1.1. This Privacy Policy sets forth the terms and conditions on how your name and other personal data relating to you will be held, maintained, recorded, processed, stored, disclosed, transferred, or used.

This Privacy Policy constitutes a legally binding agreement between the Company – CIFRA FZCO (1797 DMCC Business Centre, Level No 1, Jewellery & Gemplex 3, Dubai, United Arab Emirates) ("We", "Us", "Our") – and each registered or unregistered end user ("User", "you" or "your") of the Website (cifra.com) and the App – "CIFRA".

Users agree that CIFRA FZCO may authorize Cifra Inc. (1201 N. Orange Street, Suite 7587, Wilmington, New Castle County, Zip Code 19801-1186) to process Users' personal data in accordance with the applicable law and current Privacy Policy.

<strong>CIFRA</strong> holds your privacy with due care, and we acknowledge that we will abide and comply with the laws, rules, regulations, and customary practices in the United Arab Emirates pertaining to data protection and privacy.

We reserve the right to amend this Privacy Policy from time to time.

<strong>Please review this Privacy Policy carefully. Before accessing and using the Website (the App) you shall confirm that you have fully read and understand all provisions of this Privacy Policy and its implications.</strong>

1.2. By registering, accessing, or using CIFRA including visiting the Website or the App, you agree and confirm that you accept the requirements, policies and practices provided in this Privacy Policy and you acknowledge and adhere to practices, requirements, and/or policies outlined in this Privacy Policy.

You hereby consent to collection, storage, processing, disclosure and use of your personal data and other relevant data by CIFRA as more particularly described herein.

1. Introduction

2.1. Sources of information

<table>
<tr><td>Given to Us by You:</td><td>your Data, User’s content (i.e. information or content you uploaded and made available via the Website or the App).</td></tr>
<tr><td>Collected by us automatically:</td><td>your activity, equipment and geolocation information and others. The technologies we use for this automatic data collection may include cookies, web beacons.</td></tr>
<tr><td>Other information:</td><td>demographic, statistical, or other aggregate information that is about you, but individually does not identify you (such as age, gender etc.); publicly-available sources such as open government databases or social networks; or updates to that information, based on their relationship with you).</td></tr>
</table>

To access our services, you will require to submit certain Personal Data. Upon creation of your account, the following personal information can be collected from you:
<ol>
<li>Name</li>
<li>Date of Birth</li>
<li>Email address</li>
<li>Mobile Number</li>
<li>Payment information and payment methods</li>
<li>Social media account(s) ID</li>
</ol>
The list above is not exhaustive and only states general personal information that will be collected from you. As such, we reserve the right to request additional information to complete a registration on the Website (the App).

2.2. The personal information provided to us or through our authorized agents for the use of our services via the Website (the App) should be accurate. You must keep all your information up-to-date and inform us of any changes (if any). We reserve the right to request additional documentation to verify the authenticity of the information you provided to us. We will not be held liable for any false and misleading information provided to us.

2.3. We can only collect your personal information if you voluntarily provide said information to us. We note that if you wish to opt out or do not wish to provide any of the personal information, we will not be in a position to continue providing you access to the Website (the App) and you will not be able to use our services.

2.4. In the event that you provided personal information of a third party, we assume that you have obtained the required authorization and consent from said third party to disclose their personal information. You then hold us harmless and indemnify us from any claims, suits and/or actions arising from the collection of such third party’s information since you disclosed it to us.

2.5. For (i) measuring and analyzing the effectiveness of our marketing campaigns in our Website and App; and (ii) measuring and analyzing certain events and actions within our Website and App we may use the services of the third parties - such as Amplitude - for obtaining and analyzing statistical information about Users’ activities on our Website and App, including different features such as "Session Replay". Amplitude Services Privacy policy is available at <a href="https://amplitude.com/privacy">https://amplitude.com/privacy</a>

