PRIVACY POLICY

Last updated Feb, 2024

This privacy notice for Atwallets, operated by ATWALLETS LTD, and subsidiaries, affiliates, licensees and/or licensors of ATWALLETS LTD including atwallet ("Company," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

• Visit our website at https://www.atwallets.com, or any website of ours that links to this privacy policy;
• Download and use our mobile application (atwallets), or any other application of ours that links to this privacy policy;
• Engage with us in other related ways, including any sales, marketing, or events.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Names;
• Email addresses;
• Gender;
• Date of birth;
• Mailing addresses;
• Phone number;
• Nationality;
• Device ID;
• Transactional information
• Profile Image

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device‘s settings.
• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device‘s operating system or platform, the type of mobile device you use, your mobile device‘s unique device ID, and information about the features of our application(s) you accessed.
• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application. If you wish to opt out from receiving these types of communications, you may turn them off in your device‘s settings.
• Profile Picture Data. Our app allows users to upload a profile picture for personalization purposes. We collect and process this image data solely for the purpose of displaying the user's chosen profile picture within the app. We do not store or retain users' personal images on our servers beyond the time necessary for processing and displaying them as profile pictures. We do not share users' profile pictures with any third parties, nor do we use the images for any purpose other than the user's intended display within the app. To ensure the privacy and security of users' image data, we employ industry-standard encryption methods and access control mechanisms. In accordance with applicable data protection laws, such as the General Data Protection Regulation (GDPR) in the EU and the California Consumer Privacy Act (CCPA) in the US, users have the right to access, correct, and delete their personal data, as well as the right to object to data processing. Users can remove, update, or replace their profile pictures at any time within the app. If you wish to exercise any of your rights or have any questions or concerns about our handling of profile picture data, please contact us at support@atwallets.com

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. Why do we process my personal information?

We are using the personal information is the following purposes:

• Collected information is primarily needed to maintain the security and operation of our application, for troubleshooting and for our internal analytics and reporting purposes.
• User experience. We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual‘s vital interest, such as to prevent harm.
• Communicate with you. We use your personal information to communicate with you in relation to atwallets Services.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• 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 data for that purpose.
• Legal obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way;
• For investigations and fraud detection and prevention;
• For business transactions provided certain conditions are met;
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim;
• For identifying injured, ill, or deceased persons and communicating with next of kin;
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse;
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province;
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records;
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced;
• If the collection is solely for journalistic, artistic, or literary purposes;
• If the information is publicly available and is specified by the regulations.

4. Cookies and other identifiers

We use cookies and similar tools to enhance your user experience, provide our services, and understand how customers use our services so we can make improvements. Depending on applicable laws in the region you are located in, the cookie banner on your browser will tell you how to accept or refuse cookies.

5. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

Information about our users is an important part of our business and we are not in the business of selling our users' personal information to others. atwallets shares users' personal information only as described below and with the subsidiaries or affiliates of atwallets that are either subject to this Privacy Policy or follow practices at least as protective as those described in this Privacy Policy.

Third party service providers: We employ other companies and individuals to perform functions on our behalf. Examples include analyzing 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 further; they must process the personal information in accordance with our contractual agreements and only as permitted by applicable data protection laws.

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 atwallets or substantially all of its assets are acquired, user information will be one of the transferred assets.

Protection of atwallets and others: We release account 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 atwallets, our users or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

6. INTERNATIONAL TRANSFERS OF PERSONAL DATA

We may transfer your data outside of the country from where you have connected to our Services. We put 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.

7. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.

The Services may link to third-party websites, online services or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

8. HOW SECURE IS MY INFORMATION?

We design our systems with your security and privacy in mind. We work to protect the security of your personal information during transmission by using encryption protocols and software.

We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personal information. Our security procedures mean that we may ask you to verify your identity to protect you against unauthorized access to your account password. We recommend using a unique password for your account that is not utilized for other online accounts and to sign off when you finish using a shared computer.

9. HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than twelve (12) months past the termination of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

10. atwallets WALLET PIN RECOVERY AND IDENTITY VERIFICATION

If you forget your atwallets Wallet PIN code, you may reset it by following the procedures outlined below. Please note that this process is designed to ensure the security and safety of your atwallets Wallet account.

To reset your atwallets Wallet PIN code, you must send a petition from your verified email address to our customer support team at support@atwallets.com. Your email must include a selfie of you holding a government-issued ID such as a driver's license, passport or national ID card, along with a paper with the following copy "I forgot my atwallets Wallet PIN [MM/DD/YY]". The date should be the date on which you are making the request.

After we receive your request, our team will verify your identity based on the information you provided. If the information is verified, we will then reset your atwallets Wallet PIN code and send you an email with instructions on how to set a new one.

We take the privacy of your personal information very seriously. We will never share the data you provide during the PIN reset process with any third party, except as required by law or as necessary to protect our legal rights and interests. However, we reserve the right to keep your data to ensure the security of your atwallets Wallet account.

Please note that this process may take up to 5 business days to complete. We reserve the right to deny any request to reset the atwallets Wallet PIN code if we are not able to verify your identity or if we suspect fraudulent activity on your account.

By using the atwallets Wallet service, you agree to comply with these procedures for resetting your atwallets Wallet PIN code. We reserve the right to modify these procedures at any time without prior notice, and any such modifications will be effective immediately upon posting on the atwallets website or mobile application.

11. DO WE COLLECT INFORMATION FROM MINORS?

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers.

If we need to rely on consent, as a legal basis for processing your information and your country requires consent from a parent, we may require your parent's consent before we collect and use that information.

12. WHAT ARE YOUR PRIVACY RIGHTS?

If you have any questions or objection as to how we collect and process your personal information, please contact support@atwallets.com. When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time.

In addition, subject to applicable law, you have the right to request access to, correct, and delete your personal data, and to ask for data portability. You may also object to our processing of your personal data or ask that we restrict the processing of your personal data or delete it in certain instances, by contactingsupport@atwallets.com.

• Right to access: you have the right to obtain confirmation that your Data are processed and to obtain a copy of it as well as certain information related to its processing;
• Right to rectify: you can request the rectification of your Data, which are inaccurate, and add to it. You can also change your personal information in your Account at any time
• Right to delete: you can, in some cases, have your Data deleted;
• Right to object: you can object, for reasons relating to your particular situation, to the processing of your Data. For instance, you have the right to object to commercial prospection;
• Right to limit the processing: in certain circumstances, you have the right to limit the processing of your Data;
• Right to portability: in some cases, you can ask to receive your Data which you have provided to us in a structured, commonly used and machine-readable format, or, when this is possible, that we communicate your Data on your behalf directly to another data controller;
• Right to withdraw your consent: for processing requiring your consent, you have the right to withdraw your consent at any time. Exercising this right does not affect the lawfulness of the processing based on the consent given before the withdrawal of the latter;
• Right to define the instructions relating to the use of your personal data post mortem: you have the right to define instructions relating to the retention, deletion and communication of your Data after your death;
• Right to lodge complaint to the relevant data protection authority.

13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at support@atwallets.com.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

14. Conditions of Use, Notices and Revisions

If you choose to use our Services, your use and any dispute over privacy is subject to this Policy and our Terms of Use. If you have any concerns about privacy at atwallets, please contact us with a thorough description, and we will try to resolve it. You also have the right to contact your local Data Protection Authority.

Our business changes constantly and our Privacy Policy will change also. You should check our websites frequently to see recent changes. If you do not agree with the revised content, you shall stop accessing atwallets immediately. When an updated version of the Privacy Policy is released, your continued access to atwallets means that you agree to the updated content and agree to abide by the updated Privacy Notice. Unless stated otherwise, our current Privacy Notice applies to all information that we have about you and your account.