PRIVACY POLICY

INTRODUCTION

RockWallet (“RockWallet, “we”, “us”,“our”, “ours”) respects your privacy and is committed to protecting it. ThisPrivacy Policy (“Policy”) governs the manner in which we look after yourpersonal data when you access our services, which include content on ourwebsite www.rockwallet.com, or anyother websites, pages, or content we own or operate (collectively, the “Site(s)”)regardless of where you visit it from, or when using our mobile app, API orthird-party applications relying on such API, and related services(collectively, the “Services”), and informs you about your rights and how thelaw protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

This Policy aims to give youinformation on how we collect and process your personal data through your useof the Sites, including any data you may provide through the Sites when you useany of our Services.

Our Services are not intended for anyperson under the age of 18 (“Children”) , and we do not knowingly collect datarelating to Children.

RockWallet is the controller andresponsible for your personal data, a company registered as a Money ServicesBusiness (MSB) and included in the MSB Registrant Search Web page, pursuant tothe Bank Secrecy Act (BSA) regulations administered by the Financial Crimes EnforcementNetwork (FinCEN).

You have the right to make acomplaint at any time to your relevant data protection authority. We would,however, appreciate the chance to deal with your concerns before you approachsuch authority, so please contact us in the first instance.

Our Sites may include links tothird-party websites, plug-ins, and applications. Clicking on those links orenabling those connections may allow third parties to collect or share dataabout you. We do not control these third-party websites and are not responsiblefor their privacy statements. When you leave our Site, we encourage you to readthe privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personalinformation, means any information about an individual from which that personcan be identified. It does not include data where the identity has been removed(anonymous data).

We may collect, use, store, andtransfer different kinds of personal data about you which we have groupedtogether as follows:

§ Identity data may include your firstname, last name, username or similar identifier, title, date of birth, andgender.

§ Contact data may include your billingaddress, email address, and telephone number(s).

§ Financial data may include your bankaccount details, payment card details, and/or bitcoin wallet address(es).

§ Transaction data may includedetails about payments to and from you and other details of products andservices you have purchased from us.

§ Technical data may includeinternet protocol (IP) address, your login data, browser type and version, timezone setting and location, browser plug-in types and versions, operating systemand platform, and other technology on the devices you use to access the Sitesand Services.

§ Profile data may include yourusername and password, purchases or orders made by you, your tradingperformance, your preferences, feedback, and survey responses.

§ Usage data may include informationabout how you use the Site(s), and the Services.

§ Marketing and Communications datamay include your preferences in receiving marketing from us and our thirdparties and your communication preferences.

We also collect, use, and shareAggregated Data such as statistical or demographic data for any purpose.Aggregated Data could be derived from your personal data but is not consideredpersonal data in law as this data will not directly or indirectly reveal youridentity. For example, we may aggregate your Usage Data to calculate thepercentage of users accessing specific features on our Sites. However, if wecombine or connect Aggregated Data with your personal data so that it candirectly or indirectly identify you, we treat the combined data as personaldata which will be used in accordance with this Policy.

We do not collect any special categoriesof personal data about you (this includes details about your race or ethnicity,religious or philosophical beliefs, gender, sexual orientation, politicalopinions, trade union membership, information about your health, and geneticand biometric data). Nor do we collect any information about criminalconvictions and offenses.

IF YOU FAIL TO PROVIDE PERSONALDATA

Where we need to collect personaldata by law, or under the terms of a contract we have with you, and you fail toprovide that data when requested, we may not be able to provide our Services toyou.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

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

Direct interactions. You may giveus your identity, contact and financial data by filling in online forms or bycorresponding with us by post, phone, email, or otherwise. This includespersonal data you provide when you:

§ apply for our products orservices;

§ create an account on our website;

§ subscribe to our service orpublications;

§ request marketing to be sent toyou;

§ enter a competition, promotion, orsurvey; or

§ give us feedback or contact us.

Automated technologies orinteractions. As you interact with the Sites, we will automatically collect technicaldata about your equipment, browsing actions, and patterns. We collect thispersonal data by using cookies, server logs, and other similar technologies. Wemay also receive technical data about you if you visit other websites employingour cookies. Please see our Cookie Policy [insert link] for further details.

Third parties or publiclyavailable sources. We may receive personal data about you from various thirdparties and public sources as set out below:

§ Technical data from the followingparties:

(a) analyticsproviders;

(b) advertisingnetworks; and

§ Contact, financial and transactiondata from providers of technical, payment, and delivery services

§ Identity and contact data fromdata brokers or aggregators

§ Identity and contact data frompublicly available sources.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personaldata when the law allows us to. Most commonly, we will use your personal datain the following circumstances:

§ Where it is needed to perform anyof the Services.

