Xaru Financial Solutions P.C., registered in General Commercial Registry (G.E.MI.) under number 167396603000 in accordance with the Greek law, located at the following address: 146 Sigrou Avenue, Athens, Greece, 17671 (hereinafter referred to as the "Company").

"Service" shall mean an interactive software package owned by the Company, including a website on the Internet athttps://exchange.xaru.io, intended for use by the User in accordance with the terms and conditions and rules posted thereon.

"User" shall mean an individual located in Europe, which has registered with the Service as the User and has accepted all the necessary documents to use the Service.

All expressions "we", "us" or "our" used hereinafter shall be construed as belonging to the Company and the Service.

METHOD OF OBTAINING PERSONAL DATA INFORMATION

The SERVICE shall receive personal data in one of the following ways:

- directly from the subject of personal data, when they are provided by such subject when contacting the Company through the "Contact Us" / "Support" form, or using other methods of data transmission.

- indirectly through the User of the Service if the subject of personal data is an employee or an authorised representative of one of our Users. Our User shall be fully liable for the legality of the transfer of information to us by the subject of personal data. In case of such method of obtaining personal data, we do not own, control or use any data provided to us by our Users.

PERSONAL IDENTIFIABLE INFORMATION

"Personal Identifiable Information" (or "PII") refers to contact information that directly or indirectly identifies you in particular, such as your name, phone number, country and city, company name, email address, IP address, or any other information that can be easily linked to you. We do not collect confidential information such as GPS information, race or ethnic origin, political opinion, religious or philosophical beliefs, or trade union membership, genetic or biometric data, health or sex life of an individual.

PASSIVELY OR AUTOMATICALLY COLLECTED DATA

Passively or automatically collected data (hereinafter referred to as the "Usage Data") is collected when using the Service. We, our affiliates and our marketing partners may use automated means to collect various types of information about you, your computer or other device used to access the Service, its services, associated web applications and downloadable software. This information is based on your use of the Service and may be obtained when you visit other websites. The Usage Data is inherently anonymous, but may indirectly be used to identify a person.

PURPOSE OF DATA USE

We need to know your PII that you provide to us in order for us to respond to your request sent from the "Contact Us" page and other means of feedback. In addition, we need to know your PII in order to send you emails and for other purposes. In particular, for the exchange of PII, as described in the "Information Exchange and Disclosure" section below. We also need to know the PII of Users who are authorised representatives of our Users in order to regulate the use of our services by the Users.

We need to know your PII data (hereinafter referred to as "PIID") in order for us to identify and verify our Users in full in order to exclude malpractice, fraud, and to increase the Users’ confidence in the Service.

METHODS OF DATA COLLECTION AND USE

The Service collects the PII directly from you when you send us a message by entering your email in the "Contact Us" / "Support" form on our web pages or using other means of feedback, as well as when registering with the Service.

When you register with the Service, you give consent to the collection of your PII, as well as consent to sending you emails, including the use of the PII for promotional emails aimed at promoting our products or products similar to our products or services. You may withdraw your consent at any time by unsubscribing from our emails using the opt-out link provided in each email.

The Service uses third-party applications to add information to the data we collect from you. This data improvement allows us to provide a more useful, personalised communication.

We collect usage data as described above and cookie data. For more information and how to configure your browser to refuse to accept cookies, see the "Cookie Data and Opt-Out Procedures" section below.

We may use the Usage Data unrestrictedly for any purpose, including without limitation to customise remarketing (excluding the European Union), offers and content shown to you based on your visits and/or use of this site or services, as well as for performance analysis of advertisements, offers and content, and your interactions with them.

Subject to your right to opt-out, we may combine the Usage Data with the PII we collect and use the combined data to create profiles about you solely to improve our products and services and improve your user experience on our service.

To collect PIID information, the Service engages its authorised Partner, the Verification Service.

The Verification Service directly collects, processes and stores the PIID obtained during the verification process, in compliance with all the rules of the applicable laws of the European Union.

The Service does not participate in the process of collecting and processing the PIID, does not store nor use this information, receiving all the necessary verification data from the Verification Service.

