🔭Privacy Policy

Effective date: 21 March 2023

1. Introduction Solex Limited ("Solex", "we", "us", "our") is committed to respecting and protecting your privacy. This Privacy Policy (the "Policy"), together with our Terms of Service, sets out the basis on which any personal data we collect from you, or that you provide to us, via our Platform (https://solex.ai/), mobile application, social media and communications with you, will be processed by us.

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND OUR VIEWS AND PRACTICES REGARDING YOUR PERSONAL DATA AND HOW IT APPLIES TO OUR SERVICES.

From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any material change to the way we collect or process your personal data, we will provide you with more information or additional terms or policies. Unless otherwise stated, when we introduce these new or additional services, they will be subject to this Policy.

2. Who we are Solex Limited is the data controller and is responsible for your personal data. Our contact details are:

Solex Limited Coastal Building, Wickham’s Cay II P.O. Box 2221 Road Town, Tortola, British Virgin Islands Company Registration No: 2110566 Email: [e-mail]

3. What is personal data Personal data" means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. 4. What types of personal data do we collect and where do we get it from We collect your personal data from various sources. The table below sets out the different types of personal data we collect and the sources we collect it from. Typically, you provide us with personal data directly when you take actions on our Platform or by corresponding with us by email, social media or otherwise. This includes information you provide us with when you create an account or participate in voting and contests. We also obtain some personal data from other sources, such as credit reference agencies, web analytics and other service providers, and we create some personal data ourselves, as set out in the table.

Category	Type of personal data	Collected from
Contact Information	Email address Communication and marketing preferences Language for communication	You Third-party (e.g. Amazon Cognito)
KYC Information	First and last name Address Date of birth Passport and/or any other national identity document Utility bill and/or other proof of address, such as a bank statement or driving licence Nationality Credit reference check Tax return (where applicable)	You Third parties and systems used for our identity and anti-money laundering checks
Payment Information	Payment details Crypto wallet addresses	You Third parties
Biographical Information	Age Education history Industry and occupation Time zone Country of residence	You
Transaction Information	Forecasts submitted for each chart, including time submitted, value, chart type Rewards for each forecast in points and payment equivalent	You Our Platform
Platform Information and Cookies	Contact information (see above) IP address and other online identifiers / web beacons, time zone and language settings, browser plug-in types and versions, operating system and platform Usernames, passwords and other log-in details Connected social media accounts for login Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Platform (including date and time); products or services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page Your account settings, including any default preferences, any preferences we have observed, such as the types of offers that interest you, or the areas of our Platform that you visit Awards for forecasting precision	You Device used to access the Platform Our Platform Third parties (e.g. Google analytics, Amazon Cognito)

5. How we use your personal data and why

We are committed to minimising the data we collect and limiting its use to only that:

• for which we have been given consent;

• as necessary to deliver our services to you; or

• as might be required or permitted for legal compliance or other lawful purposes.

We collect information relating to your use and/or interaction with our Platform and use this information to:

• improve and optimise the operation and performance of our Platform or mobile application;

• diagnose problems with and identify any security risks, errors or necessary enhancements to the Platform or the services;

• detect and prevent fraud and abuse of our Platform and systems;

• collecting aggregate statistics about the use of the services and your forecasting performance; and

• understand and analyse how you use our Platform and services and what products and services are most relevant to you.

Under the General Data Protection Regulation (GDPR), UK General Data Protection Regulation (UK GDPR) and the British Virgin Islands Data Protection Act (BVI DPA), we are required to have a lawful basis for our processing of your personal data. We can outline this as follows:

