Privacy Policy

EFFECTIVE DATE: February 23, 2023

This Privacy Policy (this "Policy") applies to the trading platform (including any applicable mobile applications and websites used to access it) (collectively the "BitYetu Platform") provided by Zebraya (SU), LDA (the “Company”, “we”, “us” or “our”). It describes how the Company collects, uses and discloses Personal Information we obtain from Users of the Platform and any account services provided through the Platform, and how we use and disclose that information. For purposes of this Policy, "Personal Information" refers to information provided by a User from which that User's identity can be determined directly or indirectly.

By registering and using the Platform, you agree that your Personal Information will be treated as described in this Policy and the Terms and Conditions applicable to the Platform (the "Service Agreement"); Capitalized terms used herein shall have the same meaning as set forth in the Service Agreement.

The Information We Collect About You and How We Collect It

We collect and process personal information about you directly from you when you register to use the Platform or submit such information as part of Know Your Customer ("KYC"), as well as automatically through your use of the Platform.

Information We Collect Directly From You.

Personal Account and Profile Information: There are several types of accounts that can be established on the Platform. We collect the following information when you register an Account: name, mobile phone number and/or email address. When your Account meets certain standards, we may collect additional information: name as per ID card/passport, ID card/passport number, date of birth, nationality, mailing address, home address, cell phone number, and street address. email.

Financial Information: We may collect additional financial and investment information from you to confirm your status and eligibility to set up other types of accounts or perform certain transactions on the Platform, including your investment experience, financial qualifications (including any certifications received, issuing organization and date issuance), your annual income level, net net worth, estimated net worth, source of funds and source of wealth, and whether you have been refused an account opening by another financial institution.

Other Required Information: We may need to collect certain additional information to comply with legal requirements, such as whether you are a Politically Exposed Person or on a restricted list, and applicable tax reporting forms, such as a W8-BEN.

Communications with Us: We collect information that you provide to us during any support and feedback communications via email or when you contact us via contact forms on the Platform. We use this information to respond to your questions, provide support, facilitate transactions, and improve our Platform.

Please note that if you are acting as an Authorized Individual on behalf of a User and are providing Personal Information to that User, you are responsible for ensuring that you have all necessary permissions and consents to provide such Personal Information to us for use in connection with the Platform and that our use of such Personal Information that you provide to the Platform does not violate any applicable law, rule, regulation or order.

Information Collected Automatically.

When you use the Platform, our servers automatically record information using cookies and other tracking technologies, including information that your browser sends whenever you visit the Platform or your mobile application sends when you are using it. This log data may include your Internet Protocol address, the address of the web page you visited before accessing the Platform, your browser type and settings, the date and time of your request, information about your browser configuration, your browser and plug-ins, language preferences and cookie data. Such log data is not routinely deleted.

In addition to log data, we may also collect information about the device you use to access the Platform, including the type of device, the operating system you are using, device settings, unique device identifiers, and crash data. Whether we collect any or all of this information may depend on the type of device you are using and its settings.

We may combine this information with other information we collect about you, including, where applicable, your name, username, email address and other Personal information.

Geolocation. If you have granted permission through your mobile device to allow us to collect location information through a mobile application, we may obtain your physical location information in terms of latitude and longitude from technologies such as GPS, Wi-Fi or cell tower proximity. You may withdraw your permission for us to acquire such physical location information from your mobile device through your mobile device settings, although we do not control this process. If you have questions about how to disable location services on your mobile device, we recommend that you contact your mobile device service provider or the manufacturer of your mobile device.

How We Use Your Information

We use your information, including your Personal Information, for the following purposes:

· To provide our Platform to you, facilitate communications and transactions on the Platform, communicate with you regarding your use of our Platform, respond to your inquiries, fulfill your requests, and for other customer service purposes;

· To tailor the content and information we may send or display to you, offer location customization, personalized help and instructions, and otherwise personalize your experiences when using our Platform;

· To better understand how users access and use the Platform, both on an aggregated and individual basis, in order to improve our Platform and respond to users' desires and preferences, and for other research and analytical purposes;

· For marketing and promotional purposes. For example, we may use your information, such as your email address or contact number registered with us, to send you news and newsletters, special offers and promotions, run prize draws and competitions, or to contact you about products or information that we think you will find useful. may interest you. We may also use the information we learn about you to help us advertise our Platform on third-party websites.

How we share your information:

- Affiliates: We may disclose the information we collect from you to our affiliates or subsidiaries solely for the purpose of providing the Platform or related services, including subsite services, to you; however, if we do so, the use and disclosure of your personally identifiable information will be maintained by such affiliates and subsidiaries in accordance with this Policy.

- Service Providers: We may disclose the information we collect from you to third-party vendors, service providers, contractors or agents who perform functions on our behalf, provided that such third parties have agreed to use such information only to provide services to us.

- Business Transfers: If we are in negotiations with, or are acquired by or merged with, another company or entity, if substantially all of our assets are transferred to another company or entity, or as part of bankruptcy proceedings, we may transfer information that we collect from you to the other company or entity.

- In Response to Legal Processes: We may also disclose the information we collect from you to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a subpoena.

- To Protect Ourselves and Others: We may also disclose information we collect from you if we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Agreement of Service or this Policy, or as evidence in litigation in which we are involved.

- Aggregated and De-Identified Information: We may collect, process, analyze and share aggregated or de-identified information about users with third parties and publicly for product development, marketing, advertising, research or similar purposes.

Our Use of Cookies and Other Tracking Mechanisms:

We and our third-party service providers use cookies and other tracking mechanisms to track information about your use of our Platform. We may combine this information with other personal information we collect from you (and our third-party service providers may do this on our behalf).

