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WORLD CITIZEN NET PRIVACY POLICY

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The World Citizen Net Group, composed by, World Citizen Net, World Citizen Net Coin, and World Citizen Net Bank, recognizes the vital importance of protecting your personal and financial information.
This privacy policy details how we manage:
– Your personal information provided to us by you or a third party in connection with our provision of services.
– The information that we collect from your use of our services and/or our app(s) or website(s).

Data protection law says that the personal information we hold about you must be:

Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
– Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
– Kept securely
We reserve the right to change and amend this privacy notice from time to time to take into consideration new technology, changes to our operations and practices and new laws and regulations.

Our most current privacy policy will govern any personal information we hold on you.

1. Data controller

This privacy notice applies to the processing activities of World Citizen Net, World Citizen Net Coin, and the World Citizen Net Bank.

– World Citizen Net: It is a Social Network that through its geographical, structural organization and its functions, provides its members with different degrees of social, cultural and economic interaction.
– World Citizen Net Coin and World Citizen Net Bank: They provide, among other products and services, the purchase and sale of financial assets and other investment funds, and that is why it is the data controller of your personal information about those services.

World Citizen Net, World Citizen Net Coin, and World Citizen Net Bank will never, under any circumstances, transfer, sell or provide personal data, activity on their websites or economic data of any kind of their members or visitors, to third parties.

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2. Use of personal data

2.1. Identity verification and account management as part of the provision of services or information about our services:
– On certain occasions, we will have to verify your identity to configure you as a customer and we will need to use those details to manage your account effectively and to make sure you get the best possible service from us.
This may include third parties, who may only use your data to perform credit or identity checks on our behalf.
Before carrying out this last process, we will request your authorization, which must be granted through the appropriate means determined for this case.

It is our legitimate interest to do so and the use of your personal information in this way is necessary for us to know who you are, as we also have a legal obligation to comply with certain regulatory and legal obligations.

2.2. Provisions, improvement, and development of products and services: When opening an account, we will need to use your personal information to perform our services and fulfill our obligations to you. It is in our legitimate interest to ensure that we provide you with the best products and services so that we can periodically review your needs to ensure that you obtain the best possible products and services from us.

2.3. Settlement of inquiries and disputes: When we believe that there is a risk that we need to defend or file legal claims, we may retain your personal information as necessary for our legitimate interests to ensure that we can properly file or defend legal claims. We may also need to share this information with our insurers or legal advisors. The time during which we maintain this information will depend on the nature of the claim and for how long we believe there is a risk that we will have to defend or file a claim. It is in our legitimate interest to use your personal information in that way.

2.4. Compliance with applicable laws and regulations: We may need to use your personal information to comply with applicable law, court order or other judicial process, or the requirements of any applicable regulatory authority. We do this not only to fulfill our legal obligations but also because it may be in our legitimate interest to do so.

2.5 Profiling: We may occasionally use personal information about you to form profiles about you so that we understand your needs and provide you with the best products and services we can. We may also make decisions about you through automated profiles or automated credit checks that could affect your ability to use our services. We may need to do this to comply with our legal obligations or because it is in our legitimate interest to use your personal information in that way.

2.6. Marketing, Advertising, and Sales: We may collect your name and contact information (such as your email address, telephone number or address) to send you information about our products and services that may interest you. We may collect this directly from you or through a third party. If a third party has collected your name and contact information, it will only be transmitted to us for marketing purposes if you have given your consent to do so. It is in our legitimate interest to use your personal information in that way.

You always have the right to “choose not to receive” this type of information. You can exercise the right at any time by contacting us. If we send you Marketing, Advertising, and Sales emails, you will always be provided with an option to unsubscribe that will allow you to opt-out of receiving more marketing emails.

If you choose not to receive this type of information, you will be added to our suppression list to make sure we do not accidentally send you this type of information.
We never share your contact information or activity of any kind on our websites with third parties.

We use third-party service providers to send our advertising or information of any kind, but we only allow them to use that information confidentially and keep it secure.
It is in our legitimate interest to use your personal information in that way.
We keep your data on our list until you request to be excluded from it.

2. Use of personal data

2.7. Information about our Web pages: Our web pages or websites as well as our emails may contain web “beacons” or pixel tags or any other similar type of data analysis tools that allow us to track the receipt of the correspondence that we have sent and count the number of users who have visited our website or opened our correspondence.
When your personal information is completely anonymous, we do not require a legal basis since the information will no longer constitute personal information. However, when your personal information is not anonymous, it is in our legitimate interest to continually evaluate that personal information to ensure that the products and services we provide fit your needs.