Type of Processing	Lawful Basis	Data Types
Sending electronic marketing information to you (as an individual) except where you are an existing customer (see below)	Consent	Contact information (email address and full name)
To register your account and enable you to login to the Platform and to carry out our contractual obligations including to allow you to participate in the community and other interactive features of our service, when you choose to do so and handle complaints from or disputes with you	Performance of a contract	Contact information (email address and full name)
Setting cookies	Consent	Contact information (email address and full name) Platform information (IP address and other online identifiers, usernames, passwords and other log-in details, information about your visit, your account settings, including any default preferences)
Sending marketing information to existing customers and business prospects, including making suggestions and recommendations to you about our services where you have not opted out	Legitimate interests of promoting and growing our business	Contact information (email address and full name)
For internal operations, including operating the Platform, troubleshooting, security, data analytics, testing, research, statistical and survey purposes	Legitimate interests of protecting and maintaining our service and your information	Contact information (email address and full name) Biographical information (Education, Industry and Occupation, Age, Time zone, Country of residence)
To measure or understand the effectiveness of advertising and content we serve to you and others, and to deliver relevant advertising to you, where you have expressly agreed to receive advertising	Legitimate interests of promoting and growing our business	Contact information (email address and full name) Communication and marketing preferences
Performing our KYC and AML obligations, establishing and enforcing our legal rights and obligations and complying with instructions from law enforcement agencies	Legal obligation, consent, establishment and exercise or defence of claims	Contact information (email address and full name) KYC information (First and Last Name, Address, and Date of birth; Passport and/or any other national identity document, Utility bill and/or other proof of address, such as bank statement or driving licence, Nationality; Tax returns)
Responding to your communications with us	Legitimate interests as it’s important that we can respond to your enquiries, complaints and other communications	Contact information (email address and full name)
Manage payment, rewards and points	Performance of a contract	Payment information (Payment details; Crypto wallet addresses) Transaction information
Processing of "special categories of personal data" which we are required to process with more care, according to applicable laws	Explicit consent	Details of any criminal offences as part of KYC and AML checks

6. How do we share your personal data

We will treat your personal data with complete respect and will not disclose it to any third party, other than to those necessary or appropriate in connection with any of the purposes for which we use personal data, including to subcontractors or service providers, for example, Platform engineers and maintenance staff that help host or support the Platform, services or otherwise provide technical assistance to us.

Inside the Solex Group

We are part of a group of companies. Therefore, we will need to share your personal data with other companies in our group for our general business purposes, to manage your investment and, in some cases, for authorisations/approvals with relevant decision makers, reporting and where systems and services are provided on a shared basis. Access rights between members of our group are limited and granted only on a need-to-know basis, depending on job functions and roles.

Outside the Solex Group

1. From time to time we may ask third parties to carry out certain business functions for us, such as IT support or analytics. These third parties will process your personal data on our behalf (as our processor). We will disclose your personal data to these parties so that they can perform those functions. Before we disclose your personal data to these third parties, we will seek to ensure that they have appropriate security standards in place to protect your personal data. Examples of these third-party service providers include service providers and/or sub-contractors, which include IT systems software, customer analytics platforms, maintenance, backup, and server hosting providers.

2. In certain circumstances, we will also disclose your personal data to third parties who will receive it as controllers of your personal data in their own right, where:

• we agree to provide exchange services at your instruction, whereby your personal data will be shared with a third party exchange provider so that they can conduct the exchange and any necessary identity and anti-money laundering checks;

• we buy, sell or transfer our business (or part of it) in connection with a share or asset sale or outsourcing, we may disclose or transfer your personal data to the prospective seller, buyer or transferor and their advisors; and

• we need to disclose your personal data to comply with a legal obligation, to enforce a contract or to protect the rights, property or safety of our employees, customers, investors or others.

3. We have set out below a list of the categories of recipients with whom we are likely to share your personal data:

• Platform development, IT support, analytics, cloud platform and data hosting providers;

• database maintenance staff, database providers;

• anti-money laundering and background checking vendors;

• payment processors in relation to your investment with us;

• consultants and professional advisors, including legal advisors and accountants;

• courts, court-appointed persons/entities, receivers and liquidators; and

• governmental departments and statutory and/or regulatory bodies.

