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PRIVACY POLICY

Last updated: Mar 28, 2019

This Privacy Policy (the “Privacy Policy”), is an integral part of the Terms of Use (the “Terms”), which can be found at: http://Exchago.com/terms, and governs the processing and transfer of Personal Data (as defined below) collected in connection with [Exchago (add full name)] (“Exchago” or “we”) cryptocurrency platform for the provision of a multitude of services and/or products, including, among others, purchase, sale, trade and management of cryptocurrency (the “Platform”) and/or any other services or products as provided by Exchago (the “Services”). All capitalized terms not defined herein shall have the meaning ascribed to them in the Terms. This Privacy Policy applies to users which access or use Exchago’s Platform and any of its affiliated websites, applications, and/or the Services or any other digital services in connection with which this Privacy Policy is linked or posted (“Users” or “you”). This Privacy Policy does not apply to information that is collected offline or by any third-party websites or services that you may access through the Services. Exchago respects your right to privacy and is using its best efforts to develop and maintain high standards of security and data protection in accordance with applicable industry standards. This Privacy Policy explains how we collect and use data and information, including Personal Data. Your ability to make informed choices about the uses of your information is important to us. Please read carefully this Privacy Policy as it explains our policy regarding the collection, use, disclosure and protection of any information we receive including your Personal Data (if any). If you choose to access, use, register to the Platform or Services or provide data to us or through the Platform or Services you explicitly agree to the use of such data in accordance with this Privacy Policy. You may not use the Platform or Services or submit any data through it if you do not agree to any of the terms hereunder. This Privacy Policy shall not be construed in any manner to derogate from the Terms or any other agreement made by and between Exchago and you.

POLICY HIGHLIGHTS

In order to help you understand with better ease some of the main aspects of this Privacy Policy we have compiled the following highlights: You are not required by law to provide us with any Personal Data. Sharing Personal Data with us or other users on the Platform or Services is entirely voluntary. Our Services are intended for Users over the age of 18 or equivalent minimum age for providing consent to processing of Personal Data in the relevant jurisdiction. Children under such age are not permitted to register to or use the Platform and/or Services. If you are under such age you should cease to use the Services immediately. You may be entitled under applicable law to request to review, amend, erase or restrict the processing of your Personal Data. Please note that in case you request to erase or restrict the processing of your Personal Data, your use of the Services may be restricted or disabled. We do not sell, lease, trade, or rent Users’ Personal Data to third parties. We only share Personal Data with third parties in connection with the provision of the Services to our customers, or other limited circumstances as specified herein. If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Privacy Policy, please send us an email to: privacy@Exchago.com.

WHAT IS PERSONAL DATA, AND WHAT DATA IS COLLECTED ABOUT ME BY EXCHAGO?

Personal Data”, means any information which identifies or can be used to identify a natural person, including, but not limited to, first and last name, IP address, phone number, email, bank account, and so forth. Non-Personal Data We collect non-Personal Data regarding Users concerning their use of the Platform or Services, such as the scope, latency, pages accessed, devices used, usage within the Platform with respect to materials displayed through our Platform or Services, and other technical information regarding the device used to access the Platform or Services, such as model, operating system, etc. Personal Data Once Users access our Platform or Services, Exchago may collect information from the computer or device that you use to access the Platform or Services, such as your, browser type, IP-address and other system settings, as well as the language your system uses and the country and time zone in which your computer or device is located. Users wishing to use certain parts of the Platform or Services will have to register to Exchago’s Platform and create an account by providing certain information, such as a name, address, email-address, bank account and certain other information that may be required by Exchago or applicable law. Exchago may monitor or control the activities within the Platform by using its Platform and/or Services to collect information regarding Users’ activities and operations under Platform or Services or that interact with any content that may be available through its Platform or Services. Such information includes Session ID, browser type, IP-address, mobile or desktop ID. Such information may qualify as Personal Data in some Users’ jurisdictions.

WHAT WILL EXCHAGO DO WITH MY PERSONAL DATA?

