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1),(0,a.jsx)("li",{children:"The Administrator may implement technical measures to limit access from certain IP addresses geographically associated with regions where the provision of services is limited or not supported under the Company’s Internal Policies. Such measures are implemented solely to ensure the lawful and proper operation of the Services."})]}),(0,a.jsx)("h2",{children:"Registration, Verification and Accepting Terms and Conditions"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Applicant willing to open the Account shall complete the Registration procedure: to fill out the Registration forms on the Website, to provide the Authorization Details and to accept these Terms and Conditions by clicking the \xabRegister\xbb button and ticking on consent to the processing of personal data in the relevant field in the Registration form."}),(0,a.jsx)("li",{children:"Once the Applicant accepts these Terms and Conditions, it shall be deemed a bilateral agreement of the Parties."}),(0,a.jsxs)("li",{children:["During the Registration the Applicant shall provide the following information to the Administrator:",(0,a.jsxs)("ol",{children:[(0,a.jsxs)("li",{children:["An individual:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"Name;"}),(0,a.jsx)("li",{children:"Surname;"}),(0,a.jsx)("li",{children:"Email address;"}),(0,a.jsx)("li",{children:"Password."})]})]}),(0,a.jsxs)("li",{children:["A legal entity and an individual entrepreneur:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"Name of the company or an individual entrepreneur;"}),(0,a.jsx)("li",{children:"Website;"}),(0,a.jsx)("li",{children:"Description of the business;"}),(0,a.jsx)("li",{children:"Name and surname of the director or the authorized person;"}),(0,a.jsx)("li",{children:"Country of incorporation and registered address;"}),(0,a.jsx)("li",{children:"An email address and mobile number of the contact person;"}),(0,a.jsx)("li",{children:"Authorization details."})]})]})]})]}),(0,a.jsx)("li",{children:"By accepting the present Terms and Conditions, the Applicant declares that they are acting on their own behalf only and not acting on behalf or in the interest of third parties."}),(0,a.jsxs)("li",{children:["When undergoing the Verification in order to gain the full access to the Services, available to the Verified Accounts, the Customer shall provide the following data to the Administrator:",(0,a.jsxs)("ol",{children:[(0,a.jsxs)("li",{children:["An individual shall provide the Administrator with:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"An image of a valid ID document issued by an authorized state body, containing a unique identification number and the Customer’s photo;"}),(0,a.jsx)("li",{children:"The Customer’s mobile phone number;"}),(0,a.jsx)("li",{children:"The Internal Policies may require the Customer to disclose information on the purpose of the Account opening, source of wealth, occupation and name of employer;"}),(0,a.jsx)("li",{children:"To identify the Customer and manage fraud, the Administrator may demand that the Customer undergoes authentication with the use of videoconference, including the use of the third-party services."})]})]}),(0,a.jsxs)("li",{children:["A legal entity shall provide the Administrator with:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"A copy of the certificate of incorporation of a legal entity;"}),(0,a.jsx)("li",{children:"A certificate of good standing if the company is more than twelve (12) months old or any equivalent document issued by the state body, confirming the current legal status of the Customer;"}),(0,a.jsx)("li",{children:"The documents confirming the powers of the person having a right of signature on behalf of the company;"}),(0,a.jsx)("li",{children:"Details of the Beneficial Owners of the entity in compliance with the requirements set for individuals in the paragraph 4.5.1. of these Terms and Conditions;"}),(0,a.jsx)("li",{children:"The Customer’s mobile number;"}),(0,a.jsx)("li",{children:"If the Account is replenished by a bank transfer, additional documents are requested, including the Customer’s bank account statement;"}),(0,a.jsx)("li",{children:"The Internal Policies may call for provision of additional information."})]})]}),(0,a.jsxs)("li",{children:["Individual entrepreneurs shall provide the Administrator with:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"A copy of the certificate of state registration of an individual entrepreneur;"}),(0,a.jsx)("li",{children:"A certificate confirming an individual entrepreneur’s legal capacity if their state registration took place more than 12 (twelve) months ago, or a similar document issued by the state body and confirming the Customer’s due legal status;"}),(0,a.jsx)("li",{children:"Details of the individual registered as an individual entrepreneur in compliance with the requirements set in the paragraph 4.5.1. of these Terms and Conditions;"}),(0,a.jsx)("li",{children:"The Customer’s mobile number;"}),(0,a.jsx)("li",{children:"If the Account is replenished by a bank transfer, additional documents are requested, including the Customer’s account statement;"}),(0,a.jsx)("li",{children:"The Internal Policies may call for provision of additional information."})]})]})]})]}),(0,a.jsx)("li",{children:"To verify the phone number stipulated by the Customer in the System, the Administrator shall send an automatically generated one-time password to the stipulated phone number that should be entered on the Website."}),(0,a.jsx)("li",{children:"If the data subject to clauses 4.5.1. - 4.5.3. is not provided or proved to be unreliable, incomplete, outdated in full or in part, the Verification shall be deemed failed, and the Account shall be subject to restrictions provided for the Unverified Accounts."}),(0,a.jsx)("li",{children:"The Verification process usually shall be performed within 24 hours after the Customer has provided the requested data. The Verification may exceed the peri

1od of 24 hours, in case the Administrator has a reasonable ground to perform the enhanced due diligence."}),(0,a.jsx)("li",{children:"The Verification shall be deemed completed at the moment the Customer receives the confirmation from the Administrator via the email or via the phone number provided by the Customer in the System at the choice of the Customer. Once the Verification is completed, the Customer may use the full scope of the System Services available for the Verified Accounts."}),(0,a.jsx)("li",{children:"The Customer shall notify the Administrator about any changes in the data provided for the Verification in a timely manner and provide up-to-date data as soon as reasonably possible."}),(0,a.jsx)("li",{children:"The Administrator may regularly verify whether the data filed by the Customer is up to date. If any unreliable, incomplete, outdated data, expired filed documents are detected, the Administrator may request that the Customer files up-to-date data within 14 days."}),(0,a.jsx)("li",{children:"If the Customer fails to file the requested data within the period provided for by clause 4.11., the Administrator may cancel the Account Verification and impose the restrictions provided for the Unverified Accounts."})]}),(0,a.jsx)("h2",{children:"Account"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"Once the Applicant completes the Registration, the Account is created, and the Applicant becomes the Customer."}),(0,a.jsx)("li",{children:"The Customer may open separate Wallets for the different currencies available for use. All the Funds transferred to the Customer’s Account are stored in the Wallets in corresponding currencies."}),(0,a.jsx)("li",{children:"The Funds can be kept in the Account for an indefinite period of time. If the Account has no transactional activity for 6 months, a monthly account inactivity fee is introduced for such a Customer."}),(0,a.jsx)("li",{children:"Certain limits may be applicable to the Wallet in respect to replenishment of the Funds, payments and withdrawals of the Funds, depending on the Customer’s status, the Type of Wallet, and other factors that the Administrator may take into account. These limitations are determined in accordance with these Terms and Conditions and are available on the Website."}),(0,a.jsx)("li",{children:"The Customer may use the Unverified Account with the applicable limitations or upgrade to the Verified Account by the means of the Verification set out in the paragraphs 4.5.- 4.9."}),(0,a.jsx)("li",{children:"The Customer may open a Personal and/or a Business Account. The special features of the Personal and Business Accounts are available on the Website."}),(0,a.jsx)("li",{children:"To open the Account, an individual must be 18 years or older, acting in full capacity in accordance with their national laws. By creating the Personal Account, the Customer declares that they have reached the age of 18, the Administrator may demand that the Customer files a confirmation of their age at any time."}),(0,a.jsx)("li",{children:"To open the Business Account, the Customer must be a legal entity or an individual entrepreneur having full capacity to open the account in accordance with the laws and requirements of their country of incorporation."}),(0,a.jsx)("li",{children:"Accounts may not be opened for US citizens, US permanent residents and legal entities incorporated in the US."}),(0,a.jsx)("li",{children:"The Customer may open the Account only if this does not contradict the provisions of the laws of the country of their permanent residence or the Customer’s registration. By opening the Account, the Customer declares and guarantees to the Administrator that opening of such an Account by the Customer does not violate any laws or regulations applicable to the Customer. The Customer shall compensate the Administrator an amount of all losses incurred by the Administrator if the Customer violates provisions of this clause."}),(0,a.jsx)("li",{children:"In case the Customer intends to open the Business Account, the additional agreement shall be made between the Administrator and the Customer. The Customer must comply with the provisions of such applicable additional Agreement along with the obligations under these Terms and Conditions and the Internal Policies."}),(0,a.jsx)("li",{children:"The information on the Customer’s Transactions with the Funds and use of their Wallet is recorded and kept by the Administrator for the duration of the effective term of these Terms and Conditions and for a period of 5 (five) years after these Terms and Conditions are terminated and the Account is closed."}),(0,a.jsx)("li",{children:"By making the new Transaction resulting in the change of balance of the Funds in the Wallet, the Customer confirms the Wallet balance. The Customer’s confirmation is expressed by clicking the appropriate button confirming the new Payment Order."}),(0,a.jsx)("li",{children:"An access to the Wallet and any Transactions involving the use of the Wallet are only available upon the Authorization."}),(0,a.jsx)("li",{children:"The Login is generated by the System b

1y default from the email stipulated by the Customer upon the Registration or changed upon the Customer’s request sent to the Customer support. The Password shall be generated by the Customer independently. The Login and Password shall be used for the Authorization and can be changed at any time."}),(0,a.jsx)("li",{children:"The Customer is responsible for keeping the Authorization Details confidential. Any actions related to the Wallet performed with the use of the valid Authorization Details shall be considered to be as actions performed by the Customer."}),(0,a.jsx)("li",{children:"In case the Customer fails to enter the Authorization Details 3 times, the Account shall be blocked. To recover the access to their Wallet, the Customer shall contact the Customer support."}),(0,a.jsx)("li",{children:"In case the Customer loses the Authorization Details, the Customer shall contact the Customer support and request to recover the access to their Wallet."}),(0,a.jsxs)("li",{children:["In order to recover the access to the Personal Account:",(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Customer requests the link to be sent to the email provided by the Customer in the System;"}),(0,a.jsx)("li",{children:"In case the Customer has verified the mobile number, the Customer receives a digital code via SMS and enters the received code on the Website available by the link sent to the Customer’s email indicated by the Customer in the System;"})]})]}),(0,a.jsxs)("li",{children:["In order to recover the access to the Business Account:",(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"A request for restoring the access is to be sent to the Customer support."}),(0,a.jsx)("li",{children:"The Customer receives a digital code via SMS and enters the received code on the Website available by the link sent to the Customer’s email indicated by the Customer in the System."})]})]}),(0,a.jsx)("li",{children:"In case the activities of the Customer are deemed suspicious or controversial to the Terms and Conditions, other agreements concluded between the Customer and the Administrator, the Internal Policies or the requirements of current legislation, the Administrator shall notify the Customer via the email address indicated by the Customer in the System on such suspicious activities, suspected or actual fraud or security threats."}),(0,a.jsx)("li",{children:"The Administrator reserves the right to perform the Account Lockdown without prior notification of the Customer in case of objectively justified reasons relating to the security of the Account, the suspicion of unauthorized or fraudulent use of the Account, the violation of the provisions of the Terms and Conditions or the Internal Policies."}),(0,a.jsx)("li",{children:"The Administrator shall unblock the Account once the reasons for the Account Lockdown no longer exist."}),(0,a.jsx)("li",{children:"The Customer may close the Wallet at any time by contacting the Customer Service. Closing the particular Wallet does not lead to the Account closure."}),(0,a.jsx)("li",{children:"The Customer is restricted from registering multiple Accounts, except opening one Personal Account and one Business Account as an individual entrepreneur. Otherwise, the Administrator shall have the right to automatically mark such accounts as fraudulent and suspend the provision of the System Services of all such Accounts."})]}),(0,a.jsx)("h2",{children:"Transactions"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Customer may replenish their Wallet by logging into their Personal Account on the Website and following the relevant instructions for the Wallet replenishing. The ways of the Wallet replenishing may vary depending on the location of the Customer. The currently available ways are available on the Website."}),(0,a.jsx)("li",{children:"Wallet replenishment and the withdrawal of the Funds services are the payment services provided by third parties; therefore, they are not a part of the System Services."}),(0,a.jsx)("li",{children:"The Wallet replenishment is carried out in accordance with the procedure set forth in the Terms and Conditions, the Internal Policies, policies of third parties that provide services, and applicable law."}),(0,a.jsx)("li",{children:"The Administrator may restrict the range of the Wallet replenishment methods for certain categories of the Customers depen

1ding on the degree of risk of the activity and/or transactions of the Customer."}),(0,a.jsx)("li",{children:"When the Wallet is credited by third parties, all rights and responsibilities pertaining to the Funds credited to such Wallet shall be the Customer’s. Such transactions made by the third parties are considered by the Parties as activities by a third party on the Customer’s behalf and for the Customer’s benefit."}),(0,a.jsx)("li",{children:"The Administrator sets the limits for the Wallet replenishment for the security reasons. The limits are displayed on the Wallet page."}),(0,a.jsx)("li",{children:"Additional fees may be charged by third parties for the Wallet replenishment, depending on the method of the replenishment."}),(0,a.jsx)("li",{children:"The Transfer of Funds is carried out on the basis of the Customer’s Order electronically with the use of the Wallet."}),(0,a.jsx)("li",{children:"When the Administrator receives the Order to transfer the Funds from the Customer’s Wallet, the Administrator identifies the Customer using the Authorization Details. In some cases, the Administrator may demand that additional identification procedures should be completed before the Payment Order is fulfilled."}),(0,a.jsx)("li",{children:"All the Transactions carried out with the use of the Authorization Details of this Customer shall be considered as Transactions carried out by this Customer unless the Administrator is notified on the unauthorized or fraudulent use of the Account in accordance with the paragraph 3.4.5."}),(0,a.jsx)("li",{children:"The Transaction not exceeding the applicable limits set for the Wallets shall be performed without undue delay not later than 24 hours after the Payment Order is received by the Administrator. The timing of the Transaction that depends on third-party financial services is determined in accordance with the policies of such third parties. The Administrator shall not be liable for the delay caused by the fault of the third parties."}),(0,a.jsx)("li",{children:"The Customer may enable notifications of the executed Payment Orders in their Account on the Website."}),(0,a.jsx)("li",{children:"The Administrator may restrict the list of payees of the Funds for certain categories of the Customers depending on the degree of risk of the activity and/or transactions of the Customer. Specific restrictions are available on the Website."}),(0,a.jsx)("li",{children:"The Administrator may restrict the list of available withdrawal methods of the Funds for certain categories of the Customers depending on the degree of risk of the activity and/or the Transactions of the Customer. Specific restrictions are available on the Website."}),(0,a.jsx)("li",{children:"Existing limits on the amount of the balance of the Funds in the Wallet and amount of payments applicable to different statuses of the Accounts and categories of the Customers, depending on the level of risk associated with the Customer’s activities, and/or Transactions are available on the Website."}),(0,a.jsx)("li",{children:"The Customer may choose a method for a 

1withdrawal by creating a request for a withdrawal of the Funds from their Wallet. During the withdrawal of the Funds, the Customer may be requested to proof their identity. For the withdrawal of the Funds, an amount of the Funds on the Customer’s Wallet should be sufficient to cover the Fees for the withdrawal of the Funds."}),(0,a.jsx)("li",{children:'To replenish the Wallet with the use of a bank card, the Administrator may request the Customer to undergo the verification procedure "Know Your Customer" in accordance with the AML Policy.'}),(0,a.jsx)("li",{children:"If the Customer successfully completes the identification procedure and the Funds are credited from the Customer’s bank card to the Wallet, the card transaction is non-refundable. If the Customer does not complete the identification procedure, the card transaction is refunded automatically. The refund to a bank card may take up to 14 business days depending on the Customer’s bank’s policies."}),(0,a.jsx)("li",{children:"The Customer may download the electronic reporting documents on the executed Transactions for any period of time at their own discretion in their Account free of charge."}),(0,a.jsx)("li",{children:"All the Transactions executed by the Customer using the System are final and are not subject to disputes, revisions or cancellations, with the exception of the Wallet replenishment Transactions performed using the external systems that have been classified as fraudulent."}),(0,a.jsx)("li",{children:"When the Customer loads their Wallet with a card, these refund rules apply. If the Customer completed the card verification and received the Funds to the Wallet, the card Payment becomes non-refundable. If the card verification is not completed, the pending card Payment is dropped automatically. The Customer's bank may need several business days (usually 2 to 14) for the Funds to return to the card balance."})]}),(0,a.jsx)("h2",{children:"Rates and Procedures for Charging Fees"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Administrator shall charge the Fees for the Services provided to the Customer."}),(0,a.jsxs)("li",{children:["The amount and procedures for charging the Fees are available on the Website in the \xab",(0,a.jsx)(h(),{"data-underline":!0,href:d.qv.Fees,children:"Fees"}),"\xbb section."]}),(0,a.jsx)("li",{children:"The Administrator may unilaterally change the Fees rates. Such changes and amendments shall come into effect from the day that such changes and amendments are published on the Website."}),(0,a.jsx)("li",{children:"All Fees are calculated in the currency of the Transaction and rounded off to the nearest whole cents."}),(0,a.jsx)("li",{children:"The System Services provided to the Customer by the Administrator are not subject to VAT or any other turnover taxes."}),(0,a.jsx)("li",{children:"All the applicable Fees are charged from the Customer’s Wallet by the Administrator upon the completion of the Transaction subject to the Fees, or at the moment when the Administrator has substantiated grounds to charge the applicable Fees."}),(0,a.jsx)("li",{children:"If the current balance on the Wallet is not sufficient to charge the applicable Fees, the Administrator may reject the Transaction and request the Customer to pay the applicable Fees."}),(0,a.jsxs)("li",{children:["The exchange rates applicable to the Transfer of the Funds between the Wallets in different currencies are calculated in accordance with the"," ",(0,a.jsx)("a",{"data-underline":!0,href:"https://openexchangerates.org/",target:"_blank",rel:"noopener noreferrer nofollow",children:"Open Exchange Rates"})," ","platform plus a Fee established by the Administrator. The final exchange rates applied to the Transaction are fixed at the time of the Transaction and are reflected in the Account prior the Payment Order initiated by the Customer."]})]}),(0,a.jsx)("h2",{children:"Personal Data"}),(0,a.jsx)("ol",{children:(0,a.jsxs)("li",{children:["The Administrator processes personal data of the Applicants and the Customers. The"," ",(0,a.jsx)(h(),{"data-underline":!0,href:d.qv.DocCanadaPrivacy,children:"Privacy Notice"})," ","applicable to the Applicants and the Customers is available on the Website as a separate document."]})}),(0,a.jsx)("h2",{children:"Liability"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"In the event of failure to comply and/or improper fulfilment of the obligations under these Terms and Conditions, the Parties shall be responsible in accordance with the provisions of these Terms and Conditions, the Internal Policies, and the applicable laws."}),(0,a.jsx)("li",{children:"If the Customer delays the fulfilment of any obligation in the monetary form as set forth in these Terms and Conditions, the Customer shall pay to the Administrator a penalty fine in the amount of 0.1% (one tenth of a percentage point) of the amount of such delayed funds to be transferred to the Administrator for every day of such delay. The Customer shall pay to the Administrator the penalty fine as specified in this paragraph of the Terms and Conditions within 3 (three) business days after the date the Customer receives a relevant request from the Administrator in writing or electronically. The Administrator has the right, but not the obligation to send a penalty fine payment request."}),(0,a.jsx)("li",{children:"The Customer shall repay to the Administrator the damages incurred as a result of any damages charged from the Administrator due to the Customer’s violations of the applicable laws when using the System on condition that the Administrator can provide the relevant documents that confirm the amount of the damages incurred by the Administrator."}),(0,a.jsx)("li",{children:"The Customer shall be responsible for all the Transactions accounted for in the Wallet, including any Transactions with the use of bank payment cards. These Transactions shall also include the Transactions executed by third parties that have access to the Customer’s Wallet."}),(0,a.jsx)("li",{children:"The Customer shall take full responsibility to get acknowledged with the current legislation of the Customer’s residence, regulating the Account opening and money transfer Transactions via the System. The Administrator shall not be liable for any breach of the national laws by the Customer resulted from the use of the System. If the Customer’s use of the System and Services contradicts the laws of this Customer’s jurisdiction, such Customer should immediately stop using the Services."}),(0,a.jsx)("li",{children:"The Customer shall take full responsibility for all the risks related to the use of the Internet during the Customer’s interaction with the Administrator, other Customers and third parties."}),(0,a.jsx)("li",{children:"The Customer shall not undertake any activity that misleads other parties about the Services offered by the Administrator, which can directly or indirectly damage the Administrator’s reputation, including but not limited to impersonating themselves as representatives of the Administrator in any way or context, providing false data related to the System including but not limited to fal

1sifying transaction IDs, wallet IDs and any other data such as text, screenshots, or any other media, creating clones of the Administrator’s website, and other similar activities. In case of violation the Administrator reserves the right to block the Customer’s Accounts, freeze the Funds for the period of investigation, and limit the usage of the System in other ways. The Administrator also reserves the right to pursue legal action in courts of applicable jurisdiction, including cases when this rule is violated by other parties that are not the Customers of the Administrator."}),(0,a.jsx)("li",{children:"The Customer shall protect the Administrator’s interests, reimburse the Administrator’s losses and pay compensations to the Administrator as well as indemnify the Administrator and its affiliates against any claims or damages, costs or expenses (including expenses for legal support, penalties or forfeits) resulting from violation by the Customer of these Terms and Conditions or any applicable laws or regulations and/or use of the System. This provision shall survive termination of relations between the Parties."}),(0,a.jsx)("li",{children:"If, through the Customer’s fault, a completed Payment serves as a ground for a payer to file a claim to the Administrator for protection of their violated right, the Administrator may demand that the recipient of the Funds reimburses losses resulting from collection of funds or other property from the Administrator to the benefit of the payer."})]}),(0,a.jsx)("h2",{children:"Disclaimer"}),(0,a.jsxs)("ol",{children:[(0,a.jsxs)("li",{children:["The Administrator shall have no responsibility to the Customer:",(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"If the Customer transfers their data to any third parties, deliberate provision of access to their Wallet in the System, or any other violation of the confidentiality of the Customer’s information caused by the Customer’s fault;"}),(0,a.jsx)("li",{children:"For illegal activities of any third parties, including those related to the use of the Customer’s registration data and the Customer’s email or the Authorization Details;"}),(0,a.jsx)("li",{children:"For presence of any viruses or any other malicious software in the hardware and software used by the Customer to access the System;"}),(0,a.jsx)("li",{children:"For any disputes pertaining to any transactions between the Customers made via the System;"}),(0,a.jsx)("li",{children:"For violation of the current legislation by the Customer in relation to the use of the System as well as for the complaints pertaining to the Customer from tax, regulation, and law enforcement authorities regarding any reporting documentation or taxation in relation to the Customer’s transactions involving the System;"}),(0,a.jsx)("li",{children:"If the Customer does not have access to the software or hardware that ensure the use of the System;"}),(0,a.jsx)("li",{children:"If the Customer cannot be reached by using the Contact Details filed thereby, particularly, due to the reason that the Customer filed unreliable data or fails to update such data in a timely manner;"}),(0,a.jsx)("li",{children:"For any payment services provided to the Customer by third parties;"}),(0,a.jsx)("li",{children:"For any actions taken by third parties whose websites the Customer visited following a link or information provided on the Website;"}),(0,a.jsx)("li",{children:"For temporary inoperability of the System, malfunctioning and errors in the operation of hardware or software (including disconnection or damage of electricity supply and communication networks, software malfunctioning, interruption of mail services, Internet provider’s, payment system operations, disruption in other lines, channels and/or networks that are provided, offered or serviced by third parties, etc.), occurred not through the Administrator’s fault; in this case, the Administrator shall not bear responsibility for the Customer’s possible losses."})]})]}),(0,a.jsx)("li",{children:"In the event of the loss of the Authorization Details, the System’s locking the Wallet, the Customer’s loss of the Password, the Wallet Lockdown, or other events that cannot be remedied without the confirmation of the Customer’s identity, the Administrator shall have no responsibility if the access to the Account cannot be recovered because the Customer is lacking access to their email, mobile number, or the inability to provide other information in order to confirm their identity in accordance with the provisions of clauses 5.20 of the Terms and Conditions."}),(0,a.jsxs)("li",{children:["The Administrator shall not be responsible for any damages and losses incurred by the Customer or by any third party as a result of:",(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Wallet Lockdown in accordance with these Terms and Conditions or the requirements of the law;"}),(0,a.jsx)("li",{children:"Failure to pass the Verification;"}),(0,a.jsx)("li",{children:"Incorrect completion of the Payment Orders to carry out the Transactions or completion by mistake;"}),(0,a.jsx)("li",{children:"Violation by the Customer of the established procedure for making the Payments;"}),(0,a.jsx)("li",{children:"Administrator’s or third parties’ compliance with the legislative or regulative requirements;"}),(0,a.jsx)("li",{children:"Failure to read the up-to-date version of the Terms and Conditions or the Internal Policies and other information published on the Website;"}),(0,a.jsx)("li",{children:"Impossibility to use a desired payment method at the Customer’s location;"}),(0,a.jsx)("li",{children:"Violation by the Customer of these Terms and Conditions or the Internal Policies, as well as the Administrator’s instructions and guidelines."})]})]}),(0,a.jsx)("li",{children:"In any event, the Administrator’s responsibility to the Customer shall always be limited to the amount that does not exceed the amount of the Fees charged to such Customer for a period of the previous 3 months."}),(0,a.jsx)("li",{children:"The Administrator shall not be responsible for any indirect or consequential damages incurred by the Customer or any third parties, including any loss of profit, loss (forfeit, non-receipt, unsubstantiated spending) of revenue, income, contracts, customers, time, data, enterprise, or reputation."}),(0,a.jsx)("li",{children:"The Administrator shall provide to the Customer the Services \xabas is\xbb as at the moment, without any express, implied or statutory representations or guarantees."})]}),(0,a.jsx)("h2",{children:"Communication Between the Parties"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Administrator shall use the Contact Details as means of communication with the Customer."}),(0,a.jsx)("li",{children:"The communication between the Customer and the Administrator may be done in English language."}),(0,a.jsxs)("li",{children:["The Customer may contact the Administrator at any time by the email"," ",(0,a.jsx)("a",{"data-underline":!0,href:`mailto:${d.qv._EmailSupport}`,target:"_blank",rel:"noopener noreferrer nofollow",children:d.qv._EmailSupport}),"."]}),(0,a.jsx)("li",{children:"The Administrator may inform the Customer on the changes in the Services provided either by sending email notifications or by posting the updates on the Website."}),(0,a.jsx)("li",{children:"The document flow between the Customer and the Administrator shall be in electronic form via the Account. Moreover, the use of the Authorization Details by the Customer shall be deemed by the Parties due and sufficient method of the Customer Authentication for the purposes of the document flow as well as for c

