Privacy Notice

The term “Personal Data” describes information that can be associated with a specific person and can identify that person. Personal Data does not include information that has been aggregated or anonymized. Any reference to “Personal Data” in this Privacy Notice includes without limitation “Personal Data” as defined by the Data Protection Act 2018.

A Personal Data controller is a person or organisation who controls the collection, holding, processing or use of Personal Data, including a person or organisation who instructs another person or organisation to collect, hold, process, use, transfer or disclose Personal Data on their behalf.

The types of Personal Data that we may collect from you or through third parties will depend on our interactions with you and may include:

• Financial information such as your wallet addresses;
• Transaction information such as the wallet addresses of senders and recipients of Digital Assets, activities on the Sidiora Platform, your inquiries and our responses;
• Usage Data which can include your IP address, your country of origin, the features of the browser or operating system utilised by you, how you use the Sidiora Platform, among other identifiers;
• Other personal data or commercial and/or identification information that we, in our sole discretion, may deem necessary to comply with applicable anti-money laundering laws and regulations.

We may also collect Personal Data about you from third parties and other sources such as publicly available sources of information.

Unless specified otherwise, all Personal Data requested by us is mandatory and failure to provide this Personal Data may make it impossible for you to access or use the Sidiora Platform.

When you visit the Sidiora Platform, we may automatically collect certain information about your device, including information about your web browser, IP address and/or domain name, IMEI or other device information, your login information, browser type and version, timezone setting, browser plug-in types and versions, operating systems and platforms, location information, and cookies installed on your device. Additionally, as you browse the Site, we may collect information about the individual web pages or services that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site.

We use cookies (small, often encrypted, text files that are stored on your computer or mobile device) and similar technologies (“Cookies”) to provide you with certain functions on our Site and help collect data.

How We Use Cookies

We use Cookies to track how you use the Sidiora Platform by providing usage statistics. Cookies are also used to deliver our information and allow account authentication based upon your browsing history and previous visits to the Site.

For the avoidance of doubt, we do not combine or link data or information gathered from Cookies with third party data for targeted advertising or advertising measurement purposes or sharing data collected about a particular end-user or device with a data broker.

Types of Cookies

• Strictly Necessary: These Cookies are necessary for the Site to work properly. They include any essential authentication and authorisation Cookies.
• Functionality: These Cookies enable technical performance and allow us to remember the choices you make while browsing our Site, including sign-in and authentication Cookies.
• Performance/Analytical: These Cookies allow us to collect certain information about how you navigate the Site and services running on your device.
• Targeting: These Cookies are used to deliver relevant information related to our Site to an identified machine which has previously been used to visit our Site.

How to Control and Delete Cookies

Cookies can be controlled, blocked or restricted through your web browser settings. All Cookies are browser specific. Therefore, if you use multiple browsers or devices, you will need to manage your Cookie preferences across these environments. Please note that if you restrict, disable or block any or all Cookies, the Site may not operate properly.

We may use Google Analytics to help analyze how you use our Site. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated is used to create reports about the use of our Site. If you do not want your Site visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on.

We take appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data. The Personal Data processing is carried out using computers and/or IT enabled tools, following organisational procedures strictly related to the purposes indicated.

Legal basis of processing

We may process Personal Data relating to you if one of the following applies:

• You have given your consent for one or more specific purposes;
• Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;
• Processing is necessary for compliance with a legal obligation to which we are subject;
• Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us;
• Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

Data we collect about you is collected to:

• Provide the Site and Sidiora Platform and customer support you request;
• Process transactions and send notices about your transactions;
• Detect any malicious or fraudulent activity;
• Enable us to monitor and analyse your behaviour (“Analytics”);
• Beta test certain features or the Sidiora Platform;
• Contact you;
• Allow us to register you as a user and authenticate your credentials;
• Comply with legal obligations and respond to enforcement requests;
• Protect the rights and interests of Sidiora and its affiliates;
• Infrastructure monitoring and traffic optimisation.

We may share your Personal Data with our service providers and vendors to assist us in providing you with the Sidiora Platform. We do not share your Personal Data with third parties without your consent, except as described in this Privacy Notice or as otherwise required or permitted by applicable law.

We may share your Personal Data with third party companies and individuals that provide services on our behalf. These third parties may use your Personal Data only as directed or authorised by us and are prohibited from using or disclosing your information for any other purpose.

We may sell, transfer or otherwise share some or all of our business or assets, including your Personal Data, in connection with a business transaction such as a merger, consolidation, acquisition, reorganisation or sale of assets, or in the event of bankruptcy or dissolution.

We will retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

Once the retention period expires, Personal Data will be deleted (or, where permitted under applicable law, may be de-identified instead). Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period. However not all your Personal Data may be able to be deleted; see the “Blockchain Transactions” section below.

Your use of digital assets may be recorded on a public blockchain. Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems. As blockchains are decentralised or third-party networks which are not controlled or operated by us, we are not able to erase, modify, or alter personal data on such networks.

The Sidiora Platform may contain links to other websites, mobile applications, and other online services operated by third parties. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites and services you use.

The security of your Personal Data is important to us. We employ a number of administrative, technical, and physical safeguards designed to protect the Personal Data we collect. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of Personal Data transmitted to the Sidiora Platform. Any transmission of Personal Data is at your own risk.

Sidiora is a company with operations throughout the world. As a result, Personal Data may be transferred outside the country in which you reside. Any such transfer shall take place under applicable law and will be protected through international data transfer agreements where necessary. By using the Sidiora Platform you understand that your Personal Data may be processed in the United States and outside of the EEA and the UK.

Residents of the EEA and the UK are granted certain rights over their Personal Data, which include:

• The right to obtain confirmation of the Personal Data we process;
• The right to rectify inaccurate Personal Data that we process;
• The right to request erasure of your Personal Data, subject to exceptions provided under the law;
• The right to restrict certain processing of your Personal Data;
• The right to receive your Personal Data in a structured, commonly used and machine readable format;
• The right to object to the processing of your Personal Data, including the right to object to automated decision-making and profiling;
• The right to withdraw your consent where you have previously given it.

If you would like to exercise any of the rights listed above, or if you have questions regarding your Personal Data, please contact Support and provide (i) enough information to identify you and (ii) a description of what right you want to exercise. Any Personal Data we collect from you to verify your identity will be used solely for the purposes of verification.

If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may contact us or your local data protection authority.