2. What information do we collect? We collect Personal Data and Anonymous Data, as described below. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

• We may collect Personal Data from you, such as your first and last name, e-mail and mailing addresses, date of birth, government issued identification, tax ID, identity information, photographs, company name, and password when you use our Site.
• We may also collect other Personal Data provided by third party identity verification, market surveillance providers, and sanctions screening services, service providers, regulators or via social networking websites.
• If you fill out a survey or tell us where you are (e.g., by allowing your mobile device or computer to send us your location), we may store that information.
• Certain Services, such as two-factor authentication, may require our collection of your phone number. We may associate that phone number to your mobile device identification information.
• If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
• We also collect other types of Personal Data that you provide to us voluntarily when seeking support and other Services, such as email, chat name and logs, information submitted via online form, video conferencing service information, other contact information, or other information provided to support services staff.
• We may collect referral URLs, your location, and blockchain analytics information related to blockchain addresses you provide. Some of the Personal Data used by the blockchain and crypto exchange services is public information and can be seen by others, including, your public address and the type and amount of digital assets transferred. Additionally, certain technologies, such as blockchain, are immutable meaning that information, including Personal Data, cannot be deleted from the ledger. If you have concerns about this use of your Personal Data, do not use the Services.

Some information is collected automatically by our servers:

• Our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
• As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data.
• Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website.
• We retain information on your behalf, such as transactional data including records for trades, deposits, and withdraws for you and the counterparty to the transaction and other session data linked to your Account.

Some information is collected from third parties: We may obtain Personal Data about you from other sources, including through third party services such as sanctions screening services and other organizations to supplement information provided by you. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services. 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 with you. In this case, we may have to close your Account but we will notify you if this is the case at the time.

4. How do we share your Personal Data? We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

• It may be necessary to disclose your information to law enforcement agencies, regulators, government/public officials, or other relevant third parties to comply with any law, subpoenas, court orders, or government request, defend against claims, investigate or bring legal action against illegal or suspected illegal activities, enforce our Terms, or to protect the rights, safety, and security of us, our users, or the public.
• We may share Personal Data with our affiliated companies.
• We may allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such data and other information with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks.
• We may share your Personal Data with third party service providers to provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; to verify your identity; and/or to provide other services to us. These third party service providers are required not to use your Personal Data other than to provide the services requested by us.
• We may provide Personal Data to business partners with whom we jointly offer products or services as allowed by law. In such cases, our business partner’s name will appear with ours.
• We may share some or all of your Personal Data with third parties (e.g. the purchaser or new owner) in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

The Site may contain links to other third party websites which are regulated by their own privacy policies. We are not responsible for the privacy policies of these third party websites even if they were accessed using the links from our Site. Other than as stated in this Privacy Policy, we do not disclose any of your Personal Data to third parties unless required to do so by law enforcement, court order, or in compliance with legal reporting obligations.

6. How can you update your information? You can update your information by contacting support and making a request. We will retain your information for as long as your Account has not been closed or as needed to provide you access to your Account. If you wish to close your Account, open a ticket in our support center. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our Terms.

8. How do we use cookies, social media, advertising and other technologies? We collect web browser Information in order to enhance your experience on our Site and track how the Services are being used. Cookies are small data files that are stored on your computer’s hard drive, and in addition to using cookies to provide you with a better user experience, we use cookies to identify and prevent fraudulent activity. The information collected can include, but is not limited to, your IP address, referral URLs, the type of device you use, your operating system, the type of browser you use, geographic location, and other session data. Cookies are not permanent and will expire after a short time period of inactivity. You may opt to deactivate your cookies, but it is important to note that you may not be able to access or use some features of our site. Please note that we are not responsible or can be held liable for any loss resulting from your decision or inability to use such features. For more information about the cookies we use, please see our Cookie Policy. We may also use Google Analytics, Mixpanel and other service providers to collect information regarding visit, or behavior and visitor demographics on our Services. For more information about Google Analytics: www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA's AppChoices application from your device's app store. Alternatively, for some devices you may use your device's platform controls in your settings to exercise choice. Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes. Our Services may include public blockchain technology, publicly accessible blogs, forums, social media pages, and private messaging features. As such information will be public, the Personal Data provided by you may be viewed and used by third parties for any number of purposes. In addition, social media buttons such as Twitter (that might include widgets such as the “share this” button or other interactive mini-programs) may be on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our site. Your interactions with these features apart from your visit to our site are governed by the privacy policy of the company providing it. We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including analytics and advertising partners to collect your Personal Data for various purposes including to provide analytics services and content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below. Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. At this time, we do not respond to DNT signals.

10. Your legal rights Under certain circumstances, you have rights under data protection laws in relation to your Personal Data which are set out in more detail below: Request access This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it. This is also commonly known as a "data subject access request". Request correction 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. If you need to add or change any information, you can log into your Account and make the change in your settings. If it doesnt look like you can make the change on your own, please reach out to us via the Support Center and we'll take care of it. Request deletion 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 applicable law. Please note: your right of deletion would not apply for various reasons including if we need to retain your Personal Data in order to comply with a legal obligation or to establish or defend a legal claim. Where we are unable to comply with your request of deletion, we will notify you at the time of your request. Object to processing You have the right to object to the 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. Request restriction of processing This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:

• 1. if you want us to establish the data's accuracy;
• 2. where our use of the data is unlawful but you do not want us to delete it;
• 3. 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
• 4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request to transfer If you ask us, we will provide 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. Withdrawal of consent This applies 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 No fee usually required You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your rights to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

12. Contacting Us If you have any questions about our Privacy Policy as outlined above, please contact us through our support center.