February 2023 – Vs1

Hashrift Ltd

1. Definitions

As used herein, the following terms are defined as follows:

• “ Hashrift Ltd.’’, “We,” and “Us” refers to Hashrift Ltd

and its wholly owned subsidiaries (also referred to collectively as " Hashrift

Ltd" " Hashrift Ltd" "we," or "us").

• “Digital Asset” is a digital representation of value (also referred to as “cryptocurrency,”

“virtual currency,” “digital currency,” “crypto token,” “crypto asset,” or “digital

commodity”), such as bitcoin, XRP or ether, which is based on the cryptographic protocol

of a computer network that may be (i) centralized or decentralized, (ii) closed or open-

source, and (iii) used as a medium of exchange and/or store of value.

• “Hashrift Ltd Account” means a user-accessible account offered via

the Hashrift Ltd where Digital Assets are stored by Hashrift

Ltd Account

• “.com” or “. io” means Hashrift Ltd branded websites, applications,

services, or tools operated by Hashrift Ltd group companies.

2. IMPORTANT INFORMATION AND WHO WE ARE

2.1. WHO WE ARE

Hashrift Ltd, an entity existing under the laws of Marshall islands

, licensed by the Financial Supervision Commission, as a virtual currency

provider, having its registered address at Ajeltake Island Trust Company Complex, Ajeltake Road, \

Marshall islands, 96960 (“Hashrift Ltd”).

IO Solutions International Ltd respects and will protect the privacy of all users of the io-

convert platform. In order to provide you with more accurate and personalized services, io-

convert will use and disclose your personal information in accordance with this privacy

policy. Except as otherwise stated in this privacy policy, io-convert will not disclose or

provide any information to third party sources without prior consent from the user or as

required by law. By using any part of the io-convert platform, you have agreed to the

contents of this privacy policy.

Please read this carefully as this policy is legally binding when you use our io-convert as

defined below.

This Privacy Notice applies to any .com and. exchange or .io, as defined below, regardless

of how you access or use them, including through mobile devices.

We may amend this Privacy Notice at any time by posting the amended version on this site

including the effective date of the amended version. We will announce any material

changes to this Privacy Notice via email.

2.2. PROTECTION OF PERSONAL DATA

We are serious about guarding the privacy of your Personal Information and work hard to

protect IO Solutions International Ltd and you from unauthorized access to, or

unauthorized alteration, disclosure, or destruction of Personal Information we collect and

store. Measures we take include encryption with SSL; the availability of two-factor

authentication at your discretion, and periodic review of our Personal Information

collection, storage, and processing practices. We restrict access of your Personal

Information only to those IO Solutions International Ltd employees, affiliates, and

subcontractors who have a legitimate business need for accessing such information. We

continuously educate and train our employees about the importance of confidentiality and

privacy of customer information. We maintain physical, electronic, and procedural

safeguards that comply with the relevant laws and regulations to protect your Personal

Information from unauthorized access.

Unfortunately, despite best practices and technical safeguards, 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 your Personal Data during

transmission, and any acts of transmission are at your own risk.

2.3. PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how the Company collects and processes

your personal data through your use of this website, including any data you may provide through

this website when you sign up to any of the services offered by the Company.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair

processing notice we may provide on specific occasions when we are collecting or processing

personal data about you so that you are fully aware of how and why we are using your data. This

privacy notice supplements the other notices and is not intended to override them.

This Privacy Policy is based on data protections rules and principles deriving from applicable law

such as the Processing of Personal Data (Protection of Individuals) Law of 2007, the Regulation

of Electronic Communications and Postal Services Law of 2004 and the General Data Protection

Regulation (GDPR) (EU) 2016/679 effected as from the 25th of May 2018.

2.4. CONTROLLER

We are acting as the controller and responsible for your personal data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in

relation to this privacy notice. If you have any questions about this privacy notice, including any

requests to exercise your legal rights, please contact us at support@hashrift.com

You have the right to make a complaint at any time to the Commission for Personal Data Protection

(CPDP). We would, however, appreciate the chance to deal with your concerns before you

approach the Commission so please contact us in the first instance.

2.5. CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF

CHANGES

It is important that the personal data we hold about you is accurate and current. Please keep us

informed if your personal data changes during your relationship with us.

2.6. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those

links or enabling those connections may allow third parties to collect or share data about you. We

do not control these third-party websites and are not responsible for their privacy statements. When

you leave our website, we encourage you to read the privacy notice of every website you visit.

3. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which

that person can be identified. It does not include data where the identity has been removed

(anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have

grouped together follows:

3.1. Application information

Personal information Client provides to the Company in its application form, such as name,

address, date of birth, email address, income and income source etc. in order to facilitate the

evaluation of Client’s application. The information provides is also used for the purposes of

communicating with the Clients.