1onfirmation of authenticity and integrity of the provided electronic document, except for the cases provided for by the Terms and Conditions or the Internal Policies. Entering the Customer’s Authenticated Data shall be deemed by the Parties equal to the Customer’s handwritten signature."}),(0,a.jsx)("li",{children:"Administrator may send emails to the Customer informing about new features of the Wallet and special offers. By accepting these Terms, the Customer agrees to receive such communication. The Customer may unsubscribe anytime."})]}),(0,a.jsx)("h2",{children:"Term and Termination"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"These Terms and Conditions shall be in effect for an indefinite period of time until terminated in accordance with the provisions stated below."}),(0,a.jsx)("li",{children:"The Customer may close the Account at their discretion at any time if the Customer does not have any unfulfilled obligations to the Administrator. The Account can be closed at the Customer’s personal account."}),(0,a.jsx)("li",{children:"After the Customer initiates closure of the Account, the execution of the Transactions with the use of the Account shall be impossible. Any monetary obligations of the Parties created prior to the date of deletion of the Account shall retain until they are fully executed."}),(0,a.jsx)("li",{children:"In case any Funds remain on the Account of the Customer with whom the Agreement is terminated, the Administrator shall transfer the remaining Funds to the payment details indicated by the Customer, deducting the applicable fees."}),(0,a.jsx)("li",{children:"The Administrator may unilaterally terminate these Terms and Conditions, sending the obligatory written notification to the Customer no later than two months in advance."}),(0,a.jsx)("li",{children:"After the Account is deleted, information on completed Transactions shall be kept by the Administrators for 5 years in accordance with the requirements of the law."})]}),(0,a.jsx)("h2",{children:"Amendments"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Administrator may unilaterally amend these Terms and Conditions by publishing the updated text on the Website."}),(0,a.jsx)("li",{children:"The Administrator shall notify the Customer on the upcoming amendments of these Terms and Conditions by posting an informational message inside the Client’s Account no later than 2 (two) months before such amendments come into force. The Customer shall either accept or reject the changes before the date of their proposed date of entry into force. The Customer shall notify the Administrator on rejection of the amendments via contacting the Customer support. In case of rejection, the Agreement shall be terminated on the date the amendments enter into force."}),(0,a.jsx)("li",{children:"The amendments come into force since the updated text is published on the Website."}),(0,a.jsx)("li",{children:"The use of the Services by the Customer shall be considered as the unconditional acceptance of the updated Terms and Conditions."}),(0,a.jsx)("li",{children:"Any appendixes to the Terms and Conditions shall constitute the integral part of these Terms and Conditions."}),(0,a.jsx)("li",{children:"Without limitations to the provisions stated in the present Section 13, the period stated in the paragraph 13.2. does not cover the notification timeframe to any amendments of the Fees applicable to the Services provided by the Company. The Fees changes may be applied immediately and without prior notice. In addition, amendments necessary for compliance with applicable laws or regulations may take effect immediately, without prior notice to the Customer."})]}),(0,a.jsx)("h2",{children:"Force Majeure"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Parties shall not be responsible for any delays in the performance or non-performance of the obligations, any expenses, including losses, and costs related to complaints by any third parties that may result from any acts of God, acts of civil or military authorities, civil disturbances, strikes or other labour disputes, fires, transportation contingencies, interruptions in telecommunications, utility, Internet services or network provider services, acts or omissions of a third party, infiltration or disruption of the services by a third party by any means, including without limitation, DDoS attacks, software viruses, Trojan horses, worms, time bombs or any other software program or technology designed to disrupt or delay the Services (each a \xabForce Majeure Event\xbb). The Party experiencing the impact of any Force Majeure Event shall notify the other Party within 10 days after the commencement of such Force Majeure Event."}),(0,a.jsx)("li",{children:"The provisions of paragraph 14.1. shall not limit or terminate the Customer’s obligations pertaining to making the returning Payments, as well as payment of any fines, penalties, fees, commissions, returning any goods, or (not) performing any works or services after the Force Majeure is over."})]}),(0,a.jsx)("h2",{children:"Miscellaneous"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"These Terms and Conditions and the relations between the Administrator and the Customer arising from them are governed by the laws of Canada for all relations concerning the System Services rendered by Queensland Foreign Exchange, Inc.;"}),(0,a.jsx)("li",{children:"All the disputes between the Parties arising from these Terms and Conditions shall be settled through negotiations. The basis for negotiations shall be either Party’s submitting a written complaint to the other Party. All the complaints and claims shall be reviewed within thirty days of their receipt."}),(0,a.jsx)("li",{children:"In case a dispute cannot be resolved by negotiations within the specified period of time, either Party may apply to a court. The following courts shall have the jurisdiction to settle any dispute arising out of or in connection with these Terms and Conditions the courts of Canada for all relations concerning the System Services rendered by Queensland Foreign Exchange, Inc.;"}),(0,a.jsx)("li",{children:"The choice of law and jurisdiction in the clause 15.3. does not affect the mandatory rights of the Customer under the laws of the country of their residence."}),(0,a.jsx)("li",{children:"The Customer shall not transfer any rights or obligations under these Terms and Conditions to any third party without the prior written consent given by the Administrator."}),(0,a.jsx)("li",{children:"If any provision of these Terms and Conditions is held to be invalid or unenforceable, such provision shall be struck out and the remaining provisions shall be enforced."}),(0,a.jsx)("li",{children:"This Agreement enters into force since the Applicant clicks the \xabRegister\xbb button during the Registration process."}),(0,a.jsx)("li",{children:"The Customer acknowledges and confirms that all the provisions of the Terms and Conditions are clear, and that the Customer agrees with the Internal Policies available on the Website, accepts them unconditionally and shall comply with their provisions and requirements."})]}),(0,a.jsxs)("div",{"data-skip-counters":"true",children:[(0,a.jsxs)("div",{"data-appendix":"true",children:["APPENDIX 1",(0,a.jsx)("br",{}),"TO VOLET.COM TERMS AND CONDITIONS"]}),(0,a.jsx)("h2",{children:"Goods, Works, and Services Prohibited for Sale via the System:"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"Weapons, arms, ammunition and defense products, guns, replicas of firearms or cold steel weapons."}),(0,a.jsx)("li",{children:"Drugs, drug-like substances and plants (including marijuana/cannabis), as well as their ingredients, or any substances for their production, as well as de

1scriptions of methods for producing such substances."}),(0,a.jsx)("li",{children:"Medical drugs and medications dispensed on prescription only, as well as raw materials or instructions for their production."}),(0,a.jsx)("li",{children:"State awards or distinguishing badges."}),(0,a.jsx)("li",{children:"Identification documents and government issued documents (including falsified documents), and everything connected with creating or obtaining false identification documents or counterfeit government issued documents."}),(0,a.jsx)("li",{children:"Government agencies’ uniforms."}),(0,a.jsx)("li",{children:"Specialty items related to the police and law enforcement agencies."}),(0,a.jsx)("li",{children:"Electronic equipment prohibited for use in this country or region."}),(0,a.jsx)("li",{children:"Devices used for hacking and tampering with locks."}),(0,a.jsx)("li",{children:"Information containing personal data or data suitable for undertaking illegal activities (spam emails, etc.)."}),(0,a.jsx)("li",{children:"GWS or information containing state, banking, or trade secrets."}),(0,a.jsx)("li",{children:"GWS whose sale violates any third parties’ copyright and/or related rights, trademark rights, or patents."}),(0,a.jsx)("li",{children:"Information that violates a person’s privacy, infringing upon the honor, dignity and business reputation of individuals and legal entities."}),(0,a.jsx)("li",{children:"Information transmitted exclusively virtually and not recorded on any material carrier (ideas, methods, principles, etc.)."}),(0,a.jsx)("li",{children:"Archaeological heritage items."}),(0,a.jsx)("li",{children:"Precious metals."}),(0,a.jsx)("li",{children:"Items or services that violate the norms of public morality (including, but not limited to, child pornography, Nazi memorabilia items, escort services, prostitution, and adult)."}),(0,a.jsx)("li",{children:"Any items with available initially but removed serial numbers."}),(0,a.jsx)("li",{children:"Internet gambling."}),(0,a.jsx)("li",{children:"Malicious software."}),(0,a.jsx)("li",{children:"Goods or services directly or indirectly compelling illegal actions (promoting social, racial, religious, or ethnic strife; discrimination, violence, hatred, revenge, harassment; containing propaganda of terror or physical harm)."}),(0,a.jsx)("li",{children:"Perishable goods."}),(0,a.jsx)("li",{children:"Fake or counterfeit goods."}),(0,a.jsx)("li",{children:"Items and equipment intended for use (including illegal transfer) of copyright protected items without the permission of the authors (including, but not limited to, components designed to remove copyright protection or regional restrictions, or software elements of electronic devices)."}),(0,a.jsx)("li",{children:"Dangerous goods (including, but not limited to, those that contain explosive, toxic, poisonous, and/or radioactive materials)."}),(0,a.jsx)("li",{children:"Information about the production of explosive, pyrotechnic, incendiary, and other similar substances and devices."}),(0,a.jsx)("li",{children:"Human organs and human remains."}),(0,a.jsx)("li",{children:"Goods or services that have no value in use."}),(0,a.jsx)("li",{children:"Services of auctions or trading systems that allow carrying out activities excluding transfer of GWS that have value in use."}),(0,a.jsx)("li",{children:"Financial or payment instruments whose accounting systems do not ensure proper identification of the owner for the purpose of combating illegal trade, financial fraud, and money laundering of funds obtained by illegal means."}),(0,a.jsx)("li",{children:"Asset management and investment services provided by unlicensed businesses, as well as any intermediary activity that facilitates the transfer of funds between the parties entering into a transaction forbidden herein."}),(0,a.jsx)("li",{children:"Items of artistic and historical value that constitute a country’s cultural values."}),(0,a.jsx)("li",{children:"Services of organizers and operators of lotteries, betting, casinos and any other types of gambling."}),(0,a.jsx)("li",{children:"Services of advertising (promoting) goods, works and services specified in items 1-33 of this list."})]})]})]})}},latest:"v1"},"agreement-costa-rica":{versions:{v1:function(){return(0,a.jsxs)("div",{"data-template":"default",children:[(0,a.jsx)("p",{children:"These Terms and Conditions shall enter into force from the 26th of March 2024."}),(0,a.jsx)("h2",{children:"Preamble"}),(0,a.jsxs)("ol",{children:[(0,a.jsxs)("li",{children:["This document (hereinafter — ",(0,a.jsx)("strong",{children:"the Terms and Conditions"}),") contains the principal provisions pertaining to the operation of the System and working in this System. System Services are provided, where applicable, by one or more of the following companies (hereinafter called the “Administrator”) depen

1ding on the services provided to the Customer by Second February Limitada, a company with registration number: 3-102-918773, incorporated under the laws of Costa Rica, having registered address at: Costa Rica, San Jos\xe9, Mata Redonda, Sabana Oeste, twelfth avenue, ninetieth street, ERP Lawyers Law Firm offices."]}),(0,a.jsx)("li",{children:"The Terms and Conditions define the principles and conditions on which the Administrator – provides the Customers with an access to the System Services, charging Fees as per the agreed Rates, and a Customer shall use the System and its Services in accordance with these Terms and Conditions and the Internal Policies."}),(0,a.jsx)("li",{children:"These Terms and Conditions are the Administrator’s official public offer intended for eligible parties regarding the opportunity to use the System and its Services."}),(0,a.jsx)("li",{children:"Pertaining to any and all matters not provided for in the Terms and Conditions, the Administrator may regulate such matters on the basis of its Internal Policies providing information regarding such Internal Policies on the Website. Acceptance of these Terms and Conditions means the Customer’s consent with all provisions of both the Terms and Conditions and the Internal Policies."}),(0,a.jsx)("li",{children:"The content of the Website is provided on an \xabas is\xbb basis for information purposes only. The Administrator shall not make any guarantees, representations or warranties both express or implied, that the content of the Website is accurate, up-to-date, and complete and/or can be used as a basis for any action or inaction."})]}),(0,a.jsx)("h2",{children:"Definitions of Terms"}),(0,a.jsxs)("ol",{children:[(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Account"})," shall mean the virtual account of the Customer in the System registered in accordance with these Terms and Conditions and the Internal Policies. Unless otherwise specified, the Account shall mean both Business and Personal Account."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Account Lockdown"})," shall mean suspension by the Administrator of all the Transactions from all the Customer’s Wallets in case the activities of the Customer are deemed suspicious and controversial to the Internal Policies and the requirements of the current legislation."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Administrator’s Contact Details"})," shall mean the following address:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"for communication by mail: Second February Limitada, Costa Rica, San Jos\xe9, Mata Redonda, Sabana Oeste, twelfth avenue, ninetieth street, ERP Lawyers Law Firm offices;"}),(0,a.jsxs)("li",{children:["for communication via email:"," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",target:"_blank",rel:"noopener noreferrer nofollow",children:"[email protected]"}),"."]})]})]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Applicant"})," shall mean either an individual, an individual entrepreneur or a legal entity willing to open an account within the System and submitting the registration application via the System during the identification under these Terms and Conditions;"]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Authorization"})," shall mean providing a person with the right to carry out the Transactions in the Account as a result of their authentication by the Login and Password."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Authorization Details"})," shall mean the data that allows the Customer to be authenticated. By default, the Authorization Details are the Login and Password of the Customer. The Administrator has the right, at its discretion, to require the Customer to use additional Authorization Details."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Beneficial Owners"})," shall mean individuals who directly or indirectly hold or control 10% or more shares of a legal entity."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Business Account"})," shall mean the Account opened by a legal entity or an individual entrepreneur duly registered in accordance with the requirements of the current legislation."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Chargeback"})," shall mean the procedure of cancelling a bank card payment initiated by the cardholder through their bank."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Contact Details"})," shall mean email address and mobile number entered by the Customer into the System."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Customer"})," shall mean an individual, an individual entrepreneur or a legal entity, being the Account holder, that has completed the Registration and has a right to use the System in accordance with the Terms and Conditions and the Internal Policies."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Fees"})," shall mean remuneration charged by the Administrator for the System Services provided to the Customer."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Funds"})," shall mean electronic money that is owned by the Customer and accounted for as funds in this Customer’s Wallet."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Internal Policies"})," shall mean Administrator’s internal documents that govern operation of the System, including the AML Policy and the Privacy Notice published on the Website."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Login"})," shall mean the Customer’s email address or an alphanumeric combination specified by the Customer."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Merchant"})," shall mean the Customer carrying out commercial activities and receiving the Funds from other Customers for any goods, works or services. Either an individual or a legal entity may be a Merchant."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Parties"})," shall mean the Administrator and the Customer."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Password"})," shall mean a combination consisting of letters, numbers and other symbols, specified by the Customer during the Registration and used together with the Login to access the Account."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Payment"})," shall mean the Funds accounted for as funds in the Wallet and transferred from the Customer to a third party or from a third party to the Customer."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Payment Order"})," shall mean an instruction given by the Customer in a form of the electronic document with the template provided by the Administrator through the System, requesting the execution of the Transaction."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Personal Account"})," shall mean the Account opened by an individual."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Prohibited Activities"})," shall mean activities characterized by one or more of the following qualities: constitute criminal offense in the Customer’s country of jurisdiction; are connected with sales of goods, works or services distribution (GWS) prohibited for sale in the Customer’s country of jurisdiction; are connected with sales of any GWS (any and all transactions) referred to in the Appendix 1 to the Terms and Conditions; contradict the accepted universal standards of ethics and morality."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Registration"})," shall mean the result of entering a person’s data in the System, after which the Customer accepted the Terms and Conditions and is identified by the System."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Shell Bank"})," shall mean a bank that has no physical presence in the jurisdiction in which it is registered, and which is unaffiliated with a financial organisation that is subject to relevant legislation."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Store"})," shall mean a website or a mobile application that is used by the Merchant for the sale of their goods, works, or services to the Customers."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"System"})," shall mean a set of hardware and software developed, created and operating for the purpose of the Administrator’s providing the System Services to the Customer."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"System Services"})," shall mean the Transactions entered into with the use of the System for receipt and transfer of the Funds from/to the Customers’ Wallets."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Transaction"})," shall mean an act initiated by the Customer of receiving to or sending from the Account the Funds within the System."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Type of Wallet"})," shall mean a Wallet in one of the available currencies."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Unverified Account"})," shall mean an Account of the registered Customer whose identity and/or mobile number was/were not verified. 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1y filling out an online questionnaire along with attaching supporting documents in accordance with the instructions in the Account, in compliance with the requirements of the current legislation and the AML Policy."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Verified Account"})," shall mean the status of a registered Customer’s Account who has entered their data to the System and confirmed it, after having completed the Verification in accordance with clauses 4.5. - 4.9. of the Terms and Conditions."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Wallet"})," shall mean the part of the Account which reflects the balance of the Funds owned by the Customer in one of the chosen currencies. One Account can have multiple Wallets in different currencies."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Website"})," shall mean"," ",(0,a.jsx)(h(),{"data-underline":!0,href:d.qv._Promo,children:"www.volet.com"}),"."]})]}),(0,a.jsx)("h2",{children:"General Provisions"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"To become the Customer and use the System Services, the Applicant has to open the Account in accordance with the procedures stated in the Section 4."}),(0,a.jsx)("li",{children:"The Customer has the right to receive the information about the System Services provided by the Administrator, about these Terms and Conditions and the Internal Policies, to obtain access to the System Services in accordance with the Customer’s status and any other restrictions described by the present Terms and Conditions and the Internal Policies."}),(0,a.jsx)("li",{children:"The Customer may receive technical and informational support in relation to the use of the System Services."}),(0,a.jsxs)("li",{children:["The Customer shall:",(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"comply with the provisions of the Terms and Conditions and the Internal Policies;"}),(0,a.jsx)("li",{children:"provide accurate, complete and up to date information during the Registration in the System, the Verification and at any request of the Administrator due to the Terms and Conditions and the Internal Policies;"}),(0,a.jsx)("li",{children:"not allow any third parties to use the Customer’s Wallet;"}),(0,a.jsx)("li",{children:"take all reasonable measures to keep the Authorization Details secret and not to disclose them to any third parties. The Customer shall assume full responsibility for the security of the Authorization Details and for all the risks related to their loss, theft and/or compromise;"}),(0,a.jsx)("li",{children:"immediately notify the Administrator via contacting the Customer support when discovering the Transaction carried out without permission of the Customer, unauthorized access to the personal information, or loss of the Authorization Details;"}),(0,a.jsx)("li",{children:"use fully operational device with Internet access;"}),(0,a.jsx)("li",{children:"not use any malicious software on their computer (or any other data carrier); use only licensed software; work with the System on a computer that has the following installed: antivirus software with the database updated to date, the updated version of a browser, all the necessary updates for the operating system and the software;"}),(0,a.jsx)("li",{children:"not use the System to carry out the Transactions aimed at obtaining illegal profit or tax evasion;"}),(0,a.jsx)("li",{children:"not use the System for any purposes that violate laws of the country of the Customer’s residence, including attempts to carry out Prohibited Activities under the applicable laws, including the Prohibited Activities listed in the Appendix 1;"}),(0,a.jsx)("li",{children:"ensure that the Funds balance in their Wallets is not negative;"}),(0,a.jsx)("li",{children:"undertake full responsibility for any cancelled, invalid, and disputed Transactions, and for any Chargebacks;"}),(0,a.jsx)("li",{children:"not make the Transactions to/from the Shell banks."})]})]}),(0,a.jsx)("li",{children:"The Administrator shall provide the System Services to the Customers in accordance with these Terms and Conditions and the Internal Policies."}),(0,a.jsx)("li",{children:"The Administrator shall keep the Customer’s Funds credited to the Account in the System safe."}),(0,a.jsx)("li",{children:"The Administrator shall fulfil the Customer’s orders for disposal of the Funds in the Account within the framework provided for by these Terms and Conditions, the Internal Policies and current legislation."}),(0,a.jsx)("li",{children:"The Administrator shall retain the right to change the System Services, including updating software, procedures and interfaces."}),(0,a.jsx)("li",{children:"The Administrator may suspend operations of the System in the event of detecting any defects or failures, for maintenance purposes and the purpose of preventing unauthorized access to the System, and also in order to carry out preventive maintenance."}),(0,a.jsx)("li",{children:"The System Services are subject to the Fees in accordance with the Section 7 of the Terms and Conditions."}),(0,a.jsx)("li",{children:"The Administrator organizes and carries out control over the Customers’ compliance with the Terms and Conditions and the Internal Policies. The Administrator may refuse to carry out a Transaction in the cases that are prescribed by the Terms and Conditions, any other additional agreement, or the Internal Policies."}),(0,a.jsx)("li",{children:"The Administrator reserves the right to request confirmation of the Customer’s actual geolocation at any time, including during withdrawal or other sensitive operations, for compliance and security purposes."}),(0,a.jsx)("li",{children:"To ensure uninterrupted and verifiable access to the Services, the Customers are encouraged to maintain a consistent and identifiable network environment. The Customers are responsible for ensuring a secure and stable connection to the Services. Inconsistent or frequently changing network environments may lead to additional verification requests or temporary service limitations. Maintaining a trusted and consistent connection helps ensure uninterrupted access and transaction continuity."}

1),(0,a.jsx)("li",{children:"The Administrator may implement technical measures to limit access from certain IP addresses geographically associated with regions where the provision of services is limited or not supported under the Company’s Internal Policies. Such measures are implemented solely to ensure the lawful and proper operation of the Services."})]}),(0,a.jsx)("h2",{children:"Registration, Verification and Accepting Terms and Conditions"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Applicant willing to open the Account shall complete the Registration procedure: to fill out the Registration forms on the Website, to provide the Authorization Details and to accept these Terms and Conditions by clicking the \xabRegister\xbb button and ticking on consent to the processing of personal data in the relevant field in the Registration form."}),(0,a.jsx)("li",{children:"Once the Applicant accepts these Terms and Conditions, it shall be deemed a bilateral agreement of the Parties."}),(0,a.jsxs)("li",{children:["During the Registration the Applicant shall provide the following information to the Administrator:",(0,a.jsxs)("ol",{children:[(0,a.jsxs)("li",{children:["An individual:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"Name;"}),(0,a.jsx)("li",{children:"Surname;"}),(0,a.jsx)("li",{children:"Email address;"}),(0,a.jsx)("li",{children:"Password."})]})]}),(0,a.jsxs)("li",{children:["A legal entity and an individual entrepreneur:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"Name of the company or an individual entrepreneur;"}),(0,a.jsx)("li",{children:"Website;"}),(0,a.jsx)("li",{children:"Description of the business;"}),(0,a.jsx)("li",{children:"Name and surname of the director or the authorized person;"}),(0,a.jsx)("li",{children:"Country of incorporation and registered address;"}),(0,a.jsx)("li",{children:"An email address and mobile number of the contact person;"}),(0,a.jsx)("li",{children:"Authorization details."})]})]})]})]}),(0,a.jsx)("li",{children:"By accepting the present Terms and Conditions, the Applicant declares that they are acting on their own behalf only and not acting on behalf or in the interest of third parties."}),(0,a.jsxs)("li",{children:["When undergoing the Verification in order to gain the full access to the Services, available to the Verified Accounts, the Customer shall provide the following data to the Administrator:",(0,a.jsxs)("ol",{children:[(0,a.jsxs)("li",{children:["An individual shall provide the Administrator with:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"An image of a valid ID document issued by an authorized state body, containing a unique identification number and the Customer’s photo;"}),(0,a.jsx)("li",{children:"The Customer’s mobile phone number;"}),(0,a.jsx)("li",{children:"The Internal Policies may require the Customer to disclose information on the purpose of the Account opening, source of wealth, occupation and name of employer;"}),(0,a.jsx)("li",{children:"To identify the Customer and manage fraud, the Administrator may demand that the Customer undergoes authentication with the use of videoconference, including the use of the third-party services."})]})]}),(0,a.jsxs)("li",{children:["A legal entity shall provide the Administrator with:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"A copy of the certificate of incorporation of a legal entity;"}),(0,a.jsx)("li",{children:"A certificate of good standing if the company is more than twelve (12) months old or any equivalent document issued by the state body, confirming the current legal status of the Customer;"}),(0,a.jsx)("li",{children:"The documents confirming the powers of the person having a right of signature on behalf of the company;"}),(0,a.jsx)("li",{children:"Details of the Beneficial Owners of the entity in compliance with the requirements set for individuals in the paragraph 4.5.1. of these Terms and Conditions;"}),(0,a.jsx)("li",{children:"The Customer’s mobile number;"}),(0,a.jsx)("li",{children:"If the Account is replenished by a bank transfer, additional documents are requested, including the Customer’s bank account statement;"}),(0,a.jsx)("li",{children:"The Internal Policies may call for provision of additional information."})]})]}),(0,a.jsxs)("li",{children:["Individual entrepreneurs shall provide the Administrator with:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"A copy of the certificate of state registration of an individual entrepreneur;"}),(0,a.jsx)("li",{children:"A certificate confirming an individual entrepreneur’s legal capacity if their state registration took place more than 12 (twelve) months ago, or a similar document issued by the state body and confirming the Customer’s due legal status;"}),(0,a.jsx)("li",{children:"Details of the individual registered as an individual entrepreneur in compliance with the requirements set in the paragraph 4.5.1. of these Terms and Conditions;"}),(0,a.jsx)("li",{children:"The Customer’s mobile number;"}),(0,a.jsx)("li",{children:"If the Account is replenished by a bank transfer, additional documents are requested, including the Customer’s account statement;"}),(0,a.jsx)("li",{children:"The Internal Policies may call for provision of additional information."})]})]})]})]}),(0,a.jsx)("li",{children:"To verify the phone number stipulated by the Customer in the System, the Administrator shall send an automatically generated one-time password to the stipulated phone number that should be entered on the Website."}),(0,a.jsx)("li",{children:"If the data subject to clauses 4.5.1. - 4.5.3. is not provided or proved to be unreliable, incomplete, outdated in full or in part, the Verification shall be deemed failed, and the Account shall be subject to restrictions provided for the Unverified Accounts."}),(0,a.jsx)("li",{children:"The Verification process usually shall be performed within 24 hours after the Customer has provided the requested data. The Verification may exceed the peri

1od of 24 hours, in case the Administrator has a reasonable ground to perform the enhanced due diligence."}),(0,a.jsx)("li",{children:"The Verification shall be deemed completed at the moment the Customer receives the confirmation from the Administrator via the email or via the phone number provided by the Customer in the System at the choice of the Customer. Once the Verification is completed, the Customer may use the full scope of the System Services available for the Verified Accounts."}),(0,a.jsx)("li",{children:"The Customer shall notify the Administrator about any changes in the data provided for the Verification in a timely manner and provide up-to-date data as soon as reasonably possible."}),(0,a.jsx)("li",{children:"The Administrator may regularly verify whether the data filed by the Customer is up to date. If any unreliable, incomplete, outdated data, expired filed documents are detected, the Administrator may request that the Customer files up-to-date data within 14 days."}),(0,a.jsx)("li",{children:"If the Customer fails to file the requested data within the period provided for by clause 4.11., the Administrator may cancel the Account Verification and impose the restrictions provided for the Unverified Accounts."})]}),(0,a.jsx)("h2",{children:"Account"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"Once the Applicant completes the Registration, the Account is created, and the Applicant becomes the Customer."}),(0,a.jsx)("li",{children:"The Customer may open separate Wallets for the different currencies available for use. All the Funds transferred to the Customer’s Account are stored in the Wallets in corresponding currencies."}),(0,a.jsx)("li",{children:"The Funds can be kept in the Account for an indefinite period of time. If the Account has no transactional activity for 6 months, a monthly account inactivity fee is introduced for such a Customer."}),(0,a.jsx)("li",{children:"Certain limits may be applicable to the Wallet in respect to replenishment of the Funds, payments and withdrawals of the Funds, depending on the Customer’s status, the Type of Wallet, and other factors that the Administrator may take into account. These limitations are determined in accordance with these Terms and Conditions and are available on the Website."}),(0,a.jsx)("li",{children:"The Customer may use the Unverified Account with the applicable limitations or upgrade to the Verified Account by the means of the Verification set out in the paragraphs 4.5.- 4.9."}),(0,a.jsx)("li",{children:"The Customer may open a Personal and/or a Business Account. The special features of the Personal and Business Accounts are available on the Website."}),(0,a.jsx)("li",{children:"To open the Account, an individual must be 18 years or older, acting in full capacity in accordance with their national laws. By creating the Personal Account, the Customer declares that they have reached the age of 18, the Administrator may demand that the Customer files a confirmation of their age at any time."}),(0,a.jsx)("li",{children:"To open the Business Account, the Customer must be a legal entity or an individual entrepreneur having full capacity to open the account in accordance with the laws and requirements of their country of incorporation."}),(0,a.jsx)("li",{children:"Accounts may not be opened for US citizens, US permanent residents and legal entities incorporated in the US."}),(0,a.jsx)("li",{children:"The Customer may open the Account only if this does not contradict the provisions of the laws of the country of their permanent residence or the Customer’s registration. By opening the Account, the Customer declares and guarantees to the Administrator that opening of such an Account by the Customer does not violate any laws or regulations applicable to the Customer. The Customer shall compensate the Administrator an amount of all losses incurred by the Administrator if the Customer violates provisions of this clause."}),(0,a.jsx)("li",{children:"In case the Customer intends to open the Business Account, the additional agreement shall be made between the Administrator and the Customer. The Customer must comply with the provisions of such applicable additional Agreement along with the obligations under these Terms and Conditions and the Internal Policies."}),(0,a.jsx)("li",{children:"The information on the Customer’s Transactions with the Funds and use of their Wallet is recorded and kept by the Administrator for the duration of the effective term of these Terms and Conditions and for a period of 5 (five) years after these Terms and Conditions are terminated and the Account is closed."}),(0,a.jsx)("li",{children:"By making the new Transaction resulting in the change of balance of the Funds in the Wallet, the Customer confirms the Wallet balance. The Customer’s confirmation is expressed by clicking the appropriate button confirming the new Payment Order."}),(0,a.jsx)("li",{children:"An access to the Wallet and any Transactions involving the use of the Wallet are only available upon the Authorization."}),(0,a.jsx)("li",{children:"The Login is generated by the System b

