UnitedCoin

UnitedCoin, Inc. manages www.unitedcoin.org (the “Site”). This page informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of the Site.

We use your Personal Information only for providing and improving the Site. By using the Site, you agree to the collection and use of information in accordance with this policy.

1. Introduction

This Privacy Policy applies to the processing activities performed by UnitedCoin to the personal data of its clients, prospective clients, and website visitors.

Your privacy is of the utmost importance to us. It is our policy to safeguard the confidentiality of information and respect the privacy of individuals.

Please see below for information about how we manage personal data, and for information about your rights with respect to the processing of your personal data.

2. Definitions

The following terms are defined as follows:

2.1 “AML” means anti-money laundering.

2.2 “Digital Asset” means any digital representation of value that may be traded via UnitedCoin’s services, excluding non-fungible tokens. 2.3 “UnitedCoin”, “We”, “Us”, "Our", refers collectively to UnitedCoin, Inc. its partners, and its subsidiaries.

2.4 “Personal data” refers to any information relating to an identified or identifiable natural person, including names, identification numbers,

location data, an online identifier, or to one or more factors specific to the physical, economic, cultural or social identity of a natural person.

3. Your Data Controller

You are contracting with UnitedCoin. The company you are contracting with is your Data Controller, and is responsible for the collection, use, disclosure, retention and protection of your personal data in accordance with our global privacy standards, this Privacy Policy, as well as any applicable laws.

4. Protecting personal data

UnitedCoin takes the security of personal data incredibly seriously. The security of your Personal Information is important to us, however remember no method of transmission over the Internet, or method of electronic storage, is 100% secure. We strive to use commercially acceptable means, including but not limited to encryption and cold storage, to protect your Personal Information, we cannot guarantee its absolute security.

5. Information we may collect about you

We obtain information about you in a number of ways through your use of our products and services, including through any of our websites, the account opening process, sign-up forms, subscribing and from information provided over the course of support communications.

In order to open an account with us, you must first complete and submit a “create account” form to us by completing the required information. By completing this form, you are requested to disclose

personal data in order to enable UnitedCoin to assess your application and comply with the relevant laws and regulations.

The minimum information required for entering into a contract governing your use of our products and services, and for enabling us to comply with our statutory obligations in respect of anti-money laundering and crime and fraud prevention, is biographical information and contact information, verification information, PEP information, and financial information.

The information that we may collect from you is as follows: • Full name, residential address and contact details (e.g. email address, telephone number etc.), date of birth, place of birth, gender, citizenship;

• Bank account information, wallet addresses, credit card details, details about your source of funds, assets and liabilities, and information relating to economic and trade sanctions lists;

• Trading account balances, trading activity, your inquiries and our responses;

• Information on whether you (or someone close to you) holds a prominent public function;

• Verification information, which includes information necessary to verify your identity such as a passport, driver’s license, selfie photos / videos, login credentials or Government-issued identity card;

• Other personal data or commercial and/or identification information – Information necessary to comply with our legal obligations.

Information we collect about you automatically:

Like many site operators, we collect information that your browser sends whenever you visit our Site (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics.

In addition, we may use third party services such as Google Analytics that collect, monitor and analyze this data for the purpose of extracting insights into visitors to our website and thereafter to improve, promote and market our services.

Information we receive about you from other sources.

We also receive information about you from third parties such as your payment providers, our service providers assisting with AML, fraud, and security compliance, and through publicly available sources. For example:

• The banks you use to transfer money to us will provide us with your basic personal data, such as your name and address, as well as your financial information such as your bank account details.

• Advertising networks, analytics providers and search information providers may provide us with anonymized or de-identified information about you, such as confirming how you found our website.

• Our service providers may provide us with information relating to fraud, security, sanctions and AML and other risks, for example,

confirmation of identity attributes, and information about any attributes linked to such matters.

• Credit reference agencies may provide us with your personal data during the credit referencing process.

6. Our legal justification for processing personal data

We process the following personal data:

• Biographical information

• contact information

• address information

• financial information

• trading information

• PEP information (where relevant)

• verification information

• other information

• browser information

• log information

The legal justification we have for processing personal data includes but is not limited to:

• Performance of a contract

• Legal obligation to comply with “Know your customer” and customer due diligence regulatory obligations.

• Legal obligation to comply with anti-money laundering laws, financial services laws, corporation laws, privacy laws, tax laws and other relevant laws.

• In order to ensure effective provision of our products and services and to meet our clients’ needs it is in our legitimate interest to

administer our products and services, to provide you with information about our products or services, to troubleshoot our products and services and to review our clients’ ongoing needs. It is also in our legitimate interest to improve our products and services, including support services and to develop and market new products and services.

• Consent

• To ensure the addresses clients submit are accurate. For additional information, please see Google’s privacy notice.

• Legal obligations to keep certain records.

• Legal obligation.

7. Disclosure of your personal data

As part of processing your personal data for the purposes set out above, UnitedCoin may disclose your personal data to members of the UnitedCoin company group, and to third parties. For example, UnitedCoin may disclose your personal data to any of our service providers and business partners, for business or other legitimate purposes, such as specialist advisors who have been contracted to provide us with administrative, financial, legal, tax, compliance, insurance, IT, debt-recovery, analytics, research or other services. If UnitedCoin discloses your personal data to service providers and business partners, in order to perform the services requested by clients or to comply with our legal and regulatory obligations, such providers and partners may store your personal data within their own systems. We require them to protect the confidentiality of this personal data, and comply with all relevant privacy and data protection laws.

8. Where we store your personal data

Our operations are supported by a network of computers, servers, other infrastructure and information technology, and third-party service providers. We and our third-party service providers and business partners store and process your personal data in the European Union, Japan, Australia, the United Kingdom, the United States of America and elsewhere in the world. Courts, law enforcement and security agencies of these jurisdictions may be able to use legal processes to access your personal data.

