Privacy Policy

This "Privacy Notice" describes the privacy practices of Smart.fun and Smart.fun Affiliates (collectively, "Smart.fun", "our", "us" or "we"), in connection with the Sites and the Smart.fun Platform (collectively, "Services"). This Privacy Notice also explains the rights and choices available to individuals with respect to their information.

Please read this Privacy Notice carefully to understand our policies and practices regarding your information. If you do not agree with our policies and practices, please do not use the Smart.fun Platform. By accessing or using the Smart.fun Platform, you acknowledge and agree to the terms of this Privacy Notice.

We may update this Privacy Notice based upon evolving laws, regulations and industry standards, or as we may make changes to the Smart.fun Platform. If we make changes that materially alter your privacy rights, we will take appropriate measures to inform you, consistent with the significance of the changes we make. If you disagree with the changes to this Privacy Notice, you should discontinue your access and use of the Smart.fun Platform.

Our Site and the Smart.fun Platform are not directed to, and we do not knowingly collect Personal Data from, anyone under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information, they should contact us. We will delete such information from our files as soon as reasonably practicable.

Personal Data Controller

The term "Personal Data" as used in this policy, describes information that can be associated with a specific person and can identify that person. Personal Data does not include information that has been aggregated or anonymized so that a specific person can no longer be identified. Any reference to "Personal Data" in this Privacy Notice includes without limitation "Personal Data" as defined by the Data Protection Act 2018.

A Personal Data controller is a person or organisation who controls the collection, holding, processing or use of Personal Data, including a person or organisation who instructs another person or organisation to collect, hold, process, use, transfer or disclose Personal Data on his or her behalf.

Types of Personal Data Collected

The types of Personal Data that we may collect from you or through third parties will depend on our interactions with you and may include:

• Financial information such as your wallet addresses;
• Transaction information such as the wallet addresses of senders and recipients of Digital Assets, activities on the Smart.fun Platform, your inquiries and our responses;
• Usage Data which can include your IP address, your country of origin, the features of the browser or operating system utilised by you, how you use the Smart.fun Platform, among other identifiers;
• Other personal data or commercial and/identification information that we, in our sole discretion, may deem necessary to comply with various applicable anti-money laundering laws and regulations.

Information We Automatically Collect

When you visit the Smart.fun Platform, we may automatically collect certain information about your device, including information about your web browser, IP address and/or domain name, IMEI or other device information, your login information, browser type and version, timezone setting, browser plug-in types and versions, operating systems and platforms, location information, and some of the cookies that are installed on your device using cookies and similar technologies. Additionally, as you browse the Site, we may collect information about the individual web pages or services that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site.

Cookies & Similar Technologies

We use cookies (small, often encrypted, text files that are stored on your computer or mobile device) and similar technologies ("Cookies") to provide you with certain functions on our Site and help collect data. This section explains how we use Cookies to collect information about the way you use our Site and how you can control them.

How We Use Cookies

We use Cookies to track how you use the Smart.fun Platform by providing usage statistics. Cookies are also used to deliver our information (including updates) and allow account authentication to you based upon your browsing history and previous visits to the Site.

Types of Cookies

We use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your device until you delete them). To make it easier for you to understand why we need them, the Cookies we use on our Site can be grouped into the following categories:

• Strictly Necessary: These Cookies are necessary for the Site to work properly. They include any essential authentication and authorisation Cookies for our Site.
• Functionality: These Cookies enable technical performance and allow us to remember the choices you make while browsing our Site, including any preferences you set. They also include sign-in and authentication Cookies and IDs that enable you to return without additional sign-in.
• Performance/Analytical: These Cookies allow us to collect certain information about how you navigate the Site and services running on your device. They help us understand which areas you use and what we can do to improve them.
• Targeting: These Cookies are used to deliver relevant information related to our Site to an identified machine or other device (not a named or otherwise identifiable person) which has previously been used to visit our Site. Some of these types of Cookies on our Site are operated by third parties with our permission and are used to identify advertising sources that are effectively driving customers to our Site.