1y default from the email stipulated by the Customer upon the Registration or changed upon the Customer’s request sent to the Customer support. The Password shall be generated by the Customer independently. The Login and Password shall be used for the Authorization and can be changed at any time."}),(0,a.jsx)("li",{children:"The Customer is responsible for keeping the Authorization Details confidential. Any actions related to the Wallet performed with the use of the valid Authorization Details shall be considered to be as actions performed by the Customer."}),(0,a.jsx)("li",{children:"In case the Customer fails to enter the Authorization Details 3 times, the Account shall be blocked. To recover the access to their Wallet, the Customer shall contact the Customer support."}),(0,a.jsx)("li",{children:"In case the Customer loses the Authorization Details, the Customer shall contact the Customer support and request to recover the access to their Wallet."}),(0,a.jsxs)("li",{children:["In order to recover the access to the Personal Account:",(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Customer requests the link to be sent to the email provided by the Customer in the System;"}),(0,a.jsx)("li",{children:"In case the Customer has verified the mobile number, the Customer receives a digital code via SMS and enters the received code on the Website available by the link sent to the Customer’s email indicated by the Customer in the System;"})]})]}),(0,a.jsxs)("li",{children:["In order to recover the access to the Business Account:",(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"A request for restoring the access is to be sent to the Customer support."}),(0,a.jsx)("li",{children:"The Customer receives a digital code via SMS and enters the received code on the Website available by the link sent to the Customer’s email indicated by the Customer in the System."})]})]}),(0,a.jsx)("li",{children:"In case the activities of the Customer are deemed suspicious or controversial to the Terms and Conditions, other agreements concluded between the Customer and the Administrator, the Internal Policies or the requirements of current legislation, the Administrator shall notify the Customer via the email address indicated by the Customer in the System on such suspicious activities, suspected or actual fraud or security threats."}),(0,a.jsx)("li",{children:"The Administrator reserves the right to perform the Account Lockdown without prior notification of the Customer in case of objectively justified reasons relating to the security of the Account, the suspicion of unauthorized or fraudulent use of the Account, the violation of the provisions of the Terms and Conditions or the Internal Policies."}),(0,a.jsx)("li",{children:"The Administrator shall unblock the Account once the reasons for the Account Lockdown no longer exist."}),(0,a.jsx)("li",{children:"The Customer may close the Wallet at any time by contacting the Customer Service. Closing the particular Wallet does not lead to the Account closure."}),(0,a.jsx)("li",{children:"The Customer is restricted from registering multiple Accounts, except opening one Personal Account and one Business Account as an individual entrepreneur. Otherwise, the Administrator shall have the right to automatically mark such accounts as fraudulent and suspend the provision of the System Services of all such Accounts."})]}),(0,a.jsx)("h2",{children:"Transactions"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Customer may replenish their Wallet by logging into their Personal Account on the Website and following the relevant instructions for the Wallet replenishing. The ways of the Wallet replenishing may vary depending on the location of the Customer. The currently available ways are available on the Website."}),(0,a.jsx)("li",{children:"Wallet replenishment and the withdrawal of the Funds services are the payment services provided by third parties; therefore, they are not a part of the System Services."}),(0,a.jsx)("li",{children:"The Wallet replenishment is carried out in accordance with the procedure set forth in the Terms and Conditions, the Internal Policies, policies of third parties that provide services, and applicable law."}),(0,a.jsx)("li",{children:"The Administrator may restrict the range of the Wallet replenishment methods for certain categories of the Customers depen

1ding on the degree of risk of the activity and/or transactions of the Customer."}),(0,a.jsx)("li",{children:"When the Wallet is credited by third parties, all rights and responsibilities pertaining to the Funds credited to such Wallet shall be the Customer’s. Such transactions made by the third parties are considered by the Parties as activities by a third party on the Customer’s behalf and for the Customer’s benefit."}),(0,a.jsx)("li",{children:"The Administrator sets the limits for the Wallet replenishment for the security reasons. The limits are displayed on the Wallet page."}),(0,a.jsx)("li",{children:"Additional fees may be charged by third parties for the Wallet replenishment, depending on the method of the replenishment."}),(0,a.jsx)("li",{children:"The Transfer of Funds is carried out on the basis of the Customer’s Order electronically with the use of the Wallet."}),(0,a.jsx)("li",{children:"When the Administrator receives the Order to transfer the Funds from the Customer’s Wallet, the Administrator identifies the Customer using the Authorization Details. In some cases, the Administrator may demand that additional identification procedures should be completed before the Payment Order is fulfilled."}),(0,a.jsx)("li",{children:"All the Transactions carried out with the use of the Authorization Details of this Customer shall be considered as Transactions carried out by this Customer unless the Administrator is notified on the unauthorized or fraudulent use of the Account in accordance with the paragraph 3.4.5."}),(0,a.jsx)("li",{children:"The Transaction not exceeding the applicable limits set for the Wallets shall be performed without undue delay not later than 24 hours after the Payment Order is received by the Administrator. The timing of the Transaction that depends on third-party financial services is determined in accordance with the policies of such third parties. The Administrator shall not be liable for the delay caused by the fault of the third parties."}),(0,a.jsx)("li",{children:"The Customer may enable notifications of the executed Payment Orders in their Account on the Website."}),(0,a.jsx)("li",{children:"The Administrator may restrict the list of payees of the Funds for certain categories of the Customers depending on the degree of risk of the activity and/or transactions of the Customer. Specific restrictions are available on the Website."}),(0,a.jsx)("li",{children:"The Administrator may restrict the list of available withdrawal methods of the Funds for certain categories of the Customers depending on the degree of risk of the activity and/or the Transactions of the Customer. Specific restrictions are available on the Website."}),(0,a.jsx)("li",{children:"Existing limits on the amount of the balance of the Funds in the Wallet and amount of payments applicable to different statuses of the Accounts and categories of the Customers, depending on the level of risk associated with the Customer’s activities, and/or Transactions are available on the Website."}),(0,a.jsx)("li",{children:"The Customer may choose a method for a 

1withdrawal by creating a request for a withdrawal of the Funds from their Wallet. During the withdrawal of the Funds, the Customer may be requested to proof their identity. For the withdrawal of the Funds, an amount of the Funds on the Customer’s Wallet should be sufficient to cover the Fees for the withdrawal of the Funds."}),(0,a.jsx)("li",{children:'To replenish the Wallet with the use of a bank card, the Administrator may request the Customer to undergo the verification procedure "Know Your Customer" in accordance with the AML Policy.'}),(0,a.jsx)("li",{children:"If the Customer successfully completes the identification procedure and the Funds are credited from the Customer’s bank card to the Wallet, the card transaction is non-refundable. If the Customer does not complete the identification procedure, the card transaction is refunded automatically. The refund to a bank card may take up to 14 business days depending on the Customer’s bank’s policies."}),(0,a.jsx)("li",{children:"The Customer may download the electronic reporting documents on the executed Transactions for any period of time at their own discretion in their Account free of charge."}),(0,a.jsx)("li",{children:"All the Transactions executed by the Customer using the System are final and are not subject to disputes, revisions or cancellations, with the exception of the Wallet replenishment Transactions performed using the external systems that have been classified as fraudulent."}),(0,a.jsx)("li",{children:"When the Customer loads their Wallet with a card, these refund rules apply. If the Customer completed the card verification and received the Funds to the Wallet, the card Payment becomes non-refundable. If the card verification is not completed, the pending card Payment is dropped automatically. The Customer's bank may need several business days (usually 2 to 14) for the Funds to return to the card balance."})]}),(0,a.jsx)("h2",{children:"Rates and Procedures for Charging Fees"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Administrator shall charge the Fees for the Services provided to the Customer."}),(0,a.jsxs)("li",{children:["The amount and procedures for charging the Fees are available on the Website in the \xab",(0,a.jsx)(h(),{"data-underline":!0,href:d.qv.Fees,children:"Fees"}),"\xbb section."]}),(0,a.jsx)("li",{children:"The Administrator may unilaterally change the Fees rates. Such changes and amendments shall come into effect from the day that such changes and amendments are published on the Website."}),(0,a.jsx)("li",{children:"All Fees are calculated in the currency of the Transaction and rounded off to the nearest whole cents."}),(0,a.jsx)("li",{children:"The System Services provided to the Customer by the Administrator are not subject to VAT or any other turnover taxes."}),(0,a.jsx)("li",{children:"All the applicable Fees are charged from the Customer’s Wallet by the Administrator upon the completion of the Transaction subject to the Fees, or at the moment when the Administrator has substantiated grounds to charge the applicable Fees."}),(0,a.jsx)("li",{children:"If the current balance on the Wallet is not sufficient to charge the applicable Fees, the Administrator may reject the Transaction and request the Customer to pay the applicable Fees."}),(0,a.jsxs)("li",{children:["The exchange rates applicable to the Transfer of the Funds between the Wallets in different currencies are calculated in accordance with the"," ",(0,a.jsx)("a",{"data-underline":!0,href:"https://openexchangerates.org/",target:"_blank",rel:"noopener noreferrer nofollow",children:"Open Exchange Rates"})," ","platform plus a Fee established by the Administrator. The final exchange rates applied to the Transaction are fixed at the time of the Transaction and are reflected in the Account prior the Payment Order initiated by the Customer."]})]}),(0,a.jsx)("h2",{children:"Personal Data"}),(0,a.jsx)("ol",{children:(0,a.jsxs)("li",{children:["The Administrator processes personal data of the Applicants and the Customers. The"," ",(0,a.jsx)(h(),{"data-underline":!0,href:d.qv.DocCostaRicaPrivacy,children:"Privacy Notice"})," ","applicable to the Applicants and the Customers is available on the Website as a separate document."]})}),(0,a.jsx)("h2",{children:"Liability"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"In the event of failure to comply and/or improper fulfilment of the obligations under these Terms and Conditions, the Parties shall be responsible in accordance with the provisions of these Terms and Conditions, the Internal Policies, and the applicable laws."}),(0,a.jsx)("li",{children:"If the Customer delays the fulfilment of any obligation in the monetary form as set forth in these Terms and Conditions, the Customer shall pay to the Administrator a penalty fine in the amount of 0.1% (one tenth of a percentage point) of the amount of such delayed funds to be transferred to the Administrator for every day of such delay. The Customer shall pay to the Administrator the penalty fine as specified in this paragraph of the Terms and Conditions within 3 (three) business days after the date the Customer receives a relevant request from the Administrator in writing or electronically. The Administrator has the right, but not the obligation to send a penalty fine payment request."}),(0,a.jsx)("li",{children:"The Customer shall repay to the Administrator the damages incurred as a result of any damages charged from the Administrator due to the Customer’s violations of the applicable laws when using the System on condition that the Administrator can provide the relevant documents that confirm the amount of the damages incurred by the Administrator."}),(0,a.jsx)("li",{children:"The Customer shall be responsible for all the Transactions accounted for in the Wallet, including any Transactions with the use of bank payment cards. These Transactions shall also include the Transactions executed by third parties that have access to the Customer’s Wallet."}),(0,a.jsx)("li",{children:"The Customer shall take full responsibility to get acknowledged with the current legislation of the Customer’s residence, regulating the Account opening and money transfer Transactions via the System. The Administrator shall not be liable for any breach of the national laws by the Customer resulted from the use of the System. If the Customer’s use of the System and Services contradicts the laws of this Customer’s jurisdiction, such Customer should immediately stop using the Services."}),(0,a.jsx)("li",{children:"The Customer shall take full responsibility for all the risks related to the use of the Internet during the Customer’s interaction with the Administrator, other Customers and third parties."}),(0,a.jsx)("li",{children:"The Customer shall not undertake any activity that misleads other parties about the Services offered by the Administrator, which can directly or indirectly damage the Administrator’s reputation, including but not limited to impersonating themselves as representatives of the Administrator in any way or context, providing false data related to the System including but not limited to fal

1sifying transaction IDs, wallet IDs and any other data such as text, screenshots, or any other media, creating clones of the Administrator’s website, and other similar activities. In case of violation the Administrator reserves the right to block the Customer’s Accounts, freeze the Funds for the period of investigation, and limit the usage of the System in other ways. The Administrator also reserves the right to pursue legal action in courts of applicable jurisdiction, including cases when this rule is violated by other parties that are not the Customers of the Administrator."}),(0,a.jsx)("li",{children:"The Customer shall protect the Administrator’s interests, reimburse the Administrator’s losses and pay compensations to the Administrator as well as indemnify the Administrator and its affiliates against any claims or damages, costs or expenses (including expenses for legal support, penalties or forfeits) resulting from violation by the Customer of these Terms and Conditions or any applicable laws or regulations and/or use of the System. This provision shall survive termination of relations between the Parties."}),(0,a.jsx)("li",{children:"If, through the Customer’s fault, a completed Payment serves as a ground for a payer to file a claim to the Administrator for protection of their violated right, the Administrator may demand that the recipient of the Funds reimburses losses resulting from collection of funds or other property from the Administrator to the benefit of the payer."})]}),(0,a.jsx)("h2",{children:"Disclaimer"}),(0,a.jsxs)("ol",{children:[(0,a.jsxs)("li",{children:["The Administrator shall have no responsibility to the Customer:",(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"If the Customer transfers their data to any third parties, deliberate provision of access to their Wallet in the System, or any other violation of the confidentiality of the Customer’s information caused by the Customer’s fault;"}),(0,a.jsx)("li",{children:"For illegal activities of any third parties, including those related to the use of the Customer’s registration data and the Customer’s email or the Authorization Details;"}),(0,a.jsx)("li",{children:"For presence of any viruses or any other malicious software in the hardware and software used by the Customer to access the System;"}),(0,a.jsx)("li",{children:"For any disputes pertaining to any transactions between the Customers made via the System;"}),(0,a.jsx)("li",{children:"For violation of the current legislation by the Customer in relation to the use of the System as well as for the complaints pertaining to the Customer from tax, regulation, and law enforcement authorities regarding any reporting documentation or taxation in relation to the Customer’s transactions involving the System;"}),(0,a.jsx)("li",{children:"If the Customer does not have access to the software or hardware that ensure the use of the System;"}),(0,a.jsx)("li",{children:"If the Customer cannot be reached by using the Contact Details filed thereby, particularly, due to the reason that the Customer filed unreliable data or fails to update such data in a timely manner;"}),(0,a.jsx)("li",{children:"For any payment services provided to the Customer by third parties;"}),(0,a.jsx)("li",{children:"For any actions taken by third parties whose websites the Customer visited following a link or information provided on the Website;"}),(0,a.jsx)("li",{children:"For temporary inoperability of the System, malfunctioning and errors in the operation of hardware or software (including disconnection or damage of electricity supply and communication networks, software malfunctioning, interruption of mail services, Internet provider’s, payment system operations, disruption in other lines, channels and/or networks that are provided, offered or serviced by third parties, etc.), occurred not through the Administrator’s fault; in this case, the Administrator shall not bear responsibility for the Customer’s possible losses."})]})]}),(0,a.jsx)("li",{children:"In the event of the loss of the Authorization Details, the System’s locking the Wallet, the Customer’s loss of the Password, the Wallet Lockdown, or other events that cannot be remedied without the confirmation of the Customer’s identity, the Administrator shall have no responsibility if the access to the Account cannot be recovered because the Customer is lacking access to their email, mobile number, or the inability to provide other information in order to confirm their identity in accordance with the provisions of clauses 5.20 of the Terms and Conditions."}),(0,a.jsxs)("li",{children:["The Administrator shall not be responsible for any damages and losses incurred by the Customer or by any third party as a result of:",(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Wallet Lockdown in accordance with these Terms and Conditions or the requirements of the law;"}),(0,a.jsx)("li",{children:"Failure to pass the Verification;"}),(0,a.jsx)("li",{children:"Incorrect completion of the Payment Orders to carry out the Transactions or completion by mistake;"}),(0,a.jsx)("li",{children:"Violation by the Customer of the established procedure for making the Payments;"}),(0,a.jsx)("li",{children:"Administrator’s or third parties’ compliance with the legislative or regulative requirements;"}),(0,a.jsx)("li",{children:"Failure to read the up-to-date version of the Terms and Conditions or the Internal Policies and other information published on the Website;"}),(0,a.jsx)("li",{children:"Impossibility to use a desired payment method at the Customer’s location;"}),(0,a.jsx)("li",{children:"Violation by the Customer of these Terms and Conditions or the Internal Policies, as well as the Administrator’s instructions and guidelines."})]})]}),(0,a.jsx)("li",{children:"In any event, the Administrator’s responsibility to the Customer shall always be limited to the amount that does not exceed the amount of the Fees charged to such Customer for a period of the previous 3 months."}),(0,a.jsx)("li",{children:"The Administrator shall not be responsible for any indirect or consequential damages incurred by the Customer or any third parties, including any loss of profit, loss (forfeit, non-receipt, unsubstantiated spending) of revenue, income, contracts, customers, time, data, enterprise, or reputation."}),(0,a.jsx)("li",{children:"The Administrator shall provide to the Customer the Services \xabas is\xbb as at the moment, without any express, implied or statutory representations or guarantees."})]}),(0,a.jsx)("h2",{children:"Communication Between the Parties"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Administrator shall use the Contact Details as means of communication with the Customer."}),(0,a.jsx)("li",{children:"The communication between the Customer and the Administrator may be done in English language."}),(0,a.jsxs)("li",{children:["The Customer may contact the Administrator at any time by the email"," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",target:"_blank",rel:"noopener noreferrer nofollow",children:"[email protected]"}),"."]}),(0,a.jsx)("li",{children:"The Administrator may inform the Customer on the changes in the Services provided either by sending email notifications or by posting the updates on the Website."}),(0,a.jsx)("li",{children:"The document flow between the Customer and the Administrator shall be in electronic form via the Account. Moreover, the use of the Authorization Details by the Customer shall be deemed by the Parties due and sufficient method of the Customer Authentication for the purposes of the document flow as well as for c

1onfirmation of authenticity and integrity of the provided electronic document, except for the cases provided for by the Terms and Conditions or the Internal Policies. Entering the Customer’s Authenticated Data shall be deemed by the Parties equal to the Customer’s handwritten signature."}),(0,a.jsx)("li",{children:"Administrator may send emails to the Customer informing about new features of the Wallet and special offers. By accepting these Terms, the Customer agrees to receive such communication. The Customer may unsubscribe anytime."})]}),(0,a.jsx)("h2",{children:"Term and Termination"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"These Terms and Conditions shall be in effect for an indefinite period of time until terminated in accordance with the provisions stated below."}),(0,a.jsx)("li",{children:"The Customer may close the Account at their discretion at any time if the Customer does not have any unfulfilled obligations to the Administrator. The Account can be closed at the Customer’s personal account."}),(0,a.jsx)("li",{children:"After the Customer initiates closure of the Account, the execution of the Transactions with the use of the Account shall be impossible. Any monetary obligations of the Parties created prior to the date of deletion of the Account shall retain until they are fully executed."}),(0,a.jsx)("li",{children:"In case any Funds remain on the Account of the Customer with whom the Agreement is terminated, the Administrator shall transfer the remaining Funds to the payment details indicated by the Customer, deducting the applicable fees."}),(0,a.jsx)("li",{children:"The Administrator may unilaterally terminate these Terms and Conditions, sending the obligatory written notification to the Customer no later than two months in advance."}),(0,a.jsx)("li",{children:"After the Account is deleted, information on completed Transactions shall be kept by the Administrators for 5 years in accordance with the requirements of the law."})]}),(0,a.jsx)("h2",{children:"Amendments"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Administrator may unilaterally amend these Terms and Conditions by publishing the updated text on the Website."}),(0,a.jsx)("li",{children:"The Administrator shall notify the Customer on the upcoming amendments of these Terms and Conditions by posting an informational message inside the Client’s Account no later than 2 (two) months before such amendments come into force. The Customer shall either accept or reject the changes before the date of their proposed date of entry into force. The Customer shall notify the Administrator on rejection of the amendments via contacting the Customer support. In case of rejection, the Agreement shall be terminated on the date the amendments enter into force."}),(0,a.jsx)("li",{children:"The amendments come into force since the updated text is published on the Website."}),(0,a.jsx)("li",{children:"The use of the Services by the Customer shall be considered as the unconditional acceptance of the updated Terms and Conditions."}),(0,a.jsx)("li",{children:"Any appendixes to the Terms and Conditions shall constitute the integral part of these Terms and Conditions."}),(0,a.jsx)("li",{children:"Without limitations to the provisions stated in the present Section 13, the period stated in the paragraph 13.2. does not cover the notification timeframe to any amendments of the Fees applicable to the Services provided by the Company. The Fees changes may be applied immediately and without prior notice. In addition, amendments necessary for compliance with applicable laws or regulations may take effect immediately, without prior notice to the Customer."})]}),(0,a.jsx)("h2",{children:"Force Majeure"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Parties shall not be responsible for any delays in the performance or non-performance of the obligations, any expenses, including losses, and costs related to complaints by any third parties that may result from any acts of God, acts of civil or military authorities, civil disturbances, strikes or other labour disputes, fires, transportation contingencies, interruptions in telecommunications, utility, Internet services or network provider services, acts or omissions of a third party, infiltration or disruption of the services by a third party by any means, including without limitation, DDoS attacks, software viruses, Trojan horses, worms, time bombs or any other software program or technology designed to disrupt or delay the Services (each a \xabForce Majeure Event\xbb). The Party experiencing the impact of any Force Majeure Event shall notify the other Party within 10 days after the commencement of such Force Majeure Event."}),(0,a.jsx)("li",{children:"The provisions of paragraph 14.1. shall not limit or terminate the Customer’s obligations pertaining to making the returning Payments, as well as payment of any fines, penalties, fees, commissions, returning any goods, or (not) performing any works or services after the Force Majeure is over."})]}),(0,a.jsx)("h2",{children:"Miscellaneous"}),(0,a.jsxs)("ol",{children:[(0,a.jsxs)("li",{children:["These Terms and Conditions and the relations between the Administrator and the Customer arising from them are governed by:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"the laws of Canada for all relations concerning the System Services rendered by Queensland Foreign Exchange, Inc.; and"}),(0,a.jsx)("li",{children:"the laws of Costa Rica for all relations concerning the System Services rendered by Second February Limitada."})]})]}),(0,a.jsx)("li",{children:"All the disputes between the Parties arising from these Terms and Conditions shall be settled through negotiations. The basis for negotiations shall be either Party’s submitting a written complaint to the other Party. All the complaints and claims shall be reviewed within thirty days of their receipt."}),(0,a.jsxs)("li",{children:["In case a dispute cannot be resolved by negotiations within the specified period of time, either Party may apply to a court. The following courts shall have the jurisdiction to settle any dispute arising out of or in connection with these Terms and Conditions:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"the courts of Canada for all relations concerning the System Services rendered by Queensland Foreign Exchange, Inc.; and"}),(0,a.jsx)("li",{children:"the courts of Costa Rica for all relations concerning System Services rendered by Second February Limitada."})]})]}),(0,a.jsx)("li",{children:"The choice of law and jurisdiction in the clause 15.3. does not affect the mandatory rights of the Customer under the laws of the country of their residence."}),(0,a.jsx)("li",{children:"The Customer shall not transfer any rights or obligations under these Terms and Conditions to any third party without the prior written consent given by the Administrator."}),(0,a.jsx)("li",{children:"If any provision of these Terms and Conditions is held to be invalid or unenforceable, such provision shall be struck out and the remaining provisions shall be enforced."}),(0,a.jsx)("li",{children:"This Agreement enters into force since the Applicant clicks the \xabRegister\xbb button during the Registration process."}),(0,a.jsx)("li",{children:"The Customer acknowledges and confirms that all the provisions of the Terms and Conditions are clear, and that the Customer agrees with the Internal Policies available on the Website, accepts them unconditionally and shall comply with their provisions and requirements."})]}),(0,a.jsxs)("div",{"data-skip-counters":"true",children:[(0,a.jsxs)("div",{"data-appendix":"true",children:["APPENDIX 1",(0,a.jsx)("br",{}),"TO VOLET.COM TERMS AND CONDITIONS"]}),(0,a.jsx)("h2",{children:"Goods, Works, and Services Prohibited for Sale via the System:"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"Weapons, arms, ammunition and defense products, guns, replicas of firearms or cold steel weapons."}),(0,a.jsx)("li",{children:"Drugs, drug-like substances and plants (including marijuana/cannabis), as well as their ingredients, or any substances for their production, as well as de

1scriptions of methods for producing such substances."}),(0,a.jsx)("li",{children:"Medical drugs and medications dispensed on prescription only, as well as raw materials or instructions for their production."}),(0,a.jsx)("li",{children:"State awards or distinguishing badges."}),(0,a.jsx)("li",{children:"Identification documents and government issued documents (including falsified documents), and everything connected with creating or obtaining false identification documents or counterfeit government issued documents."}),(0,a.jsx)("li",{children:"Government agencies’ uniforms."}),(0,a.jsx)("li",{children:"Specialty items related to the police and law enforcement agencies."}),(0,a.jsx)("li",{children:"Electronic equipment prohibited for use in this country or region."}),(0,a.jsx)("li",{children:"Devices used for hacking and tampering with locks."}),(0,a.jsx)("li",{children:"Information containing personal data or data suitable for undertaking illegal activities (spam emails, etc.)."}),(0,a.jsx)("li",{children:"GWS or information containing state, banking, or trade secrets."}),(0,a.jsx)("li",{children:"GWS whose sale violates any third parties’ copyright and/or related rights, trademark rights, or patents."}),(0,a.jsx)("li",{children:"Information that violates a person’s privacy, infringing upon the honor, dignity and business reputation of individuals and legal entities."}),(0,a.jsx)("li",{children:"Information transmitted exclusively virtually and not recorded on any material carrier (ideas, methods, principles, etc.)."}),(0,a.jsx)("li",{children:"Archaeological heritage items."}),(0,a.jsx)("li",{children:"Precious metals."}),(0,a.jsx)("li",{children:"Items or services that violate the norms of public morality (including, but not limited to, child pornography, Nazi memorabilia items, escort services, prostitution, and adult)."}),(0,a.jsx)("li",{children:"Any items with available initially but removed serial numbers."}),(0,a.jsx)("li",{children:"Internet gambling."}),(0,a.jsx)("li",{children:"Malicious software."}),(0,a.jsx)("li",{children:"Goods or services directly or indirectly compelling illegal actions (promoting social, racial, religious, or ethnic strife; discrimination, violence, hatred, revenge, harassment; containing propaganda of terror or physical harm)."}),(0,a.jsx)("li",{children:"Perishable goods."}),(0,a.jsx)("li",{children:"Fake or counterfeit goods."}),(0,a.jsx)("li",{children:"Items and equipment intended for use (including illegal transfer) of copyright protected items without the permission of the authors (including, but not limited to, components designed to remove copyright protection or regional restrictions, or software elements of electronic devices)."}),(0,a.jsx)("li",{children:"Dangerous goods (including, but not limited to, those that contain explosive, toxic, poisonous, and/or radioactive materials)."}),(0,a.jsx)("li",{children:"Information about the production of explosive, pyrotechnic, incendiary, and other similar substances and devices."}),(0,a.jsx)("li",{children:"Human organs and human remains."}),(0,a.jsx)("li",{children:"Goods or services that have no value in use."}),(0,a.jsx)("li",{children:"Services of auctions or trading systems that allow carrying out activities excluding transfer of GWS that have value in use."}),(0,a.jsx)("li",{children:"Financial or payment instruments whose accounting systems do not ensure proper identification of the owner for the purpose of combating illegal trade, financial fraud, and money laundering of funds obtained by illegal means."}),(0,a.jsx)("li",{children:"Asset management and investment services provided by unlicensed businesses, as well as any intermediary activity that facilitates the transfer of funds between the parties entering into a transaction forbidden herein."}),(0,a.jsx)("li",{children:"Items of artistic and historical value that constitute a country’s cultural values."}),(0,a.jsx)("li",{children:"Services of advertising (promoting) goods, works and services specified in items 1-32 of this list."})]})]})]})}},latest:"v1"},aml:{versions:{v1:function(){return(0,a.jsxs)(c.A,{direction:"vertical",ga