7. Where do we store your personal data

Our Platform is hosted on secure servers provided by Digital Ocean LLC and Amazon Inc., located and backed up in the United States. It may also be processed by staff operating outside the UK, the BVI and EEA who process account details and who provide support and database services. Transfers will only be made to countries which are the subject of an adequacy decision of the EU Commission or recipients who have entered into binding contracts with us to comply with the terms of this Policy and Data Protection Law. Where you are an individual in the EEA, the BVI or the UK, by submitting your personal data, you agree to this transfer, storing or processing. For the purposes of this Policy, Data Protection Law means (i) the UK GDPR and Data Protection Act 2018, (ii), for customers in the EEA, the General Data Protection Regulation (GDPR), (iii) the British Virgin Islands Data Protection Act (BVI DPA), and (iv) and any national implementing laws of the GDPR, as amended from time to time and any successor legislation to the UK GDPR, the GDPR, the UK Data Protection Act 2018, or the BVI Data Protection Act 2021.

8. How we secure your personal data

We follow generally accepted standards and will take specific steps to ensure that we put in place appropriate technical and organisational measures to store and protect the personal information we collect, both during transmission and once received and stored, including utilisation of encryption where appropriate. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

9. How long do we store your personal data for?

We may keep records of any personal data obtained from you on or through our Platform, or otherwise, for as long as we believe is reasonably required for our ongoing legitimate business needs, or such longer period as may be required for legal, audit and compliance purposes. This does not affect your right to opt out from receiving marketing communications, as outlined in the section "Your rights in relation to personal data" below.

Account registration and maintenance - once you have registered an account with the Platform, your account details will be kept in the Amazon Cognito database, unless deleted by you or you ask us to delete the details. We will also delete your account after 3 years of inactivity.

Marketing - we will retain your personal data that we process with your consent for marketing purposes until such time as your consent is withdrawn. For the avoidance of doubt, if you withdraw your consent, we will not conduct any marketing that is necessary for our legitimate interests, although may still contact you for other purposes relating to the service or your account.

Handling queries/complaints relating to your account - we will retain all data relating to your account, and associated queries for the applicable limitation period under applicable national laws relevant to claims for breach by us of any contract between you and us. Please contact us for further information on the limitation period.

Transactions and processing activities - we will retain all financial data provided or generated in connection with your subscriptions for the legal retention period for tax, audit and associated reports/accounting.

Operation of the Platform, providing support and delivery of web content - we will maintain this data, including logs and web server records, for the duration of the Platform and the applicable limitation period relevant to claims for breach of contract.

Data analytics and map data flows to improve the Platform, products/services, marketing, customer relationships and experiences - this data will be deleted after one year.

Certain generic forecasting (which does not identify you individually and is labelled by reference to location, age, residence, and education) will be stored indefinitely as we consider it to be vital to Platform functionality.

Notwithstanding any of the retention periods stated above, if such data is necessary to fulfil other purposes, we will keep your personal data but only process it for such other purposes. Where we rely on the legal retention period, at the end of the legal retention period personal data stored in the databases and other electronic documents will be deleted.

10. Cookies

When you visit our Platform, we generate one or more "cookies".

If you do not agree to our use of cookies, you should set your browser settings accordingly or not use the Platform. Please be aware that if you disable the cookies that we use, this may impact your user experience while using the Platform.

The table below summarises the different types of cookies we use on the Platform, together with their respective purpose and duration (i.e. how long each cookie will remain on your device).

Two types of cookies may be used on the Platform - "session cookies" and "persistent cookies". Session cookies are temporary cookies that remain on your device until you leave the Platform. A persistent cookie remains on your device for much longer or until you manually delete it (how long the cookie remains on your device will depend on the duration or "lifetime" of the specific cookie and your browser settings).