2.8. References: If necessary, third parties, such as credit agencies, can approach us to provide a credit reference about you for credit and identity checks. It may be in our legitimate interest to comply with our legal obligations or we may be required to provide such reference to comply with a legal obligation.
Once the necessary verifications have been made, these third parties will be obliged through an agreement signed with World Citizen Net Group, to destroy and permanently eliminate the data used and not to use them under any pretext or objective.

From time to time, we may send you surveys as part of our customer feedback process and it is in our legitimate interest to request feedback to ensure that we provide you with the best service.

2.9. Internal business and record keeping: We may need to process your personal information for internal business and research purposes and record-keeping purposes. Such processing is in our legitimate interests and is necessary to comply with our legal obligations. This may include any communication we have with you regarding the services we provide and our relationship with you. We will also keep records to ensure that you meet your obligations under any contract you have entered into with us.

2.10. Our Websites or Our Websites: We collect information about visitors to our websites. We may record information about your visit, including the date and time, what content you are visiting, as well as how you interact with those contents. It is our legitimate interest to do so.

This information would only be published by court order or a formal request from the police, or as necessary in connection with disputes. It is not only a legal requirement but also our legitimate interest to do so.

2.11. Share with cooperation partners: We may share your personal information with cooperation partners that provide services on our behalf.
Before sharing your personal information, we will ask for your authorization, which you must provide us, by the means determined for that case.

2.12 Share with group entities and corporate restructuring: We may share your personal information with other entities of our group as part of our regular reporting activities on the company’s performance, in the context of a commercial reorganization or group restructuring exercise, and to system maintenance support and data hosting. It is in our legitimate interest to use your personal information in that way.

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3. Collection of personal data:

We may collect the following types of information from actual or potential customers:
Name, address and contact details, phone number and email address, date of birth and gender, professional and work details,
Card ID, passport number, national or fiscal identification number, information on your income and assets, including details about your assets and liabilities, account balances, tax, and financial statements, business history, and performance, as well as any other similar information.
We obtain this information through our services and our websites and applications, account opening applications, demo registration, webinar registration, subscription to news updates and information provided in the course of communication with the client.

We may voluntarily request other personal information from time to time and if you choose not to provide the information we need to fulfill your request for a particular product or service, we may not be able to provide the requested product or service.

Please note that we keep records of your business history, including:
Products that you sell and performance, products that we sell in your name and performance, historical data on the operations and investments you made, including the amount invested, your preference or purchase of certain types of services and products.

We may record any communication, electronic, by phone, in person or otherwise, that we have with you about the services we provide and our relationship with you.
These recordings will be our exclusive property and constitute evidence of communications between us. Any telephone conversation can be recorded without the use of a warning tone or any other additional notice.

4. Your consent

When the use of your personal information by us requires your consent, such consent will be provided under the applicable terms and conditions of the client available on our website or any other contract we have concluded with you or stipulated in our communication with you.
You have the right to withdraw your consent at any time by contacting us using the contact information enabled for that purpose.

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5. Disclosure of personal data and transfer outside the European Economic Area

In the cases in which you give us your consent, through the means enabled for that purpose, we can, in the standard operation of our business, share selected information with:
– Credit providers and any regulatory, governmental or law enforcement authority as required by law or as agreed with you.
– With our insurers, agents, service providers, specialized advisors, suppliers and subcontractors that provide us with insurance services, administrative services or IT services, financial services, verification, regulatory and compliance services.
– Professional advisors such as our lawyers concerning to any ongoing or prospective legal proceedings to establish, exercise or defend our legal rights.
– With our auditors and accountants to meet our regulatory and financial reporting obligations.
– With affiliated brokers with whom we have a mutual relationship.
– With credit reporting agencies and referral agencies.
– With any member of our group, that is, our subsidiaries, our definitive holding company and its subsidiaries, and the successors in the title of our business.

Someone authorized by you.
In general, we require that third parties that handle or obtain your personal information recognize the confidentiality of this information, undertake to respect the right of privacy of any person and comply with all relevant data protection laws and this privacy notice. When a third party uses your personal data as a data controller, such use is not covered by this privacy notice and is not subject to the privacy standards and procedures of World Citizen Net, World Citizen Net Coin, and World Citizen Net Bank.

Keep in mind that third parties, such as credit reports and referral agencies, can keep track of any search and can use search details to help other companies conduct their searches. We may transfer your personal information outside the European Economic Area (“EEA”) to other companies in our group, as well as to processors participating in our name. To the extent that we transfer your information outside the EEA, we will ensure that the transfer is legal and that adequate security measures exist.

To transfer personal information to third parties in territories where the applicable legislation may not be adequate, we will arrange with such third parties to ensure appropriate and appropriate measures based on the standard contractual terms and conditions adopted by the European Commission.
When we make transfers to third parties in the USA, in some cases, we can rely on the applicable standard contractual clauses, binding corporate rules, the EU-USA Privacy Shield, or any other applicable equivalent agreement.

