Novacest (“Novacest”, “we”, or “us”) is committed to protecting the privacy of our customers, and we take our data protection responsibilities with the utmost seriousness. This Privacy Notice describes how Novacest collects and processes your personal information through the Novacest websites and applications that reference this Privacy Notice. Novacest refers to an ecosystem comprising Novacest websites (whose domain names include but are not limited to https://novacest.com), mobile applications, clients, applets and other applications that are developed to offer Novacest Services, and includes independently-operated platforms, websites and clients within the ecosystem (e.g., Novacest’s Open Platform, Novacest Launchpad, Novacest Labs, Novacest Charity, Novacest DEX, Novacest X, JEX, and fiat gateways). “Novacest Operators” refer to all parties that run Novacest, including but not limited to legal persons, unincorporated organizations and teams that provide Novacest Services and are responsible for such services. “Novacest” as used in this Privacy Notice includes Novacest Operators. This Privacy Notice applies to all Personal Information processing activities carried out by us, across platforms, websites, and departments of Novacest and Novacest Operators. To the extent that you are a customer or user of our services, this Privacy Notice applies together with any terms of business and other contractual documents, including but not limited to any agreements we may have with you.

1. Novacest Relationship with you - Novacest, a company registered at 17, Reykjavik, Iceland (Mining Datacenter). is the data controller for personal information collected in connection with provision of Novacest services in Europe.. However, depending on your place of legal residence certain other Novacest entities could be involved in processing activities such as Know Your Customer (“KYC”) activities which are necessary for us to provide Services to you. For example, if you are resident in France, Novacest France SAS, is responsible for running KYC checks. These Novacest entities could act as Controllers of your personal information and use it in accordance with this Privacy Notice.

2. What Personal Information does Novacest collect and process? Why does Novacest process my personal information ? What are the legal basis for our use of personal information?
- email address; - name; - gender; - date of birth; - home address; - phone number; - nationality; - device ID; - a video recording of you and a photographic image; - transactional information; - the Internet protocol (IP) address used to connect your computer to the Internet; - login, e-mail address, password and location of your device or computer; - Novacest Services metrics (e.g., the occurrences of technical errors, your interactions with service features and content, and your settings preferences); - version and time zone settings;

Why does Novacest process my personal information?
- Transaction services. We use your personal information to process your orders, and to communicate with you about orders and services; - Communicate with you. We use your personal information to communicate with you in relation to Novacest Services; - We collect and process identity information and Sensitive Personal Data (as detailed in section I) to comply with our Know Your Customer (“KYC”) obligations under applicable laws and regulations, and Anti-Money Laundering laws and regulations;

Legal Basis for our use of personal information (EU and UK GDPR)
Performance of a contract when we provide you with products or services, or communicate with you about them. This includes when we use your personal information to take and handle orders, and process payments. Legal obligation; to comply with our legal obligations under applicable laws and regulations, and Anti-Money Laundering laws and regulations. Your consent when we ask for your consent to process your personal information for a specific purpose that we communicate to you. When you consent to processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing your personal information for that purpose. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

3. Can Children Use Novacest Services?
Novacest does not allow anyone under the age of 18 to use Novacest Services and does not knowingly collect personal information from children under 18.

4. Does Novacest Share My Personal Information?
We may share your Personal Data with third parties (including other Novacest entities) if we believe that sharing your Personal Data is in accordance with, or required by, any contractual relationship with you or us, applicable law, regulation or legal process. When sharing your Personal Information with other Novacest entities, we will use our best endeavours to ensure that such entity is either subject to this Privacy Notice, or follow practices at least as protective as those described in this Privacy Notice. For example, if you are resident in France, Novacest France SAS, is responsible for running KYC checks. We may also share personal information with the following persons: Third party service providers: We employ other companies and individuals to perform functions on our behalf. Examples include analysing data, providing marketing assistance, processing payments, transmitting content, and assessing and managing credit risk. These third-party service providers only have access to personal information needed to perform their functions, but may not use it for other purposes. Further, they must process the personal information in accordance with our contractual agreements and only as permitted by applicable data protection laws. Legal Authorities: We may be required by law or by Court to disclose certain information about you or any engagement we may have with you to relevant regulatory, law enforcement and/or other competent authorities. We will disclose information about you to legal authorities to the extent we are obliged to do so according to the law. We may also need to share your information in order to enforce or apply our legal rights or to prevent fraud. Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, the user consents otherwise). Also, in the unlikely event that Novacest or substantially all of its assets are acquired by a third party, user information will be one of the transferred assets. Protection of Novacest and others: We release accounts and other personal information when we believe release is appropriate to comply with the law or with our regulatory obligations; enforce or apply our Terms of Use and other agreements; or protect the rights, property or safety of Novacest, our users or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction.

5. International transfers of Personal Information
To facilitate our global operations, Novacest may transfer your personal information outside of the European Economic Area (“EEA”), UK and Switzerland. The EEA includes the European Union countries as well as Iceland, Liechtenstein, and Norway. Transfers outside of the EEA are sometimes referred to as “third country transfers”. We may transfer your personal data within our Affiliates, third-party partners, and service providers based throughout the world. In cases where we intend to transfer personal data to third countries or international organisations outside of the EEA. Novacest puts in place suitable technical, organizational and contractual safeguards (including Standard Contractual Clauses), to ensure that such transfer is carried out in compliance with applicable data protection rules, except where the country to which the personal information is transferred has already been determined by the European Commission to provide an adequate level of protection. We also rely on decisions from the European Commission where they recognise that certain countries and territories outside of the European Economic Area ensure an adequate level of protection for personal information. These decisions are referred to as “adequacy decisions”. We transfer personal data to Japan on the basis of the Japanese Adequacy Decision.

6. How Secure is My Information?
We design our systems with your security and privacy in mind. We have appropriate security measures in place to prevent your information being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We work to protect the security of your personal information during transmission and while stored by using encryption protocols and softwares. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personal information. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. Our security procedures mean that we may ask you to verify your identity to protect you against unauthorised access to your account password. We recommend using a unique password for your Novacest account that is not utilized for other online accounts and to sign off when you finish using a shared computer.

7. How Long Does Novacest Keep My Personal Information?
We keep your personal information to enable your continued use of Novacest Services, for as long as it is required in order to fulfil the relevant purposes described in this Privacy Notice, and as may be required by law such as for tax and accounting purposes, compliance with Anti-Money Laundering laws, or as otherwise communicated to you.

8. Notices and Revisions
If you have any concerns about privacy at Novacest, please contact us, and we will try to resolve it. You also have the right to contact your local Data Protection Authority. Our business changes regularly, and our Privacy Notice may change also. You should check our websites frequently to see recent changes. Unless stated otherwise, our current Privacy Notice applies to all information that we have about you and your account.