1p:2,children:[(0,a.jsx)("div",{children:(0,a.jsx)(h(),{"data-underline":!0,href:d.qv.DocCanadaAML,children:"AML Canada"})}),(0,a.jsx)("div",{children:(0,a.jsx)(h(),{"data-underline":!0,href:d.qv.DocCostaRicaAML,children:"AML Costa Rica"})})]})}},latest:"v1"},"aml-canada":{versions:{v1:function(){return(0,a.jsxs)("div",{"data-template":"default",children:[(0,a.jsx)("h2",{children:"General Provisions"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"System Services are provided, where applicable, by Queensland Foreign Exchange (hereinafter — the Company), incorporation number 1000433476, registered at 36 Toronto Street, Suite 850, Toronto, Ontario, Canada, M5C 2C5, is a registered provider of money service business (MSB), regulated by the FINTRAC Canada, MSB registration number: M23153297."}),(0,a.jsx)("li",{children:"The Company shall comply with the requirements contained in the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated Regulations, as well as the requirements of other laws and regulations to the extent in which they relate to the Company’s operations."}),(0,a.jsx)("li",{children:"The Company adheres to the policies and procedures outlined in this document (hereinafter – the AML Policy (CA))."}),(0,a.jsx)("li",{children:"The Company develops this AML Policy (CA), introduces amendments and additions to it at its own discretion, and oversees compliance with its provisions and requirements. The Company also adopts internal policies and procedures to ensure compliance with anti-money laundering and terrorist financing laws."}),(0,a.jsxs)("li",{children:["The current version of the AML Policy (CA) is always available on the website"," ",(0,a.jsx)("a",{"data-underline":!0,href:d.qv._Promo,target:"_blank",rel:"noopener noreferrer nofollow",children:"www.volet.com"}),"."]}),(0,a.jsxs)("li",{children:["The Customer shall read the AML Policy (CA) before accepting the System Terms and Conditions (hereinafter – Terms and Conditions), published at:"," ",(0,a.jsx)("a",{"data-underline":!0,href:d.qv._Promo,target:"_blank",rel:"noopener noreferrer nofollow",children:"www.volet.com"}),"."]})]}),(0,a.jsx)("p",{children:"Acceptance by the Customer of the Terms and Conditions, as well as the performance by the Customer, who previously accepted the Agreement, of transactions in the System, means the Customer's consent to all the provisions of the current version of this AML Policy (CA)."}),(0,a.jsx)("h2",{children:"Appointment of a Designated Compliance Office"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Company appoints a designated Compliance Officer (MLRO) to implement and monitor performance of the procedures reflected in the AML Policy (CA). The Compliance Officer is responsible for the direction of the AML Policy (CA), and for ensuring that all existing and future employees and business affiliates of the Company adhere to the policy and procedural standards outlined in this document."}),(0,a.jsx)("li",{children:"The Compliance Officer is responsible for the collection, analysis, and investigation of information on any suspicious activities and the training of the Company’s employees pertaining to the relevant procedures; the Compliance Officer shall determine the procedures and rules for carrying out Customers’ identification, reviewing and monitoring unusual transactions and technical features of the Company’s implementation of this AML Policy (CA); assessing the adequacy of system resources, including those required to identify and report suspicious and attempted suspicious transactions; ensuring that customer due diligence (“CDD”) and enhanced due diligence (“EDD”) is conducted."})]}),(0,a.jsx)("h2",{children:"Customer Information Collected"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Company uses specific procedures for identification and verification of Customers."}),(0,a.jsx)("li",{children:"From Customers who request demo access to the System (financial transactions are not available), the Company requests only the name and email address."}),(0,a.jsxs)("li",{children:["In order to get full access to the System Services, Customers are subject to identification procedure. For the purposes of Customers’ identification, the Company requests the following:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"proof of identity document (passport, driving license, national identity card, etc.);"}),(0,a.jsx)("li",{children:"proof of address (bank statement, utility bill, etc.);"}),(0,a.jsx)("li",{children:"phone number verification by receiving a code via SMS;"}),(0,a.jsx)("li",{children:"requires to undergo a liveness check via KYC service provider."}),(0,a.jsx)("li",{children:"information on the purpose and intended nature of the account opening (“PIN”), source of wealth, occupation and name of employer. The PIN provides context for the types of transactions and activities that the customer conducts."})]})]}),(0,a.jsx)("li",{children:"The Company places transaction limits on all individual transactions. For customers with higher limits, the Company requires that customers provide the additional information and documents to fulfill the enhanced KYC requirements, including, but not limited to, confirmation of source of funds (i.e.: income statement, tax receipt, inheritance proof form, bank statement, etc.). All requests for higher limits are reviewed on a case-by-case basis with a focus on validating source of wealth."})]}),(0,a.jsx)("h2",{children:"Customer Identity Verification"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"When the C

1ompany is required to verify the identity of an individual, the government photo identification document method must be used. The Company relies on valid, current, and authentic photo identification documents (“ID”), issued by a federal, provincial, or territorial government to verify the identity of an individual. An ID issued by a municipal government (either Canadian or foreign) is not acceptable."}),(0,a.jsxs)("li",{children:["The Company does not accept an ID when:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"it does not indicate the individual’s name, or the name that the individual provided does not match the name appearing on the ID;"}),(0,a.jsx)("li",{children:"it does not have a photo, or the photo on the ID provided does not match the likeness of the individual presenting it;"}),(0,a.jsx)("li",{children:"the ID does not have a unique identifier; or"}),(0,a.jsx)("li",{children:"the ID is expired."})]})]}),(0,a.jsx)("li",{children:"When verifying the identity of an individual remotely, the Company relies on a third-party provider that verifies the authenticity of the ID, conducts “liveness testing”, and confirms that the ID belongs to the individual whose identity is being verified."}),(0,a.jsx)("li",{children:"The Company conducts CDD and EDD procedures to avoid the risk of being held liable and to protect Customers and itself from a Customer’s attempts to use the services for carrying out illegal activities."}),(0,a.jsx)("li",{children:"As part of the CDD procedures, the Company evaluates Customers’ transactions, as well as collects and stores information on the essential facts pertaining to Customers, potential Customers, and their transactions."}),(0,a.jsx)("li",{children:"After carrying out the identification procedures pertaining to a Customer, the Company stores the information obtained in this Customer’s file. The Company retains information on potential Customers to whom access to the services was denied due to the AML Policy (CA) and procedures."}),(0,a.jsxs)("li",{children:["The Company is committed to protecting Customers’ privacy rights and the confidentiality of their personal data. The Company collects personal data from Customers only to the extent necessary to ensure the Company is properly providing services to Customers and to comply with the applicable laws. Such personal data of Customers and former Customers may be disclosed to third parties only in a limited number of circumstances, in accordance with the applicable laws and agreements between the Company and the Customer. Privacy Notice is available here:"," ",(0,a.jsx)("a",{"data-underline":!0,href:d.qv._Promo,target:"_blank",rel:"noopener noreferrer nofollow",children:"www.volet.com"}),"."]}),(0,a.jsx)("li",{children:"The Company shall carefully maintain at head office Customers’ files, including statements, transaction reports, receipts, notes, internal correspondence, and any other documents related to the Customer in a machine-readable or electronic form for a period of 5 (five) years after: the day on which the account to which they relate is closed, or the day on which the last business transaction is conducted; or the day on which they were created depending on the nature of a record as defined in article 148 of Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLFTR)."})]}),(0,a.jsx)("h2",{children:"Periodic Review of Collected Information"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Company will review the information, data and documents obtained from the Customer together with the risk assessment periodically to ensure that the information and the assessment are up-to-date and remain relevant. The frequency of such reviews shall be determined by the level of risk the Customer poses or at trigger events."}),(0,a.jsxs)("li",{children:["All customer profiles are subject to ongoing monitoring to:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"classify and periodically reassess customer risk level based on transactions and activities;"}),(0,a.jsx)("li",{children:"keep customer identification and PIN records up to date; and"}),(0,a.jsx)("li",{children:"detect any suspicious transactions."})]})]}),(0,a.jsxs)("li",{children:["Customer information is updated on an ongoing basis, if in the course of operations new information becomes available. If during a customer information review, any of the following has not been updated, the Company takes steps to update the following information:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"Customer’s name;"}),(0,a.jsx)("li",{children:"Customer’s address;"}),(0,a.jsx)("li",{children:"Customer’s occupation;"}),(0,a.jsx)("li",{children:"Customer’s telephone number and email;"}),(0,a.jsx)("li",{children:"Customer’s PEP/HIO status."})]})]}

1),(0,a.jsx)("li",{children:"The PIN record is considered during reviews of unusual transactions and during scheduled transaction reviews. If the transaction activity does not appear to be consistent with the stated PIN, the Customer is contacted to update it."})]}),(0,a.jsx)("h2",{children:"Third-Party Determination"}),(0,a.jsx)("ol",{children:(0,a.jsx)("li",{children:"The Company takes reasonable measures to determine whether a Customer is acting on behalf of a third party and keeps third-party determination records."})}),(0,a.jsx)("h2",{children:"Classification of Customer Risk"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Company conducts and documents a risk assessment of the relationship with the Customer and conducts due diligence measures consistent with the Company’s risk assessment to ensure that enhanced measures are put in place for high-risk relationships."}),(0,a.jsx)("li",{children:"The Company uses an industry recognized software provider to assist in the risk assessment process. Risk ratings are applied in a manner that is consistent with the Company’s risk assessment."}),(0,a.jsx)("li",{children:"The Company assigns a risk rating to each customer. A classification of high risk is determined by several factors including transaction type, certain patterns of transaction activity, and customer specific characteristics. Customers are assessed as low risk if they are not assessed as high risk."}),(0,a.jsx)("li",{children:"All information collected as part of the customer risk assessment, including if a Customer is rated high risk, becomes part of the customer profile."}),(0,a.jsx)("li",{children:"Excessive risk occurs in situations where the risk of dealing with a certain individual, entity, or customer type is too high for the Company to accept the relationship with the Customer."}),(0,a.jsxs)("li",{children:["Risk ratings are updated on an ongoing and periodic basis and are based on factors that include, but are not limited to:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"transaction activity; and"}),(0,a.jsx)("li",{children:"characteristics, including PEP/HIO and sanctions status."})]})]}),(0,a.jsxs)("li",{children:["A reassessment of customer risk may also be triggered by:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"becoming aware of illegal or illicit activities;"}),(0,a.jsx)("li",{children:"a change in characteristics, including PIN or other risk factors for assessing customer risk; and"}),(0,a.jsx)("li",{children:"submitting a report to intelligence or enforcement agencies with respect to suspicious transactions or terrorist property."})]})]}),(0,a.jsx)("li",{children:"Company’s monitoring software assists in its ongoing assessment of relationship-based risk by adjusting a customer’s numerical risk score whenever there is a change to the customer information, or as a result of transaction activity. The numeric score is updated for a variety of attributes and related formulas which are associated with higher ML/TF risk in publications issued by FINTRAC and FATF and Company’s risk assessment."})]}),(0,a.jsx)("h2",{children:"Enhanced Due Diligence"}),(0,a.jsx)("ol",{children:(0,a.jsx)("li",{children:"The Company applies EDD measures when a Customer is determined to be high risk. Measures are designed to mitigate the specific risks posed by each high-risk Customer to sufficiently mitigate a customer’s risk."})}),(0,a.jsx)("h2",{children:"Ongoing Monitoring of Transactions"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Company applies various checking and monitoring algorithms to make sure all required CDD procedures are executed in a timely manner, persons with limitations (sanctions list and politically exposed persons screening) are detected, and comprehensive automated online monitoring is carried out."}),(0,a.jsxs)("li",{children:["Financial data analysis includes several major components:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"Monitoring of sanctions lists;"}),(0,a.jsx)("li",{children:"Monitoring of user activity and user system environment;"}),(0,a.jsx)("li",{children:"Transaction monitoring;"}),(0,a.jsx)("li",{children:"Analysis of remaining balances, exchange rate fluctuations and other aspects;"}),(0,a.jsx)("li",{children:"Tools enhancing manual data analysis possibilities."})]})]}),(0,a.jsx)("li",{children:"The Company applies risk-based approach to define account and transaction risk level. The Company has implemented automated risk assessment system (RAS) to analyse the risk profile of the users and ongoing transactions to prevent illegal and fraudulent activities. However, any significant decisions that may impact the Customer are subject to a manual review."}),(0,a.jsx)("li",{children:"Transaction monitoring is conducted systematically by the C

1ompany’s third-party systems both in real-time and historically by generating alerts for transactions and transaction patterns that meet a series of rules within the system. These rules are based on a variety of attributes and related formulas which are associated with higher ML/TF risk in publications issued by FINTRAC and the FATF and adjusted for based on the Corporation’s Risk Assessment."})]}),(0,a.jsx)("h2",{children:"Identification and Detection of Suspicious Activities"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Company understands the importance of identifying and detecting suspicious activity through monitoring and reviewing the activity of customer transactions. The Company has a process for reviewing transactions to identify potentially suspicious activity and takes reasonable measures to identify individuals and entities who conduct or attempt to conduct a suspicious transaction. The Company monitors the transactions for evidence of certain patterns of activity that could be indicative of suspicious activity, such as whether the transactions are consistent with the information known about the Customer or the transactions are demonstrative of known suspicious indicators. Monitoring is also conducted to determine whether a customer’s current risk rating needs to be adjusted. Any financial transaction that may be related to money laundering activities shall be considered to be suspicious activities."}),(0,a.jsx)("li",{children:"Grounds for determining that a specific transaction is suspicious may be personal observations and experience of the Company’s employees, as well as information received or identified. Suspicious activity includes a transaction that any employee knows or suspects to: involve proceeds from an illegal activity; evade currency transaction reporting requirements; vary significantly from the customer’s normal transactions; a third party gained access to the customer's account or the activities are performed under instructions of a third party; or has no business or apparent lawful purpose and the Company knows of no reasonable explanation for the transaction after examining the available facts, including the background and possible purpose of the transaction."}),(0,a.jsx)("li",{children:"The Company will apply enhanced scrutiny to manually monitor customer transactions, in a manner reasonably designed to detect money laundering and suspicious activity. To identify suspicious transactions, the Company is entitled to perform enhanced due diligence measures and request additional information from the Customer confirming the economic purpose of the transaction and the origin of funds. Any potentially suspicious activity is escalated to the MLRO for investigation. In conducting their assessment as to whether there are reasonable grounds to suspect, the MLRO must consider additional information sources such as the customer’s transaction history, as well as customer characteristics and information (such as the PIN) that are contained in the customer’s file. If required, the MLRO may elect to contact the customer or employee to obtain additional information about the transaction."}),(0,a.jsx)("li",{children:"In accordance with the applicable laws of Canada and the requirements of international organizations, the Company may, where appropriate and without the obligation of obtaining the Customer’s approval or notifying the Customer, notify regulating and/or law enforcement agencies of any suspicious transactions."}),(0,a.jsx)("li",{children:"Different requirements for reporting suspicious transactions may depend on the nature and amount of a transaction."}),(0,a.jsx)("li",{children:"The Company shall continuously conduct due diligence procedures pertaining to its Customers and scrutinize transactions carried out by them to ensure these transactions’ compatibility with the Company’s knowledge of its Customers, their business and, when necessary, their source of funds."})]}),(0,a.jsx)("h2",{children:"PEP, HIO and Sanctions Screening"}),(0,a.jsxs)("ol",{children:[(0,a.jsxs)("li",{children:["The Company shall comply with the requirements contained in the Canada’s legislative measure against terrorists, terrorist groups, and other listed and sanctioned individuals and entities are contained in various Canadian statutes and regulations, or those adopted by Canada, including the Criminal Code of Canada, United Nations Act, and Special Economic Measures Act (“SEMA”). Specific measures vary depending on the relevant legislation, but broadly include:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"prohibitions in dealing with property owned or c

1ontrolled by any person or entity listed on a government created list, or one created by a relevant regulatory body, of those individuals or entities associated with or suspected of being associated with terrorism (“Designated Persons”);"}),(0,a.jsx)("li",{children:"prohibitions on providing any financial or related services in respect of property owned or controlled by Designated Persons; and"}),(0,a.jsx)("li",{children:"prohibitions on entering or facilitating transactions with, or making available property or financial services to, Designated Persons."})]})]}),(0,a.jsx)("li",{children:"The Company does not knowingly enter into transactions with, or provide or assist transfers to, or for the benefit of, governments, entities, charities, organizations, and individuals targeted by required sanctions, including, but not limited to, Canadian anti-terrorism measures and Canadian economic sanctions. To that end, the Company screens its customer database and payments records for the names of Designated Persons."}),(0,a.jsxs)("li",{children:["The Company is required to determine if a customer is a politically exposed person (“PEP”)/head of an international organization (“HIO”). Reasonable measures to make a PEP determination include:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"asking the Customer if they are a PEP and documenting their response; and/or"}),(0,a.jsx)("li",{children:"independently confirming the customer’s PEP status by using an industry-recognized database."})]})]}),(0,a.jsx)("li",{children:"The Company does not knowingly enter into transactions with, or provide or assist transfers to, or for the benefit of the Politically Exposed Persons."}),(0,a.jsx)("li",{children:"The Company uses an external industry recognized software provider for PEP, HIO and Sanctions screening, which automatically scans names in the system to find potential name matches."}),(0,a.jsx)("li",{children:"Scans are conducted at onboarding and every transaction for all names collected as part of that transaction, including counterparties and any known third parties."}),(0,a.jsx)("li",{children:"The Company shall periodically refer to and consult the lists published by the authorities of Canada, other countries and international organizations that contain lists of known terrorists or persons suspected of terrorist activities, terrorist organizations, high-risk countries, a limited list of countries subject to the OFAC sanctions, jurisdictions that do not provide sufficient level of anti-money laundering procedures, as well as countries subject to sanctions to determine whether the Company’s Customer or potential Customer, and/or such Customer’s country of jurisdiction is included in the above lists."}),(0,a.jsxs)("li",{children:["The Company continuously conducts check against the Sanctions lists and the lists promulgated pursuant to the laws listed below:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"Criminal Code;"}),(0,a.jsx)("li",{children:"United Nations Act;"}),(0,a.jsx)("li",{children:"Justice for Victims of Corrupt Foreign Officials Act;"}),(0,a.jsx)("li",{children:"Freezing the Assets of Corrupt Foreign Officials Act;"}),(0,a.jsx)("li",{children:"SEMA;"}),(0,a.jsx)("li",{children:"UN Sanctions;"}),(0,a.jsx)("li",{children:"Interpol Red List;"}),(0,a.jsx)("li",{children:"HM Treasury;"}),(0,a.jsx)("li",{children:"US OFAC Sanctions;"}),(0,a.jsx)("li",{children:"UK Sanctions;"}),(0,a.jsx)("li",{children:"EU Consolidated list of Sanctions."})]})]}),(0,a.jsx)("li",{children:"To adjudicate a potential name match, common differentiators such as date of birth or country of origin are compared to identification information collected to determine the veracity of the match. If the match is a true match, any customer funds in possession are held and no transactions are processed (regardless of the status of the transactions) without an evidence-based discount of the match, or written judicial, law enforcement, or ministerial direction."})]}),(0,a.jsx)("h2",{children:"Third Parties"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"To perform some services and conduct business activities, the Company uses third-party service providers. The company shall try to determine, during the initial and ongoing due diligence process, to the extent possible whether there are any initiated investigations and filed lawsuits against any such third-party service providers. The company shall also determine whether a third-party provider has obtained all the necessary licenses, permits, and approvals before establishing a business relationship with such third-party service provider."}),(0,a.jsx)("li",{children:"Regarding its own staff, the Company shall carefully review all candidates for employment and determine whether the activities of a new employee fall in the category that is susceptible to money laundering activities. In addition, the Company has prepared and implements a number of personnel training programs on customer identification procedures and prevention of money laundering activities."})]}),(0,a.jsx)("h2",{children:"Civil and Criminal Penalties"}),(0,a.jsx)("ol",{children:(0,a.jsx)("li",{children:"Government authorities and international organizations may impose severe civil and criminal penalties against any person who violates the laws and regulations referred to in paragraph 1.2 of the AML Policy (CA). Such civil and criminal penalties may include fines in the amount of up to millions of dollars, and the term of criminal punishment may be up to 10 (ten) years in prison. In addition, government authorities may confiscate any property involved in criminal violation of these laws and regulations, including companies, bank accounts, or any other assets that may be associated with criminal violations."})}),(0,a.jsx)("h2",{children:"Compliance Statement"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Customer certifies that he/she has read and understood this AML Policy (CA), and that they shall operate in full compliance with the requirements and standards outlined in the AML Policy (CA) and comply with all applicable laws and other regulations and requirements governing its activities as a customer."}),(0,a.jsx)("li",{children:"The Customer acknowledges that he/she is responsible for his/her actions in accordance with the effective laws in the field discussed in this AML Policy (CA) and shall bear responsibility pertaining to failure to comply with such laws."})]})]})}},latest:"v1"},"aml-costa-rica":{versions:{v1:function(){return(0,a.jsxs)("div",{"data-template":"default",children:[(0,a.jsx)("h2",{children:"Introduction"}),(0,a.jsx)("p",{children:"Within the scope of its business activities, the company Second February Limitada (hereinafter “the Company”) provides services related to virtual assets (crypto assets)."}),(0,a.jsx)("p",{children:"The Company issues this binding document – Anti-Money Laundering and Countering the Financing of Terrorism COMPLIANCE POLICY – establishing the standards obligatory for the Company to efficie

1ntly reduce or eliminate illegal activities in full while providing its services to the customers. This goal is to be achieved by implementing and adhering to the FATF’s Standards for virtual assets as a priority."}),(0,a.jsx)("p",{children:"Among the most crucial preventive measures the Company carries out are: - customer due diligence (CDD), - record keeping and - suspicious transactions/activities monitoring and reporting (STR)."}),(0,a.jsx)("p",{children:"To prevent fraudulent activity, the Company performs monitoring of customers' activity within its system using both numerous automated mechanisms and IT solutions and manual checks."}),(0,a.jsx)("p",{children:"The best practices to be implemented by the Company in its internal scrutiny procedures will contribute the belief that virtual asset technologies and businesses can continue to grow and innovate in a responsible way, and in its turn, it will contribute to creation of a level playing field."}),(0,a.jsx)("p",{children:"The Company also implements sanction measures applied by the Republic of Costa Rica in relation to quite a wide group of natural persons and legal entities. That means permanent checks whether a customer is subject to international sanctions or not, respectively fulfilment of other procedures as described in the Company’s internal binding documents."}),(0,a.jsx)("h2",{children:"Customer Due Diligence (CDD)"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Company shall apply customer due diligence measures in respect of customers, business relationships and transactions, and conduct ongoing monitoring of business relationships."}),(0,a.jsx)("li",{children:"To be able to establish the identity of its customers, the Company must obtain sufficient data/documents/information from a (perspective) customer and verify such data/documents/information against independent sources. Customers that in the opinion of Company pose higher risk may be investigated more thoroughly which may result in requesting of additional information and taking longer term for verification of the identity of such customer. Company retains a right to re-establish the identity of the customer in cases where the Company sees it fit and in relation to that requests additional data/documents/information or to renew previously submitted."})]}),(0,a.jsx)("h2",{children:"Enhanced customer due diligence (EDD)"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Company applies on a risk-sensitive basis enhanced customer due diligence measures and enhanced ongoing monitoring in any situation which by its nature presents a higher risk of money laundering, terrorist financing activities or other criminal conduct on the basis of national risk assessment."}),(0,a.jsx)("li",{children:"The Company, proportionate to risk, applies enhanced customer due diligence measures and enhanced ongoing monitoring in respect of business relationships and transactions with legal and natural persons from countries which do not apply or fully apply the Financial Action Task Force Recommendations."}),(0,a.jsx)("li",{children:"Enhanced due diligence measures in business relationship monitoring include, among other things monitoring the business relationship more efficiently by increasing the number and frequency of applicable verification measures and selecting the transaction indicators that will be additionally checked."})]}),(0,a.jsx)("h2",{children:"Record keeping"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The data and documents related to the business relationship shall be archived."}),(0,a.jsxs)("li",{children:["All records must be kept for a minimum period of five (5) years from the date",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"of the relevant event;"}),(0,a.jsx)("li",{children:"of any transaction or correspondence relating to a customer;"}),(0,a.jsx)("li",{children:"on which evidence of a person’s identity is obtained;"}),(0,a.jsx)("li",{children:"in the case of an ongoing business relationship, after the business relationship ceases."})]})]}),(0,a.jsx)("li",{children:"Records do not have to be kept in hard copy. Retention may be by way of original documents, or by way of copies in any machine-readable or electronic form from which a paper copy can be readily produced."})]}),(0,a.jsx)("h2",{children:"Suspicious transactions/activities monitoring and reporting (STR)"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Company shall conduct ongoing monitoring (check) of a business relationship."}),(0,a.jsxs)("li",{children:["In accordance with a Section 46(2) of the AML/CFT Act “ongoing monitoring” of a business relationship means —",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"(a) scrutinising transactions undertaken throughout the relationship to ensure that the transactions are consistent with a company knowledge of the customer, the business and risk profile and the source of funds of the customer; and"}),(0,a.jsx)("li",{children:"(b) keeping the documents, data or information obtained for the purpose of applying customer due diligence measures up to date."})]})]}),(0,a.jsx)("li",{children:"Following its AML Policy and the applicable legal acts, the Company, when necessary, will report to the respective authorities of the activities that may be considered as money laundering and terrorist financing. The Company will not disclose any information about such a report being made and will not address any questions in relation to that."}),(0,a.jsx)("li",{children:"The requirement to report suspicious transactions applies to all types of transactions or activities."})]}),(0,a.jsx)("h2",{children:"Sanctions and PEP monitoring"}),(0,a.jsxs)("ol",{children:[(0,a.jsxs)("li",{children:["The Company is not allowed to:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"conclude transactions with parties subject to the sanctions;"}),(0,a.jsx)("li",{children:"conclude transactions the execution of which would be in conflict with the sanctions;"}),(0,a.jsx)("li",{children:"perform the actions the performance of which is prohibited by the sanctions."})]})]}),(0,a.jsx)("li",{children:"A Compliance officer shall be responsible for organization of implementation of the sanctions in accordance with the law of the Republic of Costa Rica."}),(0,a.jsx)("li",{children:"The Company implements the sanctions by using the sanctions screening tools, which automatically scans names of the clients in the system to find potential name matches."}),(0,a.jsx)("li",{children:"The initial sanctions screening constitutes a part of the CDD. During a customer identification process the Company uses the sanctions screening tools to check whether sanctions are applied to the customer, their representatives, related persons and beneficial owners(s)."}),(0,a.jsx)("li",{children:"Before each transaction the Company should check if the transaction does not fall within the scope of sectorial sanctions."}),(0,a.jsxs)("li",{children:["In the course of business relationship, the Company shall perform sanctions screening in the following cases:",(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"the Company obtains data that information about the client, his/her/its representative, related persons or the beneficial owner(s) has changed (e. g. the name, surname or the legal name of the customer has changed, the representative of the customer has changed, the beneficial owner(s) of the customer has changed);"}),(0,a.jsx)("li",{children:"a customer updates due diligence information;"}),(0,a.jsx)("li",{children:"legal acts establishing sanctions requirements have changed;"}),(0,a.jsx)("li",{children:"before each transaction;"}),(0,a.jsx)("li",{children:"regularly on ongoing basis."})]})]})]}

1),(0,a.jsx)("h2",{children:"Risk assessment"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Company takes measures to identify, assess, understand and monitor its risks of ML and TF activities and take appropriate measures to mitigate the risks identified."}),(0,a.jsx)("li",{children:"Prior to the launch of a new product or business practice or the use of a new or developing technology, the Company identifies and assesses the ML and TF risks that may arise in relation to the development and use of new products or business practices, or new or developing technologies for both new and pre-existing products and take appropriate measures to manage and mitigate those risks."}),(0,a.jsx)("li",{children:"The Company shall document the outcome of the risk assessment and regularly update it."})]})]})}},latest:"v1"},"consent-personal-data-processing":{versions:{v1:function(){return(0,a.jsxs)("div",{"data-template":"simple",children:[(0,a.jsx)("p",{children:"Please carefully review this Consent to biometric data processing form before consenting to our collection and use of your facial features data."}),(0,a.jsx)("p",{children:"Volet.com services are provided by the listed below companies, who may act as independent or joint controllers depending on the services provided to the Customer:"}),(0,a.jsx)("p",{children:"Queensland Foreign Exchange Inc., company number 1000433476, 36 Toronto Street, Suite 850, Toronto, Ontario, Canada, M5C 2C5."}),(0,a.jsx)("p",{children:"Second February Limitada, registration number 3-102-918773, Costa Rica, San Jos\xe9, Mata Redonda, Sabana Oeste, twelfth avenue, ninetieth street, ERP Lawyers Law Firm offices."}),(0,a.jsx)("p",{children:"To allow you to use the full scope of our services, we require you to undergo an identity verification process."}),(0,a.jsx)("p",{children:"In order to facilitate verification, we subcontract Sumsub (Sum and Substance Ltd, address: 30 St. Mary Axe, London, England, EC3A 8BF, registered number: 09688671) – which acts as a processor as defined in GDPR."}),(0,a.jsx)("p",{children:"We ask you to conduct a liveness check to prove you are a real person and your ID document belongs to you. We will process your personal data for identity verification and to prevent the creation of multiple accounts in a fraudulent manner for the purpose of client diligence compliance in accordance with the applicable AML laws."}),(0,a.jsx)("p",{children:"To achieve this, we have to process your biometric data – facial features. When we ask you to move your face in front of the camera, a biometric template is created. It is compared against the photo placed in your ID document. 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1s which act as controllers as defined in GDPR."}),(0,a.jsx)("p",{children:"To allow you to use the full scope of our services, we require you to undergo an identity verification process."}),(0,a.jsx)("p",{children:"In order to facilitate verification, we subcontract Sumsub (Sum and Substance Ltd, address: 30 St. Mary Axe, London, EC3A 8BF, United Kingdom, registered number: 09688671) – which acts as a processor as defined in GDPR."}),(0,a.jsx)("p",{children:"We ask you to conduct a liveness test to prove you are a real person and your ID document belongs to you. We will process your personal data for identity verification and to prevent the creation of multiple accounts in a fraudulent manner for the purpose of client diligence compliance in accordance with the applicable AML laws."}),(0,a.jsx)("p",{children:"To achieve this, we have to process your biometric data – facial features. When we ask you to move your face in front of the camera, a biometric template is created. It is compared against the photo placed in your ID document. The biometric template is stored for up to 5 years, unless you request its deletion earlier, where applicable."}),(0,a.jsx)("p",{children:"You hereby acknowledge and agree that your biometrics shall be processed by means of automated reading, verification of the authenticity and other automated processing, which includes the processing of facial scan while passing liveness, video-selfie or video identification process, biometric authorisation, face comparison from the photo of an identity document and the facial image, searching of multiple identity creation, work and development of fraud control network to detect and prevent fraud and criminal activity."}),(0,a.jsx)("p",{children:"Furthermore, you hereby acknowledge and agree that your personal data shall be processed by means of 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."}),(0,a.jsx)("p",{children:"Your personal data shall be processed only on the servers physically located within the European Union."}),(0,a.jsx)("p",{children:"Please note that if you refuse to consent to the collection and processing of your biometric data, then we may not be able to verify you at the required level of assurance for use of all the Volet.com services."}),(0,a.jsx)("p",{children:"You further acknowledge and agree that your electronic acceptance of this document shall have the same force and effect as a written ink signature, and that by ticking the box “Agree to the personal data processing” or through similar action, you have provided informed written consent to Queensland Foreign Exchange Inc. and Second February Limitada, with respect to the collection, use, retention and deletion of your biometric data such as facial features as described above, and to the provision of such data to Sumsub."})]})}},latest:"v2"},"cookie-policy":{versions:{v1:function(){return(0,a.jsxs)("div",{"data-template":"default",children:[(0,a.jsxs)("p",{children:["The Cookies Policy describes the conditions, procedures, and purposes of the use and storage of cookies by us when you use the Website (",(0,a.jsx)("a",{"data-underline":!0,href:d.qv._Promo,target:"_blank",rel:"noopener noreferrer nofollow",children:"www.volet.com"}),","," ",(0,a.jsx)("a",{"data-underline":!0,href:"https://account.volet.com/",target:"_blank",rel:"noopener noreferrer nofollow",children:"www.account.volet.com"}),","," ",(0,a.jsx)("a",{"data-underline":!0,href:d.qv._Support,target:"_blank",rel:"noopener noreferrer nofollow",children:"www.support.volet.com"}),"). The cookies are located on the promo page (when you visit the Website and do not log in) and on the Wallet page (when you log in to your Wallet)."]}),(0,a.jsx)("p",{children:"Services on the Website are provided by the listed below companies, who may act as independent or joint controllers depen

