PRIVACY POLICY

This privacy policy (the "Privacy Policy") sets out the different areas where user´s privacy is concerned and outlines how EXAFIN LTD., a company incorporated under the laws of British Virgin Islands (the “Company” or “Exactly”) recollects and uses personal data of users (“Users”) for the use of its Platform (as defined in our terms and conditions). Furthermore, this Privacy Policy explains the way the Company processes, stores and protects user data and information.

The purpose of our Platform is primarily to enable registered users to carry out certain transactions involving digital assets, including but not limited to digital loans and credit products (“Digital Assets Services”).

Exafin’s approach to Users´ privacy is to ensure that all the necessary steps are taken to protect the privacy of its Users.

Please read this carefully as this Privacy Policy is legally binding when you use the Platform.

As used in this Privacy Policy, "we", "us" or "our" refers to the Company. You can contact us with any request relating to this Privacy Policy via the contact details provided below.

1. DATA PROCESSING IN CONNECTION WITH THE PLATFORM

1.1 Collect of Information

We collect information about you when you: (i) operate and/or upload information while using our Platform; and/or (ii ) Contact us either through our Platform or through other direct means of electronic communication (including but not limited to our Discord and/or Telegram channel and our Twitter).

1.2 Information that we collect

We get information about you in a range of ways:

• Information You Give Us. Information we collect directly from you from your interaction with our Platform and the Digital Assets Services, includes:
  • Some information of the transactions you made within the Platform (including but not limited to financial information);
  • Your Wallet address that will be published in the blockchain and the smart contract.
  • Your geographical region (if applicable);
  • Feedback and correspondence, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with Digital Asset Services, receive customer support or otherwise correspond with us;
  • Usage information, such as information about how you use our Platform and you interact with us;
  • Marketing information, such as your preferences for receiving marketing communications and details about how you engage with them.

• Information Automatically Collected. We may automatically record certain information about how you use our Platform and the Digital Assets Services (we refer to this information as “Log Data”). Log Data may include information such as a user’s Internet Protocol (IP) address, device and browser type, operating system, your location; time, date and duration of your visit to our Platform, previous visits to our Platform, the features of our Platform you browsed and the time spent on those features, the frequency with which you use the Platform, search terms, the links on our Platform that you clicked on or used, and other statistics. We use this information to administer our Platform and the Digital Asset Services and we analyze (and may engage third parties to analyze) this information to improve and enhance our Platform and Digital Asset Services by expanding its features and functionality and tailoring it to our Users’ needs and preferences.

1.3 Use of your personal data

We use Personal Data about you in connection with the following purposes:

• To provide the Digital Asset Services:
  • To provide and deliver the Digital Asset Services you may request, this includes administering your account with us, verifying and carrying out transactions and notifying you about changes to our Platform and services.
  • To send you information, including confirmations, technical notices, updates, security alerts, and support and administrative messages.
• Sites and Services improvements:
  • To ensure that content from our Platform and other online presences are presented in the most effective manner to you;
  • To administer our Platform, and other online presences, for internal business administration and operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and
  • As part of our efforts to keep our Platform safe and secure.
  • To optimize your user experience, this includes, operate, maintain, and improve our Platform and services.
  • To create reports, analysis, or similar services for the purposes of research or business intelligence to improve our Platform and services.

1.4 Use of Cookies and Similar Technologies

The Platform may use cookies in accordance with our “Cookies Policy” which you should look at https://exact.ly/cookies-policy. The Cookies Policy is part of this Privacy Policy and will be considered accepted with any use of our Platform.

If you would like information about how we may use cookies and similar devices, we recommend you consult the Cookies Policy.

1.5 Your inquiries

For any queries you may contact us by e-mail to the following e-mail address: [email protected] We use the data that you provide in an email to us, which you may give voluntarily, only in order to answer your contact question or to reply to your email in the best possible manner.

2. YOUR RIGHTS

You have the following rights regarding your personal data:

1. Access: to obtain free information about your personal data processed at any time and a copy of this information.
2. Correct: to obtain from us, without undue delay, the rectification of inaccurate personal data concerning you.
3. Delete: to obtain from us the erasure of personal data concerning you as soon as possible.
4. Restrict: in certain circumstances, to obtain from the Company restriction of processing your personal data.
5. Object: to object, on grounds relating to your particular situation, at any time, to the processing of personal data concerning you.
6. Withdraw: to withdraw your consent to processing your personal data at any time.
7. Opt-out: stop sending you direct marketing communications which you have previously consented to receive. We may continue to send you Service-related and other non-marketing communications.

For purposes of exercising such rights please contact by email to [email protected] We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

If you would like to submit a complaint about our use of your personal data or response to your requests regarding your personal data, you may contact us at [email protected] or submit a complaint to the data protection regulator in your jurisdiction.

3. INTERNATIONAL TRANSFERS

We are entitled to transfer your personal data to third parties abroad for the purposes of the data processing. The data that we collect from you may be transferred to, and stored at, a destination outside the British Virgin Islands, including without limitation the United States of America or any other country that may not offer an adequate level of data protection. The transfer shall be made on the basis of a previous agreement with the third-party processor. Users hereby consent to the international transfer of data as provided above.

4. DATA SECURITY

We use appropriate technical and organizational security measures to protect your personal data. Our security measures are continuously being improved in line with technical developments.

Please note that any data transmission on the Internet (e.g. communication by e-mail) is generally not secure and we accept no liability for data transmitted to us via the Internet.

Unfortunately, absolute protection is not technically possible. This information does not apply to the websites of third parties and the corresponding links given on the Platform. We assume no responsibility and liability for these.

5. DURATION OF DATA PROCESSING

We retain your personal data only for as long as is necessary for the purposes for which we process the information as set out in this Privacy Policy. Records can be held on a variety of media (physical or electronic) and formats.

Retention periods are determined based on the type of record, the nature of the record and activity and the legal or regulatory requirements that apply to those records. However, we may retain your personal data for a longer period of time where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person or where we have a legitimate interest to do so.

6. SHARING YOUR PERSONAL DATA

We may pass your information to our related entities, affiliates, administration centers, third party service providers, agents, subcontractors and other associated organizations for the purposes of completing tasks and providing our services to you.

When we use any other third party service providers, we will disclose only the personal data that is necessary to deliver the service required and we will ensure that they keep your information secure and not to use it for their own purposes.

In addition, we may transfer your personal data to a third party as part of a sale of some, or all, of our business and assets or as part of any business restructuring or reorganization, or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation. However, we will take steps to ensure that your privacy rights continue to be protected.

7. AMENDMENTS TO THIS POLICY

We may amend this Privacy Policy at any time by posting the amended version on the Platform including the effective date of the amended version. The current version of the Privacy Policy, as published on the Platform, is applicable.

8. CONTACT

Please contact us with questions, comments, or concerns regarding our Privacy Policy as well as with any requests at [email protected]