3.2. Transaction information

Information about the anticipated volume and value of Client’s transactions with us and income

information provided in order to enable the construction of Client’s economic profile.

3.3. Verification information

Information necessary to verify Client’s identity, such as an identification card, passport or driver’s

license. This also includes background information the Company receives about the Client from

public records or from other entities not affiliated with the Company.

We also collect, use and share Aggregated Data such as statistical or demographic data for any

purpose. Aggregated Data may be derived from your personal data but is not considered personal

data in law as this data does not directly or indirectly reveal your identity. For example, we may

aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly

or indirectly identify you, we treat the combined data as personal data which will be used in

accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about

your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political

opinions, trade union membership, information about your health and genetic and biometric data).

Nor do we collect any information about criminal convictions and offences.

3.4. IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you

and you fail to provide that data when requested, we may not be able to perform the contract we

have or are trying to enter into with you. In this case, we may have to cancel the contractual

relationship you have with us but we will notify you if this is the case at the time.

3.5. Data Control

IO Solutions International Ltd is responsible for the collection, use, disclosure, retention

and protection of your personal information in accordance with our privacy standards, this

Privacy Notice, as well as any applicable local laws. IO Solutions International Ltd uses

encryption to protect your information and store decryption keys in separate systems. Data

controllers process and retain your personal information on our servers where our data

centers are located.

Where we have a legal obligation to do so, we have appointed GDPR Officer to be

responsible for IO Solutions International Ltd privacy program. If you have any questions

about how we protect or use your Personal Information, you can contact our GDPR Officer

by email at support@hashrift.com

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

3.6. Direct interactions. You may give us your personal data by filling in forms or by

corresponding with us by post, phone, email or otherwise. This includes personal data you

provide when you:

3.6.1. apply for our products or services;

3.6.2. create an account on our website;

3.6.3. subscribe to our service or publications;

3.6.4. request marketing to be sent to you;

3.6.5. enter a competition, promotion or survey; or

3.6.6. give us some feedback.

3.7. Automated technologies or interactions. As you interact with our website, we may

automatically collect Technical Data about your equipment, browsing actions and

patterns. We collect this personal data by using cookies, server logs and other similar

technologies. We may also receive Technical Data about you if you visit other websites

employing our cookies.

3.8. Third parties or publicly available sources. We may receive personal data about you

from various third parties and public sources such as Technical Data from analytics

providers such as Google based outside the EU;

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your

personal data in the following circumstances:

A. Where we need to perform the contract we are about to enter into or have entered into with

you.

B. Where it is necessary for our legitimate interests (or those of a third party) and your interests

and fundamental rights do not override those interests.

C. Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other

than in relation to sending third party direct marketing communications to you via email or

text message. You have the right to withdraw consent to marketing at any time by contacting

us at the following email: support@hashrift.com

4.1. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal

data, and which of the legal bases we rely on to do so. We have also identified what our legitimate

interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the

specific purpose for which we are using your data. Please Contact us at support@io-convert.com

if you need details about the specific legal ground we are relying on to process your personal data

where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing

including basis of legitimate interest

To register you as a new client

(a) Identity

(b) Contact details

(d) Financial Profile

(e) Economic Profile

Performance of a contract with you

To process and deliver your

order including:

(a) Manage payments, fees

(a) Identity

(b) Contact details

(a) Performance of a contract with you

(b) Necessary for our legitimate

interests (to recover debts due to us)

Purpose/Activity

Type of data

Lawful basis for processing

including basis of legitimate interest

and charges

(b) Collect and recover money

owed to us

document

(d) Financial Profile

(e) Economic Profile

(f) Transaction

(g) Marketing and

Communications

To manage our relationship

with you which will include:

(a) Notifying you about

changes to our terms or

(b) Asking you to leave a

review or take a survey

(a) Identity

(b) Contact details

document

(d) Financial Profile

(e) Economic Profile

(f) Transaction

(g) Marketing and

Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal

obligation

interests (to keep our records updated

and to study how customers use our

products/services)

To administer and protect our

business and this website

(including troubleshooting,

data analysis, testing, system

maintenance, support,

reporting and hosting of data)

(a) Identity

(b) Contact details

(a) Necessary for our legitimate

interests (for running our business,

provision of administration and IT

services, network security, to prevent

fraud and in the context of a business

reorganization or group restructuring

exercise)

(b) Necessary to comply with a legal

obligation

To deliver relevant website

content and advertisements to

you and measure or

understand the effectiveness

of the advertising we serve to

you

(a) Identity

(a) Contact details

(b) Profile

(d) Marketing and

Communications

(e) Technical

Necessary for our legitimate interests

(to study how clients use our

products/services, to develop them, to

grow our business and to inform our

marketing strategy)

To use data analytics to

improve our website,

products/services, marketing,

clients’ relationships and

experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests

(to define types of clients for our

products and services, to keep our

website updated and relevant, to

develop our business and to inform our

Purpose/Activity

Type of data

Lawful basis for processing

including basis of legitimate interest

marketing strategy)

To make suggestions and

recommendations to you about

goods or services that may be

of interest to you

(a) Identity

(b) Contact details

(d) Usage

(e) Profile

Necessary for our legitimate interests

(to develop our products/services and

grow our business)

4.2. MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around

marketing and advertising.

