(A) Please read this Privacy Policy carefully. This Privacy Policy constitutes an integral part of the Terms of Use (the «Terms») entered into between you, a user and a data subject (the «User») and us, STSS (Malta) Limited (the «Company»). Capitalised terms used in this Privacy Policy and not otherwise defined herein shall have the meaning ascribed to them in the Terms.

(B) This Privacy Policy comprises the accepted international and European data privacy principles (including the GDPR) without replacing existing national laws. It supplements national data privacy laws in each jurisdiction where the Company operates. The relevant national law will take precedence in the event of conflict with this Privacy Policy or where it has stricter requirements. This Privacy Policy must also be observed in the absence of corresponding national legislation.

(C) This Privacy Policy describes the Company’s privacy practices with regard to how the Company collects, stores, uses, shares, discloses and protects your Personal Data obtained through the Site or any of our Apps. «Personal Data» includes any data about you that specifically identifies you as an individual and information about your activities, such as information about your access and use of the Site, any of our Apps (and any related services which the Company may provide to you) (the «Service»), when directly linked to personally identifiable information, any other information and data which this Privacy Policy describes as collectable by us.

(D) The Service is provided by the Company at no cost and is intended for use on an «as is» basis.

(E) By using the Service, you accept this Privacy Policy and consent to the collection, storage, sharing, use and disclosure of your Personal Data in accordance with this Privacy Policy and applicable laws and regulations. You may withdraw your consent and require removal of your Personal Data by contacting us using the information below.

(A) When you use the Service, we may request to provide data which is necessary for the provision of the Service and the use of the Service. When we ask for certain personal information from users it is because we may be required by law to collect this information or it is relevant for specified purposes.

(B) Any non-required information you provide to us is done so voluntarily. You decided whether to provide us with these non-required information; you may not be able to access or utilize all of the Services if you choose not to.

(C) We may collect some Personal Data automatically (your IP address, cryptocurrency address, email, text, code, browser type and version, information about your visits (including the URL clickstream) to, through and from, the Service, web pages you viewed or searched for, length of visits to certain web pages, web page interaction, etc), through the use of tracking technologies, including cookies .

(D) All processing of Personal Data is carried out by the Company or its employees in accordance with the principles enshrined in the GDPR, being the following:

• fairness and lawfulness
• limited to purpose of collection (purpose limitation)
• transparency
• data minimisation
• storage limitation and deletion
• factual accuracy
• confidentiality and integrity of Personal Data
• accountability

We may use and process your Personal Data for the following purposes:

• proper provision of the Service or processing connected to a contractual relationship;
• compliance with applicable law and regulations or a legal authorisation;
• registration if any on the Site;
• following your consent to data processing;
• processing of your inquiries and operations in relation to the Service;
• preventing, detecting and investigating potentially prohibited or illegal activities, including fraud and activities in breach of the Terms and to enforce our Terms and other agreements, or otherwise processing pursuant to a legitimate interest which merits protection;
• investigation and/or enforcement of violations of this Privacy Policy, or to protect our interests and legal rights and, if required by law, those of our users;
• sending you marketing emails with the information about our Service and other products that we deem to be interesting for you. You may opt out of such emails by sending the respective request to us or by clicking the respective link in the email.

(A) The Company and its employees treat Personal Data as confidential and may not pass on or use any of such data without valid legal grounds as indicated above. We may disclose some information which constitutes Personal Data with certain third parties. Therefore normally we do not share such information with companies, organizations and individuals outside of the Company unless one of the following circumstances applies:
(i) where we have a good-faith belief that access, use, preservation or disclosure of the Personal Data is reasonably necessary to:

• meet any applicable law, regulation, legal process or enforceable governmental request;
• enforce applicable actions, including investigation of potential violations;
• detect, prevent, or otherwise address fraud, security or technical issues;
• protect against harm to the rights, property or safety of the Company, our users or the public as required or permitted by law;

(ii) we may share non-personally identifiable information publicly and with our partners (for example, where we wish to show trends about the general use of the Service);
(iii) if the Company is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any Personal Data and give affected Users notice before Personal Data is transferred or becomes subject to a different privacy policy.