1ding on the specific Services provided to the Customer:"}),(0,a.jsx)("p",{children:"Queensland Foreign Exchange Inc., incorporation number: 1000433476, MSB registration number: M23153297, registered address: 36 Toronto Street, Suite 850, Toronto, Ontario, Canada, M5C 2C5."}),(0,a.jsx)("p",{children:"Second February Limitada, registration number: 3-102-918773, registered address: Costa Rica, San Jos\xe9, Mata Redonda, Sabana Oeste, twelfth avenue, ninetieth street, ERP Lawyers Law Firm offices."}),(0,a.jsx)("h2",{children:"What are cookies?"}),(0,a.jsx)("p",{children:"Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) which enables the Website to recognize your browser and capture and remember certain information. 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Information about your use of the Website collected by cookies will be transferred to Yandex and stored on Yandex’s server in the EU. Yandex will process this information to assess how you use the Website, compile reports for us on the Website operation, and provide other services. Yandex processes this information as specified in the"," ",(0,a.jsx)("a",{"data-underline":!0,href:"https://yandex.ru/legal/metrica_termsofuse/?lang=en",target:"_blank",rel:"noopener noreferrer nofollow",children:"Yandex.Metrica Terms of use"}),". You can decline marketing cookies or opt out of using cookie files by choosing the corresponding settings in your browser. You can also use the tool"," ",(0,a.jsx)("a",{"data-underline":!0,href:"https://yandex.com/support/metrika/general/opt-out.html",target:"_blank",rel:"noopener noreferrer nofollow",children:"https://yandex.com/support/metrika/general/opt-out.html"}),". However, it can affect some Website functions. 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We recommend that you check the privacy and cookies policies of these websites for information about the cookies they may use and personal data they may collect. We therefore have no responsibility or liability for the content and activities of these linked sit

1es. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites."}),(0,a.jsx)("h2",{children:"How to decline the use of cookies"}),(0,a.jsx)("p",{children:"You can choose to decline the use of cookies directly on the Website by hitting the decline button on the pop-up window on the site."}),(0,a.jsx)("p",{children:"You can also deactivate/delete cookies via your browser settings. If you do this, please be aware that you may lose some of the functionalities of the Website."}),(0,a.jsxs)("p",{children:["To opt out of being tracked by Google Analytics across all websites, visit"," ",(0,a.jsx)("a",{"data-underline":!0,href:"https://tools.google.com/dlpage/gaoptout",target:"_blank",rel:"noopener noreferrer nofollow",children:"https://tools.google.com/dlpage/gaoptout"}),"."]}),(0,a.jsxs)("p",{children:["Users can find information about how to manage Cookies in their browser by visiting Google Chrome, Mozilla Firefox, Apple Safari or Microsoft Windows Explorer websites. For further information about cookies and how to disable them, you can visit"," ",(0,a.jsx)("a",{"data-underline":!0,href:"https://www.aboutcookies.org/",target:"_blank",rel:"noopener noreferrer nofollow",children:"https://www.aboutcookies.org/"})," ","or"," ",(0,a.jsx)("a",{"data-underline":!0,href:"https://www.allaboutcookies.org/",target:"_blank",rel:"noopener noreferrer nofollow",children:"https://www.allaboutcookies.org/"}),"."]})]})}},latest:"v1"},dpa:{versions:{v1:function(){return(0,a.jsxs)("div",{"data-template":"dpa",children:[(0,a.jsx)("h2",{children:"General"}),(0,a.jsxs)("p",{children:['This Data Processing Agreement ("',(0,a.jsx)("strong",{children:"Agreement"}),'") forms part of the ',(0,a.jsx)("strong",{children:"Principal Agreement"})," (as defined below) between"]}),(0,a.jsx)("p",{children:(0,a.jsx)("strong",{children:"Merchant"})}),(0,a.jsx)("p",{children:"and"}),(0,a.jsxs)("p",{children:["Queensland Foreign Exchange., incorporation number: 1000433476, MSB registration number: M23153297; registered address: 36 Toronto Street, Suite 850, Toronto, Ontario, Canada, M5C 2C5 and Second February Limitada, registration number: 3-102-918773, registered address: Costa Rica, San Jos\xe9, Mata Redonda, Sabana Oeste, twelfth avenue, ninetieth street, ERP Lawyers Law Firm offices (herein called the “",(0,a.jsx)("strong",{children:"Companies"}),"”),"]}),(0,a.jsxs)("p",{children:["together referred as the “",(0,a.jsx)("strong",{children:"Parties"}),"”,"]}),(0,a.jsx)("h3",{children:"Whereas"}),(0,a.jsxs)("ol",{"data-bullets":"decimal","data-counter-decoration":"dot",children:[(0,a.jsx)("li",{children:"Merchant wishes to use the Services provided by the Company, which imply the processing of personal data of the Merchant’s users."}),(0,a.jsx)("li",{children:"The Merchant as the Controller uses Company as the Processor for processing the Personal data of Users."}),(0,a.jsx)("li",{children:"The Parties seek to implement a data processing agreement that complies with the requirements of the current legal framework in relation to data processing and with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)."}),(0,a.jsx)("li",{children:"The Agreement is an annex to the Terms and Conditions, as defined below, and is an integral part of annexes to the agreements that are applied to the Merchant when using the services of online payment collection from users, online payment collection by payment cards, and payment collection via the external operators, provided in accordance to provisions of the Terms and Conditions, Merchant Agreement (Fiat), Merchant Agreement (Fiat and Crypto), Mass Payout Agreement (whichever is applicable)."})]}),(0,a.jsx)("p",{children:"It is agreed as follows:"}),(0,a.jsxs)("section",{children:[(0,a.jsxs)(b,{heading:"Definitions",children:[(0,a.jsxs)("p",{children:[(0,a.jsx)("strong",{children:"Applicable Laws"})," – laws and regulations the Company and Merchant are subject to, based on the material or territorial scope of such legislation."]}),(0,a.jsxs)("p",{children:[(0,a.jsx)("strong",{children:"Terms and Conditions"})," – Volet System Terms and Conditions containing the principal provisions pertaining to the operation of the Volet System and working in this System, published at the Company’s website."]}),(0,a.jsxs)("p",{children:[(0,a.jsx)("strong",{children:"GDPR"})," – Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC."]}),(0,a.jsxs)("p",{children:[(0,a.jsx)("strong",{children:"Data processing"})," – actions performed with the Personal data as defined in paragraph 2 of Article 4 of the GDPR."]}),(0,a.jsxs)("p",{children:[(0,a.jsx)("strong",{children:"Processor"})," – a person who processes personal data on behalf of a data Controller as defined in paragraph 8 of Article 4 of the GDPR."]}),(0,a.jsxs)("p",{children:[(0,a.jsx)("strong",{children:"Controller"})," – a person who determines the purposes and means of processing of data as defined in paragraph 7 of Article 4 of the GDPR."]}),(0,a.jsxs)("p",{children:[(0,a.jsx)("strong",{children:"Merchant"})," – a client of the Company’s system, using a business or personal account to carry out commercial activities, and receiving funds from other users for any goods, works or services, and using one or more services, provided by the C

1ompany."]}),(0,a.jsxs)("p",{children:[(0,a.jsx)("strong",{children:"Principal Agreement"})," – Terms and Conditions together with Merchant Agreement (Fiat), Merchant Agreement (Fiat and Crypto), Mass Payout Agreement (whichever is applicable depending on the business relations between the Company and the Merchant)."]}),(0,a.jsxs)("p",{children:[(0,a.jsx)("strong",{children:"Personal data"})," – any information about a natural person who was identified or who can be identified (data subject) as defined in paragraph 1 of Article 4 of the GDPR."]}),(0,a.jsxs)("p",{children:[(0,a.jsx)("strong",{children:"System"})," – a software solution on the Company’s web pages, developed by the Company and used for provision of the Company’s services."]}),(0,a.jsxs)("p",{children:[(0,a.jsx)("strong",{children:"User"})," – the payer and/or the final recipient of services provided and goods sold by the Merchant using the System for the collection of payments."]}),(0,a.jsx)("p",{children:"Where this Agreement use the terms defined in Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively, those terms shall have the same meaning as in that Regulation."})]}),(0,a.jsx)(b,{heading:"Purpose and scope",skipCounter:!1,children:(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The present Agreement regulates the process of the personal data processing of the Users, mutual obligations and liability between the Merchant and the Company. The aim of the present agreement is to ensure the protection and security of the Personal data of the Users, for the processing of which the Merchant uses the Company’s services, in accordance with applicable legislation."}),(0,a.jsx)("li",{children:"Section I of the Agreement governs the processing activities where the Merchant defines the purpose and methods of the data processing and hence act as the Controller, while the Company acts as Processor, operating based on the Merchant’s instructions. In cases where the Merchant processes Personal data to which a third party is the Controller, the Merchant is a Processor of such Personal data and the Company is a Sub-Processor. In this case, what has been set out as regards the rights and obligations of the Controller shall apply to the Merchant as the Processor of the Controller’s Personal data, and the Controller shall use its rights through the Merchant. The terms of processing of personal data by the Company as Processor are specified in Exhibit I."}),(0,a.jsx)("li",{children:"Section II of the Agreement governs the processing activities where the Company defines the purpose and methods of the data processing and hence act as the Controller."}),(0,a.jsx)("li",{children:"Exhibits I to V are an integral part of the Agreement."}),(0,a.jsx)("li",{children:"This Agreement is without prejudice to obligations to which the Merchant and the Company is subject by virtue of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725"})]})}),(0,a.jsxs)(b,{heading:"Section I. Data Processor Clauses",children:[(0,a.jsx)("h2",{children:"Description of processing"}),(0,a.jsx)("ol",{children:(0,a.jsx)("li",{children:"The details of the processing operations, in particular the categories of personal data and the purposes of processing for which the the Company processes personal data on behalf of the Merchant, are specified in Exhibit I."})}),(0,a.jsx)("h2",{children:"Instructions"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Company shall process personal data only on documented instructions from the Merchant, unless required to do so by Union or Member State law to which the Company is subject. In this case, the Company shall inform the Merchant of that legal requirement before processing, unless the law prohibits this on important grounds of public interest. Subsequent instructions may also be given by the Merchant throughout the duration of the processing of personal data. These instructions shall always be documented."}),(0,a.jsx)("li",{children:"Instructions may be given in any form allowing to record the fact of the insctuction given, including, but not limited to use of functionalities of the Company’s platform logged in the system, communication via emails and messengers, using the contacts defined in the Principal Areement."}),(0,a.jsx)("li",{children:"The Company shall immediately inform the Merchant if, in the Company’s opinion, instructions given by the Merchant infringe Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or the applicable Union or Member State data protection provisions."}),(0,a.jsx)("li",{children:"Whereas the Company is subject to legislation of a third country, the Company declares not to be aware of the mentioned legislation preventing the Company from fulfilling the Agreement, and that the Company will notify the Merchant in writing without undue delay, if the Company becomes aware of that such hindrance is present or will occur."})]}),(0,a.jsx)("h2",{children:"Purpose limitation"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"Where the Company acts as a data Processor, it shall process the personal data only for the specific purpose(s) of the processing, as set out in Annex II, unless it receives further instructions from the Merchant."}),(0,a.jsx)("li",{children:"Where the Company acts as a data Controller the relevant rights and obligations are defined in the Section II of the Agreement."})]}),(0,a.jsx)("h2",{children:"Duration of the processing of personal data"}),(0,a.jsx)("ol",{children:(0,a.jsx)("li",{children:"Processing by the C

1ompany on behalf of Merchant shall only take place for the duration specified in Exhibit I."})}),(0,a.jsx)("h2",{children:"Security of processing"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Company shall at least implement the technical and organisational measures specified in Exhibit II to ensure the security of the personal data. This includes protecting the data against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to the data (“Personal data breach”). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of processing and the risks involved for the data subjects."}),(0,a.jsx)("li",{children:"The Company shall grant access to the personal data undergoing processing to members of its personnel only to the extent strictly necessary for implementing, managing and monitoring of the contract."}),(0,a.jsx)("li",{children:"The Company shall ensure that persons authorised to process the personal data received have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality."})]}),(0,a.jsx)("h2",{children:"Documentation and compliance"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Parties shall be able to demonstrate compliance with this Agreement."}),(0,a.jsx)("li",{children:"The Company shall deal promptly and adequately with inquiries from the Merchant about the processing of data in accordance with this Agreement."}),(0,a.jsx)("li",{children:"The Company shall make available to the Merchant all information necessary to demonstrate compliance with the obligations that are set out in this Agreement and stem directly from Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725. At the Merchant’s request, the Company shall also permit and contribute to audits of the processing activities covered by this Agreement, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or an audit, the Merchant may take into account relevant certifications held by the Company."}),(0,a.jsx)("li",{children:"The Merchant may choose to conduct the audit by itself or mandate an independent auditor. Audits may also include inspections at the premises or physical facilities of the Company and shall, where appropriate, be carried out with reasonable notice."}),(0,a.jsx)("li",{children:"The Parties shall make the information referred to in this section, including the results of any audits, available to the competent supervisory authority/ies on request."})]}),(0,a.jsx)("h2",{children:"Use of sub-processors"}),(0,a.jsxs)("ol",{children:[(0,a.jsxs)("li",{children:["Merchant acknowledges and agrees that Company may (1) engage its Affiliates and the Authorized Sub-Processors listed in"," ",(0,a.jsx)("a",{"data-underline":!0,href:"#exhibit-iii-list-of-sub-processors",children:"Exhibit III"})," ","to this Agreement to access and process Personal Data in connection with the Services and (2) from time to time engage additional third parties for the purpose of providing the Services, including without limitation the processing of Personal Data. By way of this Agreement, Merchant provides general written authorization to Company to engage sub-processors as necessary to perform the Services."]}),(0,a.jsx)("li",{children:"The Company shall inform in writing the Merchant of any intended changes of that at least 15 days in advance by amending the Exhibit III and publishing the intended changes on the Website, thereby giving the Merchant sufficient time to be able to object to such changes prior to the engagement of the concerned sub-processor(s)."}),(0,a.jsx)("li",{children:"Where the Company engages a sub-processor for carrying out specific processing activities on behalf of the Merchant, it shall do so by way of a contract which imposes on the sub-processor, in substance, the same data protection obligations as the ones imposed on the Company in accordance with this Agreement. The Company shall ensure that the sub-processor complies with the obligations to which the C

1ompany is subject pursuant to these Clauses and to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725."}),(0,a.jsx)("li",{children:"At the Merchant’s request, the Company shall provide a copy of such a sub-processor agreement and any subsequent amendments to the Merchant. To the extent necessary to protect business secret or other confidential information, including personal data, the Company may redact the text of the agreement prior to sharing the copy."}),(0,a.jsx)("li",{children:"The Company shall remain fully responsible to the Merchant for the performance of the sub-processor’s obligations in accordance with its contract with the Company. The Company shall notify the Merchant of any failure by the sub-processor to fulfil its contractual obligations."}),(0,a.jsx)("li",{children:"The Processor shall agree a third party beneficiary clause with the sub-processor whereby - in the event the processor has factually disappeared, ceased to exist in law or has become insolvent - the Merchant shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data."})]}),(0,a.jsx)("h2",{children:"International transfers"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Merchant authorizes the Company and its sub-processors to transfer Personal data across international borders."}),(0,a.jsx)("li",{children:"The Parties agree to incorporate the Standard Contractual Clauses Module 2 (Controller to Processor) approved by the Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council as an integral part of this agreement for the processing activities where data is transferred from Merchant to Company."}),(0,a.jsx)("li",{children:"Any transfer of data to a third country or an international organisation by the Company shall be done only on the basis of documented instructions from the Merchant or in order to fulfil a specific requirement under Union or Member State law to which the Company is subject and shall take place in compliance with Chapter V of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725."}),(0,a.jsx)("li",{children:"The Company shall comply with the obligations set forth in Exhibit III regarding supplemental measures for the transfer of Personal data originating in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable Data Protection Laws."}),(0,a.jsx)("li",{children:"The Merchant agrees that where the Company engages a sub-processor in accordance with present Agreement for carrying out specific processing activities on behalf of the Merchant and those processing activities involve a transfer of personal data within the meaning of Chapter V of Regulation (EU) 2016/679, the Company and the sub-processor can ensure compliance with Chapter V of Regulation (EU) 2016/679 by using standard contractual clauses adopted by the Commission in accordance with of Article 46(2) of Regulation (EU) 2016/679, provided the conditions for the use of those standard contractual clauses are met."})]}),(0,a.jsx)("h2",{children:"Assistance to the Merchant"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"The Company shall promptly notify the Merchant of any request it has received from the data subject. It shall not respond to the request itself, unless authorised to do so by the Merchant."}),(0,a.jsx)("li",{children:"The Company shall assist the Merchant in fulfilling its obligations to respond to data subjects’ requests to exercise their rights, taking into account the nature of the processing. In fulfilling its obligations in accordance with 10.1 and 10.2, the Company shall comply with the Merchant’s instructions."}),(0,a.jsxs)("li",{children:["In addition to the Company’s obligation to assist the Merchant pursuant to Clause 10.2, the Company shall furthermore assist the Merchant in ensuring compliance with the following obligations, taking into account the nature of the data processing and the information available to the Company:",(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"the obligation to carry out an assessment of the impact of the envisaged processing operations on the protection of personal data (a ‘data protection impact assessment’) where a type of processing is likely to result in a high risk to the rights and freedoms of natural persons;"}),(0,a.jsx)("li",{children:"the obligation to consult the competent supervisory authority/ies prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the Merchant to mitigate the risk;"}),(0,a.jsx)("li",{children:"the obligation to ensure that personal data is accurate and up to date, by informing the Merchant without delay if the Company becomes aware that the personal data it is processing is inaccurate or has become outdated;"}),(0,a.jsx)("li",{children:"the obligations in Article 32 Regulation (EU) 2016/679."})]})]})]}),(0,a.jsx)("h2",{children:"Notification of personal data breach"}),(0,a.jsx)("ol",{children:(0,a.jsx)("li",{children:"In the event of a personal data breach, the Company shall cooperate with and assist the Merchant for the Merchant to comply with its obligations under Articles 33 and 34 Regulation (EU) 2016/679 or under Articles 34 and 35 Regulation (EU) 2018/1725, where applicable, taking into account the nature of processing and the information available to the Company."})}),(0,a.jsx)("h2",{children:"Data breach concerning data processed by the Merchant"}),(0,a.jsx)("ol",{children:(0,a.jsxs)("li",{children:["In the event of a personal data breach concerning data processed by the Merchant, the Company shall assist the Merchant:",(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"in notifying the personal data breach to the competent supervisory authority/ies, without undue delay after the Merchant has become aware of it, where relevant (unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons);"}),(0,a.jsxs)("li",{children:["in obtaining the following information which, pursuant to Article 33(3) Regulation (EU) 2016/679, shall be stated in the Merchant’s notification, and must at least include:",(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"brace",children:[(0,a.jsx)("li",{children:"the nature of the personal data including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;"}),(0,a.jsx)("li",{children:"the likely consequences of the personal data breach;"}),(0,a.jsxs)("li",{children:[(0,a.jsx)("p",{children:"the measures taken or proposed to be taken by the Merchant to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects."}),(0,a.jsx)("p",{children:"Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay."})]})]})]}),(0,a.jsx)("li",{children:"in complying, pursuant to Article 34 Regulation (EU) 2016/679, with the obligation to communicate without undue delay the personal data breach to the data subject, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons."})]})]})}),(0,a.jsx)("h2",{children:"Data breach concerning data processed by the C

1ompany"}),(0,a.jsxs)("ol",{children:[(0,a.jsxs)("li",{children:["In the event of a personal data breach concerning data processed by the Company, the Company shall notify the Merchant without undue delay after the Company having become aware of the breach. Such notification shall contain, at least:",(0,a.jsxs)("ol",{children:[" ",(0,a.jsx)("li",{children:"a description of the nature of the breach (including, where possible, the categories and approximate number of data subjects and data records concerned);"}),(0,a.jsx)("li",{children:"the details of a contact point where more information concerning the personal data breach can be obtained;"}),(0,a.jsx)("li",{children:"its likely consequences and the measures taken or proposed to be taken to address the breach, including to mitigate its possible adverse effects."})]})]}),(0,a.jsx)("li",{children:"Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay."})]})]}),(0,a.jsxs)(b,{heading:"Section II. Data Controller Clauses",children:[(0,a.jsx)("h2",{children:"Company obligations as the Controller"}),(0,a.jsxs)("ol",{children:[(0,a.jsxs)("li",{children:["To the extent that Company independently determines the means and purposes of processing any Personal Data pursuant to the Principal Agreement or to this Agreement, Company shall:",(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"process Personal Data for the purpose of performing its obligations under the Agreement or for the lawful purposes determined by the Company as described in the Agreement and the Company’ Privacy Notice;"}),(0,a.jsx)("li",{children:"implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, taking into account the state of the art, the costs of implementation and the nature, scope, context and purpose of processing and promptly notify the Merchant if any Personal Data is subject to any unauthorised or unlawful access, loss, destruction or damage;"}),(0,a.jsx)("li",{children:"promptly assist the Merchant in complying with any data subject rights request under the Applicable Laws that the Merchant may receive from any individuals to whom any Personal Data relates;"}),(0,a.jsx)("li",{children:"promptly assist the Merchant in complying with any duties to cooperate with Supervisory Authorities under the Applicable Laws;"}),(0,a.jsx)("li",{children:"take any other alternative or additional steps reasonably requested by the Merchant in order to ensure that appropriate measures are put in place to provide an adequate level of protection for Personal Data."})]})]}),(0,a.jsxs)("li",{children:["As a Data Controller, the Company may Process Personal Data for the following purposes:",(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"brace",children:[(0,a.jsx)("li",{children:"to provide the services under the Principal Agreement;"}),(0,a.jsx)("li",{children:"to comply with legal or regulatory obligations applicable to the Company;"}),(0,a.jsx)("li",{children:"to conduct BDD and KYC measures on the Merchant;"}),(0,a.jsx)("li",{children:"to monitor, prevent and detect frauds and security threats;"}),(0,a.jsx)("li",{children:"to verify payment’s authenticity;"}),(0,a.jsx)("li",{children:"to prevent harm to the Merchant, the Company and/or third parties;"}),(0,a.jsx)("li",{children:"to host and maintain data and systems;"}),(0,a.jsx)("li",{children:"to produce and distribute promotional marketing actions;"}),(0,a.jsx)("li",{children:"to analyse, develop and improve its products and services."})]})]}),(0,a.jsx)("li",{children:"Whenever the Company acts as a Data Controller, the Processing of Personal Data will be subject to Company’s Privacy Policy."}),(0,a.jsx)("li",{children:"The parties agreed to implement the Standard Contractual Clauses Module 1 (Controller to Controller) approved by the Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council to the transfer of data where Company acts as a Controller."})]})]}),(0,a.jsxs)(b,{heading:"Section III. Final Provisions",children:[(0,a.jsx)("h2",{children:"Final Provisions"}),(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"This Agreement covers relations between the Parties starting from the date the Principal Agreement takes effect."}),(0,a.jsx)("li",{children:"The Agreement shall be valid till the Principal Agreement is in force."}),(0,a.jsx)("li",{children:"Without prejudice to any provisions of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725, in the event that the Company is in breach of its obligations under this Agreement, the Merchant may instruct the Company to suspend the processing of personal data until the latter complies with this Agreement or the contract is terminated. The Company shall promptly inform the Merchant in case it is unable to comply with this Agreement, for whatever reason."}),(0,a.jsxs)("li",{children:["The Merchant shall be entitled to terminate the contract in part related to the processing where the Company acts on behalf of the Merchant as a Processor insofar as it concerns processing of personal data in accordance with this Agreement if:",(0,a.jsxs)("ol",{children:[(0,a.jsx)("li",{children:"the processing of personal data by the C

1ompany has been suspended by the Merchant pursuant to point (a) and if compliance with these Clauses is not restored within a reasonable time and in any event within one month following suspension;"}),(0,a.jsx)("li",{children:"the Company is in substantial or persistent breach of this Agreement or its obligations under Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725;"}),(0,a.jsx)("li",{children:"the Company fails to comply with a binding decision of a competent court or the competent supervisory authority/ies regarding its obligations pursuant to this Agreement or to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725."})]})]}),(0,a.jsx)("li",{children:"The Company shall be entitled to terminate the contract insofar as it concerns processing of personal data under this Agreement where, after having informed the Merchant that its instructions infringe applicable legal requirements in accordance with clause 7.1 (b), the Merchant insists on compliance with the instructions."})]})]})]}),(0,a.jsxs)("section",{children:[(0,a.jsxs)(b,{heading:"Exhibit I: Description of the processing",children:[(0,a.jsx)("h4",{children:"Categories of data subjects whose personal data is processed"}),(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"Users of Merchant"}),(0,a.jsx)("li",{children:"Employees of Merchant"}),(0,a.jsx)("li",{children:"Director, authorized persons and beneficial owners of Merchant"})]}),(0,a.jsx)("h4",{children:"Categories of personal data processed"}),(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"payment method information;"}),(0,a.jsx)("li",{children:"payment card details;"}),(0,a.jsx)("li",{children:"crypto wallet address details (if applicable depending on the nature of the Principal Agreement);"}),(0,a.jsx)("li",{children:"proof of payments;"}),(0,a.jsx)("li",{children:"information regarding transactions carried out in the Merchant’s website, such as volume, approval, chargeback and cancellation index;"}),(0,a.jsx)("li",{children:"unique wallet address in the System;"}),(0,a.jsx)("li",{children:"information sent by or associated with the device(s) used to access Merchant’s website, such as users device’s IP address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for user mobile device;"}),(0,a.jsx)("li",{children:"full name;"}),(0,a.jsx)("li",{children:"contact data (email, mobile number, messenger account nickname);"}),(0,a.jsx)("li",{children:"copy of a valid passport or ID of the beneficial owners (ownerships more than 25%), directors and authorized signatory;"}),(0,a.jsx)("li",{children:"utility bill (bank statement) as a proof of residence of beneficial owners (ownerships more than 25%), directors and authorized signatory;"}),(0,a.jsx)("li",{children:"document proving relation to the Merchant legal entity (share certificate, certificate of incumbency, resolution of director appointment, Register of Directors and Officers, Register of Shareholders, Minutes of a meeting of the Board of Directors or Power of Attorney giving the Authorized Signatory the authority to open and manage the account, A signed beneficial ownership structure chart etc);"}),(0,a.jsx)("li",{children:"liveness check data of the authorized person and director;"}),(0,a.jsx)("li",{children:"Recent bank statement of the corporate account."})]}),(0,a.jsx)("h4",{children:"Sensitive data processed (if applicable) and applied restrictions or safeguards that fully take into consideration the nature of the data and the risks involved, such as for instance strict purpose limitation, access restrictions (including access only for staff having followed specialised training), keeping a record of access to the data, restrictions for onward transfers or additional security measures."}),(0,a.jsx)("p",{children:"No special categiroes of data is processed. The payment data is processed with regard to the technical and organisational measures as described in the Exhibit II."}),(0,a.jsx)("h4",{children:"Nature of the processing"}),(0,a.jsx)("p",{children:"collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer, blocking, deletion, destruction of personal data;"}),(0,a.jsx)("h4",{children:"Purpose(s) for which the personal data is processed on behalf of the Controller"}),(0,a.jsx)("p",{children:"As a Data Processor on behalf of the Merchant, Company may process Personal Data for the following purposes:"}),(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"to provide the Services, including, but not limited to activities related to payment processing, reversals, and refunds of transactions;"}),(0,a.jsx)("li",{children:"to perform the obligations provided in the Agreement;"}),(0,a.jsx)("li",{children:"to monitor, prevent and detect frauds and security threats;"}),(0,a.jsx)("li",{children:"to verify payment’s authenticity;"}),(0,a.jsx)("li",{children:"to prevent harm to the Merchant, the Company and/or third parties;"}),(0,a.jsx)("li",{children:"to respond to User and Merchant support request;"}),(0,a.jsx)("li",{children:"to host and maintain data and systems;"}),(0,a.jsx)("li",{children:"otherwise to fulfill the obligations set out in the Agreement."})]}),(0,a.jsx)("h4",{children:"Duration of the processing"}),(0,a.jsx)("p",{children:"The term of the Agreement plus the retention term as required by the Applicable laws."}),(0,a.jsx)("h4",{children:"For processing by sub-processors, also specify subject matter, nature and duration of the processing"}),(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"Data storage and techinal maintenance (storage, recording, transfer; processing during the term of the Agreement);"}),(0,a.jsx)("li",{children:"Payment processing (use, transfer;