4.3. PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we

think you may want or need, or what may be of interest to you. This is how we decide which

products, services and offers may be relevant for you.

You will receive marketing communications from if you have requested information from us or

purchased services from us or if you provided us with your details when you entered our website

for the purpose of receiving information and, in each case, you have not opted out of receiving that

marketing.

4.4. PROFILING

We may in some instances use your personal data, such as your country of residence and trade

history, in order to better address your needs. For example, if you frequently trade in a specific

virtual currency, we may use this information to inform you of new product updates or features

that may be useful for you. When we do this, we take all necessary measures to ensure that your

privacy and security are protected, and we only use anonymous or de-identified data.

4.5. THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company

outside the Company’s group of companies for marketing purposes.

4.6. OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by logging

into the website and checking or unchecking relevant boxes to adjust your marketing preferences

or by following the opt-out links on any marketing message sent to you or by Contacting us at any

time at the following email address: support@hashrift.com

4.7. COOKIES

The Company’s Technology provider may use “cookies” and other tracking technologies to

collect Anonymous Information. A “cookie” is a small text file stored by a web browser when

users access a website. Cookies enable the website browsed to save and identify the user’s

browsing activity and individual preferences, for example, to collect information about the User’s

activity in relation to the Services and it may serve to recall Personal Data previously indicated by

a User, such as his/her user ID and password for access to the Service(s).

In particular, the Company’s technology providers might be using “Flash Cookies” and/or local

storage technologies to help users access the Client’s accounts seamlessly and save their account

settings to their browsers. Do note that most browsers allow controlling cookies, including whether

or not to accept them and how to remove them.

4.7.1. Reasons why the Company is using Cookies

Cookies are used on the Company’s website to:

• Identify the web browser and the settings;

• Verify our client’s identity to ensure his/her personal data protection;

• Remember the client’s individual preferences.

4.7.2. How are Cookies used by the Company

Cookies are downloaded by your browser whenever you access our websites. The stored data is

used to track your browsing path and the pages you visit most frequently.

Your privacy is important to us, so the gathered information will be stored for a period not less

than the one we are required to observe in order to comply with the applicable rules and

regulations.

Cookies are commonly introduced to improve the efficiency of websites. By tracking our user’s

behavior, we seek to make our website more user-friendly and tailored to your preferences.

You can, if you wish, set your browser to refuse all or some browser cookies, or to alert you when

websites set or access cookies. If you disable or refuse cookies, please note that some parts of this

website may become inaccessible or not function properly.

Cookies do not contain any executable code or software viruses. Instead, it is more like your

personal ID that is updated whenever you access our website.

4.8. CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we

reasonably consider that we need to use it for another reason and that reason is compatible with

the original purpose. If you wish to get an explanation as to how the processing for the new purpose

is compatible with the original purpose, please contact us at the following email: support@hashrfit.com

If we need to use your personal data for an unrelated purpose, we will notify you and we will

explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in

compliance with the above rules, where this is required or permitted by law.

4.9. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with third parties for the purpose of carrying out our

services, but should this be the case we check the issue.

We require all third parties to respect the security of your personal data and to treat it in accordance

with the law. We do not allow our third-party service providers to use your personal data for their

own purposes and only permit them to process your personal data for specified purposes and in

accordance with our instructions.

5. INTERNATIONAL TRANSFERS

We might need on certain occasions for the purposes of carrying out our services to transfer your

personal data outside the European Economic Area (EEA)

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection

is afforded to it by ensuring at least one of the following safeguards is implemented: support@hashrift.com

We will only transfer your personal data to countries that have been deemed to provide an adequate

level of protection for personal data by the European Commission.

• Where we use certain service providers, we may use specific contracts approved by the

European Commission which give personal data the same protection it has in Europe.

• Where we use providers based in the US, we may transfer data to them if they are part of the

Privacy Shield which requires them to provide similar protection to personal data shared

between the Europe and the US.

Please contact us at support@io-convert.com if you want further information on the specific

mechanism used by us when transferring your personal data out of the EEA.

6. DATA SECURITY

6.1. MEASURES WE TAKE TO SECURE YOUR DATA.

We have put in place appropriate security measures to prevent your personal data from being

accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we

limit access to your personal data to those employees, agents, contractors and other third parties

who have a business need to know. They will only process your personal data on our instructions,

and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify

you and any applicable regulator of a breach where we are legally required to do so.

