21e8, SL. Privacy Policy

21e8, SL. (“21e8”)

21e8, SL., Edifici Cornella I, Carrer Pau Casals 11, Despatx 4 Porta 1, AD500, Andorra la Vella

Email: support@21e8.tech

Last Updated: May 12, 2023

ACCEPTANCE OF THE PRIVACY POLICY

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of Your information when You use the Service. This Privacy Policy informs You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

INTERPRETATION AND DEFINITIONS

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to 21e8, SL.

• Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

• Account means a unique account created for You to access our Service or parts of our Service.

• Website refers to 21e8.tech

• Service refers to proprietary systems and methods for automating cryptocurrency point-of-sale payments through mobile and other applications, the Website, and any and all other services the Company currently offers or will offer in the future.

• Country refers to: Andorra

• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

• Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

• Personal Data is any information that relates to an identified or identifiable individual.

• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

• Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.

• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

COLLECTING AND USING YOUR PERSONAL DATA

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Usage Data
• Date of Birth
• Social Security Number
• Copy of Government Identification or Passport
• Financial Information such as bank account information like account/routing number, debit/credit card number, and more
• Employment information

Usage Data

• Usage Data is collected automatically when using the Service.
• Usage Data may include information such as:
• Online identifiers such as Your Device's Internet Protocol address (e.g. IP address)
• Browser type
• Browser version
• The pages of our Service that You visit
• The time and date of Your visit
• The time spent on those pages
• Unique device identifiers and other diagnostic data
• Device Information such as hardware, operating system
• Geolocation Data

When You access the Service by or through a mobile device We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service.

You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including monitoring the usage of our Service.

• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

• To manage Your requests: To attend and manage Your requests to Us.

• Optimize and enhance our services: We use your Personal Information to understand how our products and Services are being used to help us improve our Services and develop new products.

• To Comply with legal and regulatory requirements.

• To Detect and prevent fraud.

• To Provide you with customer support

• Other business purposes: We may use your information for additional purposes if that purpose is disclosed to you before we collect the information or if we obtain your consent.

We may share your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers so that they can provide us with services, including identity verification, fraud detection and prevention, security threat detection, payment processing, customer support, data analytics, Information Technology, advertising, marketing, data processing, network infrastructure, storage, transaction monitoring.

• For Business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.

• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

• With Business Partners: We may share Your information with Our business partners to offer You certain products, services or promotions.

• Professional Advisors. We may share your Personal Information with our professional advisors, including legal, accounting, or other consulting services for purposes of audits or to comply with our legal obligations.

• With other users: If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users may be able to view descriptions of Your activity, communicate with You and view Your profile.

• Law Enforcement: Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods. Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice to You that Your Personal Data may be transferred due to a business transaction and that You may become subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation

• Protect and defend the rights or property of the Company

• Prevent or investigate possible wrongdoing in connection with the Service and/or Your use of the Service

• Protect the personal safety of Users of the Service or the public

• Protect against legal liability

Security of Your Personal Data

We work hard to protect 21e8 and you from unauthorized access to or unauthorized alteration, disclosure, or destruction of Personal Information we collect and store. Measures we take include encryption of the 21e8 website communications with SSL; required two-factor authentication for all sessions; PIN codes; periodic review of our Personal Information collection, storage, and processing practices; and restricted access to your Personal Information on a need-to-know basis for our employees, contractors and agents who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

How You Can Access or Change Your Personal Data

The Company understands that you may want to change, access or delete your Personal Data. You may do so by contacting us via email at support@21e8.tech. To protect your privacy and security, we will verify your identity before granting access or making changes to your Personal Data. Any request to access your Personal Data will be answered in less than thirty (30) days.

What Are Your Privacy Rights

As explained above, we collect Personal Information in various ways depending upon your use of our Site. We process Personal Information on the following legal bases: (1) with your consent; (2) as necessary to perform our agreements; and (3) as necessary for our legitimate interests in providing services where those interests do not override your fundamental rights and freedom related to data privacy.

Personal Information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates, partners, or service providers maintain facilities.

If you are a resident of the European Union, European Economic Area, Channel Islands or Switzerland, you are entitled to the following rights. Please note, in order to verify your identity, we may require you to provide us with Personal Information prior to accessing any records containing information about you.

The Right to Access: You have the right to obtain information about our processing of personal data and a copy of your personal data that we store.

The Right to Rectify your Data: You have the right to request that we update your personal data if it is inaccurate or incomplete. The Right to Request Data Erasure: You have the right to have your Personal Information erased from our files if the data is no longer necessary for the purpose for which it was collected, you withdraw consent and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.

The Right to Restrict or Object to Our Processing: You have the right to restrict or object to our processing if we are processing your data based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using your data for direct marketing (including profiling); or processing your data for purposes of scientific or historical research and statistics.

The Right to Lodge a Complaint: You have the right to lodge a complaint about our data collection and processing actions with your data protection authority. Contact details for data protection authorities can be found on this website.

For California CCPA if you would like to opt out of Third Party Data Tracking, please email us at support@21e8.tech. We respond to do-not-track signals and/or other mechanisms that allow consumers to exercise choice regarding the collection of their PII over time and across third-party websites or online services as soon as commercially reasonable, and usually by email, telephone or other electronic communication. Third parties we work with may collect personal information about You when using our Service operator's website or service when the collection is over time and across different websites or services.

Data Protection Officer

We have appointed a Data Protection Officer (DPO) 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 DPO using the details set out below. Personal Data Management

According to the Privacy Policy, you agree to share your personal data with our Service. However, you still have the right to update, transfer or delete it from us.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices/data protection practices of any third party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Age Requirement

Persons under the age of 18 are not eligible to use any Services.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By visiting this page on our website: https://21e8.tech/contact