2.6. When you make a payment on our platform, your payment information (including credit/debit card details, billing address, and transaction amount) is securely transmitted directly to our third-party payment processor, <b>Stripe, Inc.</b> ("Stripe"). We do not store your full credit card details on our servers. Stripe collects, processes, and stores your payment information in accordance with their <a href="https://stripe.com/privacy">Privacy Policy</a> and <a href="https://stripe.com/legal">Terms of Service</a>.
We share the following information with Stripe to facilitate payments:
<ol>
<li>Your name</li>
<li>Billing address</li>
<li>Email address</li>
<li>Payment card details (collected directly by Stripe via embedded forms)</li>
<li>Transaction amount and currency</li>
<li>IP address (for fraud detection)</li>
</ol>

2.7. For (i) measuring and analyzing the effectiveness of our marketing campaigns for our Website and App; and (ii) attributing the source of your visit or install, we use the services of third parties – such as AppsFlyer.
AppsFlyer primary functions are attribution to determine the source of your visit, analytics to analyze user behavior and engagement, and marketing optimization to measure the effectiveness of our advertising campaigns.
When you use our website or services, AppsFlyer may automatically collect and process information which may constitute Personal Data.
This includes online identifiers:
<ol>
<li>IP address and unique device identifiers;</li>
<li>usage data such as timestamps of visits and pages viewed;</li>
<li>attribution data about the referring source like the ad network and campaign;</li>
<li>technical information including your operating system and browser type.</li>
</ol>
AppsFlyer privacy policy is available at: <a href="https://www.appsflyer.com/legal/privacy-policy/">https://www.appsflyer.com/legal/privacy-policy/</a>



2. Collection of Personal Information

3.1. We collect and use your personal information for specific, explicit, and legitimate purposes as outlined below:

Name - To create and manage your personal account. To personalize your experience and communications. To carry out our contractual obligations (e.g., processing subscriptions). For security verification and to prevent fraud.

Date of Birth - To verify your age and ensure eligibility for our services. For security verification and identity checks.

Email Address - To create and secure your account. To send you important service-related communications (e.g., updates, security alerts, support messages). To administer promotions or surveys you choose to participate in.

Mobile Number - To secure your account through two-factor authentication (if enabled). For customer support purposes.

Payment Information - To process transactions and complete purchases you authorize. To manage billing, subscriptions, and renewals. To detect and prevent fraudulent transactions. Note: We use accredited third-party payment processors. We do not store your full payment card details on our servers.

Social Media Account(s) ID - To enable you to register or log in to our service. To personalize your experience based on your preferences (with your consent, where required).

We may also use the information above for the following secondary purposes, which are grounded in our legitimate interests and your reasonable expectations:

Service Improvement: To perform analysis and research to develop and improve our App, products, and services.

Security: To detect, prevent, and investigate security breaches, fraud, and other unauthorized or illegal activities.

Support: To provide customer service, efficiently manage your requests and feedback, and administer software updates.

Compliance: To comply with our legal and regulatory obligations under UAE and other applicable laws.

3.2. To improve usage and access to the Website (the App), your personal information will be shared with the authorized service providers including our affiliates. We reasonably endeavor to ensure that the authorized service providers and affiliates secure and protect the use and access of your personal information.

3.3. We do not sell our users’ personal information.
We process payment information under Article 6(1)(b) GDPR ("performance of a contract") to fulfill your orders via Stripe.
Disclosures to Stripe are made for business purposes (processing payments) under the CCPA. Stripe is prohibited from "selling" your data.

3.4. You acknowledge that you are aware and understand that:
<ul>
<li>no data transmission over the Internet can be guaranteed as 100% secure;</li>
<li>unauthorized entry or use, hardware or software failure, and other factors may compromise the security of your data at any time;</li>
<li>the safety and security of your information also depend on you (where we have given you (or where you have chosen), you are responsible for keeping the registration information (account name, email and password) confidential and you shall not to share it with anyone;</li>
<li>we do not guarantee the security of any information that you transmit to us over the Internet and you understand and agree that you do so at your own risk.</li>
</ul>
3.5. If you are a resident of the EEA, the GDPR gives you certain rights in relation to your personal data. Hereby we have implemented additional transparency to help all Users take advantage of those rights. The rights afforded to individuals are:

<table>
<tr><td>Access:</td><td>the right to be informed of and request access to the personal data we process about you (you may also access, correct, or remove your personal information by logging into your account; herewith, in some circumstances, we may not be able to delete your data)</td></tr>
<tr><td>Rectification:</td><td>the right to request that we amend or update your personal data where it is inaccurate or incomplete (herewith, we may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect)</td></tr>
<tr><td>Restriction:</td><td>the right to request that we temporarily or permanently stop processing all or some of your personal data</td></tr>
<tr><td>Erasure:</td><td>the right to request that we delete your personal data (herewith, if you delete your user content from the services or your account, copies of it may remain viewable in cached and archived pages, or might have been copied or stored by other users of the services)</td></tr>
<tr><td>Objection:</td><td>the right, at any time, to object to us processing your personal data on grounds relating to your situation or the right to object to your personal data being processed for direct marketing purposes</td></tr>
<tr><td>Data Portability:</td><td>the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service</td></tr>
<tr><td>Exclusion of Decision-making:</td><td>the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.</td></tr>
<tr><td>Obligation to provide Data:</td><td>your data will be required depending on your activities with the Website (the App); you do not need to provide personal information to learn the functionalities of the services.</td></tr>
</table>
3.6. Subject to applicable laws and provisions of this Privacy Policy, you may withdraw your consent to processing your data by us (which you give by accepting the Terms of Services and this Privacy Policy), by contacting us via email specified in clause 8 of this Privacy Policy.

3.7. If you are not interested in receiving email notices or advertisements from us, you should unsubscribe.


3. Purpose of Collecting your Personal Information

4.1. From time to time, CIFRA and its authorized service providers implement "cookies" or other similar technologies to allow us or third parties to collect or share information that will help us improve cifra.com services. This will help us provide you with an improved, safer, faster, and customized experience when using cifra.com services.

4.2. "Cookies" are small pieces of data that we transfer to your computer or mobile device that allow us to keep track of your movements within cifra.com, help you resume where you left off, remember your registered login, theme selection, preferences, and other customization functions. We may link your cookie information to your personal data which includes the items you have selected or purchased, pages you viewed, etc.

Strictly Necessary Cookies - necessary for the functioning of the Website and cannot be disabled by the user.

<table>
<tr><td>Cookie CIFRA</td><td>CIFRA_IdToken</td></tr>
<tr><td>Microsoft MSN</td><td>SRCHD; SRCHUID; SRCHUSR; _EDGE_V</td></tr>
</table>

Analytics (analytical cookies) are necessary for transmitting user data to analytics systems and can be disabled by the User.

<table>
<tr><td>Amplitude</td><td>AMP_23cebe7409; AMP_45cf28a459; AMP_MKTG_23cebe7409; AMP_a0258e1d5c</td></tr>
<tr><td>CloudWatch RUM</td><td>cwr_s; cwr_u</td></tr>
<tr><td>Google Analytics</td><td>_ga; _ga_KFJKFKBGNJ</td></tr>
</table>

Advertising (marketing cookies) are necessary for displaying advertisements to the user on third-party websites and can be disabled by the user.

<table>
<tr><td>Google Tag Manager</td><td>__ddg1_</td></tr>
<tr><td>HubSpot</td><td>__hssc; __hssrc; __hstc; hubspotutk</td></tr>
<tr><td>Microsoft Ads</td><td>MSPTC; MUID; _uetsid; _uetvid</td></tr>
<tr><td>Microsoft Clarity</td><td>_clck</td></tr>
<tr><td>Facebook Pixel</td><td>_fbp</td></tr>
<tr><td>Google Ads</td><td>_gcl_au</td></tr>
<tr><td>Tiktok Marketing</td><td>_tt_enable_cookie; _ttp</td></tr>
<tr><td>Bing Maps</td><td>SRCHHPGUSR; _HPVN; _UR</td></tr>
</table>

Upon first visit to the Website, User will see a cookie banner that informs about CIFRA’s use of cookies and provides User with the option to accept or manage cookie preferences.

The cookie banner will present the following options:

<table>
<tr><td>Accept Cookies:</td><td>By clicking this option, User consents to the use of all cookies as described in this Privacy Policy.</td></tr>
<tr><td>Manage Cookies:</td><td>By clicking this option, User can customize cookie settings. User can choose which categories of cookies User wishes to accept or reject, including necessary cookies, analytics cookies, and marketing cookies.</td></tr>
</table>


4. Allowing Cookies

5.1. We implement security measures to ensure protection of your personal information on the Website (the App). We adhere to the laws, rules, and regulations in relation to the collection, retention and protection of data privacy.