How to Control and Delete Cookies

Cookies can be controlled, blocked or restricted through your web browser settings. Information on how to do this can be found within the Help section of your browser. All Cookies are browser specific. Therefore, if you use multiple browsers or devices to access websites, you will need to manage your Cookie preferences across these environments.

Google Analytics

We may use Google Analytics to help analyze how you use our Site. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated is used to create reports about the use of our Site. Google will store this information.

Method and Basis of Processing Data

Methods of processing

We take appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.

Legal basis of processing

We may process Personal Data relating to you if one of the following applies:

• You have given your consent for one or more specific purposes.
• Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;
• Processing is necessary for compliance with a legal obligation to which we are subject;
• Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us;
• Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

How We Use Personal Data

Data we collect about you is collected to:

• Provide the Site and Smart.fun Platform and customer support you request;
• Process transactions and send notices about your transactions on the Smart.fun Platform;
• Detect any malicious or fraudulent activity;
• Enable us to monitor and analyse your behaviour ("Analytics");
• Beta test certain features or the Smart.fun Platform;
• Contact you;
• Display content from external platforms;
• Handle productivity related activities;
• Provide social features;
• Optimise traffic and performance of the Smart.fun Platform;
• Allow us to register you as a user of the Smart.fun Platform and authenticate your credentials;
• Comply with legal obligations and respond to enforcement requests;
• Protect the rights and interests of Smart.fun and Smart.fun Affiliates;
• Infrastructure monitoring;
• Interaction with external social networks and platforms;
• Location-based interactions;
• Tag management;
• Engage in traffic optimisation and distribution.

How We Share Personal Data

We may share your Personal Data with our service providers and vendors to assist us in providing you with the Smart.fun Platform. We do not share your Personal Data with third parties without your consent, except as described in this Privacy Notice or as otherwise required or permitted by applicable law. We may share your Personal Data within our group, and with affiliates, for purposes consistent with this Privacy Notice.

Retention of Personal Data

We will 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, regulatory, accounting, or reporting requirements. We determine data retention based on the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from an unauthorised user, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and applicable legal requirements.

Privacy Technology Practices

Links to Third-Party Sites

The Smart.fun Platform may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your Personal Data. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Data Security

The security of your Personal Data is important to us. We employ a number of administrative, technical, and physical safeguards designed to protect the Personal Data we collect. The safety and security of your information also depends on you. We ask you not to share any of your personal security information.

Blockchain Transactions

Your use of digital assets may be recorded on a public blockchain, in particular the settlement of your trades in digital assets. 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 re-identification of transacting individuals and the revelation of personal data, especially when blockchain data is combined with other data.

Overseas Disclosure and Your Privacy Rights

For purposes of relevant data protection legislation, Smart.fun is the Personal Data controller. Smart.fun is a company with operations throughout the world. As a result, Personal Data may be transferred outside the country in which you reside for the purposes identified. Any such transfer of Personal Data shall take place under applicable law and will be protected through international data transfer agreements where necessary that have been recognised by relevant data protection authorities as providing an adequate level of protection to the Personal Data we process. By using the Smart.fund Platform you understand that your Personal Data may be processed in the United States and outside of the EEA and the UK.

Residents of the EEA and the UK are granted certain rights over their Personal Data, which include:

• The right to obtain confirmation of the Personal Data we process.
• The right to rectify inaccurate Personal Data that we process.
• The right to request erasure of your Personal Data, subject to exceptions provided under the law.
• The right to restrict certain processing of your Personal Data, so long as the processing is not necessary for the performance of or in relation to a contract or service to which you are a party.
• The right to receive your Personal Data in a structured, commonly used and machine readable format
• The right to object to the processing of your Personal Data, including the right to object to automated decision-making and profiling.
• The right to withdraw your consent where you have previously given it for the processing of your Personal Data

General

If you would like to exercise any of the rights listed above, or if you would like to contact us about any questions you may have regarding your Personal Data, please contact Support and provide (i) enough information to identify you and (ii) a description of what right you want to exercise and the information to which your request relates. Any Personal Data we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may contact us or your local data protection authority.