1 processing during the period of the operation);"}),(0,a.jsx)("li",{children:"Customer support (Ticket system) (recording, storage, transfer, use; processing within the period established by law for the storage of communication with the Company's client);"})]})]}),(0,a.jsxs)(b,{heading:"Exhibit II. Technical and organisational measures including technical and organisational measures to ensure the security of the data",children:[(0,a.jsx)("h4",{children:"Measures of pseudonymisation and encryption of personal data"}),(0,a.jsx)("p",{children:"Each user and transaction in the system database has a unique identifier that pseudonymizes them. The users' personal data is stored in a separate table from the transaction log. Using the SafeNet Luna HSM hardware encryption module, they are encrypted with different keys."}),(0,a.jsx)("h4",{children:"Measures for ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services"}),(0,a.jsx)("p",{children:"All the information necessary for the operation of the system is stored in encrypted form using different keys in a separate location. Two certified hosting services in the Netherlands (Serverius), Germany (Hetzner) and a distributed cloud solution from Amazon (AWS) are used for storage."}),(0,a.jsx)("h4",{children:"Measures for ensuring the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident"}),(0,a.jsx)("p",{children:"In addition to the use of two redundant encrypted data storage and the use of distributed cloud solutions from the industry leader AW

1S, all data, encrypted, with a certain periodicity, is stored in an encrypted backup storage with a version control system (hourly, weekly, monthly); thus double encryption is achieved. Data can be retrieved at any time in the event of technical failures, even if they are extremely unlikely."}),(0,a.jsx)("h4",{children:"Processes for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures in order to ensure the security of the processing"}),(0,a.jsx)("p",{children:"The software development of the system requires that each edit before being included in the module code be subject to CodeReview (checked by others or by a group of developers). After being included in the code of the module, it undergoes local testing using both automatic and manual tests. After successful testing, the application code is sent to a dedicated test server and is tested there as well. The compiled application will only go to the Product server after going through all the stages. To automate and manage testing, a solution from qameta.io is used."}),(0,a.jsx)("h4",{children:"Measures for user identification and authorisation"}),(0,a.jsx)("p",{children:"Access to designated systems and customer data is limited to personnel for whom access is required based on job function. Employees who have access to systems in which personal data is stored are granted access using unique accounts assigned to a specific employee. To access the system, a login and a unique password are required, as well as a two-factor authentication method. If the token is entered incorrectly, access is blocked. Employees have different levels of access depending on their job responsibilities. Access to all systems is deleted or suspended upon termination of employment."}),(0,a.jsx)("h4",{children:"Measures for the protection of data during transmission"}),(0,a.jsx)("p",{children:"All employees work through secure communication channels, with encryption occurring at several levels, at the network connection level (using VPN) and at the session level (using SSL, HTTPS). The traffic is encrypted using SSL and strict restrictions on connections to IP addresses are set when interacting with providers or clients of other services."}),(0,a.jsx)("h4",{children:"Measures for the protection of data during storage"}),(0,a.jsx)("p",{children:"Information is stored in a comprehensible encrypted form in different locations. The company will introduce a trade secret regime and the principle of the minimum possible access, so employees get access only to the information that is necessary to solve their professional duty tasks."}),(0,a.jsx)("h4",{children:"Measures for ensuring physical security of locations at which personal data are processed"}),(0,a.jsx)("p",{children:"Employees with access to protected information work in protected premises with an installed access control and management system and a video surveillance system."}),(0,a.jsx)("h4",{children:"Measures for ensuring events logging"}),(0,a.jsx)("p",{children:"Information system logging is built on several levels:"}),(0,a.jsxs)("ol",{"data-counter-decoration":"dot","data-bullets":"lower-latin",children:[(0,a.jsx)("li",{children:"Logging at the operating system and hardware and software services levels. The operating system and services running on the server keep logs that reflect the state and changes in the hardware, software, and infrastructure parts."}),(0,a.jsx)("li",{children:"Logging actions of back office operators - logs of actions of support service operators, employees of departments that have access to protected information."}),(0,a.jsx)("li",{children:"System users' actions are logged - logging into the system (environment fingerprints, IP addresses, time zones), actions performed within the system, and interactions with external providers."})]}),(0,a.jsx)("h4",{children:"Measures for ensuring system configuration, including default configuration"}),(0,a.jsx)("p",{children:"The Company ensures a secure configuration of the service environment by using automated, repeatable and well-defined baseline standards when deploying and updating environments using industry leading infrastru

1cture as code software tooling."}),(0,a.jsx)("h4",{children:"Measures for internal IT and IT security governance and management"}),(0,a.jsx)("p",{children:"The Company ensures effective internal IT and IT security governance and management by implementing an information security management program. The IT department is separated from the IT security department. They are managed by different people and pursue different goals, resulting in a conflict of interest and mutual control."}),(0,a.jsx)("h4",{children:"Measures for certification/assurance of processes and products"}),(0,a.jsx)("p",{children:"The Company align with PCI-DSS security standards level 3 to implement solutions that meet the modern requirements of the standards of financial organizations. The compliance is verified and certified by TrustWave (https://www.trustwave.com)"}),(0,a.jsx)("h4",{children:"Measures for ensuring data minimisation"}),(0,a.jsx)("p",{children:"The Company ensures data minimisation by processing only that data which is relevant and necessary for the provision of the service. The Company implementated the internal procedures based on the assessment and analysis of the proportionality data collection as necessary to the service performance."}),(0,a.jsx)("h4",{children:"Measures for ensuring data quality"}),(0,a.jsx)("p",{children:"For data which is available to the Company within its systems, DataStax ensures data quality by ensuring such details are up to date, reviewing data regularly and following data deletion practices."}),(0,a.jsx)("h4",{children:"Measures for ensuring limited data retention"}),(0,a.jsx)("p",{children:"The Company defines in the internal Data renetion policy a timeframe to the data retention for each category of data. Different sets of data in database are market with the defined retention term and thus are deleted automatically upon the term expiration."}),(0,a.jsx)("h4",{children:"Measures for ensuring accountability"}),(0,a.jsx)("p",{children:"The Company ensures accountability through the logging of access activity. Logs are retained for defined periods and can be reviewed to ensure that any access is proportionate and appropriate. The Company maintains the Register of processing activities, maintain an Internal privacy policy and procedures, conducts a DPIA when necessary."}),(0,a.jsx)("h4",{children:"Measures for allowing data portability and ensuring erasure"}),(0,a.jsx)("p",{children:"Due to the nature of the processing and the categories of data, the data portability right cannot be enacted regarding the said processing. In accordance with the WP29 Guidelines on the right to data portability, there is no obligation for financial institutions to answer a data portability request regarding personal data processed as part of their obligations to prevent and detect money laundering and other financial crimes."}),(0,a.jsx)("h4",{children:"For transfers to (sub-) processors, also describe the specific technical and organisational measures to be taken by the (sub-) processor to be able to provide assistance to the Controller."}),(0,a.jsx)("p",{children:"The Processor undertakes to ensure that the involved subprocessors provide a level of protection not lower than that established by this Agreement."}),(0,a.jsx)("h4",{children:"Description of the specific technical and organisational measures to be taken by the processor to be able to provide assistance to the Controller."}),(0,a.jsx)("p",{children:"The Company ensures assistance to the Merchant to comply with any data subject or regulatory requests by providing the ability for the data within the service to be easily exported into an industry standard data format such as a CSV file by the Merchant."})]}),(0,a.jsxs)(b,{heading:"Exhibit III: List of sub-processors",children:[(0,a.jsx)("p",{children:"The Controller has authorised the use of the following sub-processors:"}),(0,a.jsxs)("ol",{"data-bullets":"decimal","data-counter-decoration":"dot",children:[(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Name:"})," Motaev Marx Motaev GbR (Questionstar)",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Address:"})," Vahrenwalder Str. 253, 30179 Hanover, Germany",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"E-mail:"})," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",children:"[email protected]"}),(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Description of the processing:"})," Engaging subprocessor to perform online surveys."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Name:"})," IPQualityScore LLC",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Address:"})," Las Vegas, Nevada USA",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"E-mail:"})," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",children:"[email protected]"}),(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Description of processing:"})," traffic data analysys aimed to fraud prevention, using a tool that enable bot detection and user screening to prevent fake accounts, chargebacks, & malicious users without interrupting the user experience."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Name:"})," FDC Servers.net LLC (“FDC”)",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Email:"})," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",children:"[email protected]"}),(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Representative in EU is:"})," Agency Delfa Bri Jaronku 5217 Zlin, 760 01 Czech republic",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Descrition of the processing:"})," data transmission via proxy server for the security reasons."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Name:"})," Serverius (Holding) B.V.,",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Email:"})," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",children:"[email protected]"}),(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Description of processing:"})," data transmission through web hosting."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Name:"})," Hetzner Hetzner Online GmbH",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Address:"})," Industriestr 25, 91710 Gunzenhausen, Germany",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Email:"})," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",children:"[email protected]"}),(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Description of the processing:"})," data storage at the bare metal server."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Name:"})," OVH US LLC dba OVHcloud",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Address:"})," 11950 Democracy Drive, Suite 300, Reston, VA 20191",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Email:"})," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",children:"[email protected]"}),(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Description of the processing:"})," VPS and Bare metal server hosting"]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Name:"})," Microsoft Office",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Address:"})," Microsoft Ireland Operations Limited, Attn: Data Protection Officer, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland.",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Description of processing:"})," intra-group processing using Microsoft offie solutions, cloud storage."]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Name:"})," Google LLC",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Address:"}

1)," 1600 Amphitheatre Parkway, Mountain View, California 94043, USA",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Description of processing:"})," google tag manager used for user activities on the website analytics, marketing campaign effectivness, etc.; Google Analytics cookies used to analyse user’s activities on the website"]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Name:"})," Amazon Web Services, Inc",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Address:"})," P.O. Box 81226, Seattle, WA 98108.",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Description of processing:"})," Cloud database storage"]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Name:"})," Imperva, Inc.",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Address:"})," One Curiosity Way, Suite 203, San Mateo, CA 94403",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Email:"})," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",children:"[email protected]"}),(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Description of data processing:"})," data transmission through firewall"]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Name:"})," Zendesk, Inc.",(0,a.jsx)("br",{})," ",(0,a.jsx)("strong",{children:"Email:"})," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",children:"[email protected]"}),".",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Description of data processing:"})," data processing due to communication with users via ticket systems"]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Name:"})," Sum and Substance Ltd (UK)",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Address:"})," 30 St. Mary Axe, London, England, EC3A 8BF",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Description of processing:"})," liveness test and ID documents verification in order to combat fraud and misconduct"]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Name:"})," Usercentrics A/S (Cookiebot)",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Address:"})," Havnegade 39, 1058 Copenhagen, Denmark"," ",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"E-mail:"})," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",children:"[email protected]"}),(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Description of processing:"})," management of cookies setting on the website"]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Name:"})," Intertech Services AG (Yandex Metrica)",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Address:"})," Werftestrasse 4, 6005 Luzern, Switzerland",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Description of processing:"})," use of cookies to analyse user’s activities on the website"]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Name:"})," Cloudflare Portugal, Unipessoal Lda.",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Address:"})," Largo Rafael Bordalo Pinheiro 29, 1200-369 Lisboa",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Email:"})," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",children:"[email protected]"}),(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Description of processing:"})," data transmission, content delivery network services, cloud cybersecurity, DDoS mitigation"]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Name:"})," PostHog Inc.",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Address:"})," 2261 Market Street #4008, San Francisco, CA 94114",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Description of processing:"})," collection and analysis of user behavior without creating the individual profiles"]})]})]}),(0,a.jsxs)(b,{heading:"Exhibit IV",children:[(0,a.jsx)("p",{children:"To the Data Processing Agreement"}),(0,a.jsxs)("p",{children:["STANDARD CONTRACTUAL CLAUSES",(0,a.jsx)("br",{}),"Module 2: controller to processor"]})]})]}),(0,a.jsxs)("section",{children:[(0,a.jsxs)(b,{heading:"Section I",children:[(0,a.jsx)("h2",{children:"Purpose and scope"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"The purpose of these standard contractual clauses is to ensure compliance with the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation) for the transfer of personal data to a third country."}),(0,a.jsxs)("li",{children:["The Parties:",(0,a.jsxs)("ol",{"data-bullets":"lower-roman","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"the natural or legal person(s), public authority/ies, agency/ies or other body/ies (hereinafter “entity/ies”) transferring the personal data, as listed in Annex I.A. (hereinafter each “data exporter”), and"}),(0,a.jsx)("li",{children:"the entity/ies in a third country receiving the personal data from the data exporter, directly or indirectly via another entity also Party to these Clauses, as listed in Annex I.A. (hereinafter each “data importer”) have agreed to these standard contractual clauses (hereinafter: “Clauses”)."})]})]}),(0,a.jsx)("li",{children:"These Clauses apply with respect to the transfer of personal data as specified in Annex I.B."}),(0,a.jsx)("li",{children:"The Appendix to these Clauses containing the Annexes referred to therein forms an integral part of these Clauses."})]}),(0,a.jsx)("h2",{children:"Effect and invariability of the Clauses"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"These Clauses set out appropriate safeguards, including enforceable data subject rights and effective legal remedies, pursuant to Article 46(1) and Article 46 (2)(c) of Regulation (EU) 2016/679 and, with respect to data transfers from controllers to processors and/or processors to processors, standard contractual clauses pursuant to Article 28

1(7) of Regulation (EU) 2016/679, provided they are not modified, except to select the appropriate Module(s) or to add or update information in the Appendix. This does not prevent the Parties from including the standard contractual clauses laid down in these Clauses in a wider contract and/or to add other clauses or additional safeguards, provided that they do not contradict, directly or indirectly, these Clauses or prejudice the fundamental rights or freedoms of data subjects."}),(0,a.jsx)("li",{children:"These Clauses are without prejudice to obligations to which the data exporter is subject by virtue of Regulation (EU) 2016/679."})]}),(0,a.jsx)("h2",{children:"Third-party beneficiaries"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsxs)("li",{children:["Data subjects may invoke and enforce these Clauses, as third-party beneficiaries, against the data exporter and/or data importer, with the following exceptions:",(0,a.jsxs)("ol",{"data-bullets":"lower-roman","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"Clause 1, Clause 2, Clause 3, Clause 6, Clause 7;"}),(0,a.jsx)("li",{children:"Clause 8 - Module One: Clause 8.5 (e) and Clause 8.9(b); Module Two: Clause 8.1(b), 8.9(a), (c), (d) and (e); Module Three: Clause 8.1(a), (c) and (d) and Clause 8.9(a), (c), (d), (e), (f) and (g); Module Four: Clause 8.1 (b) and Clause 8.3(b);"}),(0,a.jsx)("li",{children:"Clause 9 - Module Two: Clause 9(a), (c), (d) and (e); Module Three: Clause 9(a), (c), (d) and (e);"}),(0,a.jsx)("li",{children:"Clause 12 - Module One: Clause 12(a) and (d); Modules Two and Three: Clause 12(a), (d) and (f);"}),(0,a.jsx)("li",{children:"Clause 13;"}),(0,a.jsx)("li",{children:"Clause 15.1(c), (d) and (e);"}),(0,a.jsx)("li",{children:"Clause 16(e);"}),(0,a.jsx)("li",{children:"Clause 18 - Modules One, Two and Three: Clause 18(a) and (b); Module Four: Clause 18."})]})]}),(0,a.jsx)("li",{children:"Paragraph (a) is without prejudice to rights of data subjects under Regulation (EU) 2016/679."})]}),(0,a.jsx)("h2",{children:"Interpretation"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"Where these Clauses use terms that are defined in Regulation (EU) 2016/679, those terms shall have the same meaning as in that Regulation."}),(0,a.jsx)("li",{children:"These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679."}),(0,a.jsx)("li",{children:"These Clauses shall not be interpreted in a way that conflicts with rights and obligations provided for in Regulation (EU) 2016/679."})]}),(0,a.jsx)("h2",{children:"Hierarchy"}),(0,a.jsx)("p",{children:"In the event of a contradiction between these Clauses and the provisions of related agreements between the Parties, existing at the time these Clauses are agreed or entered into thereafter, these Clauses shall prevail."}),(0,a.jsx)("h2",{children:"Description of the transfer(s)"}),(0,a.jsx)("p",{children:"The details of the transfer(s), and in particular the categories of personal data that are transferred and the purpose(s) for which they are transferred, are specified in Annex I.B."}),(0,a.jsx)("h2",{children:"Docking clause"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"An entity that is not a Party to these Clauses may, with the agreement of the Parties, accede to these Clauses at any time, either as a data exporter or as a data importer, by completing the Appendix and signing Annex I.A."}),(0,a.jsx)("li",{children:"Once it has completed the Appendix and signed Annex I.A, the acceding entity shall become a Party to these Clauses and have the rights and obligations of a data exporter or data importer in accordance with its designation in Annex I.A."}),(0,a.jsx)("li",{children:"The acceding entity shall have no rights or obligations arising under these Clauses from the period prior to becoming a Party."})]})]}),(0,a.jsxs)(b,{heading:"Section II – Obligations of the parties",children:[(0,a.jsx)("h2",{children:"Data protection safeguards"}),(0,a.jsx)("p",{children:"The data exporter warrants that it has used reasonable efforts to determine that the data importer is able, through the implementation of appropriate technical and organisational measures, to satisfy its obligations under these Clauses."}

1),(0,a.jsx)("h3",{"data-sub-counter":!0,children:"Instructions"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"The data importer shall process the personal data only on documented instructions from the data exporter. The data exporter may give such instructions throughout the duration of the contract."}),(0,a.jsx)("li",{children:"The data importer shall immediately inform the data exporter if it is unable to follow those instructions."})]}),(0,a.jsx)("h3",{"data-sub-counter":!0,children:"Purpose limitation"}),(0,a.jsx)("p",{children:"The data importer shall process the personal data only for the specific purpose(s) of the transfer, as set out in Annex I.B, unless on further instructions from the data exporter."}),(0,a.jsx)("h3",{"data-sub-counter":!0,children:"Transparency"}),(0,a.jsx)("p",{children:"On request, the data exporter shall make a copy of these Clauses, including the Appendix as completed by the Parties, available to the data subject free of charge. To the extent necessary to protect business secrets or other confidential information, including the measures described in Annex II and personal data, the data exporter may redact part of the text of the Appendix to these Clauses prior to sharing a copy, but shall provide a meaningful summary where the data subject would otherwise not be able to understand the its content or exercise his/her rights. On request, the Parties shall provide the data subject with the reasons for the redactions, to the extent possible without revealing the redacted information. This Clause is without prejudice to the obligations of the data exporter under Articles 13 and 14 of Regulation (EU) 2016/679."}),(0,a.jsx)("h3",{"data-sub-counter":!0,children:"Accuracy"}),(0,a.jsx)("p",{children:"If the data importer becomes aware that the personal data it has received is inaccurate, or has become outdated, it shall inform the data exporter without undue delay. In this case, the data importer shall cooperate with the data exporter to erase or rectify the data."}),(0,a.jsx)("h3",{"data-sub-counter":!0,children:"Duration of processing and erasure or return of data"}),(0,a.jsx)("p",{children:"Processing by the data importer shall only take place for the duration specified in Annex I.B. After the end of the provision of the processing services, the data importer shall, at the choice of the data exporter, delete all personal data processed on behalf of the data exporter and certify to the data exporter that it has done so, or return to the data exporter all personal data processed on its behalf and delete existing copies. Until the data is deleted or returned, the data importer shall continue to ensure compliance with these Clauses. In case of local laws applicable to the data importer that prohibit return or deletion of the personal data, the data importer warrants that it will continue to ensure compliance with these Clauses and will only process it to the extent and for as long as required under that local law. This is without prejudice to Clause 14, in particular the requirement for the data importer under Clause 14(e) to notify the data exporter throughout the duration of the contract if it has reason to believe that it is or has become subject to laws or practices not in line with the requirements under Clause 14(a)."}),(0,a.jsx)("h3",{"data-sub-counter":!0,children:"Security of processing"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"The data importer and, during transmission, also the data exporter shall implement appropriate technical and organisational measures to ensure the security of the data, including protection against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to that data (hereinafter “personal data breach”). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purpose(s) of processing and the risks involved in the processing for the data subjects. The Parties shall in particular consider having recourse to encryption or pseudonymisation, including during transmission, where the purpose of processing can be fulfilled 

1in that manner. In case of pseudonymisation, the additional information for attributing the personal data to a specific data subject shall, where possible, remain under the exclusive control of the data exporter. In complying with its obligations under this paragraph, the data importer shall at least implement the technical and organisational measures specified in Annex II. The data importer shall carry out regular checks to ensure that these measures continue to provide an appropriate level of security."}),(0,a.jsx)("li",{children:"The data importer shall grant access to the personal data to members of its personnel only to the extent strictly necessary for the implementation, management and monitoring of the contract. It shall ensure that persons authorised to process the personal data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality."}),(0,a.jsx)("li",{children:"In the event of a personal data breach concerning personal data processed by the data importer under these Clauses, the data importer shall take appropriate measures to address the breach, including measures to mitigate its adverse effects. The data importer shall also notify the data exporter without undue delay after having become aware of the breach. Such notification shall contain the details of a contact point where more information can be obtained, a description of the nature of the breach (including, where possible, categories and approximate number of data subjects and personal data records concerned), its likely consequences and the measures taken or proposed to address the breach including, where appropriate, measures to mitigate its possible adverse effects. Where, and in so far as, it is not possible to provide all information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay."}),(0,a.jsx)("li",{children:"The data importer shall cooperate with and assist the data exporter to enable the data exporter to comply with its obligations under Regulation (EU) 2016/679, in particular to notify the competent supervisory authority and the affected data subjects, taking into account the nature of processing and the information available to the data importer."})]}),(0,a.jsx)("h3",{"data-sub-counter":!0,children:"Sensitive data"}),(0,a.jsx)("p",{children:"Where the transfer involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions and offences (hereinafter “sensitive data”), the data importer shall apply the specific restrictions and/or additional safeguards described in Annex I.B."}),(0,a.jsx)("h3",{"data-sub-counter":!0,children:"Onward transfers"}),(0,a.jsx)("p",{children:"The data importer shall only disclose the personal data to a third party on documented instructions from the data exporter. In addition, the data may only be disclosed to a third party located outside the European Union (in the same country as the data importer or in another third country, hereinafter “onward transfer”) if the third party is or agrees to be bound by these Clauses, under the appropriate Module, or if:"}),(0,a.jsxs)("ol",{"data-bullets":"lower-roman","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"the onward transfer is to a country benefitting from an adequacy decision pursuant to Article 45 of Regulation (EU) 2016/679 that covers the onward transfer;"}),(0,a.jsx)("li",{children:"the third party otherwise ensures appropriate safeguards pursuant to Articles 46 or 47 Regulation of (EU) 2016/679 with respect to the processing in question;"}),(0,a.jsx)("li",{children:"the onward transfer is necessary for the establishment, exercise or defence of legal claims in the context of specific administrative, regulatory or judicial proceedings; or"}),(0,a.jsx)("li",{children:"the onward transfer is necessary in order to protect the vital interests of the data subject or of another natural person."})]}),(0,a.jsx)("p",{children:"Any onward transfer is subject to compliance by the data importer with all the other safeguards under these Clauses, in particular purpose limitation."}

1),(0,a.jsx)("h3",{"data-sub-counter":!0,children:"Documentation and compliance"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"The data importer shall promptly and adequately deal with enquiries from the data exporter that relate to the processing under these Clauses."}),(0,a.jsx)("li",{children:"The Parties shall be able to demonstrate compliance with these Clauses. In particular, the data importer shall keep appropriate documentation on the processing activities carried out on behalf of the data exporter."}),(0,a.jsxs)("li",{children:[(0,a.jsx)("p",{children:"The data importer shall make available to the data exporter all information necessary to demonstrate compliance with the obligations set out in these Clauses and at the data exporter’s request, allow for and contribute to audits of the processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance."}),(0,a.jsx)("p",{children:"In deciding on a review or audit, the data exporter may take into account relevant certifications held by the data importer."})]}),(0,a.jsx)("li",{children:"The data exporter may choose to conduct the audit by itself or mandate an independent auditor. Audits may include inspections at the premises or physical facilities of the data importer and shall, where appropriate, be carried out with reasonable notice."}),(0,a.jsx)("li",{children:"The Parties shall make the information referred to in paragraphs (b) and (c), including the results of any audits, available to the competent supervisory authority on request."})]}),(0,a.jsx)("h2",{children:"Use of sub-processors"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"The data importer has the data exporter’s general authorisation for the engagement of sub-processor(s) from an agreed list. The data importer shall specifically inform the data exporter in writing of any intended changes to that list through the addition or replacement of sub-processors at least 15 days in advance, thereby giving the data exporter sufficient time to be able to object to such changes prior to the engagement of the sub-processor(s). The data importer shall provide the data exporter with the information necessary to enable the data exporter to exercise its right to object."}),(0,a.jsx)("li",{children:"Where the data importer engages a sub-processor to carry out specific processing activities (on behalf of the data exporter), it shall do so by way of a written contract that provides for, in substance, the same data protection obligations as those binding the data importer under these Clauses, including in terms of third-party beneficiary rights for data subjects. The Parties agree that, by complying with this Clause, the data importer fulfils its obligations under Clause 8.8. The data importer shall ensure that the sub-processor complies with the obligations to which the data importer is subject pursuant to these Clauses."}),(0,a.jsx)("li",{children:"The data importer shall provide, at the data exporter’s request, a copy of such a sub-processor agreement and any subsequent amendments to the data exporter. To the extent necessary to protect business secrets or other confidential information, including personal data, the data importer may redact the text of the agreement prior to sharing a copy."}),(0,a.jsx)("li",{children:"The data importer shall remain fully responsible to the data exporter for the performance of the sub-processor’s obligations under its contract with the data importer. The data importer shall notify the data exporter of any failure by the sub-processor to fulfil its obligations under that contract."}),(0,a.jsx)("li",{children:"The data importer shall agree a third-party beneficiary clause with the sub-processor whereby - in the event the data importer has factually disappeared, ceased to exist in law or has become insolvent - the data exporter shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data."})]}),(0,a.jsx)("h2",{children:"Data subject rights"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"The data importer shall promptly notify the data exporter of any request it has received from a data subject. It shall not respond to that request itself unless it has been authorised to do so by the data exporter."}),(0,a.jsx)("li",{children:"The data importer shall assist the data exporter in fulfilling its obligations to respond to data subjects’ requests for the exercise of their rights under Regulation (EU) 2016/679. In this regard, the Parties shall set out in Annex II the appropriate technical and organisational measures, taking into account the nature of the processing, by which the assistance shall be provided, as well as the scope and the extent of the assistance required."}),(0,a.jsx)("li",{children:"In fulfilling its obligations under paragraphs (a) and (b), the data importer shall comply with the instructions from the data exporter."})]}),(0,a.jsx)("h2",{children:"Redress"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"The data importer shall inform data subjects in a transparent and easily accessible format, through individual notice or on its website, of a contact point authorised to handle complaints. It shall deal promptly with any complaints it receives from a data subject."}),(0,a.jsx)("li",{children:"In case of a dispute between a data subject and one of the Parties as regards compliance with these Clauses, that Party shall use its best efforts to resolve the issue amicably in a timely fashion. The Parties shall keep each other informed about such disputes and, where appropriate, cooperate in resolving them."}),(0,a.jsxs)("li",{children:["Where the data subject invokes a third-party beneficiary right pursuant to Clause 3, the data importer shall accept the decision of the data subject to:",(0,a.jsxs)("ol",{"data-bullets":"lower-roman","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"lodge a complaint with the supervisory authority in the Member State of his/her habitual residence or place of work, or the competent supervisory authority pursuant to Clause 13;"}),(0,a.jsx)("li",{children:"refer the dispute to the competent c