§ Where it is necessary for ourlegitimate interests (or those of a third-party) and your interests andfundamental rights do not override those interests.

§ Where we need to comply with alegal obligation.

§ Generally, we do not rely onconsent as a legal basis for processing your personal data although we will getyour consent before sending third-party direct marketing communications to youvia email or text message. You have the right to withdraw consent to marketingat any time by contacting us.

PURPOSES FOR WHICH WE WILL USEYOUR PERSONAL DATA

We have set out below adescription of all the ways we plan to use your personal data, and which of thelegal bases we rely on to do so. We have also identified what our legitimateinterests are where appropriate.

Note that we may process yourpersonal data for more than one lawful ground depending on the specific purposefor which we are using your data. Please contact us if you need details aboutthe specific legal grounds we are relying on to process your personal datawhere more than one ground has been set out in the table below (“Table 1”).

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order including managing payments, fees, and charges

(a) Identity

(b) Contact

(d) Transaction

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a competition or complete a survey

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(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 reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our Site, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

MARKETING

We strive to provide you withchoices regarding certain personal data uses, particularly around marketing andadvertising.

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 wantor 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 marketingcommunications from us if you have requested information from us or use any ofour Services and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-inconsent before we share your personal data with any third-party for marketingpurposes.

OPTING OUT

You can ask us or third parties tostop sending you marketing messages at any time by following the opt-out linkson any marketing message sent to you or by contacting us at any time.

Where you opt-out of receivingthese marketing messages, this will not apply to personal data provided to us inconnection with use of any of our Services.

You can set your browser to refuseall or some browser cookies or to alert you when websites set or accesscookies. If you disable or refuse cookies, please note that some parts of thisSite may become inaccessible or not function properly. For more informationabout the cookies we use, please see our Cookie Policy <insert embedded link>.

CHANGE OF PURPOSE

We will only use your personaldata for the purposes for which we collected it unless we reasonably considerthat we need to use it for another reason and that reason is compatible withthe original purpose. If you wish to get an explanation as to how theprocessing for the new purpose is compatible with the original purpose, pleasecontact us.

If we need to use your personaldata for an unrelated purpose, we will notify you and we will explain the legalbasis which allows us to do so.

Please note that we may processyour personal data without your knowledge or consent, in compliance with theabove rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal datawith the parties set out below for the purposes set out in Table 1 above.

§ Internal third parties (otheraffiliated companies acting as joint controllers or processors that providetechnical, marketing, and/or project management services).

§ External third parties (serviceproviders or professional advisers acting as processors).

§ Third parties to whom we maychoose to sell, transfer or merge parts of our business or our assets.Alternatively, we may seek to acquire other businesses or merge with them. If achange happens to our business, then the new owners may use your personal datain the same way as set out in this Policy.

We require all third parties torespect the security of your personal data and to treat it in accordance withthe law. We do not allow our third-party service providers to use your personaldata for their own purposes and only permit them to process your personal datafor specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We share your personal data withinternal third parties. This will involve transferring your data to othercountries than your country of nationality or residence.

We ensure your personal data isprotected by requiring all our affiliated companies to follow the same ruleswhen processing your personal data.

Whenever we transfer your personaldata, we ensure a similar degree of protection is afforded to it by ensuring atleast one of the following safeguards is implemented:

§ We will only transfer yourpersonal data to countries that have been deemed to provide an adequate levelof protection for personal data.

§ Where we use providers based inEurope, we may use specific contracts approved by the European Commission. Forfurther details, see European Commission: Model contracts for the transfer ofpersonal data to third countries.

Please contact usif you want further information on the specific mechanism used by us whentransferring your personal data.

7. DATA SECURITY

We have put in place appropriatesecurity measures to prevent your personal data from being accidentally lost,used, or accessed in an unauthorized way, altered or disclosed. In addition, welimit access to your personal data to those employees, agents, contractors, andother third parties who have a business need to know. They will only processyour personal data on our instructions, and they are subject to a duty ofconfidentiality.

We have put in place procedures todeal with any suspected personal data breach and will notify you and anyapplicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONALDATA FOR?

We will only retain your personaldata for as long as reasonably necessary to fulfill the purposes we collectedit for, including the purposes of satisfying any legal, regulatory, tax,accounting, or reporting requirements. We may retain your personal data for alonger period in the event of a complaint or if we reasonably believe there isa prospect of litigation in respect to our relationship with you.

To determine the appropriateretention period for personal data, we consider the amount, nature andsensitivity of the personal data, the potential risk of harm from unauthorized useor disclosure of your personal data, the purposes for which we process yourpersonal data, and whether we can achieve those purposes through other means,and the applicable legal, regulatory, tax, accounting, or other requirements.

