Privacy Policy

Kaia DLT Foundation (the "Company", “we” or “us”) considers the data provided by the users who have access to the Services (“Users” or “you”) important and complies with privacy laws. This Privacy Policy applies to the Kaia Square Service (the “Services”) provided through our website [http://portal.kaia.io] (the “Website”). Our Privacy Policy can be found on the Website where we provide information on how and for what purposes data provided by the Users is used and what measures are taken for the protection of privacy.

Collection and Processing of the Data

Depending on the features of the Service you wish to use, we may collect the following types of information (the “Data”): digital wallet address, device and browser information, IP address and approximated location data, transaction logs, data collected via cookies and similar technologies.

However, we do not collect any data or information about an individual who can be identified from the data, either on its own or when combined with other accessible information held by us, such as names and email address.

In the event we collect or process any personal data, we take the security of your personal data very seriously. We take all possible steps to help protect your personal data from loss, misuse, unauthorized access, disclosure, alteration or destruction. While we do implement appropriate safeguards, no security system is impenetrable.

Due to the inherent nature of the internet, we cannot guarantee that Data is absolutely safe from third party interference, either during transmission or during the time it is stored on our systems.

Purpose of Processing the Data

We collect and process Data as (a) required for the provision of the Services for your use or (b) necessary to analyze and improve our Services. We may also process Data for marketing purposes.

Retention of the Data and Period of Use

We retain the Data for so long as reasonably necessary to achieve the Purpose specified hereunder, and to comply with our legal and regulatory obligations. In the event you terminate using our Services, we may continue to retain your Data, including your personal data (if any), as necessary to comply with our legal and regulatory obligations, including our internal compliance guidelines.

Method of Consent

1. You agree to the collection and process of your Data by accessing to the Services. Upon your access to the Services, we process your Data provided by you or recorded on the blockchain for the aforementioned purposes.

2. In the event we process your personal data for any advertising, marketing, and promotional purposes, we will obtain your explicit consent for the collection and use of your personal data for any such purposes.

Your Rights and Deletion of the Data

You are entitled to ask for details of the information we collect from you and how we process it. For any personal data we process, if any, you are entitled to receive a copy of your personal data. You may also object to the further processing of your Data or choose to withdraw your consent. Please note that any objection to process your data or your withdrawal of consent may restrict your use of the Services.

When there is no need or grounds for processing the Data, we will use our best efforts to return, delete or anonymize the data we collected. If deletion or anonymization is not possible for technical reason, we will use our best efforts to implement appropriate measures to prevent any further processing until deletion is possible.

Provision of Data to Third Parties

We do not share the Data that you provide us with any third party without your express consent except as described in this Privacy Policy. We may disclose your Data and/or personal data (if any), to the extent necessary for the provision of our Services, to third parties as follows:

• to subcontractors of the Company in connection with the provision of the Services; and

• to third-party service providers including Alchemy Pay, but not limited to, data analytics venders or payment service providers, processing the Data on behalf of the Company ( https://alchemypay.org/privacy-policy );

• to any governmental bodies or authorities for compliance with applicable laws and regulations, including, but not limited to, KYC and AML requirements.

Please note that we are not responsible for Data that is not controlled or operated by us. The procedures and policies described in this Privacy Policy do not apply to other websites or services provided by third parties, including, but not limited to, the third-party digital wallet providers. These third-party service providers may have their own privacy policies, place their own cookies on your browser, or store information about you using methods different from ours. It is your responsibility to carefully read and understand the policies of these third-party service providers. In no event shall the Company be responsible or liable for any damages or losses caused by such third-party service providers in connection with your loss of Data or personal data. Users shall indemnify, defend, and hold the Company harmless from any damages or losses caused by such third-party service providers.

The data transfer prescribed hereunder may involve transfer to or from the United Arab Emirates or other locations outside of your state, province, country, or other governmental jurisdiction where privacy laws may not be as protective as the those in your jurisdiction, provided, however, the cross-border transfer of personal data, if any, will be made to the recipient who is bound by legally enforceable obligation to provide to the personal data transferred a standard of protection that is comparable to that under the Federal Decree Law No. 45 of 2021 on the Protection of Personal Data of the United Arab Emirates.

Governing Law and Dispute Resolution

This Privacy Policy shall be prescribed, implemented and construed in accordance with the laws of Abu Dhabi and the applicable Federal Laws of the UAE and the competent courts of Abu Dhabi shall have exclusive jurisdiction over any disputes between the Company and Users with regard to this Privacy Policy.

Change of Privacy Policy

We reserve the right to change this Privacy Notice at any time. We will notify you of the changes on the Services’ Website screen provided upon login from seven (7) days prior to the enforcement date of the amended Privacy Policy by providing both the existing and amended Privacy Policy and clearly stating the enforcement date and reasons for amendment; provided, however, in the case where these Privacy Policy are amended in such a way that may be disadvantageous to you, we will make a notice on the Services’ Website screen provided upon login from thirty (30) days prior to the enforcement date and clearly notify them individually by electronic means such as a consent pop-up appearing on the login screen.

In the event you object or fail to provide objections to such changes despite the Company having notified the amendment in accordance with the preceding paragraph or the Company having made a clear notice to the you that “Users shall be deemed to have consented if they do not express any objection from the date of announcement/notice to the enforcement date” and you have failed to express objection, you shall be deemed to have consented to the amended Privacy Policy.

Privacy Complaints

For any inquiries, please contact us via the following e-mail address.

E-mail: [e-mail]

Addendum

This Privacy Policy shall be effective as of [2024 August 2024]