9. For UK & EEA clients: Transfers of personal data outside of the European Economic Area (EEA) and the United Kingdom (UK)

We may transfer your personal data outside the EEA and UK to other UnitedCoin group companies, service providers and business partners. Transfers outside of the EEA or the UK (as appropriate) shall be in accordance with lawful transfer mechanisms. If personal data is transferred to a country which has been found by the European Commission to have an essentially equivalent standard of data protection to the EEA, then UnitedCoin may rely on an ‘adequacy decision’ to transfer that personal data. If personal data is transferred from the EEA or UK to the US, we may rely on standard contractual clauses.

10. Privacy when using digital assets and blockchains

Your use of digital assets may be recorded on a public blockchain. 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.

As blockchains are decentralized or third-party networks which are not controlled or operated by UnitedCoin, we are not able to erase, modify, or alter personal data on such networks.

11. Data retention

When personal data is no longer necessary for the purposes for which it may lawfully be processed, we will remove any details that will identify you, or we will securely destroy the relevant records. We may need to maintain records for a significant period of time after you cease being our client for legal or regulatory reasons, for example when we need to retain information to help manage a dispute or legal claim. Additionally, we are subject to certain anti-money laundering laws which may require us to retain the following for a period (e.g., 5 years) after our business relationship with you has ended:

• A copy of the records we used in order to comply with our client due diligence obligations;

• Supporting evidence and records of transactions with you, and your relationship with us.

If you have opted out of receiving marketing communications we will hold your details on our suppression list so that we know you do not want to receive these communications.

We may keep your personal data for longer than 5 years if we cannot delete it for legal, regulatory, or technical reasons.

12. Cookies

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your device’s hard drive.

Like many sites, we use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.

We use cookies to help us recognize you as a customer, collect information about your use of our products and services, to better customize our services and content for you, and to collect information about your computer or other access devices to ensure our compliance with our U.S. Bank Secrecy Act, fraud, security, sanctions and AML obligations.

13. Your rights regarding your personal data

The rights that are available to you in relation to the personal data we process are outlined below. You may request to exercise these rights subject to any limitations provided for under applicable data protection laws.

Access

You can ask us to confirm whether we are processing your personal data and, if so, what information we process and to provide you with a copy of that information.

Rectification

It is important to us that your personal data is up to date. We will take all reasonable steps to make sure that your personal data remains accurate, complete and up-to-date. Please inform us if your personal data changes. If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have disclosed

your personal data to others, we will let them know about the rectification where possible. If you ask us, and if possible and lawful to do so, we will also inform you with whom we have shared your personal data.

You may inform us at any time that your personal details have changed by emailing us at support@unitedcoin.org. Subject to applicable law, UnitedCoin will change your personal data in accordance with your instructions. To proceed with such requests, in some cases we may need supporting documents from you as proof i.e. personal data that we are required to keep for regulatory or other legal purposes.

Erasure

You can ask us to delete or remove your personal data in certain circumstances. Such requests may be subject to any retention limits we are required to comply with in accordance with applicable laws and regulations. If we have disclosed your personal data to others, we will let them know about the erasure request where possible. If you ask us, and if possible and lawful to do so, we will also inform you with whom we have shared your personal data.

Processing restrictions

You can ask us to block or suppress the processing of your personal data in certain circumstances such as if you contest the accuracy of that personal data or object to us processing it. It will not stop us from storing your personal data. If we have disclosed your personal data to others, we will let them know about the restriction of processing if possible. If you ask us, and if possible and lawful to do so, we will also inform you with whom we have shared your personal data.

Data portability

In certain circumstances you may have the right to obtain personal data you have provided to us, in a structured, commonly used and machine-readable format, and to re-use it elsewhere or ask us to transfer this to a third party of your choice, where technically feasible.

Objection

You can ask us to stop processing your personal data, and we will do so, if we are:

• Relying on our own or someone else’s legitimate interests to process your personal data except if we can demonstrate compelling legal grounds for the processing or for the establishment, exercise or defense of legal claims;

• Processing your personal data for direct marketing; or

• Processing your personal data for research unless we reasonably believe such processing is necessary for the performance of a task carried out for reasons of public interest (such as by a regulatory or enforcement agency).

Automated decision-making and profiling

If we have made a decision about you based solely on an automated process (e.g. through automatic profiling) that affects your ability to access our products and services or has another significant effect on you, you can request not to be subject to such a decision unless we can demonstrate to you that such decision is necessary for entering into, or the performance of, a contract between you and us. Even if a decision is necessary for entering into or performing a contract, you may contest the decision and require human intervention. We may not be able to offer our products or services to you, if we agree to such a request (i.e. end our relationship with you).

Complaints

We ask that you contact support@unitedcoin.org to give us an opportunity to address any concerns. You have the right to complain to a data protection authority.

Withdraw consent

You have the right to withdraw consent to processing based on consent at any time. Note this will not affect the lawfulness of processing based on consent prior to the withdrawal of consent or on grounds where consent is not required.

14. Changes to this Privacy Policy

This Privacy Policy is effective as of 24 March 2024 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

15. Our products and services are not available to children

Our products and services are not directed to persons under the age of 18 (herein, “Children”, “Child”) and we do not knowingly collect

personal data from children. If we learn that we have inadvertently processed personal data from a child, we will take legally permissible measures to remove that data from our records. UnitedCoin will require the child user to close his or her account and will not allow the use of our products and services. If you are a parent or guardian of a child, and you become aware that a child has provided personal data to us, please contact us at support@unitedcoin.org

16. Contact information

Any questions, complaints, comments and requests regarding this Privacy Policy are welcome and should be addressed to support@unitedcoin.org.