DATA PROCESSING

The user acknowledges and agrees that the company may engage third-party data processors to process personal data on its behalf. The company will ensure that any such third-party data processors comply with the requirements of the GDPR and provide sufficient guarantees regarding the implementation of appropriate technical and organizational measures to protect the rights and freedoms of the data subjects. The company will only disclose or transfer personal data to third parties if necessary and in compliance with applicable data protection laws. The user understands and acknowledges that their personal data may be transferred to, and stored at, destinations outside the European Economic Area (EEA). In such cases, the company will take all necessary steps to ensure that adequate safeguards are in place to protect the personal data as required by the GDPR.

DATA STORAGE PERIOD

We will not keep your PII longer than required. This means that we will retain your PII for any period of time described below (or a combination of both):

• as long as it is required by law,
• as long as we have a good reason to keep it,
• until you ask us to stop using it, or
• as long as our User, for whom you are an authorised representative, remains a User.

When we remove your PII from our databases, it will remain in our backup system until it is cleared.

The Verification Service keeps your PIID in full compliance with the above rules of this section.

INFORMATION EXCHANGE AND DISCLOSURE

General Disclosure Policy. We may share and disclose your PII as described below. We may disclose and share the Usage Data without restriction, including in the situations described below.

Please contact us at[email protected]to opt out of sharing your information with third parties.

Affiliates. We may share your PII and Usage Data with any affiliates we may have, including our subsidiaries. Affiliates are companies legally controlling or controlled by us.

Subprocessors. We may share your PII and Usage Data with our trusted Subprocessors who assist us in setting up and maintaining the Service. For example, we may contract with third parties to process payments, host servers, ensure security, and provide services for the creation, support, optimisation, analytics, reporting and maintenance, and software development. In addition, our Subprocessors will only be granted access to your information if it is really necessary to provide the services specified in the contracts.

Successors. If we sell or otherwise transfer part or all of our business or assets to another organisation (for example, in case of acquisition, merger, bankruptcy, or liquidation), we may transfer your PII and Usage Data. In this case, we shall ensure that the buyer or transferee agrees to the obligations set out in this Policy.

Compulsory obligations. Except for the exchange of your information as described in this “Information Exchange and Disclosure” clause, the Service will not disclose information about you or the content of your messages, unless it is forced to do so due to circumstances, in one of the following cases, when it is required:

• (a) to comply with the law;
• (b) in the event of a lawsuit;
• (c) in order to comply with these terms and conditions;
• (d) in case of complaints about content that infringes the rights of third parties;
• (e) to enforce the terms and conditions for the acquisition of the Service or its merger with another company, or
• (f) to protect the interests of the Service in relation to its property, including but not limited to its intellectual property.

Authorised Resellers. We may share your PII and Usage Data with our authorised partners so that they can provide Users with temporary and useful information about our products and services. Our partners shall comply with the terms of this Service Policy, but may not share your information with any other third parties.

Marketing partners for remarketing purposes. We may share your information with third party services for remarketing purposes. A description of remarketing and opt-out rights can be found in the "Remarketing" section below.

COOKIE DATA AND OPT-OUT PROCEDURES

The Service may automatically collect the Usage Data using cookies. Cookies are small text files that the Service website uses to recognise repeated user visits, to ensure constant user access to the site and to facilitate the use of the site. Cookies also allow the site to track user behaviour and to collect information about site usage that will improve the content.

You may refuse to accept cookies by enabling the settings in your browser that allow refusing to save the cookies. However, if you choose this option, you may not be able to access certain parts of our site. If you do not choose to disable cookies in your browser settings, our system will provide cookies when you log in to our site.

REMARKETING

The Service uses third party tracking cookies and pixels, including the Google Ads tracking code.

This means that we will continue to serve you advertisements over the Internet, in particular on the Google Content Network. Third party vendors, including Google, will place cookies on web browsers to serve ads based on your past visits to our website. This allows us to make special offers and continue to sell services to those who have expressed an interest in them. We do not use remarketing for users from any country outside of Europe.

You may opt out of Google cookies use by visitingAd Settings Manager.

