PRIVACY POLICY

12.1. We reserve the right to revise, update, or amend this Privacy Policy from time to time in order to reflect changes in applicable laws, regulations, our practices, or service enhancements. Any changes We make will never restrict or diminish Your legal rights under applicable data protection law.

12.2. Whenever We make material changes to this Privacy Policy, the revised version will be published on the Website and will indicate the date of the latest revision. Unless otherwise stated, the new version shall become effective immediately upon publication. We will also notify You via email or through other reasonable communication methods about significant amendments.

12.3. Your continued use of the Website, Stockity Mobile Application, or Our Services after changes to this Privacy Policy have become effective shall constitute Your acknowledgment and acceptance of the updated terms. If You do not accept the revised Privacy Policy, You must discontinue use of the Stockity Trading Platform and may close Your Account by withdrawing Your funds and contacting Our support service using the contact methods described in the Stockity Client Agreement.

12.4. In case of any discrepancy between the English version of this Privacy Policy and its translations into other languages, the English version shall prevail for purposes of interpretation and legal enforcement.

13. CONTACT INFORMATION

13.1. If You have questions, concerns, or requests related to the processing of Your personal data, or if You wish to exercise any of Your rights as described in this Privacy Policy, including withdrawing Your consent or verifying the data We hold about You, You may contact Our designated data protection team at the following email address: [email protected].

Effective October 21, 2025