9. YOUR LEGAL RIGHTS

Under certain circumstances, youhave rights under data protection laws in relation to your personal data:

Request access to your personaldata (commonly known as a “data subject access request”). This enables you toreceive a copy of the personal data we hold about you and to check that we arelawfully processing it.

Request correction of the personaldata that we hold about you. This enables you to have any incomplete orinaccurate data we hold about you corrected, though we may need to verify theaccuracy of the new data you provide to us.

Request erasure of your personaldata. This enables you to ask us to delete or remove personal data where thereis no good reason for us continuing to process it. You also have the right toask us to delete or remove your personal data where you have successfullyexercised your right to object to processing (see below), where we may haveprocessed your information unlawfully or where we are required to erase yourpersonal data to comply with local law. Note, however, that we may not alwaysbe able to comply with your request of erasure for specific legal reasons whichwill be notified to you, if applicable, at the time of your request.

Object to processing of yourpersonal 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 toobject to processing on this ground as you feel it impacts your fundamentalrights and freedoms. You also have the right to object where we are processingyour personal data for direct marketing purposes. In some cases, we maydemonstrate that we have compelling legitimate grounds to process yourinformation which override your rights and freedoms.

Request restriction of processingof your personal data. This enables you to ask us to suspend the processing ofyour personal data in the following scenarios:

§ If you want us to establish the data’saccuracy.

§ Where our use of the data isunlawful, but you do not want us to erase it.

§ Where you need us to hold the dataeven if we no longer require it as you need it to establish, exercise or defendlegal claims.

§ You have objected to our use ofyour data, but we need to verify whether we have overriding legitimate groundsto use it.

Request the transfer of yourpersonal data to you or to a third-party. We will provide to you, or a third-partyyou have chosen, your personal data in a structured, commonly used,machine-readable format. Note that this right only applies to automatedinformation which you initially provided consent for us to use or where we usedthe information to perform a contract with you.

Withdraw consent at any time wherewe are relying on consent to process your personal data. However, this will notaffect the lawfulness of any processing carried out before you withdraw yourconsent. If you withdraw your consent, we may not be able to provide certainproducts or services to you. We will advise you if this is the case at the timeyou withdraw your consent.

If you wish to exercise any of therights set out above, please contact us.

NO FEE USUALLY REQUIRED

You will not have to pay a fee toaccess your personal data (or to exercise any of the other rights provided forunder this Policy). However, we may charge a reasonable fee if your request is deemedby us to have no foundation, inaccurate, abusive, or unreasonable.

WHAT WE MAY NEED FROM YOU

We may need to request specificinformation from you to help us confirm your identity and ensure your right toaccess your personal data (or to exercise any of your other rights). This is asecurity measure to ensure that personal data is not disclosed to any personwho has no right to receive it. We may also contact you to ask you for furtherinformation in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimaterequests within one month. Occasionally it could take us longer than a month ifyour request is particularly complex or you have made a number of requests. Inthis case, we will notify you and keep you updated.

REVIEW/MODIFICATION OF THIS POLICY

We endeavor to keep our Policyunder regular review. Accordingly, we may update this Policy from time to timeto respond to updates in legal, technical, or business requirements anddevelopments. If we make any material changes, we will notify you based on thecontact information provided from your account with us, or as otherwiserequired by law, and post the updated Policy on our Sites.

YOUR DUTY TO INFORM US OF CHANGES

It is important that the personaldata we hold about you is accurate and current. Please keep us informed if yourpersonal data changes during your relationship with us.

10. LEGAL RIGHTS OF CALIFORNIA RESIDENTS

In addition to the legal rightsprovided above, in compliance with the California Privacy Act of 2018 (“CCPA”),residents of California may contact us at legal@RockWallet.com to request information on the types of personalinformation that we have disclosed during the preceding 12 months to thirdparties for their direct marketing purposes and the identities of those thirdparties.

For personal information collectedby us during the preceding 12 months that is not otherwise subject to anexception pursuant to the CCPA, you have the right to access and delete yourpersonal information, and we hereby declare that we shall not discriminateagainst those who exercise those rights. Specifically, we shall not:

§ deny you our services;

§ charge you differently;

§ provide you with a different levelof quality of services; or

§ suggest that you may receive adifferent price or rate for services or a different level or quality ofservices.

We further declare that we do notsell your personal information in our ordinary course of business and willnever sell your personal information to third parties without your explicitconsent.

If you seek to exercise CCPAaccess or deletion rights on behalf of another person, you must confirm thatthe person has authorized you to act as their agent under the CCPA by providingus with a completed, signed, and notarized CCPA Agent Authorisation Form [link]pursuant to California Probate Code Section 4000 to 4465. Please note that wemay deny requests from agents who do not submit the relevant proof of authorizationor agents we are unable to verify their identity.

‍