Non-Personal Data. Exchago may use non-Personal Data mainly for statistical analysis in order to constantly improve and maintain Exchago’s Platform and/or Services, including among others, for ensuring the technical functioning of our website, Platform and/or Services, to help prevent fraudulent use of our Platform and/or Services and for developing new services and features. Exchago may also analyze statistical traffic patterns, users’ demographics and behavior, for general business analytics and in order to provide Users with a more personalized experience. We may share non-Personal Data, aggregate information regarding the Platform or Service with our affiliates, partners and advertisers. From time to time, we may release non-Personal Data in the aggregate, e.g., by publishing a report on trends in our website or Services usage. To clarify the foregoing, such non-Personal Data will not include information which can be used to identify a natural person. Personal Data. Personal Data is used only for limited purposes such as: To provide you with the Platform or Services. We may also use Personal Data to communicate with Users regarding customer service issues, billing information etc. These communications are not promotional in nature. When you send communications to us, we may retain those communications in order to process your inquiries, respond to your requests, to improve our Platform or Services and to develop new features, products and services. To comply with applicable laws and regulations, including laws relating to money laundry or prevention of fraud. For the purposes of our legitimate interests, to the extent permitted under applicable law. To store user preferences, provide you the Platform or Services, to contact you in response to requests or inquiries, or purchases, or to optimize the content we display and personalize your experience. To protect the security or integrity of our databases and the Services, and to take precautions against legal liability.

DOES EXCHAGO USE COOKIES?

es, we use data files such as cookies, pixel tags, “Flash cookies”, or other local storage files provided by your browser or associated applications (“Cookies”). We use these technologies in order to recognize you as a User; help ensure that your account security is not compromised; mitigate risk and prevent fraud; customize our website and/or Services, content, and advertising; measure promotional effectiveness; and to promote trust and safety across our website and Services. All cookies used by Exchago are session cookies, i.e., these are temporary cookies that expire at the end of a browser session; that is, when you leave the Platform. Session cookies allow the Platform to recognize you as you navigate between pages during a single browser session and allow you to use the website most efficiently. For example, session cookies enable a website to remember that a user has placed items in an online shopping basket. Cookies placed on a User’s computer will transmit the User’s Personal Data as specified above to Exchago for the purposes also specified above during each session.

EXCHAGO CAN I OPT-OUT OF RECEIVING COOKIES?

You may at any time program your web browser to block cookies, but please be aware that such blocking may prevent us from providing some or all of the Services to you. If you wish not to receive Cookies from us, with the exception of technical Cookies, you may notify us by following the instructions for opting out of such Cookies on our website or sending us an email to: privacy@Exchago.com. If you are accessing our website from the European Economic Area (“EEA”), the use of Cookies, including third party and persistent Cookies, shall be made in accordance with the laws applicable to you. If you have any questions about how we use Cookies not answered in this statement, you may contact us by sending us an email to: privacy@Exchago.com.

WHAT IS THE LAWFUL BASIS UNDER WHICH EXCHAGO PROCESSES PERSONAL DATA?

Certain processing activities conducted by us are based on the necessity of such activities for the performance of our website, Platform and/or Services and the contract between us and our Users. Other processing activities are based on the grounds that they are necessary for the purposes of our legitimate interests or the legitimate interests of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of natural persons which require protection of Personal Data. There may be certain processing activities based on your express consent. In connection with such activities, you may rescind your consent, by sending us an email to: privacy@Exchago.com. Please note that in the event you rescind your consent to the processing of Personal Data, we may not be able to provide you with some or all of the Services.

WILL I RECEIVE SPAM FROM EXCHAGO?

If you provide us with your email, or otherwise expressly consent to receive marketing materials, we may send you with information from time to time on new products, features, activities, services and also periodic announcements or newsletters which may interest you. By accepting this Privacy Policy, or otherwise indicating your consent to such materials, you hereby provide us with your explicit, written consent to receive marketing communications. Even after consenting to receive such communications you may at any time choose to opt-out and to not receive these communications, by contacting us at privacy@Exchago.com.

DOES EXCHAGO SHARE MY PERSONAL DATA?

ExchagoExchago does not sell, rent, lease or trade any of your personal data to non-affiliated third parties for such third parties’ marketing purposes. Please be aware that Non-Personal Data, aggregate and statistical or otherwise anonymized data may be shared without limitation with third parties at our sole discretion. This information does not contain any Personal Data and is used to provide and improve services for our Users and clients. We share Personal Data only under the following limited circumstances: As required to help detect and prevent potentially illegal acts and fraud, and to guide decisions about products, services and communications or as required under applicable laws and regulations. With trusted third parties under contractual obligations, who assist us in operating our website or Services, conducting our business, expanding our business or servicing you, and for personalizing your experience of the Services. To comply with a legal requirement, for the administration of justice, to protect your vital interests, to protect the security or integrity of our platform or the Services, to take precautions against legal liability, or in the event of a corporate sale, merger, reorganization, dissolution or similar event. With our affiliates and connected companies, such as subsidiaries, sister-companies and parent companies. Other third parties with your express consent or direction to do so. We engage and collaborate with the following third-party service providers and data processors in connection with our website, Platform and Services. We may share data regarding your use of our website, Platform or Services with these providers. We encourage you to review the privacy policies of the third parties specified below, by following the appropriate links: Hetzner Online GmbH. Privacy Policy available at: https://www.hetzner.com/rechtliches/datenschutz/. Online SAS France

WHAT KIND OF SECURITY MEASURES ARE USED BY EXCHAGO TO PROTECT MY DATA?