6.2. PRIVACY WHEN USING DIGITAL ASSETS AND BLOCKCHAINS

Your funding of bitcoin, XRP, ether, and other 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. Many blockchains are open to forensic analysis which

can lead to deanonymization and the unintentional revelation of private financial information,

especially when blockchain data is combined with other data.

Because blockchains are decentralized or third-party networks which are not controlled or operated

by IO Solutions International Ltd or its affiliates, we are not able to erase, modify, or alter

personal data from such networks.

7. DATA RETENTION

7.1. HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only 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, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature,

and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure

of your personal data, the purposes for which we process your personal data and whether we can

achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity,

Financial and Transaction Data) for five years after they cease being customers for regulatory

purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further

information.

In some circumstances we may anonymize your personal data (so that it can no longer be

associated with you) for research or statistical purposes in which case we may use this information

indefinitely without further notice to you.

8. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your

personal data:

8.1. Request access to your personal data (commonly known as a “data subject access

request”). This enables you to receive a copy of the personal data we hold about you and

to check that we are lawfully processing it.

8.2. Request correction of the personal data that we hold about you. This enables you to have

any incomplete or inaccurate data we hold about you corrected, though we may need to

verify the accuracy of the new data you provide to us.

8.3. Request erasure of your personal data. This enables you to ask us to delete or remove

personal data where there is no good reason for us continuing to process it. You also have

the right to ask us to delete or remove your personal data where you have successfully

exercised your right to object to processing (see below), where we may have processed

your information unlawfully or where we are required to erase your personal data to

comply with local law. Note, however, that we may not always be able to comply with

your request of erasure for specific legal reasons which will be notified to you, if

applicable, at the time of your request.

8.4. Object to processing of your personal data where we are relying on a legitimate interest

(or those of a third party) and there is something about your particular situation which

makes you want to object to processing on this ground as you feel it impacts on your

fundamental rights and freedoms. You also have the right to object where we are

processing your personal data for direct marketing purposes. In some cases, we may

demonstrate that we have compelling legitimate grounds to process your information

which override your rights and freedoms.

8.5. Request restriction of processing of your personal data. This enables you to ask us to

suspend the processing of your personal data in the following scenarios: (a) if you want

us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do

not want us to erase it; (c) where you need us to hold the data even if we no longer require

it as you need it to establish, exercise or defend legal claims; or (d) you have objected to

our use of your data but we need to verify whether we have overriding legitimate grounds

to use it.

8.6. Request the transfer of your personal data to you or to a third party. We will provide to

you, or a third party you have chosen, your personal data in a structured, commonly used,

machine-readable format. Note that this right only applies to automated information which

you initially provided consent for us to use or where we used the information to perform

a contract with you.

8.7. Withdraw consent at any time where we are relying on consent to process your personal

data. However, this will not affect the lawfulness of any processing carried out before you

withdraw your consent. If you withdraw your consent, we may not be able to provide

certain products or services to you. We will advise you if this is the case at the time you

withdraw your consent.

➢ If you wish to exercise any of the rights set out above, please Contact us at

support@hashrift.com

▪ Account Information – Information that is generated by your Hashrift

Ltd account activity including, but not limited to, instructions regarding funding and

disbursement, orders, trades, and account balances;

▪ Correspondence – Information that you provide to us in written or oral correspondence,

including opening an Hashrift Ltd account, and with respect to ongoing

customer support; and logging of phone numbers used to contact us.

9. General Provisions

Personal Information you provide during the registration process may be retained, even if

your registration is left incomplete or abandoned. If you are located within the EEA, this

Information will not be retained without your consent.

In providing the personal data of any individual (other than yourself) to us during your use

of the .com or .exchange or .io, you promise that you have obtained consent from such

individual to disclose his/her personal data to us, as well his/her consent to our collection,

use and disclosure of such personal data for the purposes set out in this Privacy Notice.

• We are under a duty to disclose or share your personal data in order to comply with any legal

obligation, or in order to enforce or apply our Terms and Conditions and other applicable

agreements; or to protect the rights, property, or safety of IO Solutions International Ltd,

our customers, or others. This includes exchanging information with other companies and

organizations for the purposes of fraud protection and credit risk reduction;

In order to provide our Services to you, it may be sometimes necessary for us to transfer

your data to the third parties that are based outside of the European Economic Area

("EEA"). In these cases, we ensure that both ourselves and our partners take adequate and

appropriate technical, physical, and organizational security measures to protect your data.

We also ensure we have appropriate contractual protections in place with these third

parties.

By using IO Solutions International Ltd, you consent to your Personal Data being

transferred to other countries, including countries that have different data protection rules

than your country. In all such transfers, we will protect your personal information as

described in this Privacy Policy. For more information, please contact us at support@hashrift.com