Last Updated: August 2023


Overview


Your privacy is important to us. REtokens USA Inc. (“REtokens USA Inc.”, “we”, or “us”) wants you to be familiar with how we collect, use and disclose your Personal Information.

This Privacy Policy (“Policy”) explains how we collect, use, and disclose your Personal Information when you visit or use services made available through our websites (“Websites”) and associated platforms operated by us from which you are accessing this Policy (collectively, the “Services”) including:


For you to exercise these rights, please get in touch with us using the information in the section "Contact Us". We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex and/or if we receive a high number of requests, in which case we will respond within three months.

Please be aware that there are exceptions and exemptions that apply to some of the rights which we will apply in accordance with the applicable laws. Moreover, due to the nature of blockchain technology, information that is recorded “on-chain” cannot practically be corrected, revised or deleted. Please see the section “Information Recorded On-Chain” for more information.


It is important that you ensure you have read this Privacy Policy - and if you do not think that we have processed your Personal Information in accordance with this Privacy Policy - you should let us know as soon as possible using the information at the section "Contact Us".


Similarly, you may complain to the relevant supervisory authority in your country. In the UK this is the Information Commissioner's Office, information about how to contact this

regulator can be found at www.ico.org.uk. Ideally, we recommend that you get in touch with us first so we can resolve any issues directly with you as quickly as possible.

Transfer of Personal Information Outside UK and EEA


Any transfer of your Personal Information outside the UK and the EEA will be carried out in accordance with the European Data Protection Laws to safeguard your privacy rights and give you remedies in the unlikely event of a security breach or to any other similar approved mechanisms.

Retention


The Personal Information we collect is stored on our servers or those of our service providers. We retain Personal Information in accordance with our record retention policies. Our record retention periods are established taking into account requirements of privacy laws, the purposes for which the information was collected, legal and regulatory requirements to retain the information for minimum periods, limitation periods for taking legal action, and our business needs. We may retain anonymous and aggregate information indefinitely.

Security


REtokens USA Inc. uses physical, technological, and organizational security measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Our employees, representatives and agents will have access to your Personal Information as necessary for the purposes described in this Policy.

Personal Information may be accessed by persons within our organization, or our third party service providers, who require such access to carry out the purposes indicated in this Policy, or such other purposes as may be permitted or required by the applicable law. Personal Information we collect is managed from our affiliate offices in Spokane Valley, Washington, United States.

However, while we have taken steps to help protect your Personal Information, we cannot fully eliminate security risks associated with Personal Information. No security

measures can provide absolute protection. We cannot ensure or warrant the security of any information you provide to us.


We may Transfer Personal Information Outside of your Country


Some or all of the Personal Information we collect may be stored or processed outside of your jurisdiction of residence, including in the United States. Your Personal Information may be processed and stored in the United States and the governments, courts or law enforcement or regulatory agencies of the United States may be able to obtain disclosure of your Personal Information through a lawful order made where the information is located.

By providing us with Personal Information, for users outside of the UK and EEA, you understand and expressly agree that we may transfer your information to another country, including Canada. If you are a user in the UK or EEA, please refer to our section “Transfer of Personal Information Outside UK and EEA”. If you do not agree to the transfer of your Personal Information outside of your jurisdiction (including to the US), as described here, do not provide us with Personal Information.


This Policy does not apply to third party sites


Our Services may contain links to websites owned by third parties. These other websites may have their own privacy policies and terms and conditions that are not governed by this Privacy Policy. We are not responsible for the privacy practices or the content of any website(s) owned and operated by third parties. Other websites may collect and treat information collected differently, so we encourage you to carefully read and review the privacy policy for each website you visit. Any links from our Services to other websites, or references to products, services or publications other than those of REtokens USA Inc., do not imply the endorsement or approval of such websites, products, services or publications by REtokens USA Inc.

Access and Correction

You may request access to your Personal Information and to request a correction if you believe it is inaccurate.

Please contact us by e-mail at legal@retokens.com if you would like to exercise either of these options. Please note that in some circumstances we may not be able to allow you to access certain Personal Information, for example if it contains Personal Information of other persons, or for legal reasons. We may require you to verify your identity before allowing you to access your Personal Information.

Contact Us


If you have any questions about this Policy, please contact our Policy Department at legal@retokens.com.

You may also contact our Privacy Officer in our primary office at 12904 E Nora Ste. C, Spokane Valley, WA 99216.