1ourts within the meaning of Clause 18."})]})]}),(0,a.jsx)("li",{children:"The Parties accept that the data subject may be represented by a not-for-profit body, organisation or association under the conditions set out in Article 80(1) of Regulation (EU) 2016/679."}),(0,a.jsx)("li",{children:"The data importer shall abide by a decision that is binding under the applicable EU or Member State law."}),(0,a.jsx)("li",{children:"The data importer agrees that the choice made by the data subject will not prejudice his/her substantive and procedural rights to seek remedies in accordance with applicable laws."})]}),(0,a.jsx)("h2",{children:"Liability"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"Each Party shall be liable to the other Party/ies for any damages it causes the other Party/ies by any breach of these Clauses."}),(0,a.jsx)("li",{children:"The data importer shall be liable to the data subject, and the data subject shall be entitled to receive compensation, for any material or non-material damages the data importer or its sub-processor causes the data subject by breaching the third-party beneficiary rights under these Clauses."}),(0,a.jsx)("li",{children:"Notwithstanding paragraph (b), the data exporter shall be liable to the data subject, and the data subject shall be entitled to receive compensation, for any material or non-material damages the data exporter or the data importer (or its sub-processor) causes the data subject by breaching the third-party beneficiary rights under these Clauses. This is without prejudice to the liability of the data exporter and, where the data exporter is a processor acting on behalf of a controller, to the liability of the controller under Regulation (EU) 2016/679 or Regulation (EU) 2018/1725, as applicable."}),(0,a.jsx)("li",{children:"The Parties agree that if the data exporter is held liable under paragraph (c) for damages caused by the data importer (or its sub-processor), it shall be entitled to claim back from the data importer that part of the compensation corresponding to the data importer’s responsibility for the damage."}),(0,a.jsx)("li",{children:"Where more than one Party is responsible for any damage caused to the data subject as a result of a breach of these Clauses, all responsible Parties shall be jointly and severally liable and the data subject is entitled to bring an action in court against any of these Parties."}),(0,a.jsx)("li",{children:"The Parties agree that if one Party is held liable under paragraph (e), it shall be entitled to claim back from the other Party/ies that part of the compensation corresponding to its / their responsibility for the damage."}),(0,a.jsx)("li",{children:"The data importer may not invoke the conduct of a sub-processor to avoid its own liability."})]}),(0,a.jsx)("h2",{children:"Supervision"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsxs)("li",{children:[(0,a.jsx)("p",{children:"Where the data exporter is established in an EU Member State: The supervisory authority with responsibility for ensuring compliance by the data exporter with Regulation (EU) 2016/679 as regards the data transfer, as indicated in Annex I.C, shall act as competent supervisory authority."}),(0,a.jsx)("p",{children:"Where the data exporter is not established in an EU Member State, but falls within the territorial scope of application of Regulation (EU) 2016/679 in accordance with its Article 3(2) and has appointed a representative pursuant to Article 27(1) of Regulation (EU) 2016/679: The supervisory authority of the Member State in which the representative within the meaning of Article 27(1) of Regulation (EU) 2016/679 is established, as indicated in Annex I.C, shall act as competent supervisory authority."}),(0,a.jsx)("p",{children:"Where the data exporter is not established in an EU Member State, but falls within the territorial scope of application of Regulation (EU) 2016/679 in accordance with its Article 3(2) without however having to appoint a representative pursuant to Article 27(2) of Regulation (EU) 2016/679: The supervisory authority of one of the Member States in which the data subjects whose personal data is transferred under these Clauses in relation to the offering of goods or services to them, or whose behaviour is monitored, are located, as indicated in Annex I.C, shall act as competent supervisory authority."})]}),(0,a.jsx)("li",{children:"The data importer agrees to submit itself to the jurisdiction of and cooperate with the competent supervisory authority in any procedures aimed at ensuring compliance with these Clauses. In particular, the data importer agrees to respond to enquiries, submit to audits and comply with the measures adopted by the supervisory authority, including remedial and compensatory measures. It shall provide the supervisory authority with written confirmation that the necessary actions have been taken."})]})]}),(0,a.jsxs)(b,{heading:"Section III – Local laws and obligations in case of access by public authorities",children:[(0,a.jsx)("h2",{children:"Local laws and practices affecting compliance with the Clauses"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"The Parties warrant that they have no reason to believe that the laws and practices in the third country of destination applicable to the processing of the personal data by the data importer, including any requirements to disclose personal data or measures authorising access by public authorities, prevent the data importer from fulfilling its obligations under these Clauses. This is based on the understanding that laws and practices that respect the essence of the fundamental rights and freedoms and do not exceed what is necessary and proportionate in a democratic society to safeguard one of the objectives listed in Article 23(1) of Regulation (EU) 2016/679, are not in contradiction with these Clauses."}),(0,a.jsxs)("li",{children:["The Parties declare that in providing the warranty in paragraph (a), they have taken due account in particular of the following elements:",(0,a.jsxs)("ol",{"data-bullets":"lower-roman","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"the specific circumstances of the transfer, including the length of the processing chain, the number of actors involved and the transmission channels used; intended onward transfers; the type of recipient; the purpose of processing; the categories and format of the transferred personal data;

1 the economic sector in which the transfer occurs; the storage location of the data transferred;"}),(0,a.jsx)("li",{children:"the laws and practices of the third country of destination– including those requiring the disclosure of data to public authorities or authorising access by such authorities – relevant in light of the specific circumstances of the transfer, and the applicable limitations and safeguards;"}),(0,a.jsx)("li",{children:"any relevant contractual, technical or organisational safeguards put in place to supplement the safeguards under these Clauses, including measures applied during transmission and to the processing of the personal data in the country of destination."})]})]}),(0,a.jsx)("li",{children:"The data importer warrants that, in carrying out the assessment under paragraph (b), it has made its best efforts to provide the data exporter with relevant information and agrees that it will continue to cooperate with the data exporter in ensuring compliance with these Clauses."}),(0,a.jsx)("li",{children:"The Parties agree to document the assessment under paragraph (b) and make it available to the competent supervisory authority on request."}),(0,a.jsx)("li",{children:"The data importer agrees to notify the data exporter promptly if, after having agreed to these Clauses and for the duration of the contract, it has reason to believe that it is or has become subject to laws or practices not in line with the requirements under paragraph (a), including following a change in the laws of the third country or a measure (such as a disclosure request) indicating an application of such laws in practice that is not in line with the requirements in paragraph (a)."}),(0,a.jsx)("li",{children:"Following a notification pursuant to paragraph (e), or if the data exporter otherwise has reason to believe that the data importer can no longer fulfil its obligations under these Clauses, the data exporter shall promptly identify appropriate measures (e.g. technical or organisational measures to ensure security and confidentiality) to be adopted by the data exporter and/or data importer to address the situation. The data exporter shall suspend the data transfer if it considers that no appropriate safeguards for such transfer can be ensured, or if instructed by the competent supervisory authority to do so. In this case, the data exporter shall be entitled to terminate the contract, insofar as it concerns the processing of personal data under these Clauses. If the contract involves more than two Parties, the data exporter may exercise this right to termination only with respect to the relevant Party, unless the Parties have agreed otherwise. Where the contract is terminated pursuant to this Clause, Clause 16(d) and (e) shall apply."})]}),(0,a.jsx)("h2",{children:"Obligations of the data importer in case of access by public authorities"}),(0,a.jsx)("h3",{"data-sub-counter":!0,children:"Notification"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsxs)("li",{children:["The data importer agrees to notify the data exporter and, where possible, the data subject promptly (if necessary with the help of the data exporter) if it:",(0,a.jsxs)("ol",{"data-bullets":"lower-roman","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"receives a legally binding request from a public authority, including judicial authorities, under the laws of the country of destination for the disclosure of personal data transferred pursuant to these Clauses; such notification shall include information about the personal data requested, the requesting authority, the legal basis for the request and the response provided; or"}),(0,a.jsx)("li",{children:"becomes aware of any direct access by public authorities to personal data transferred pursuant to these Clauses in accordance with the laws of the country of destination; such notification shall include all information available to the importer."})]})]}),(0,a.jsx)("li",{children:"If the data importer is prohibited from notifying the data exporter and/or the data subject under the laws of the country of destination, the data importer agrees to use its best efforts to obtain a waiver of the prohibition, with a view to communicating as much information as possible, as soon as possible. The data importer agrees to document its best efforts in order to be able to demonstrate them on request of the data exporter."}),(0,a.jsx)("li",{children:"Where permissible under the laws of the country of destination, the data importer agrees to provide the data exporter, at regular intervals for the duration of the contract, with as much relevant information as possible on the requests received (in particular, number of requests, type of data requested, requesting authority/ies, whether requests have been challenged and the outcome of such challenges, etc.)."}),(0,a.jsx)("li",{children:"The data importer agrees to preserve the information pursuant to paragraphs (a) to (c) for the duration of the contract and make it available to the competent supervisory authority on request."}),(0,a.jsx)("li",{children:"Paragraphs (a) to (c) are without prejudice to the obligation of the data importer pursuant to Clause 14(e) and Clause 16 to inform the data exporter promptly where it is unable to comply with these Clauses."})]}

1),(0,a.jsx)("h3",{"data-sub-counter":!0,children:"Review of legality and data minimisation"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"The data importer agrees to review the legality of the request for disclosure, in particular whether it remains within the powers granted to the requesting public authority, and to challenge the request if, after careful assessment, it concludes that there are reasonable grounds to consider that the request is unlawful under the laws of the country of destination, applicable obligations under international law and principles of international comity. The data importer shall, under the same conditions, pursue possibilities of appeal. When challenging a request, the data importer shall seek interim measures with a view to suspending the effects of the request until the competent judicial authority has decided on its merits. It shall not disclose the personal data requested until required to do so under the applicable procedural rules. These requirements are without prejudice to the obligations of the data importer under Clause 14(e)."}),(0,a.jsx)("li",{children:"The data importer agrees to document its legal assessment and any challenge to the request for disclosure and, to the extent permissible under the laws of the country of destination, make the documentation available to the data exporter. It shall also make it available to the competent supervisory authority on request."}),(0,a.jsx)("li",{children:"The data importer agrees to provide the minimum amount of information permissible when responding to a request for disclosure, based on a reasonable interpretation of the request."})]})]}),(0,a.jsxs)(b,{heading:"Section IV – Final provisions",children:[(0,a.jsx)("h2",{children:"Non-compliance with the Clauses and termination"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"The data importer shall promptly inform the data exporter if it is unable to comply with these Clauses, for whatever reason."}),(0,a.jsx)("li",{children:"In the event that the data importer is in breach of these Clauses or unable to comply with these Clauses, the data exporter shall suspend the transfer of personal data to the data importer until compliance is again ensured or the contract is terminated. This is without prejudice to Clause 14(f)."}),(0,a.jsxs)("li",{children:["The data exporter shall be entitled to terminate the contract, insofar as it concerns the processing of personal data under these Clauses, where:",(0,a.jsxs)("ol",{"data-bullets":"lower-roman","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"the data exporter has suspended the transfer of personal data to the data importer pursuant to paragraph (b) and compliance with these Clauses is not restored within a reasonable time and in any event within one month of suspension;"}),(0,a.jsx)("li",{children:"the data importer is in substantial or persistent breach of these Clauses; or"}),(0,a.jsx)("li",{children:"the data importer fails to comply with a binding decision of a competent court or supervisory authority regarding its obligations under these Clauses."})]}),(0,a.jsx)("p",{children:"In these cases, it shall inform the competent supervisory authority of such non-compliance. Where the contract involves more than two Parties, the data exporter may exercise this right to termination only with respect to the relevant Party, unless the Parties have agreed otherwise."})]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("p",{children:"Personal data that has been transferred prior to the termination of the contract pursuant to paragraph (c) shall at the choice of the data exporter immediately be returned to the data exporter or deleted in its entirety. The same shall apply to any copies of the data."}),(0,a.jsx)("p",{children:"The data importer shall certify the deletion of the data to the data exporter. Until the data is deleted or returned, the data importer shall continue to ensure compliance with these Clauses. In case of local laws applicable to the data importer that prohibit the return or deleti

1on of the transferred personal data, the data importer warrants that it will continue to ensure compliance with these Clauses and will only process the data to the extent and for as long as required under that local law."})]}),(0,a.jsx)("li",{children:"Either Party may revoke its agreement to be bound by these Clauses where (i) the European Commission adopts a decision pursuant to Article 45(3) of Regulation (EU) 2016/679 that covers the transfer of personal data to which these Clauses apply; or (ii) Regulation (EU) 2016/679 becomes part of the legal framework of the country to which the personal data is transferred. This is without prejudice to other obligations applying to the processing in question under Regulation (EU) 2016/679."})]}),(0,a.jsx)("h2",{children:"Governing law"}),(0,a.jsx)("p",{children:"These Clauses shall be governed by the law of one of the EU Member States, provided such law allows for third-party beneficiary rights. The Parties agree that this shall be the law of Ireland"}),(0,a.jsx)("h2",{children:"Choice of forum and jurisdiction"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"Any dispute arising from these Clauses shall be resolved by the courts of an EU Member State."}),(0,a.jsx)("li",{children:"The Parties agree that those shall be the courts of Ireland."}),(0,a.jsx)("li",{children:"A data subject may also bring legal proceedings against the data exporter and/or data importer before the courts of the Member State in which he/she has his/her habitual residence."}),(0,a.jsx)("li",{children:"The Parties agree to submit themselves to the jurisdiction of such courts."})]})]}),(0,a.jsxs)(b,{heading:"Appendix",children:[(0,a.jsx)("h2",{"data-skip-counter":!0,children:"Annex I"}),(0,a.jsx)("h3",{children:"A. List of parties"}),(0,a.jsxs)("p",{children:[(0,a.jsx)("strong",{children:"Data exporter:"})," Merchant as identified in the Principal Agreement"]}),(0,a.jsx)("p",{children:"Role: controller"}),(0,a.jsx)("p",{children:(0,a.jsx)("strong",{children:"Data importer:"})}),(0,a.jsxs)("ol",{"data-bullets":"decimal","data-counter-decoration":"dot",children:[(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Name:"})," Queensland Foreign Exchange.",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Address:"})," 36 Toronto Street, Suite 850, Toronto, Ontario, Canada, M5C 2C5",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Contact:"})," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",children:"[email protected]"}),(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Activities relevant to the data transferred under these Clauses:"})," ","payment processing services",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Signature and date:"})," date of the Principal Agreement",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Role (controller/processor):"})," processor"]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Name:"})," Second February Limitada",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Address:"})," Costa Rica, San Jos\xe9, Mata Redonda, Sabana Oeste, twelfth avenue, ninetieth street, ERP Lawyers Law Firm offices",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Contact:"})," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",children:"[email protected]"}),(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Activities relevant to the data transferred under these Clauses:"})," ","payment processing services",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Signature and date:"})," date of the Principal Agreement",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Role (controller/processor):"})," processor"]})]}),(0,a.jsx)("h3",{children:"B. Description of transfer"}),(0,a.jsx)("p",{children:"Please refer to the Data Processing Agreement Exhibit I."}),(0,a.jsx)("h3",{children:"C. Competent supervisory authority"}),(0,a.jsx)("p",{children:"The compenent supervisory authority shall be Data Protection Commission of Ireland."}

1),(0,a.jsx)("h2",{"data-skip-counter":!0,children:"Annex II - Technical and organisational measures including technical and organisational measures to ensure the security of the data"}),(0,a.jsx)("p",{children:"Please refer to the Data Processing Agreement Exhibit II."})]})]}),(0,a.jsxs)("section",{children:[(0,a.jsxs)(b,{heading:"Exhibit V",children:[(0,a.jsx)("p",{children:"To the Data Processing Agreement"}),(0,a.jsxs)("p",{children:["STANDARD CONTRACTUAL CLAUSES",(0,a.jsx)("br",{}),"Module 1: controller to controller"]})]}),(0,a.jsxs)(b,{heading:"Section I",children:[(0,a.jsx)("h2",{children:"Purpose and scope"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"The purpose of these standard contractual clauses is to ensure compliance with the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation) for the transfer of personal data to a third country."}),(0,a.jsxs)("li",{children:["The Parties:",(0,a.jsxs)("ol",{"data-bullets":"lower-roman","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"the natural or legal person(s), public authority/ies, agency/ies or other body/ies (hereinafter “entity/ies”) transferring the personal data, as listed in Annex I.A. (hereinafter each “data exporter”), and"}),(0,a.jsx)("li",{children:"the entity/ies in a third country receiving the personal data from the data exporter, directly or indirectly via another entity also Party to these Clauses, as listed in Annex I.A. (hereinafter each “data importer”)"})]})]}),(0,a.jsx)("li",{children:"have agreed to these standard contractual clauses (hereinafter: “Clauses”)."}),(0,a.jsx)("li",{children:"These Clauses apply with respect to the transfer of personal data as specified in Annex I.B."}),(0,a.jsx)("li",{children:"The Appendix to these Clauses containing the Annexes referred to therein forms an integral part of these Clauses."})]}),(0,a.jsx)("h2",{children:"Effect and invariability of the Clauses"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"These Clauses set out appropriate safeguards, including enforceable data subject rights and effective legal remedies, pursuant to Article 46(1) and Article 46 (2)(c) of Regulation (EU) 2016/679 and, with respect to data transfers from controllers to processors and/or processors to processors, standard contractual clauses pursuant to Article 28(7) of Regulation (EU) 2016/679, provided they are not modified, except to select the appropriate Module(s) or to add or update information in the Appendix. This does not prevent the Parties from including the standard contractual clauses laid down in these Clauses in a wider contract and/or to add other clauses or additional safeguards, provided that they do not contradict, directly or indirectly, these Clauses or prejudice the fundamental rights or freedoms of data"}),(0,a.jsx)("li",{children:"These Clauses are without prejudice to obligations to which the data exporter is subject by virtue of Regulation (EU) 2016/679."})]}),(0,a.jsx)("h2",{children:"Third-party beneficiaries"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsxs)("li",{children:["Data subjects may invoke and enforce these Clauses, as third-party beneficiaries, against the data exporter and/or data importer, with the following exceptions:",(0,a.jsxs)("ol",{"data-bullets":"lower-roman","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"Clause 1, Clause 2, Clause 3, Clause 6, Clause 7;"}),(0,a.jsx)("li",{children:"Clause 8 - Module One: Clause 8.5 (e) and Clause 8.9(b); Module Two: Clause 8.1(b), 8.9(a), (c), (d) and (e); Module Three: Clause 8.1(a), (c) and (d) and Clause 8.9(a), (c), (d), (e), (f) and (g); Module Four: Clause 8.1 (b) and Clause 8.3(b);"}),(0,a.jsx)("li",{children:"Clause 9 - Module Two: Clause 9(a), (c), (d) and (e); Module Three: Clause 9(a), (c), (d) and (e);"}),(0,a.jsx)("li",{children:"Clause 12 - Module One: Clause 12(a) and (d); Modules Two and Three: Clause 12(a), (d) and (f);"}),(0,a.jsx)("li",{children:"Clause 13;"}),(0,a.jsx)("li",{children:"Clause 15.1(c), (d) and (e);"}),(0,a.jsx)("li",{children:"Clause 16(e);"}),(0,a.jsx)("li",{children:"Clause 18 - Modules One, Two and Three: Clause 18(a) and (b); Module Four: Clause 18."})]})]}),(0,a.jsx)("li",{children:"Paragraph (a) is without prejudice to rights of data subjects under Regulation (EU) 2016/679."})]}),(0,a.jsx)("h2",{children:"Interpretation"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"Where these Clauses use terms that are defined in Regulation (EU) 2016/679, those terms shall have the same meaning as in that Regulation."}),(0,a.jsx)("li",{children:"These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679."}),(0,a.jsx)("li",{children:"These Clauses shall not be interpreted in a way that conflicts with rights and obligations provided for in Regulation (EU) 2016/679."})]}),(0,a.jsx)("h2",{children:"Hierarchy"}),(0,a.jsx)("p",{children:"In the event of a contradiction between these Clauses and the provisions of related agreements between the Parties, existing at the time these Clauses are agreed or entered into thereafter, these Clauses shall prevail."}),(0,a.jsx)("h2",{children:"Description of the transfer(s)"}),(0,a.jsx)("p",{children:"The details of the transfer(s), and in particular the categories of personal data that are transferred and the purpose(s) for which they are transferred, are specified in Annex I.B."}),(0,a.jsx)("h2",{children:"Docking clause"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"An entity that is not a Party to these Clauses may, with the agreement of the Parties, accede to these Clauses at any time, either as a data exporter or as a data importer, by completing the Appendix and signing Annex I.A."}),(0,a.jsx)("li",{children:"Once it has completed the Appendix and signed Annex I.A, the acceding entity shall become a Party to these Clauses and have the rights and obligations of a data exporter or data importer in accordance with its designation in Annex I.A."}),(0,a.jsx)("li",{children:"The acceding entity shall have no rights or obligations arising under these Clauses from the peri

1od prior to becoming a Party."})]})]}),(0,a.jsxs)(b,{heading:"Section II – Obligations of the parties",children:[(0,a.jsx)("h2",{children:"Data protection safeguards"}),(0,a.jsx)("p",{children:"The data exporter warrants that it has used reasonable efforts to determine that the data importer is able, through the implementation of appropriate technical and organisational measures, to satisfy its obligations under these Clauses."}),(0,a.jsx)("h3",{"data-sub-counter":!0,children:"Purpose limitation"}),(0,a.jsx)("p",{children:"The data importer shall process the personal data only for the specific purpose(s) of the transfer, as set out in Annex I.B. It may only process the personal data for another purpose:"}),(0,a.jsxs)("ol",{"data-bullets":"lower-roman","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"where it has obtained the data subject’s prior consent;"}),(0,a.jsx)("li",{children:"where necessary for the establishment, exercise or defence of legal claims in the context of specific administrative, regulatory or judicial proceedings; or"}),(0,a.jsx)("li",{children:"where necessary in order to protect the vital interests of the data subject or of another natural person."})]}),(0,a.jsx)("h3",{"data-sub-counter":!0,children:"Transparency"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsxs)("li",{children:["In order to enable data subjects to effectively exercise their rights pursuant to Clause 10, the data importer shall inform them, either directly or through the data exporter:",(0,a.jsxs)("ol",{"data-bullets":"lower-roman","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"of its identity and contact details;"}),(0,a.jsx)("li",{children:"of the categories of personal data processed;"}),(0,a.jsx)("li",{children:"of the right to obtain a copy of these Clauses;"}),(0,a.jsx)("li",{children:"where it intends to onward transfer the personal data to any third party/ies, of the recipient or categories of recipients (as appropriate with a view to providing meaningful information), the purpose of such onward transfer and the ground therefore pursuant to Clause 8.7."})]})]}),(0,a.jsx)("li",{children:"Paragraph (a) shall not apply where the data subject already has the information, including when such information has already been provided by the data exporter, or providing the information proves impossible or would involve a disproportionate effort for the data importer. In the latter case, the data importer shall, to the extent possible, make the information publicly available."}),(0,a.jsx)("li",{children:"On request, the Parties shall make a copy of these Clauses, including the Appendix as completed by them, available to the data subject free of charge. To the extent necessary to protect business secrets or other confidential information, including personal data, the Parties may redact part of the text of the Appendix prior to sharing a copy, but shall provide a meaningful summary where the data subject would otherwise not be able to understand its content or exercise his/her rights. On request, the Parties shall provide the data subject with the reasons for the redactions, to the extent possible without revealing the redacted information."}),(0,a.jsx)("li",{children:"Paragraphs (a) to (c) are without prejudice to the obligations of the data exporter under Articles 13 and 14 of Regulation (EU) 2016/679."})]}),(0,a.jsx)("h3",{"data-sub-counter":!0,children:"Accuracy and data minimisation"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"Each Party shall ensure that the personal data is accurate and, where necessary, kept up to date. The data importer shall take every reasonable step to ensure that personal data that is inaccurate, having regard to the purpose(s) of processing, is erased or rectified without delay."}),(0,a.jsx)("li",{children:"If one of the Parties becomes aware that the personal data it has transferred or received is inaccurate, or has become outdated, it shall inform the other Party without undue delay."}),(0,a.jsx)("li",{children:"The data importer shall ensure that the personal data is adequate, relevant and limited to what is necessary in relation to the purpose(s) of processing."})]}

1),(0,a.jsx)("h3",{"data-sub-counter":!0,children:"Storage limitation"}),(0,a.jsx)("p",{children:"The data importer shall retain the personal data for no longer than necessary for the purpose(s) for which it is processed. It shall put in place appropriate technical or organisational measures to ensure compliance with this obligation, including erasure or anonymisation of the data and all back-ups at the end of the retention period."}),(0,a.jsx)("h3",{"data-sub-counter":!0,children:"Security of processing"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"The data importer and, during transmission, also the data exporter shall implement appropriate technical and organisational measures to ensure the security of the personal data, including protection against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access (hereinafter “personal data breach”). In assessing the appropriate level of security, they shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purpose(s) of processing and the risks involved in the processing for the data subject. The Parties shall in particular consider having recourse to encryption or pseudonymisation, including during transmission, where the purpose of processing can be fulfilled in that manner."}),(0,a.jsx)("li",{children:"The Parties have agreed on the technical and organisational measures set out in Annex II. The data importer shall carry out regular checks to ensure that these measures continue to provide an appropriate level of security."}),(0,a.jsx)("li",{children:"The data importer shall ensure that persons authorised to process the personal data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality."}),(0,a.jsx)("li",{children:"In the event of a personal data breach concerning personal data processed by the data importer under these Clauses, the data importer shall take appropriate measures to address the personal data breach, including measures to mitigate its possible adverse effects."}),(0,a.jsx)("li",{children:"In case of a personal data breach that is likely to result in a risk to the rights and freedoms of natural persons, the data importer shall without undue delay notify both the data exporter and the competent supervisory authority pursuant to Clause 13. Such notification shall contain i) a description of the nature of the breach (including, where possible, categories and approximate number of data subjects and personal data records concerned), ii) its likely consequences, iii) the measures taken or proposed to address the breach, and iv) the details of a contact point from whom more information can be obtained. To the extent it is not possible for the data importer to provide all the information at the same time, it may do so in phases without undue further delay."}),(0,a.jsx)("li",{children:"In case of a personal data breach that is likely to result in a high risk to the rights and freedoms of natural persons, the data importer shall also notify without undue delay the data subjects concerned of the personal data breach and its nature, if necessary in cooperation with the data exporter, together with the information referred to in paragraph (e), points ii) to iv), unless the data importer has implemented measures to significantly reduce the risk to the rights or freedoms of natural persons, or notification would involve disproportionate efforts. In the latter case, the data importer shall instead issue a public communication or take a similar measure to inform the public of the personal data breach."}),(0,a.jsx)("li",{children:"The data importer shall document all relevant facts relating to the personal data breach, including its effects and any remedial action taken, and keep a record thereof."})]}),(0,a.jsx)("h3",{"data-sub-counter":!0,children:"Sensitive data"}),(0,a.jsx)("p",{children:"Where the transfer involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions or offences (hereinafter “sensitive data”), the data importer shall apply specific restrictions and/or additional safeguards adapted to the specific nature of the data and the risks involved. This may include restricting the personnel permitted to access the personal data, additional security measures (such as pseudonymisation) and/or additional restrictions with respect to further disclosure"}