(B) We may hire other companies to perform certain business-related functions such as processing payments on our behalf. Our payment processing partner may request that you provide certain Personal Data (for example, a valid government-issued ID, your legal name, address, and date of birth, banking credentials, etc.) for the purpose of making payment through its financial institutions and complying with any applicable laws and regulations. They may also communicate directly with you regarding any issues as to a payment. Any information provided to such third party will be confidential and only be used for intended purposes.

(A) We do not sell, provide on lease, or share any Personal Data of the Users to third parties.

(B) Our Service may contain links to and from third parties’ websites, apps or other services (including social media). If you follow a link to any of them, please note that those websites have their own privacy practices and policies. We shall not be liable for the respective policies and any collection, use or disclosure of your Personal Data in accordance thereto. Please check the third parties’ policies before you submit any Personal Data to their services.

(C) When we use third-party vendors to perform certain services on behalf of us, such as hosting the site or application, analytical or other services, such third-party vendors may collect or have access to information about you (for example, automatically collected information through tracking technologies). Please recognize that we and/or our vendors may store this information and share this information with third parties as necessary to provide you with the Service.

(D) No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

(A) We will use all reasonable measures to protect your Personal Data from unauthorized access, alteration, disclosure or removal. The Service is equipped with the means of security and protection of your Personal Data.

(B) Immediate access to your Personal Data is allowed only to us and persons authorized by us and involved in the maintenance of the Service. Such persons have been instructed to keep strict confidentiality of and prevent unauthorized third-party access to your Personal Data.

(C) Please remember that the Service (and your Personal Data) may be hosted on a server outside your home country. Supplying us with your Personal Data, you permit its transfer outside the country, within the bounds of use of such Personal Data in accordance with the applicable law.

(D) Transmission of Personal Data to recipients by the Company, both internally and externally, is subject to the authorisation requirements and pursuant to defined purposes, as specified above. Personal Data transmitted to a recipient outside the EEA must be subject protection at least equivalent to that sought by the GDPR.

(E) We emphasize that none of the existing ways of data transfer can be absolutely safe. The Company does not guarantee the absolute security of data in case of unauthorized access of the third parties.

(F) We shall not be responsible for unlawful acts of third parties, hackers, intruders, and other offenders of applicable legislation that can violate the provisions of this Privacy Policy and try to collect, either fully or in part, your Personal Data and to use it for personal advantages.

(A) We do not collect, use or share the Personal Data of children (under the age under the applicable law). You must be a legal adult to access the Service under the applicable law and the law of the country where you are located.

(B) While individuals under the childhood age may use the Service, they shall do so only with the involvement, supervision, and approval of a parent or legal guardian. At any case, we are committed to comply with applicable laws and requirements of the residence country.

(A) To ensure that the Site and our Apps functions properly, we may use various tracking technologies like cookies, web beacons or similar technologies. By using the Site and any App, you provide us your consent for our using of cookies and similar tracking technologies under the terms hereof.

(B) Cookies are small data files that are commonly stored on your device when you browse and use online services. They are widely used to make web applications work or to work more efficiently, as well as to provide reporting information and assist with service or advertising personalization.

(C) We, or third parties with our permission, may use cookies in the following ways:

• to manage our business and improve the Service based on factors such as how many users visit or use the Service, what pages and views are accessed, whether visitors are new or repeat visitors, which features of the Service most interest our visitors etc.;
• to provide personalized recommendations, advertising, marketing emails, and guidance on Service features based on your activity using the Service and browsing activities;
• to remember actions you took to avoid asking you to repeat them during a session or to provide features such as enabling you to resume reading at the last page you accessed, synchronized across devices;
• to measure and analyze activity on our services, or third-party services. In addition, we or any provider of such measurement and analytical services may provide non-personally identifiable data to third parties.

(D) The User may block, clear and delete cookies in accordance with the instruction for their web-browser or device.

Every User has the following rights in relation to the processing of his or her Personal Data in accordance with the GDPR and other applicable law:

• right of access
• right of rectification
• data portability
• right to erasure
• right to restrict processing
• right to object to processing

We have the right to amend this Private Policy at any time, without prior notice to each User. Any changes we may make to our Privacy Policy in the future will be posted here. Please check back frequently to see any updates or changes to our Privacy Policy.

If at any time you would like to contact us or the Company’s Data Protection Officer with your views about our privacy practices, or with any inquiry relating to your Personal Data (its correction, removal or use) or the exercise of any of your rights described above or would like to receive the Company’s Data Protection Policy, you can do so by sending a letter to our email address: [email protected].