5.2. We ensure that the personal information we collected is kept secure in our networks and is only accessible by our authorized service providers. As such, we keep your personal information confidential and all personal information provided is encrypted in our databases to be accessed for the purposes mentioned above.

5.3. As for accessing third party and/or linked sites, we do not guarantee the security of your personal information that you provide. Our security measures are limited to safeguarding personal information provided to us that is subject to our control and possession. We therefore have no obligation and liability for the security arrangements of these third party / linked sites.

5. Protection of Personal Information

We will periodically review the sufficiency and contents of our Privacy Policy. We reserve the right to amend, modify, add, remove, or suspend all or any portion of our Privacy Policy at any time and it will be posted on cifra.com. Your continued use, access or registration at the Website (the App) after posting such changes constitutes your binding acceptance to it.

6. Changes to Privacy Policy

7.1. In case your personal information is requested to be disclosed by an order or a mandate of court, regulatory, tax, law enforcement, governmental and/or judicial authority or under any law, you agree and acknowledge that we have the right to disclose your personal information to satisfy such mandate or order. You therefore agree not to take any action and/or waive your rights to take any action against us including the disclosure of your personal information in these circumstances.

7.2. We will not share your data without your explicit permission, except in the following circumstances (to which you hereby agree):
<table>
<tr><td>For anonymized analytics:</td><td>we may disclose aggregated or anonymized information about you without any restrictions</td></tr>
<tr><td>To affiliates for our business purposes:</td><td>we may disclose your data to our affiliated persons for purposes of management and analysis, decision-making, and other business purposes</td></tr>
<tr><td>Due to corporate restructuring or sale of our business:</td><td>if we become involved with a restructuring, reorganization, dissolution, merger or other sale or transfer of some or all of the company's assets (whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding), we may disclose your data to business entities or people involved in the negotiation or execution of the respective transactions and actions</td></tr>
<tr><td>If required by law:</td><td>we may disclose your data to comply with any court order, law, or legal process, including to respond to any government or regulatory request</td></tr>
<tr><td>If we enforce our rights or help protect lawful interests:</td><td>we may disclose your data
<ul>
<li>to enforce or apply the <a href="https://cifra.com/terms" target="_blank">Terms of Service</a>, including this Privacy Policy, and other agreements, including for billing and collection purposes and/or</li>
<li>if we believe disclosure will help us protect the rights, property, or safety of CIFRA, our users, partners, agents, and others (e.g., we may exchange information with other companies and organizations for fraud protection, and spam and malware prevention).</li>
</ul>
</td></tr>
<tr><td>With your consent:</td><td>we may disclose your Data to achieve the purpose for which you provide it to us, for any other purpose disclosed by us when you provide the information, or with your consent</td></tr>
</table>

7. Right to disclose information

Each User shall keep confidential and shall not, without the written consent of CIFRA (or another User) (such consent not to be unreasonably withheld), disclose to any other party the negotiations, the terms of the Agreement signed, technological or artistic vision and development of the platform or any documents or other information furnished directly or indirectly by CIFRA (or another User) in connection with the platform (collectively referred to as Confidential Information).

Each Party may disclose Confidential Information upon prior notification of another Party:
<ol>
<li>if and to the extent, such disclosure is required by Law,</li>
<li>pursuant to any order or direction of any court of competent jurisdiction or any competent judicial governmental, regulatory, or supervisory body,</li>
<li>as necessary to comply with its obligations under this Agreement provided that the Party ensures the recipient is made aware of and complies with this confidentiality obligation as if the recipient was a party to this Agreement and that recipient may not further disclose the Confidential Information.</li>
</ol>

If the Website (or App) is not functioning properly or requires enhancements, we invite you to share your feedback at support@cifra.com. Please note that discussing these issues publicly (such as on social media) may not assist us in resolving the problem and could be considered a breach of confidential information.


8. Confidentiality

If you have any questions or concerns about our privacy policy or your interactions with <a href="https://cifra.com" target="_blank">cifra.com</a> services, please contact us at <a href="mailto:privacy@cifra.com">privacy@cifra.com</a>