Privacy Policy

1. Introduction

We respect your privacy and are committed to protecting your personal data. We take our data protection responsibilities with the utmost seriousness. Details of which are available in Section 3 below in connection with:

2. Purpose

This Privacy Notice describes how we collect and process your personal data, why and how we collect and process your personal data, details of which are available in Section 3 below in connection with:

Use of any of our products, services, or applications (together the "Services"),

Visit or use of our venkate.io (or other affiliated) websites ("Site") or mobile application ("App").

This Privacy Policy applies to all personal data processing activities carried out by us, across the Services and the App.

This Privacy Notice informs you about your privacy rights and how the data protection principles set out in the applicable privacy legislation protect you.

It is important that you read this Privacy Notice together with any other notice or policy we may provide from time to time when we are collecting or processing personal data about you so that you are fully aware of why and how we are using your data. This Privacy Notice

supplements other notices and policies and is not intended to override them. Where any

conflict arises between this Privacy Notice and other notices and policies, the terms of this Privacy Notice shall prevail.

Our Services, Site, and App are not intended for minors under the age of 18 years, and we do not knowingly collect data relating to minors.

3. Who We Are

Data Controller

The controller of your personal data is the legal entity that determines the "means" and the "purposes" of any processing activities that it carries out.

Venkate Limited, a company incorporated under the laws of BVI, is the controller and is responsible for handling your personal data.

Complaints

You may contact us at [e-mail] for any issues in relation to the processing of your personal data.

Our Duties and Your Duties in Case of Changes

We regularly review our Privacy Notice. This version was last updated on the date above

written. Please check from time to time for new versions of the Privacy Notice. We will also additionally notify you of any material changes in this Privacy Notice in a manner which will effectively bring the changes to your attention.

It is important that the personal data we hold about you is accurate and up-to-date. Please keep us informed if your personal data changes during your relationship with us.

Third-party Links

The Site and any applicable web browser, the App or application programming interface required to access the Services ("Applications"), may include links to third-party websites, plug-ins, and applications ("Third-Party Sites"). 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 Sites and are not responsible for their privacy statements and policies.

When you leave our Site or Applications, we encourage you to read the privacy notice or policy of every Third-Party Site you visit or use.

4. What Data We Collect About You

We collect various types of information, including:

Identity Data: Full name, username, date of birth, biometric information, and identification documents.

Contact Data: Email address, phone numbers, and proof of address.

Financial Data: Bank account details, payment card information, virtual currency accounts.

Transactional Data: Details about transactions to and from you.

Technical Data: IP address, login data, browser type and version, device information, and diagnostic data.

Profile Data: Username, password, user ID, interests, preferences, and feedback.

Usage Data: Information on how you use our site, services, and app.

Marketing and Communications Data: Your preferences for receiving marketing from us and your communication preferences.

5. How We Collect Your Data

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

Direct interactions: You may provide us with your Identity Data, Contact Data, Financial Data, Profile Data, and Marketing and Communications Data by directly interacting with us, including by filling in forms, providing a visual image of yourself via the Service, by email or otherwise. This includes personal data you provide when you:

Visit our Site or App; Apply for our Services; Create an account;

Make use of any of our Services;

Request marketing to be sent to you, for example by subscribing to our newsletters;

Enter a competition, promotion, or survey, including through social media channels; or

Give us feedback or contact us.

Automated technologies or interactions: As you interact with us via our Site or App, we will automatically collect Technical Data about your equipment, browsing actions,

and patterns. We collect this personal data by using cookies, server logs, and other online identifiers. We will also collect Transactional Data and Usage Data. We may also receive Technical Data and Marketing and Communications Data about you if you visit other

websites employing our cookies. You may find more information about how we use cookies through the Cookie Preferences.

Third-party sources: We may receive data about you from public sources, identity verification agencies, and other third parties.

6. How We Use Your Data

We will only use your personal data when the applicable legislation allows us to. In other

words, we must ensure that we have a lawful basis for such use. Most commonly, we will use your personal data in the following circumstances:

Performance of a contract: Processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract; we use this basis for the provision of our Services.

Legitimate interests: Our interests (or those of a third party), where we make sure we use this basis as far as your interests and individual rights do not override those interests.

Compliance with a legal obligation: Processing your personal data where we need to comply with a legal obligation we are subject to.

Consent: Freely given, specific, informed, and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to you; under specific circumstances this consent

should be explicit – if this is the case, we will ask for it properly.

Purposes for Which We Use Your Personal Data

We have set out below, in table format, a description of 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.