ANALYTICS

We may connect third party analytics services to monitor and analyse web traffic and track user behaviour on this site.

Google Analytics (Google). Google Analytics is a web analysis service provided by Google Inc. ("Google"). Google uses the data collected to track and study how users use this site, to prepare reports on site activity and to share this data with other Google services.

Collected information: Cookies and Usage Data. Go to the Privacy Policy athttps://policies.google.com/?hl=ru. You may opt out of Google Analytics using the Google browser settings available athttps://tools.google.com/dlpage/gaoptout

YOUR RIGHTS

You may contact us to find out if we are processing your PII. If so, you may ask us what kind of PII we keep and what we do with your data. If desired, we may provide you (or, if technically possible, a third party designated by you) with a copy of any PII we keep about you for a statutory fee (not exceeding the cost of reproducing these documents).

We may deny a request to access or correct PII in circumstances required by law. And, if so, we will provide you with a written notice of the reasons for the refusal.

In addition, you may:

• request access and correct or delete your PII,
• request a restriction on the processing of your PII, and
• withdraw your consent at any time.

If you send us a request to exercise any of the above rights, if necessary, we will send a notice of your request to other authorised parties that store and process your PII.

NOTICE OF BREACH OF CONFIDENTIALITY TO EUROPEAN UNION USERS

The Company shall resolve complaints about the rules for the storage or use of your personal information. European Union (EU) residents having inquiries or complaints regarding this Policy shall first contact the Company at[email protected].

You may complain about unresolved privacy disputes to the EU data protection authorities. Contact information for EU data protection authorities can be found athttp://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

The Company will cooperate with the relevant EU data protection authorities in the investigation and resolution of the complaints filed.

As a last resort, complaints about the violation of the safety of personal information that remain unresolved after passing through these and other channels shall go through compulsory internal arbitration before the European Commission creates a special Commission for the Protection of Personal Data.

LINKS TO OTHER SITES

The Service may contain links to other websites. If you click on any links on the Service or agree to any promotional offers, your click-through information and any information you provide during registration or service provision will be transferred to those sites. We shall not be liable in any way for the policies and practices of those sites. You need to be careful and review all privacy policies posted on any of these sites before providing information to them.

ONLINE CHILDREN POLICY

We are committed to maintaining the security of personal information on the Internet for all visitors to our site, including children. This site is a public site. In accordance with the Children’s Online Privacy Protection Act (COPPA), we will not knowingly collect or sell any information about children under the age of 13. If you are a parent or guardian who discovers that your child under the age of 13 has submitted their personal information without your permission or consent, we will remove the information from our list at your request. To request the deletion of information about your child, please contact our website at the “Support” link below and be sure to include in the message the same login information that was sent by your child.

DO NOT TRACK REQUESTS

Some web browsers include a Do Not Track feature that signals the sites you visit that you do not want your online activity to be tracked. Each browser sends Do Not Track signals to the website differently, interfering with the site’s normal handling of each request. To avoid errors between browsers and the website, we do not currently respond to Do Not Track signals. As the technology and interaction between the browser and the website improves, we will review the ability to respond to Do Not Track signals and will make changes to our policy.

AMENDMENTS TO THE POLICY

We reserve the right to modify, alter, or update this Privacy Policy at any time. We may make changes as necessary to ensure our policy remains compliant with laws and regulations or to incorporate changes in our data collection and use practices. We encourage all users to review our Privacy Policy periodically to stay informed about how we are protecting the personal information we collect.

Your continued use of our services after the revised Policy has become effective indicates that you have read, understood, and agreed to the current version of this Policy. Any significant changes to the policy will be communicated via an update on our website or through other appropriate means of communication.

INQUIRIES AND COMPLAINTS

If you have any questions or complaints about the use of your PII, please let us know. You can contact us at any time through the "Support" section below, and we will do our best to solve the problem and answer you.

CONTACT US

Xaru Financial Solutions P.C., registered in General Commercial Registry (G.E.MI.) under number 167396603000, located at the following address: 146 Sigrou Avenue, Athens, Greece, 17671[email protected]

If you have any questions, please contact us at[email protected]

Effective date – 01.06.2023