Cookies used on the Platform:

Type of Cookie	What Do They Do?	Do These Cookies Collect My Personal Data / Identify Me?
Necessary	Cookies that are essential to making the Platform work correctly. They enable visitors to move around our Platform and use our features. Examples include remembering previous actions (e.g. entered text) when navigating back to a page in the same session.	These cookies do not identify you as an individual. If you do not accept these cookies, it may affect the performance of our Platform.
Performance	Cookies that help us understand how visitors interact with our web properties by providing information about the areas visited, the time spent on the Platform and any issues encountered, such as error messages. They help us improve the performance of our Platform, alert us of any concerns and more.	These cookies do not identify you as an individual. All data is collected and aggregated anonymously.
Functionality	Cookies that allow our web properties to remember the choices you make (such as your user name, language or the region you are in) to provide a more personalised online experience.	The information these cookies collect may include personally identifiable information that you have disclosed, such as a username, for example. We shall always be transparent with you about what information we collect, what we do with it and with whom we share it. If you do not accept these cookies, it may affect Platform performance and functionality and may restrict access to web content.
Targeting / advertising	Cookies that are used to deliver content that is more relevant to you and your interests. They may be used to deliver targeted advertising or to limit the number of times you see an advertisement. They also help us measure the effectiveness of advertising campaigns on the Platform. We may use these cookies to remember websites you have visited and we may share this information with other parties, including advertisers and our agencies.	Most types of these cookies track consumers via their IP address so will collect some personal data.

What are cookies?

Cookies are files or pieces of information that may be stored on your computer (or other internet-enabled devices, such as a smartphone or tablet) when you visit our Platform. A cookie will usually contain the name of the Platform from which the cookie has come, the "lifetime" of the cookie (i.e. how long it will remain on your device) and a value, which is usually a randomly generated unique number.

What do we use cookies for?

We use cookies to make the Platform easier to use and to better tailor our web presence and products to your interests and needs. Cookies may also be used to help speed up your future activities and experience on the Platform. We also use cookies to compile anonymous, aggregated statistics that allow us to understand how people use our web properties and to help us improve web structure and content. We cannot identify you personally from this information.

How can I control or delete cookies?

Most internet browsers are initially set up to accept cookies automatically. You can change the settings to block cookies or to alert you when cookies are being sent to your device. There are a number of ways to manage cookies. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings.

If you disable the cookies that we use, this may impact your experience while on the Platform. For example, you may not be able to visit certain areas of the Platform.

If you use different devices to view and access the Platform (e.g. your computer, smartphone, tablet etc.), you will need to ensure that each browser on each device is adjusted to suit your cookie preferences.

11. Your rights in relation to personal data Where our processing of your personal data is based on your consent (please see the table above), you have the right to withdraw your consent at any time. If you do decide to withdraw your consent, we will stop processing your personal data for that purpose, unless there is another lawful basis we can rely on – in which case, we will let you know.

Where our processing of your personal data is based on legitimate interests (please see the table above), you can object to this processing at any time. If you do this, we will need to show either a compelling reason why our processing should continue, which overrides your interests, rights and freedoms or that the processing is necessary for us to establish, exercise or defend a legal claim.

Where we are processing your personal data for direct marketing purposes, you have the right to object to that processing.

You have the following rights in relation to your personal data (subject to applicable laws and certain limitations:

• access your personal data and to be provided with certain information in relation to it, such as the purpose for which it is processed, the persons to whom it is disclosed and the period for which it will be stored;

• require us to correct any inaccuracies in your personal data without undue delay;

• in certain circumstances, require us to erase your personal data;

• in certain circumstances, require us to restrict processing of your personal data;

• receive the personal data which you have provided to us, in a machine readable format, where we are processing it on the basis of your consent or because it is necessary for your contract with us (please see the tables above) and where the processing is automated; and

• object to a decision that we make which is based solely on automated processing of your personal data (however, we do not currently conduct any such decision making).

In order to exercise any of the above rights, please contact us at [e-mail].

You may also have the right to lodge a complaint with the relevant data protection regulator (for example the Office of the Information Commissioner on British Virgin Islands or the Information Commissioner’s Office in the UK).

It is critical that the personal data that we hold about you is current and accurate. Please let us know without delay if your personal information changes during the period for which we hold it.

Please note that this Policy does not apply to information collected through third-party websites or apps or services that you may access through our Platform. Please ensure that you read the third-party services’ privacy policies to understand how your personal information may be collected, used and shared.

12. Changes to this policy

We reserve the right to modify this Policy at any time. If we decide to change our Policy, we will post those changes on our Platform and any other places we deem appropriate, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.