PRIVACY POLICY

1. INTRODUCTION

1. The Company is committed to being a responsible custodian of the information you provide to us and the information we collect in the course of operating our business. This Privacy Policy describes how the Company may collect and process information received by us in association with the operation of the USDT Guard Website and the provision of Services outlined in the Terms of Use. This Policy is addressed to the Company's clients as well as to those individuals who will provide their personal data for processing (hereinafter – Data Subjects).
2. Your Personal Data is processed in accordance with the General Data Protection Regulation (Regulation EU 2016/679, further - "the GDPR"), the Data Protection Act 2018 and other relevant legislation with respect to the accepted principles of good information handling (collectively referred to as the "Data Protection Legislation").
3. This Privacy Policy shall be governed by the laws of Hong Kong.
4. For all intents and purposes, the English language version of this Privacy Policy will be the original, governing instrument. In the event of any conflict between the English language version of this Privacy Policy and any subsequent translation into any other language, the English language version will govern and control.

2. DEFINITIONS

1. "Company", "We" means: a) SAFELEMENT LIMITED, a company registered in Hong Kong with registration number 3148041, having its registered office at Office 1111, Suite 1102, Lee Garden One, 33 Hysan Avenue, Causeway Bay, Hong Kong in case you are the resident of any country excluding European Union; b) SAFE3 UAB having its registered office at Vilnius, J. Jasinskio g. 16B, LT-03163 in case you are resident of European Union, which both operate USDT Guard website available at https://usdtguard.us (referred to as "we" and "us" hereinafter);
2. "Website" means the USDT Guard website operated by the Company and available at https://usdtguard.us;
3. "Privacy Policy" means the latest version of the Company's Privacy Policy which describes our policies and procedures pertaining to the collection, use, and disclosure of your Personal Data;
4. "Personal Data" means any information relating to the User, which identifies or may identify the User;
5. "User" means an individual or a legal entity that has read and agreed to the Terms of Use and the Privacy Policy and uses the services of USDT Guard provided by the Company through the Website (referred to as "you" or "yours" hereinafter);
6. "Services" means the services of USDT Guard provided by the Company and available to Users via the Website as set out in detail in the Terms of Use.

3. SCOPE OF THE POLICY

The purpose of this policy is to ensure that the Company's staff shall comply with the provisions of Hong Kong law and the EU GDPR when processing personal data. Any serious infringement will be treated seriously and may be considered under disciplinary procedures. The company adheres to the principles of data protection as laid down by the EU GDPR. In accordance with those principles personal data shall be:

• Processed fairly and lawfully and in a transparent manner in relation to the data subject;
• Processed for specified, explicit and legitimate purposes only and not further processed in a manner that is incompatible with those purposes;
• Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
• Accurate and up to date;
• Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
• Not kept longer than necessary;
• Processed in a manner that ensures appropriate security of the personal data;
• Not transferred outside the countries of the European Economic Area or the EU without adequate protection.

4. INFORMATION WE COLLECT

1. When you engage with us, we collect and process your Personal Data, which includes as follows:
   1. Personal identification information, including: name, e-mail address, phone number, country, full address, date of birth, registered address, banking details;
   2. Data collected in connection with "Know Your Customer" (KYC) compliance, "Anti-Money Laundering" (AML) compliance and "Counter-Terrorist Financing" (CTF) compliance;
   3. Device and website usage data, including: IP addresses; language preferences and other device identifiers; information relating to your access to the Platforms, such as device characteristics, date and time.
   4. The Company subjects the personal data to automated reading, verification of the authenticity and other automated processing of photos and scanned copies of documents and with further check against the data in multiple databases, including inter alia International politically exposed persons (PEPs) and Sanctions, Country Specific Sanctions Lists, Criminal Lists and Financial Lists. Once the personal data is not any more necessary for the purposes of applicable compliance rules, the Company shall erase the data completely off its servers without leaving any backup copies or, based on the same condition, transfer the data to the relevant Controller.

5. HOW WE COLLECT YOUR DATA

1. We collect Personal Data directly from you when you use our Website or services, communicate with us, or interact directly with us. For example, when you complete the contact form on our Website, Application or when you contact us via email.
2. We use industry standards for automatically collecting certain information about visitors to our Website. We collect information about you, or information collected by cookies and similar technologies, when you use, access, or interact with our Website. We shall ensure that processing is proportionate and that we have carried out a legitimate interest impact assessment. To the extent that the use of cookies or similar technologies requires your consent, we may also process your Personal Data based on your consent.
3. We also may collect information about you from third-party sources, including but not limited to, the following channels:
   1. marketing partners and resellers;
   2. advertising partners and analytics providers;
   3. public databases, credit bureaus and ID verification partners;
   4. social networks (for example, Twitter).
4. We protect the Personal Data obtained from third parties according to the practices described in this Privacy Policy and we also apply additional restrictions imposed by such third parties.