Exchago implements a variety of security measures to maintain the safety of your Personal Data as are customary in the industry with similar websites, platforms and/or services, both during transmission and once Exchago receives it. These measures will be continuously adjusted and updated in accordance with current industry standards. Nevertheless, these security measures cannot fully eliminate security risks associated with Personal Data. Therefore, while Exchago strives to use commercially acceptable means to protect Personal Data, Exchago cannot guarantee its absolute security, and therefore, Exchago shall not be liable for any damages caused by unauthorized access to your Personal Data.

TRANSFER OF DATA ACROSS INTERNATIONAL BORDERS

Our databases are currently operated by Hetzner Online GmbH. servers, located in the EU - Germany. Therefore, the hosting of Personal Data from the EEA in such servers located within the EU is permitted under the GDPR. Hetzner Online GmbH. terms of service and privacy policy is available at: https://www.hetzner.com/rechtliches/datenschutz and here: https://www.hetzner.com/rechtliches/agb/.

PERSONS UNDER THE AGE OF 18

Our website, Platform and/or Services are intended for general audiences, which are not directed to persons under 16 years old. If a parent or guardian becomes aware that his/her child has provided us with Personal Data without their consent, he/she should contact us immediately. We do not knowingly collect or solicit Personal Data from people under 16 years old. If we become aware that a person under 16 years old has provided us with Personal Data, we will delete such data from our databases.

LINKS TO THIRD-PARTY WEBSITES

Please note that we may link to other websites of third-parties that provide useful information/services. Any information User provides on the linked pages is provided directly to this third-party and is subject to that third-party’s provider’s privacy policy. Exchago is not responsible for the content or privacy practices of websites to which it links. Links from Exchago’s platform to third parties or other sites are provided for User’s convenience. You should learn about the privacy practices of each web site before providing them with Personal Data.

WHAT CAN I DO TO CONTROL MY PERSONAL DATA?

Right of Erasure and Restriction. You may request the erasure or the restriction of your Personal Data, and Exchago will comply with such requests, to the extent required under applicable law. Reviewing and Amending your Personal Data. You are entitled to review your Personal Data, and may exercise such right by sending us a request to: privacy@Exchago.com or sending a paper letter to Exchago’s Privacy Officer at the following address: Habankim 18, Haifa, Israel, 3326504. In the event any Personal Data is incorrect or outdated, you may update and correct such data by providing us with appropriate notification. Personal Data Portability of Personal Data. To the extent applicable to you and the Services, you may request the portability of your Personal Data, and we will comply with such requests, to the extent required under applicable law. Retention of Data. Exchago reserves the right to retain any Personal Data for as long as reasonably necessary in order to: (i) fulfill the purposes described herein; (ii) in the defense or assertion of legal claims and liability; (iii) for the analyses and improvement of the Services; and (iv) to comply with applicable law. Non-Personal Data and statistical anonymized data may be retained by us without limitation.

APPLICABLE LAWS

The provisions included in this Privacy Policy relating to matters regulated under the GDPR will apply only to the processing of Personal Data which is subject to the GDPR in accordance with the applicability provisions contained therein. If the GDPR does not apply to the processing of your Personal Data, some of the provisions above may not apply to you. For the purpose of this Privacy Policy “GDPR” means the General Data Protection Regulation (GDPR) (EU) 2016/679 as may be amended from time to time.

QUESTIONS OR CONCERNS REGARDING PRIVACY

This Privacy Policy is incorporated by reference into the Terms available at http://Exchago.com/terms. We may change the terms of this Privacy Policy at any time, so please review this page regularly. If required under applicable law, we will provide you with written notice of our changes. We will not make changes that have a material retroactive effect unless we are legally required to do so. Your continued use of the Services constitutes your acceptance of the amended policy. The amended Privacy Policy supersedes all previous versions, notices or statements of or about the Privacy Policy. If any provision of this Privacy Policy is held unenforceable, then such provision will be modified to the extent possible to reflect the parties’ intention. All remaining provisions of this Privacy Policy shall remain in full force and effect. If you have any questions or comments regarding this Privacy Policy, please contact us at privacy@exchago.com or sending a paper letter to Exchago’s Privacy Officer at the following address: Habankim 18, Haifa, Israel, 3326504. Facsimile copies can be sent to the following number:+972 (077) 220-0206 , however we do encourage you to reach out via email which is checked more often. You are also entitled to file a complaint with the appropriate supervisory authority in connection with concerns you may have with regards to your privacy and Personal Data.