Before transferring any type of information to third parties, World Citizen Net Group, (World Citizen Net, World Citizen Net Coin, and World Citizen Net Bank), as well as any other company that depends on or belongs to our group, will be responsible for:
– Obtain your authorization through the means specified for that purpose.
– Obliging using the necessary means, to that or those third parties, to use the information provided, to fulfill only and exclusively with the objective for which said information has been provided and that once that objective has been achieved, the information provided will be removed from the database of that or those third parties.

6. Security and storage of personal information

World Citizen Net, World Citizen Net Coin, and World Citizen Net Bank, as well as any other company that belongs to the World Citizen Net Group, takes the protection of your data very seriously.

To meet that goal, we have taken measures and precautions that protect the security of your personal information and any other type. Our employees understand that they must respect the confidentiality of your personal information. We have a security team to ensure compliance with this privacy policy and applicable laws and regulations.

We maintain personal information in secure storage facilities, paper files and / or other records. When we consider that such personal information is no longer needed or that maintaining it may cause you some damage, we will proceed to remove all the details that identify you and destroy all records in a secure manner, provided that, this way of proceeding, do not enter in contradiction with any law or open legal procedure.

Please note that we are subject to certain laws and regulations that require us to keep a copy of the documents we use to comply with our customer’s due diligence obligations, and supporting evidence and transaction records with you and your relationship with us. for a period of five (5) years after our relationship with you has ended.

Personal information in writing form is subject to a storage period of twelve (12) years after our relationship with you has ended.

If we have personal information in the form of recorded communication, by phone, electronic, in person or otherwise, this information will be kept in line with local regulatory requirements, which will be five (5) or ten (10) years later. Our relationship With you it’s over.

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7. Cookies

A cookie is a small text that is stored on your computer or device when you visit a website or application. We use cookies on our websites and applications to provide you with a more relevant and effective experience.

WORLD CITIZEN NET PRIVACY POLICY

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8. Technological improvements

We want to give you a better experience through constant technological development. This may cause a change in the way personal information is collected or used. The impact of any technological change that may affect your privacy will be notified in this privacy notice at the time of the change.

9. Links to third-party websites

Our websites or applications may have links to external third-party websites. Please note that third-party websites are not covered by this privacy notice and those websites are not subject to our Privacy Policy. Verify with each third party your privacy standards and procedures.

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10. Your rights

The data protection law gives you a series of rights when it comes to the personal information we have about you. The key rights are set out below. You can get more information about your rights at the Office of the Information Commissioner (“ICO”).

You can also get more information on the following European Union website:
http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm

In certain circumstances, by law, you have the right to:

– Be informed in a clear, transparent and easily understandable way about how we use your personal information and about your rights. That is why we provide you with the way we treat the information in our Privacy Policy section.
If you need more information on how we use your personal information, let us know.
– Request access to your personal information (commonly known as “data subject access request”), which allows you to receive a copy of the personal information we have about you and verify that we process it legally.
– Request the correction of the personal information we have about you. This allows you to correct any incomplete or inaccurate information we have about you.
– Request the deletion of your personal information. This allows you to ask us to delete or delete personal information when there is no good reason to continue processing it (for example, we may need to continue using your personal data to comply with our legal obligations).
– You also have the right to ask us to partially or totally delete your personal information when you have exercised your right to object to the processing (see below).
– Object the processing of your personal information when we depend on a legitimate interest (or that of a third party) and there is something about your particular situation that makes you want to object to the use of your information on this basis and we do not have a compelling legitimate basis to do so that overrides your rights, interests and freedoms (for example, we may need it to defend a legal claim).
– Request the restriction of the processing of your personal information. This allows you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
– Request the transfer of your personal information to a third party, to carry out a contract between you and that third party.
– Withdraw your consent for the collection, processing, and transfer of your personal information for a specific purpose.
Once this request is received, we will no longer use your information for that specific purpose, as long as it does not harm us due to an open legal process or possible opening phase.
– File a complaint. If you believe we are using your information in a way that violates the data protection law, you have the right to file a complaint with your national data protection supervisory authority.
– You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your access request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information to help us understand the nature of your request, confirm your identity and guarantee your right to access the information (or exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who is not entitled to receive it.

Consider your request responsibly before submitting it. We will respond to your request as soon as possible. In general, this will be within a month from the moment we receive your request, but, if the request will take longer to be answered, we will let you know.

11. Complaint and Contact

If you are concerned about us ensuring your privacy, you can make a complaint. We will act upon it promptly. You can contact us as set out below.

If you are not satisfied with our response to your complaint, you have the right to file a complaint with the Information Commissioner’s Office (“ICO”) or in the competent authorities of the European Union.

If you have any questions regarding our privacy policy, please email: web@worldcitizennet.com

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