6. HOW WE USE YOUR DATA

We use your Personal Data for the following purposes:

• To provide, maintain, and improve our Services;
• To process transactions and send related information;
• To send administrative information, such as updates to our terms and policies;
• To respond to your inquiries and provide customer support;
• To comply with legal obligations and regulatory requirements;
• To detect, prevent, and address technical issues and security threats.

7. DATA SHARING AND DISCLOSURE

We do not sell, trade, or otherwise transfer your Personal Data to third parties except as described in this Privacy Policy. We may share your Personal Data with:

• Service providers who assist us in operating our Website and conducting our business;
• Legal authorities when required by law or to protect our rights;
• Business partners with your explicit consent.

8. COOKIES POLICY

1. We use cookies and similar technologies like pixels, tags, and other identifiers in order to remember your preferences, to understand how our Website is used, and to customize our marketing offerings.
2. A cookie is a small data file containing a string of characters that is sent to your computer when you visit a website. When you visit the websites again, the cookie allows that site to recognize your browser.
3. We use the following types of cookies on our Website:
   1. Strictly necessary cookies: these are essential for you to browse our Website and use its features.
   2. Performance cookies: these collect information about how you use our Website.
   3. Functional cookies: these allow our Website to remember the choices you make while browsing.
   4. Analytics cookies: these help us understand how visitors interact with our Website.
4. Most web browsers allow you to control cookies through their settings preferences. However, if you limit the ability of our Website to set cookies, you may impair your overall user experience.

9. DATA RETENTION

The Company will retain your Personal Data for as long as we deem it necessary to enable you to use the Website and to provide Services to you, to comply with applicable laws (including those regarding document retention), resolve disputes with any parties and otherwise as necessary to allow us to conduct our business. When the Company no longer needs to keep your Personal Data, it will securely delete or destroy it.

10. PROTECTION OF PERSONAL DATA

1. Your Personal data integrity is of high concern to us. We follow the standard practices within the industry to protect the Personal Data that we collect and maintain, including using Transport Layer Security (TLS) to encrypt information as it travels over the internet.
2. We have implemented technology and security policies and procedures intended to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to, such information, reasonably appropriate to the nature of the data concerned.
3. If you suspect that your Personal Data has been compromised, please immediately contact our Customer Support Team.

11. USER'S RIGHTS

Users residing in certain countries, including the EU, are afforded certain rights regarding their personal information:

• The right to access: you have the right to confirmation as to whether or not we process your Personal Data and, where we do, to access the Personal Data.
• The right to object to processing: you have the right to object to us processing your Personal Data, citing personal reasons.
• The right to rectification: you have the right to have any inaccurate Personal Data about you rectified.
• The right to data portability: you have the right to obtain and reuse your Personal Data for your own purposes across different services.
• The right to erasure: you have the right to request that the Company erase your Personal Data under certain conditions.
• The right to restrict processing: you have the right to request that the Company restrict the processing of your Personal Data under certain conditions.
• The right to withdraw consent: to the extent that the legal basis for our processing of your Personal Data is consent, you have the right to withdraw that consent at any time.

You may exercise any of your rights in relation to your Personal Data by contacting our Customer Support. We will aim to respond to your requests regarding your Personal Data within 1 (one) month of receipt of any such request.

12. INTERNATIONAL TRANSFER OF PERSONAL DATA

We may need to transfer your Personal Data to countries which are located outside the European Economic Area ("EEA"), for the purpose of providing the Services to you. Any transfer of your personal information outside of the EEA will be subject to a GDPR-compliant guarantee (such a Model Contract Clause approved by the European Commission) that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.

13. CHANGES TO THE PRIVACY POLICY

We may update this Privacy Policy from time to time and we encourage you to periodically review this page. If we make any material changes in the way we collect, use, and/or share your Personal Data, we will notify you by posting notice of the changes in a clear and conspicuous manner on the USDT Guard Website.

14. CONTACT INFORMATION

Should you have any questions regarding this Privacy Policy, please do not hesitate to contact us.