- Cookies: Cookies are alphanumeric identifiers that we transfer to your computer's hard drive through your web browser for record keeping purposes. Some cookies allow us to facilitate your navigation on our Platform, while others are used to enable a faster login process or to allow us to track your activities on our Platform. There are two types of cookies: session and persistent.

  - Session Cookies: Session cookies only exist during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Platform. This allows us to process your online transactions and requests and verify your identity, after you have logged in, while you browse our Platform.

  - Persistent Cookies: Persistent cookies remain on your computer after you close your browser or turn off your computer. We use persistent cookies to track aggregate and statistical information about user activity.

  Please note that our systems do not currently respond to “do not track” signals.

Disabling Cookies: Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The general settings on most browsers will show you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies completely. Users of our Platform who disable cookies will not be able to browse certain areas of the Platform.

- Third Party Analytics: We use automated devices and applications, such as Google Analytics, to evaluate the use of our Platform. We may also use other analytical means to evaluate our Platform. We use these tools to help us improve our Platform, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your personal information with these third parties.

Third Party Links

Our Platform may contain links to third party websites. Any access to and use of these linked sites is not governed by this Policy, but rather by the privacy policies of those third-party sites. We are not responsible for the information practices of these third-party sites.

Security of Your Personal Information

We implement reasonable precautions in accordance with applicable laws and regulations to protect the Personal Information we collect from loss, misuse, unauthorized access, disclosure, alteration and destruction. Please be aware that despite our efforts, no data security measures can guarantee 100% security. Therefore, all Users (including your Authorized Individuals) of the Platform must comply with the security requirements in the Terms and take the following additional measures to help ensure the security of your Personal Information and access to your account:

(a) You must choose a robust user ID, password and PIN to access your account ("User Credentials") that no one else knows or can easily guess. User Credentials must meet the requirements we specify when you establish such User Credentials. You must keep your User Credentials secure and private, and not share them with third parties

(b) You must install antivirus, antispyware and firewall software on your personal computers and mobile devices;

(c) You must update operating systems, antivirus and firewall products with security patches or newer versions regularly;

(d) You must remove file and printer sharing on computers, especially when they are connected to the internet;

(e) You must make regular backups of your critical data;

(f) You should consider using encryption technology to protect highly sensitive or confidential information;

(g) You must completely log out and clear your browser cache after each online session with the Platform;

(h) You must not install software or run programs of unknown origin;

(i) You must delete unwanted or threaded emails;

(j) You must not open email attachments from strangers;

(k) You must not disclose personal, financial or credit card information to little-known or suspicious websites;

(l) You must not use a computer or device that cannot be trusted; It is

(m) You must not use public or internet café computers to access online services or carry out financial transactions.

You must immediately notify us at [email protected] if you become aware of any unauthorized use or access of your Account or User Credentials. We are not responsible for any lost, stolen or compromised User Credentials or for any activity on your Account via unauthorized activity using your User Credentials.

Access, correction and deletion rights

You may access, edit, update or delete your Account or Personal Information we have collected at any time by accessing your account settings or emailing us at [email protected] . We will respond to your requests within a reasonable period of time, but at most within the period of time required by law.

Please note that, notwithstanding the foregoing, there may be circumstances in which we are unable to accommodate a request to edit, update, access or delete an account profile or Personal Information. This includes, but is not limited to:

any basis on which such request may be denied under applicable law;

where we need to retain information to comply with federal, state or local laws or for accounting or tax purposes;

where we need to comply with a civil, criminal or regulatory investigation, subpoena or summons by federal, state or local authorities;

where we need to cooperate with law enforcement agencies regarding conduct or activity that the business, service provider or third party reasonably and in good faith believes may violate federal, state, country or local law;

where we need to retain information to exercise or defend legal claims;

where the information contains legal privilege or proprietary information of another party; or

·where complying with the request would compromise the privacy of others or other legitimate rights.

If we determine that we are unable to respond to any particular request, we will provide an explanation of why that determination was made and a point of contact for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before responding to any request under this provision, including complying with any applicable legal requirement to verify your identity.

Information Transfer

Please note that we may store your Personal Information on servers located in the countries where our main offices are located. If such jurisdiction is outside your jurisdiction of residence, you consent to the transfer of your Personal Information to such jurisdiction for the purpose of providing the Platform to you, even if such other jurisdiction has fewer protections for Personal Information than your jurisdiction of residence . We will ensure that security provisions are in place consistent with our obligations to maintain the security of your Personal Information under the laws of your jurisdiction of residence.

Retention

We retain your Personal Information for as long as you maintain an Account on the Platform. We will stop retaining your Personal Information, or remove the means by which Personal Information can be associated with specific individuals, as soon as it is reasonable to assume that:

(a) the purpose for which such Personal Information was collected is no longer being served by its retention; It is

(b) retention is no longer required for legal, accounting or business purposes.

Please note that certain laws may require us to maintain records of transactions or accounts for a certain period of time.

Children Under 18

Our Platform is not designed for children under the age of 18. If we discover that a child under 18 has provided us with Personal Information, we will delete such information from our systems.

Contact us

If you have questions about the privacy aspects of our Platform or would like to make a complaint, please contact us via our live chat services or at [email protected] .

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on the Platform. If we make any changes to this Policy that materially affect our practices with respect to Personal Information we have previously collected from you, we will endeavor to provide you with advance notice of such change by highlighting it on our Platform or providing a push notification through the Site (you you must ensure that your Site settings allow for such push notifications) or by sending an email that you have provided in your Account, (for this reason, please be sure to update your account information promptly if it changes).