Purpose and/or activity	Categories of personal data	Legal basis for processing
To register you as a new customer	Identity Data, Contact Data, Financial Data	Performance of a contract
To comply with anti-money laundering requirements	Identity Data, Contact Data, Financial Data, Transactional Data, Technical Data, Profile Data	Compliance with a legal obligation
To process and deliver our Services and any App features to you, including to execute, manage, and process any instructions or orders you make	Identity Data, Contact Data, Financial Data, Transactional Data, Technical Data	Performance of a contract
To prevent abuse of our Services and promotions	Identity Data, Contact Data, Financial Data, Transactional Data, Technical Data, Marketing and Communications Data	Legitimate interests: safeguarding the security and integrity of our Services by detecting and preventing fraud and unauthorized activities, thereby protecting both our business and our customers
To manage our relationship with you which will include asking you to leave a review, take a survey or keeping you informed of our company's business and product development	Identity Data, Contact Data, Profile Data, Transactional Data, Marketing and Communications Data	Performance of a contract, Consent, if required
To keep our records updated and to study how customers use our products/services	Identity Data, Contact Data, Profile Data, Transactional Data, Technical Data, Marketing and Communications Data	Legitimate interests: to maintain accurate customer data for effective service and informed business decisions, and to enhance our offerings by understanding customer interactions; Consent, if required
To manage, process, collect and transfer payments, fees, and charges	Identity Data, Contact Data, Financial Data, Transactional Data	Performance of a contract
To comply with applicable legislation and handle complaints, including: - manage risk and crime prevention involving performance of anti-money laundering, counter-terrorism, sanction screening, fraud, and other background checks; - detect,	Identity Data, Contact Data, Financial Data, Transactional Data, Technical Data, Profile Data, Usage Data, Sensitive Data	Compliance with a legal obligation, Performance of a contract, Legitimate interests: ensuring that we are not involved in dealing with the proceeds of criminal activities and do not assist in any other unlawful or fraudulent activities, as

investigate, report and prevent financial crime in a broad sense; - ensure your account's security, in order to honor requests regarding information and/or changes to your account		well as to develop and improve our internal systems for dealing with financial crime and to ensure effective dealing with complaints
To enable you to partake in a prize draw, competition or complete a survey	Identity Data, Contact Data, Profile Data, Usage Data, Marketing and Communications Data	Performance of a contract, Consent, if required
To gather market data for studying customers' behavior including their preference, interest, and how they use our products/services, determining our marketing campaigns and growing our business	Identity Data, Contact Data, Profile Data, Usage Data, Marketing and Communications Data	Legitimate interests: understanding

Automated Decision Making

What is an automated decision?

An automated decision is a decision made automatically using software algorithms without human intervention, which may affect you. For example, we use automated decisions to

streamline the customer onboarding process or to conduct fraud monitoring.

Why is an automated decision important to you?

In certain situations, using your personal data may result in automated decisions (including profiling) that can have legal or significant impacts on you.

How do we protect your interests?

We implement appropriate measures to protect the rights and interests of individuals whose personal data is subject to automated decision-making. If an automated decision is made

about you, you have the right to object to it. For more detailed information or to exercise this right, please contact us.

Marketing

We may use your Identity Data, Contact Data, Technical Data, Transaction Data, Usage Data, and Profile Data to determine what products, services, and offers may be of interest to you.

You will receive marketing communications from us if you have requested information from us and consented to receive marketing communications, or if you have made a purchase from us and have not opted out of receiving such communications. We will use your Marketing and Communications Data for our activities.

Third-party marketing

We will obtain your explicit consent before sharing your personal data with any third party for marketing purposes.

Opting out

You can opt out of marketing communications at any time by following the opt-out links in any marketing message sent to you.

Additionally, you can log in and cancel marketing messages in the Notifications section.

Opting out of receiving marketing messages will not affect service messages related to the use of our Services (e.g., maintenance, changes in terms and conditions, etc.).

Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. Please note that some parts of our Services or Site may become inaccessible or not function properly if you disable or refuse cookies. For more information

about the cookies we use, please review our Cookie Preferences.

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 that is compatible with the original purpose. If you would like an explanation of how the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.

Sale or transfer of business

In the event of a merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding involving all or part of our shares, business, or assets, we may need to process your data. This will be based on our legitimate interests in carrying out such transactions or to meet our legal obligations.

7. Disclosure of Your Data

We may share your personal data with third-party service providers, agents, subcontractors, associated organizations, our group companies, and affiliates to complete tasks and provide the Services and use of the App to you on our behalf. Third-party service providers are required to respect the security of your personal data and treat it in accordance with the law.

We share your personal data with the following entities:

Companies and organizations that assist us in processing, verifying, or refunding transactions/orders you make and in providing any of the Services you have requested.

Identity verification agencies to undertake required verification checks.

Fraud or crime prevention agencies to help combat crimes including fraud, money- laundering, and terrorist financing.

Any party to whom we lawfully transfer or may transfer our rights and duties under the relevant terms and conditions governing the use of any of the Services.

Any third party in the event of a restructure, sale, or acquisition of our group or any

affiliates, provided that any recipient uses your information for the same purposes as it was originally supplied to us and/or used by us.

Regulatory and law enforcement authorities, whether outside or inside the Republic of Seychelles, where the law allows or requires us to do so.

Specifics regarding the use of blockchain

The blockchain technology used in certain Services operates on a decentralized network, where transactions are recorded in an immutable and transparent manner. This ensures the integrity and security of data stored on the blockchain. However, once data is added to the blockchain, it cannot be removed or deleted.

1. International Transfers (Cross-Border Data Flows)

Many of our external third parties are based outside the Republic of Seychelles, necessitating the transfer of your personal data outside the country.

Whenever we transfer your personal data out of the Republic of Seychelles, we ensure a similar degree of protection by implementing one of the following safeguards:

The country to which we transfer your personal data has been deemed to provide an adequate level of protection for personal data by the European Commission.

A specific contract approved by the European Commission, the Information Commission, or another competent authority, which provides safeguards to the processing of personal data, known as Standard Contractual Clauses.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the Republic of Seychelles.

9. Data Security

While there is an inherent risk in any data being shared over the internet, we have implemented appropriate security measures to prevent your personal data from being

accidentally lost, used, damaged, accessed in an unauthorized or unlawful way, altered, or disclosed. We limit access to your personal data to employees, agents, contractors, and other third parties who have a legitimate business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

Depending on the nature of the risks associated with the proposed processing of your personal data, we have implemented the following security measures:

Organizational measures, including staff training and policy development.

Technical measures, including physical protection of data, pseudonymization, and encryption.

Securing ongoing availability, integrity, and accessibility, including ensuring appropriate back-ups of personal data.

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

10. Data Retention

To determine the appropriate retention period for personal data, we consider several factors: the volume, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure; the purposes for processing the data and whether those purposes can be

achieved through other means; and the applicable legal, regulatory, tax, accounting, or other requirements. Factors we typically consider include:

If there is an ongoing complaint.

If we reasonably believe there is a potential for litigation related to our relationship with you, or if we need to retain information to defend against possible future legal claims (e.g., emails, chats, letters may be kept for up to 10 years after our relationship ends, depending on the applicable limitation period in your country).

To comply with legal and regulatory requirements concerning specific types of personal data:

Under the Seychelles AML CFT Act, we are required to retain your personal data for at least 7 years after the end of our business relationship; this period may be

extended as necessary under applicable law.

For audit purposes.

In accordance with relevant industry standards or guidelines.

To meet our legitimate business needs, such as preventing abuse of promotions. We will retain personal data for the duration of the promotion and for a period afterward to prevent abusive behavior.

Please note that under certain conditions, you can request that we delete your data. See the

section on your legal rights below for more information. We will honor your deletion request only if the conditions are met.

11. Your Legal Rights

You have certain rights regarding your personal data. The availability of these rights depends on the reason we are processing your data. If you need more detailed information or wish to exercise any of the rights listed below, please contact us.

You may:

Request access to your personal data.

Request the correction of your personal data if you believe it is inaccurate or incomplete (subject to our verification of the accuracy of the new data you provide).

Request the deletion of your personal data; however, we may not always be able to

comply with your request for specific legal reasons, which will be communicated to you.

Additionally, please refer to the "Specifics regarding the use of blockchain" section above.

Object to the processing of your personal data if you feel it impacts your fundamental rights and freedoms, particularly if we are relying on legitimate interest (or those of a

third party) as the basis for processing. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights

and freedoms. You also have the right to object if we are processing your personal data for direct marketing purposes.

Require that decisions made solely by automated means, without human intervention, be reconsidered (detailed explanation in the Automated Decision-Making section above).

Request the restriction of processing your personal data, allowing you to ask us to

suspend processing under certain circumstances, such as if you want us to verify the data's accuracy; if our use of the data is unlawful but you do not want it erased; if you need us to retain the data even if we no longer require it as you need it to establish,

exercise, or defend legal claims; or if you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or a third party. We will provide your data in a structured, commonly used, machine-readable format where technically feasible. This right applies only to automated information initially provided with your consent or where we used the information to perform a contract with you.

Withdraw consent at any time if we are relying on consent to process your personal data. 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, but we will inform you if this is the case at the time you

withdraw your consent.

File a complaint with the Seychelles’ Information Commission, or contact your local data protection authority regarding any perceived violation and seek compensation for damages in the courts.

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 or

excessive. Alternatively, we may refuse to comply with your request in such circumstances.

Period for Replying to a Legitimate Request

In compliance with privacy legislation requirements, we aim to respond to a legitimate request within one month.

Please note that we may need to request specific information from you to help us confirm your identity when you exercise a legal right concerning your personal data.