1),(0,a.jsx)("h3",{"data-sub-counter":!0,children:"Onward transfers"}),(0,a.jsx)("p",{children:"The data importer shall not disclose the personal data to a third party located outside the European Union (in the same country as the data importer or in another third country, hereinafter “onward transfer”) unless the third party is or agrees to be bound by these Clauses, under the appropriate Module. Otherwise, an onward transfer by the data importer may only take place if:"}),(0,a.jsxs)("ol",{"data-bullets":"lower-roman","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"it is to a country benefitting from an adequacy decision pursuant to Article 45 of Regulation (EU) 2016/679 that covers the onward transfer;"}),(0,a.jsx)("li",{children:"the third party otherwise ensures appropriate safeguards pursuant to Articles 46 or 47 of Regulation (EU) 2016/679 with respect to the processing in question;"}),(0,a.jsx)("li",{children:"the third party enters into a binding instrument with the data importer ensuring the same level of data protection as under these Clauses, and the data importer provides a copy of these safeguards to the data exporter;"}),(0,a.jsx)("li",{children:"it is necessary for the establishment, exercise or defence of legal claims in the context of specific administrative, regulatory or judicial proceedings;"}),(0,a.jsx)("li",{children:"it is necessary in order to protect the vital interests of the data subject or of another natural person; or"}),(0,a.jsx)("li",{children:"where none of the other conditions apply, the data importer has obtained the explicit consent of the data subject for an onward transfer in a specific situation, after having informed him/her of its purpose(s), the identity of the recipient and the possible risks of such transfer to him/her due to the lack of appropriate data protection safeguards. In this case, the data importer shall inform the data exporter and, at the request of the latter, shall transmit to it a copy of the information provided to the data subject."})]}),(0,a.jsx)("p",{children:"Any onward transfer is subject to compliance by the data importer with all the other safeguards under these Clauses, in particular purpose limitation."}),(0,a.jsx)("h3",{"data-sub-counter":!0,children:"Processing under the authority of the data importer"}),(0,a.jsx)("p",{children:"The data importer shall ensure that any person acting under its authority, including a processor, processes the data only on its instructions."}),(0,a.jsx)("h3",{"data-sub-counter":!0,children:"Documentation and compliance"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"Each Party shall be able to demonstrate compliance with its obligations under these Clauses. In particular, the data importer shall keep appropriate documentation of the processing activities carried out under its responsibility."}),(0,a.jsx)("li",{children:"The data importer shall make such documentation available to the competent supervisory authority on request."})]}),(0,a.jsx)("h2",{children:"Use of sub-processors"}),(0,a.jsx)("p",{children:"N/A"}),(0,a.jsx)("h2",{children:"Data subject rights"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"The data importer, where relevant with the assistance of the data exporter, shall deal with any enquiries and requests it receives from a data subject relating to the processing of his/her personal data and the exercise of his/her rights under these Clauses without undue delay and at the latest within one month of the receipt of the enquiry or request. The data importer shall take appropriate measures to facilitate such enquiries, requests and the exercise of data subject rights. Any information provided to the data subject shall be in an intelligible and easily accessible form, using clear and plain language."}),(0,a.jsxs)("li",{children:["In particular, upon request by the data subject the data importer shall, free of charge :",(0,a.jsxs)("ol",{"data-bullets":"lower-roman","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"provide confirmation to the data subject as to whether personal data concerning him/her is being processed and, where this is the case, a copy of the data relating to him/her and the information in Annex I; if personal data has been or will be onward transferred, provide information on recipients or categories of recipients (as appropriate with a view to providing meaningful information) to which the personal data has been or will be onward transferred, the purpose of such onward transfers and their ground pursuant to Clause 8.7; and provide information on the right to lodge a complaint with a supervisory authority in accordance with Clause 12(c)(i);"}),(0,a.jsx)("li",{children:"rectify inaccurate or incomplete data concerning the data subject;"}),(0,a.jsx)("li",{children:"erase personal data concerning the data subject if such data is being or has been processed in violation of any of these Clauses ensuring third-party beneficiary rights, or if the data subject withdraws the consent on which the processing is based."})]})]}),(0,a.jsx)("li",{children:"Where the data importer processes the personal data for direct marketing purposes, it shall cease processing for such purposes if the data subject objects to it."}),(0,a.jsxs)("li",{children:["The data importer shall not make a decision based solely on the automated processing of the personal data transferred (hereinafter “automated decision”), which would produce legal effects concerning the data subject or similarly significantly affect him / her, unless with the explicit consent of the data subject or if authorised to do so under the laws of the country of destination, provided that such laws lays down suitable measures to safeguard the data subject’s rights and legitimate interests. In this case, the data importer shall, where necessary in cooperation with the data exporter:",(0,a.jsxs)("ol",{"data-bullets":"lower-roman","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"inform the data subject about the envisaged automated decision, the envisaged consequences and the logic involved; and"}),(0,a.jsx)("li",{children:"implement suitable safeguards, at least by enabling the data subject to contest the decision, express his/her point of view and obtain review by a human being."})]})]}),(0,a.jsx)("li",{children:"Where requests from a data subject are excessive, in particular because of their repetitive character, the data importer may either charge a reasonable fee taking into account the administrative costs of granting the request or refuse to act on the request."}),(0,a.jsx)("li",{children:"The data importer may refuse a data subject’s request if such refusal is allowed under the laws of the country of destination and is necessary and proportionate in a democratic society to protect one of the objectives listed in Article 23(1) of Regulation (EU) 2016/679."}),(0,a.jsx)("li",{children:"If the data importer intends to refuse a data subject’s request, it shall inform the data subject of the reasons for the refusal and the possibility of lodging a complaint with the competent supervisory authority and/or seeking judicial redress."})]}),(0,a.jsx)("h2",{children:"Redress"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"The data importer shall inform data subjects in a transparent and easily accessible format, through individual notice or on its website, of a contact point authorised to handle complaints. It shall deal promptly with any complaints it receives from a data subject."}),(0,a.jsx)("li",{children:"In case of a dispute between a data subject and one of the Parties as regards compliance with these Clauses, that Party shall use its best efforts to resolve the issue amicably in a timely fashion. The Parties shall keep each other informed about such disputes and, where appropriate, cooperate in resolving them."}),(0,a.jsxs)("li",{children:["Where the data subject invokes a third-party beneficiary right pursuant to Clause 3, the data importer shall accept the decision of the data subject to:",(0,a.jsxs)("ol",{"data-bullets":"lower-roman","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"lodge a complaint with the supervisory authority in the Member State of his/her habitual residence or place of work, or the competent supervisory authority pursuant to Clause 13;"}),(0,a.jsx)("li",{children:"refer the dispute to the competent c

1ourts within the meaning of Clause 18."})]})]}),(0,a.jsx)("li",{children:"The Parties accept that the data subject may be represented by a not-for-profit body, organisation or association under the conditions set out in Article 80(1) of Regulation (EU) 2016/679."}),(0,a.jsx)("li",{children:"The data importer shall abide by a decision that is binding under the applicable EU or Member State law."}),(0,a.jsx)("li",{children:"The data importer agrees that the choice made by the data subject will not prejudice his/her substantive and procedural rights to seek remedies in accordance with applicable laws."})]}),(0,a.jsx)("h2",{children:"Liability"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"Each Party shall be liable to the other Party/ies for any damages it causes the other Party/ies by any breach of these Clauses."}),(0,a.jsx)("li",{children:"Each Party shall be liable to the data subject, and the data subject shall be entitled to receive compensation, for any material or non-material damages that the Party causes the data subject by breaching the third-party beneficiary rights under these Clauses. This is without prejudice to the liability of the data exporter under Regulation (EU) 2016/679."}),(0,a.jsx)("li",{children:"Where more than one Party is responsible for any damage caused to the data subject as a result of a breach of these Clauses, all responsible Parties shall be jointly and severally liable and the data subject is entitled to bring an action in court against any of these Parties."}),(0,a.jsx)("li",{children:"The Parties agree that if one Party is held liable under paragraph (c), it shall be entitled to claim back from the other Party/ies that part of the compensation corresponding to its / their responsibility for the damage."}),(0,a.jsx)("li",{children:"The data importer may not invoke the conduct of a processor or sub-processor to avoid its own liability."})]}),(0,a.jsx)("h2",{children:"Supervision"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"Where the data exporter is established in an EU Member State: The supervisory authority with responsibility for ensuring compliance by the data exporter with Regulation (EU) 2016/679 as regards the data transfer, as indicated in Annex I.C, shall act as competent supervisory authority."}),(0,a.jsx)("li",{children:"Where the data exporter is not established in an EU Member State, but falls within the territorial scope of application of Regulation (EU) 2016/679 in accordance with its Article 3(2) and has appointed a representative pursuant to Article 27(1) of Regulation (EU) 2016/679: The supervisory authority of the Member State in which the representative within the meaning of Article 27(1) of Regulation (EU) 2016/679 is established, as indicated in Annex I.C, shall act as competent supervisory authority."}),(0,a.jsx)("li",{children:"Where the data exporter is not established in an EU Member State, but falls within the territorial scope of application of Regulation (EU) 2016/679 in accordance with its Article 3(2) without however having to appoint a representative pursuant to Article 27(2) of Regulation (EU) 2016/679: The supervisory authority of one of the Member States in which the data subjects whose personal data is transferred under these Clauses in relation to the offering of goods or services to them, or whose behaviour is monitored, are located, as indicated in Annex I.C, shall act as competent supervisory authority."}),(0,a.jsx)("li",{children:"The data importer agrees to submit itself to the jurisdiction of and cooperate with the competent supervisory authority in any procedures aimed at ensuring compliance with these Clauses. In particular, the data importer agrees to respond to enquiries, submit to audits and comply with the measures adopted by the supervisory authority, including remedial and compensatory measures. It shall provide the supervisory authority with written confirmation that the necessary actions have been taken."})]})]}),(0,a.jsxs)(b,{heading:"Section III – Local laws and obligations in case of access by public authorities",children:[(0,a.jsx)("h2",{children:"Local laws and practices affecting compliance with the Clauses"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"The Parties warrant that they have no reason to believe that the laws and practices in the third country of destination applicable to the processing of the personal data by the data importer, including any requirements to disclose personal data or measures authorising access by public authorities, prevent the data importer from fulfilling its obligations under these Clauses. This is based on the understanding that laws and practices that respect the essence of the fundamental rights and freedoms and do not exceed what is necessary and proportionate in a democratic society to safeguard one of the objectives listed in Article 23(1) of Regulation (EU) 2016/679, are not in contradiction with these Clauses."}),(0,a.jsxs)("li",{children:["The Parties declare that in providing the warranty in paragraph (a), they have taken due account in particular of the following elements:",(0,a.jsxs)("ol",{"data-bullets":"lower-roman","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"the specific circumstances of the transfer, including the length of the processing chain, the number of actors involved and the transmission channels used; intended onward transfers; the type of recipient; the purpose of processing; the categories and format of the transferred personal data;

1 the economic sector in which the transfer occurs; the storage location of the data transferred;"}),(0,a.jsx)("li",{children:"the laws and practices of the third country of destination– including those requiring the disclosure of data to public authorities or authorising access by such authorities – relevant in light of the specific circumstances of the transfer, and the applicable limitations and safeguards;"}),(0,a.jsx)("li",{children:"any relevant contractual, technical or organisational safeguards put in place to supplement the safeguards under these Clauses, including measures applied during transmission and to the processing of the personal data in the country of destination."})]})]}),(0,a.jsx)("li",{children:"The data importer warrants that, in carrying out the assessment under paragraph (b), it has made its best efforts to provide the data exporter with relevant information and agrees that it will continue to cooperate with the data exporter in ensuring compliance with these Clauses."}),(0,a.jsx)("li",{children:"The Parties agree to document the assessment under paragraph (b) and make it available to the competent supervisory authority on request."}),(0,a.jsx)("li",{children:"The data importer agrees to notify the data exporter promptly if, after having agreed to these Clauses and for the duration of the contract, it has reason to believe that it is or has become subject to laws or practices not in line with the requirements under paragraph (a), including following a change in the laws of the third country or a measure (such as a disclosure request) indicating an application of such laws in practice that is not in line with the requirements in paragraph (a)."}),(0,a.jsx)("li",{children:"Following a notification pursuant to paragraph (e), or if the data exporter otherwise has reason to believe that the data importer can no longer fulfil its obligations under these Clauses, the data exporter shall promptly identify appropriate measures (e.g. technical or organisational measures to ensure security and confidentiality) to be adopted by the data exporter and/or data importer to address the situation. The data exporter shall suspend the data transfer if it considers that no appropriate safeguards for such transfer can be ensured, or if instructed by the competent supervisory authority to do so. In this case, the data exporter shall be entitled to terminate the contract, insofar as it concerns the processing of personal data under these Clauses. If the contract involves more than two Parties, the data exporter may exercise this right to termination only with respect to the relevant Party, unless the Parties have agreed otherwise. Where the contract is terminated pursuant to this Clause, Clause 16(d) and (e) shall apply."})]}),(0,a.jsx)("h2",{children:"Obligations of the data importer in case of access by public authorities"}),(0,a.jsx)("h3",{"data-sub-counter":!0,children:"Notification"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsxs)("li",{children:["The data importer agrees to notify the data exporter and, where possible, the data subject promptly (if necessary with the help of the data exporter) if it:",(0,a.jsxs)("ol",{"data-bullets":"lower-roman","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"receives a legally binding request from a public authority, including judicial authorities, under the laws of the country of destination for the disclosure of personal data transferred pursuant to these Clauses; such notification shall include information about the personal data requested, the requesting authority, the legal basis for the request and the response provided; or"}),(0,a.jsx)("li",{children:"becomes aware of any direct access by public authorities to personal data transferred pursuant to these Clauses in accordance with the laws of the country of destination; such notification shall include all information available to the importer."})]})]}),(0,a.jsx)("li",{children:"If the data importer is prohibited from notifying the data exporter and/or the data subject under the laws of the country of destination, the data importer agrees to use its best efforts to obtain a waiver of the prohibition, with a view to communicating as much information as possible, as soon as possible. The data importer agrees to document its best efforts in order to be able to demonstrate them on request of the data exporter."}),(0,a.jsx)("li",{children:"Where permissible under the laws of the country of destination, the data importer agrees to provide the data exporter, at regular intervals for the duration of the contract, with as much relevant information as possible on the requests received (in particular, number of requests, type of data requested, requesting authority/ies, whether requests have been challenged and the outcome of such challenges, etc.)."}),(0,a.jsx)("li",{children:"The data importer agrees to preserve the information pursuant to paragraphs (a) to (c) for the duration of the contract and make it available to the competent supervisory authority on request."}),(0,a.jsx)("li",{children:"Paragraphs (a) to (c) are without prejudice to the obligation of the data importer pursuant to Clause 14(e) and Clause 16 to inform the data exporter promptly where it is unable to comply with these Clauses."})]}

1),(0,a.jsx)("h3",{"data-sub-counter":!0,children:"Review of legality and data minimisation"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"The data importer agrees to review the legality of the request for disclosure, in particular whether it remains within the powers granted to the requesting public authority, and to challenge the request if, after careful assessment, it concludes that there are reasonable grounds to consider that the request is unlawful under the laws of the country of destination, applicable obligations under international law and principles of international comity. The data importer shall, under the same conditions, pursue possibilities of appeal. When challenging a request, the data importer shall seek interim measures with a view to suspending the effects of the request until the competent judicial authority has decided on its merits. It shall not disclose the personal data requested until required to do so under the applicable procedural rules. These requirements are without prejudice to the obligations of the data importer under Clause 14(e)."}),(0,a.jsx)("li",{children:"The data importer agrees to document its legal assessment and any challenge to the request for disclosure and, to the extent permissible under the laws of the country of destination, make the documentation available to the data exporter. It shall also make it available to the competent supervisory authority on request."}),(0,a.jsx)("li",{children:"The data importer agrees to provide the minimum amount of information permissible when responding to a request for disclosure, based on a reasonable interpretation of the request."})]})]}),(0,a.jsxs)(b,{heading:"Section IV – Final provisions",children:[(0,a.jsx)("h2",{children:"Non-compliance with the Clauses and termination"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"The data importer shall promptly inform the data exporter if it is unable to comply with these Clauses, for whatever reason."}),(0,a.jsx)("li",{children:"In the event that the data importer is in breach of these Clauses or unable to comply with these Clauses, the data exporter shall suspend the transfer of personal data to the data importer until compliance is again ensured or the contract is terminated. This is without prejudice to Clause 14(f)."}),(0,a.jsxs)("li",{children:["The data exporter shall be entitled to terminate the contract, insofar as it concerns the processing of personal data under these Clauses, where:",(0,a.jsxs)("ol",{"data-bullets":"lower-roman","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"the data exporter has suspended the transfer of personal data to the data importer pursuant to paragraph (b) and compliance with these Clauses is not restored within a reasonable time and in any event within one month of suspension;"}),(0,a.jsx)("li",{children:"the data importer is in substantial or persistent breach of these Clauses; or"}),(0,a.jsx)("li",{children:"the data importer fails to comply with a binding decision of a competent court or supervisory authority regarding its obligations under these Clauses."})]})]}),(0,a.jsx)("li",{children:"In these cases, it shall inform the competent supervisory authority of such non-compliance. Where the contract involves more than two Parties, the data exporter may exercise this right to termination only with respect to the relevant Party, unless the Parties have agreed otherwise."}),(0,a.jsx)("li",{children:"Personal data that has been transferred prior to the termination of the contract pursuant to paragraph (c) shall at the choice of the data exporter immediately be returned to the data exporter or deleted in its entirety. The same shall apply to any copies of the data. The data importer shall certify the deletion of the data to the data exporter. Until the data is deleted or returned, the data importer shall continue to ensure compliance with these Clauses. In case of local laws applicable to the data importer that prohibit the return or deleti

1on of the transferred personal data, the data importer warrants that it will continue to ensure compliance with these Clauses and will only process the data to the extent and for as long as required under that local law."}),(0,a.jsx)("li",{children:"Either Party may revoke its agreement to be bound by these Clauses where (i) the European Commission adopts a decision pursuant to Article 45(3) of Regulation (EU) 2016/679 that covers the transfer of personal data to which these Clauses apply; or (ii) Regulation (EU) 2016/679 becomes part of the legal framework of the country to which the personal data is transferred. This is without prejudice to other obligations applying to the processing in question under Regulation (EU) 2016/679."})]}),(0,a.jsx)("h2",{children:"Governing law"}),(0,a.jsx)("p",{children:"These Clauses shall be governed by the law of one of the EU Member States, provided such law allows for third-party beneficiary rights. The Parties agree that this shall be the law of Ireland."}),(0,a.jsx)("h2",{children:"Choice of forum and jurisdiction"}),(0,a.jsxs)("ol",{"data-bullets":"lower-latin","data-counter-decoration":"braces",children:[(0,a.jsx)("li",{children:"Any dispute arising from these Clauses shall be resolved by the courts of an EU Member State."}),(0,a.jsx)("li",{children:"The Parties agree that those shall be the courts of Ireland."}),(0,a.jsx)("li",{children:"A data subject may also bring legal proceedings against the data exporter and/or data importer before the courts of the Member State in which he/she has his/her habitual residence."}),(0,a.jsx)("li",{children:"The Parties agree to submit themselves to the jurisdiction of such courts."})]})]}),(0,a.jsxs)(b,{heading:"Appendix",children:[(0,a.jsx)("h2",{"data-skip-counter":!0,children:"Annex I"}),(0,a.jsx)("h3",{children:"A. List of parties"}),(0,a.jsxs)("p",{children:[(0,a.jsx)("strong",{children:"Data exporter(s):"})," Merchant"]}),(0,a.jsx)("p",{children:"Role: controller"}),(0,a.jsx)("p",{children:(0,a.jsx)("strong",{children:"Data importer(s):"})}),(0,a.jsxs)("ol",{"data-bullets":"decimal","data-counter-decoration":"dot",children:[(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Name:"})," Queensland Foreign Exchange.",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Address:"})," 36 Toronto Street, Suite 850, Toronto, Ontario, Canada, M5C 2C5",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Contact:"})," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",children:"[email protected]"}),(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Activities relevant to the data transferred under these Clauses:"})," ","payment processing services",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Signature and date:"})," date of the Principal Agreement",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Role (controller/processor):"})," processor"]}),(0,a.jsxs)("li",{children:[(0,a.jsx)("strong",{children:"Name:"})," Second February Limitada",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Address:"})," Costa Rica, San Jos\xe9, Mata Redonda, Sabana Oeste, twelfth avenue, ninetieth street, ERP Lawyers Law Firm offices",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Contact:"})," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",children:"[email protected]"}),(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Activities relevant to the data transferred under these Clauses:"})," ","payment processing services",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Signature and date:"})," date of the Principal Agreement",(0,a.jsx)("br",{}),(0,a.jsx)("strong",{children:"Role (controller/processor):"})," processor"]})]}),(0,a.jsx)("h3",{children:"B. Description of transfer"}),(0,a.jsx)("p",{children:"Please refer to the Data Processing Agreement Exhibit I."}),(0,a.jsx)("h3",{children:"C. Competent supervisory authority"}),(0,a.jsx)("p",{children:"The competent supervisory authorite shall be Data Protection Commission of Ireland."}),(0,a.jsx)("h2",{"data-skip-counter":!0,children:"Annex II - Technical and organisational measures including technical and organisational measures to ensure the security of the data"}),(0,a.jsx)("p",{children:"Please refer to the Data Processing Agreement Exhibit II."})]})]})]})}},latest:"v1"},"privacy-notice":{versions:{v1:function(){return(0,a.jsxs)(c.A,{direction:"vertical",ga

1p:2,children:[(0,a.jsx)("div",{children:(0,a.jsx)(h(),{"data-underline":!0,href:d.qv.DocCanadaPrivacy,children:"Privacy Notice Canada"})}),(0,a.jsx)("div",{children:(0,a.jsx)(h(),{"data-underline":!0,href:d.qv.DocCostaRicaPrivacy,children:"Privacy Notice Costa Rica"})})]})}},latest:"v1"},"privacy-notice-canada":{versions:{v1:function(){return(0,a.jsxs)("div",{"data-template":"default",children:[(0,a.jsx)("p",{children:"Last updated: 20.06.2024"}),(0,a.jsx)("h2",{children:"Introduction"}),(0,a.jsxs)("p",{children:["The Privacy Notice together with Volet Terms and Conditions (and any other document referred to therein) describes how we collect, process, use and disclose your information, including any personal data we collect from you, or which you provide to us through the website"," ",(0,a.jsx)("a",{"data-underline":!0,href:d.qv._Promo,target:"_blank",rel:"noopener noreferrer nofollow",children:"www.volet.com"})," ","(hereinafter referred to as the Website). When you contact us via the Website, complete any forms or submit any details using the Website, we will collect, use and disclose your personal information as described in this Privacy Notice."]}),(0,a.jsx)("h2",{children:"Details of the Data Controller and the Data Protection Officer"}),(0,a.jsx)("p",{children:"The Data Controller is the company that determines the purpose and means of personal data processing:"}),(0,a.jsx)("p",{children:"Queensland Foreign Exchange., incorporation number 1000433476, MSB registration number M23153297; 36 Toronto Street, Suite 850, Toronto, Ontario, Canada, M5C 2C5."}),(0,a.jsxs)("p",{children:["Privacy related questions may be addressed to"," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",target:"_blank",rel:"noopener noreferrer nofollow",children:"[email protected]"}),"."]}),(0,a.jsx)("h2",{children:"What is personal data?"}),(0,a.jsx)("p",{children:"Under PIPEDA, personal information includes any factual or subjective information, recorded or not, about an identifiable individual. In this policy definitions “personal data” and “personal information” shall be user interchangeably."}),(0,a.jsx)("p",{children:"The General Data Protection Regulation (GDPR) (EU Regulation 2016/679) defines personal data as \xabany information relating to an identified or identifiable natural person (data subject), directly or indirectly, by reference to an identifier, such as name, an identification number, location data, an online identifier\xbb. Simply put, personal information is any information about you that enables your identification."}),(0,a.jsx)("p",{children:"The personal data we collect and use is described in this Privacy Notice."}),(0,a.jsx)("h2",{children:"Personal data we collect and process"}),(0,a.jsx)("p",{children:"We process certain personal data as described below:"}),(0,a.jsx)("h3",{children:"1. Information that you provide when you set up an account:"}),(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"Name, surname;"}),(0,a.jsx)("li",{children:"Email, hashed password."})]}),(0,a.jsx)("h3",{children:"2. When you verify your account:"}),(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"Mobile phone number;"}),(0,a.jsx)("li",{children:"Identity document data, such as document type, issuing country, number, expiry date, MRZ, information embedded into document barcodes (may vary depending on the document), and security features;"}),(0,a.jsx)("li",{children:"Facial image data, such as photos of the face (including selfie images), a photo or scan of the face on the identification document, video screenshots and sound recordings;"}),(0,a.jsx)("li",{children:"Biometric data such as facial features to perform a liveness check."})]}),(0,a.jsx)("h3",{children:"3. When you order a card:"}),(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"Copy of ID document;"}),(0,a.jsx)("li",{children:"Copy of proof of address document (utility bill, bank statement, etc);"}),(0,a.jsx)("li",{children:"Delivery address."})]}),(0,a.jsx)("h3",{children:"4. When we inquire about your transactions to prevent fraud and misuse of your account:"}),(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"Information required to prove the source of funds, such as documents, bank statements, verbal explanations, and screenshots;"}),(0,a.jsx)("li",{children:"Information needed to indicate the purpose and economic sense of a financial transaction;"}),(0,a.jsx)("li",{children:"Information you fill in the questionnaire to prove your capacity and understanding of the consequences of your actions;"}),(0,a.jsx)("li",{children:"Facial data for a liveness check if required by AML procedures based on the risk level assessment."})]}),(0,a.jsx)("h3",{children:"5. When you communicate with us:"}),(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"Your contact email;"}),(0,a.jsx)("li",{children:"Content of your communication, messages, and files you attach to your messages;"}),(0,a.jsx)("li",{children:"Unique ticket system identifier;"}),(0,a.jsx)("li",{children:"Technical data related to your messages (including date, time zone, environment, etc.)."})]}),(0,a.jsx)("h3",{children:"6. Transaction information:"}),(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"Details of your Wallets, a unique identifier in System, Volet debit card details;"}),(0,a.jsx)("li",{children:"Payments performed within your account, including date, time, amount, currencies, participants associated with the transaction, messages sent and received with the payment, merchant information, payment methods used, technical usage data, and geolocation information;"}),(0,a.jsx)("li",{children:"Bank card details that you may connect to your account, such as cardholder name, expiry date, first 6 and last 4 digits of the card number."})]}),(0,a.jsx)("h3",{children:"7. Information from your device:"}),(0,a.jsx)("ul",{children:(0,a.jsx)("li",{children:"IP address, environment, log-in information, browser type and settings, time zone, the operating system, the type of device you use, a unique device identifier, screen size, mobile network information, mobile operating system and type of mobile browser you are using, date, time and length of your visit."})}),(0,a.jsx)("h3",{children:"8. Information we may receive from third parties:"}),(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"Information received by one of our affiliates;"}),(0,a.jsx)("li",{children:"Information from payment systems, payment providers;"}),(0,a.jsx)("li",{children:"Information received by the card schemes (e.g. Visa, Mastercard, Unionpay, etc.), fraud prevention agencies, credit reference agencies, government and law enforcement agencies;"}),(0,a.jsx)("li",{children:"Information received via public sources like company registers, websites for enhanced due diligence checks."})]}),(0,a.jsx)("h2",{children:"Legal basis and use of your personal data"}),(0,a.jsx)("p",{children:"We only process your personal data where a lawful basis exists. The legal basis for each processing will be one of the following:"}),(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:(0,a.jsx)("strong",{children:"Performance of a contract we enter with you;"})}),(0,a.jsx)("li",{children:(0,a.jsx)("strong",{children:"Our legal obligation;"})}),(0,a.jsx)("li",{children:(0,a.jsx)("strong",{children:"Our legitimate interests, taking into consideration your rights, interests, and expectations;"})}),(0,a.jsx)("li",{children:(0,a.jsx)("strong",{children:"Your consent."})})]}),(0,a.jsx)("h3",{children:"1. Performance of a contract we enter with you"}),(0,a.jsxs)("p",{children:["We process your personal data to provide you with the Services based on the"," ",(0,a.jsx)(h(),{"data-underline":!0,href:d.qv.DocCanadaTerms,children:"Terms and Conditions"})," ","that you accept when you register in System."]}),(0,a.jsx)("p",{children:"We collect your data to set up and administer your Volet account."}),(0,a.jsx)("p",{children:"Furthermore, we also process your data to ensure secure access to your Volet account when we send you a one-time password or other access codes."}),(0,a.jsx)("p",{children:"We use your data to process transactions you make with your Volet account or Volet card, such as transferring funds, making Payments, adding money to the Wallet, or withdrawing funds."}),(0,a.jsx)("p",{children:'We process your data when you issue an Volet card to provide you with relevant Services. To achieve this, we share data with third parties who provide such Services. You can find out more about this in the "Disclosure of personal data to third parties" section.'}),(0,a.jsx)("p",{children:"We may send you important information about the system, login confirmation, suspicious authorization attempts and completed transactions notifications, as well as provide technical support."}),(0,a.jsx)("p",{children:"We process personal data to assist you in resolving issues related to the use of System, when you contact Customer Care via ticket, email, or phone."}),(0,a.jsx)("h3",{children:"2. Our legal obligation"}),(0,a.jsx)("p",{children:"We process your personal data to comply with our legal obligations, in particular the requirements of anti-money laundering and terrorist financing legislation, to verify and confirm your identity as part of the KYC procedure."}),(0,a.jsx)("p",{children:"When you order a Volet card, start a wire transfer, we also send your data to the providers of these Services to meet AML requirements and follow KYC rules."}),(0,a.jsx)("p",{children:"We may use your data to assist any law enforcement authority with their investigation or disclose data required by a court order as we may be obliged to by law."}),(0,a.jsx)("h3",{children:"3. Our legitimate interests"}),(0,a.jsx)("p",{children:"We may use anonymized and aggregated data to analyse how Customers use our Services and evaluate the quality and convenience of our product, site operation and functionality."}),(0,a.jsx)("p",{children:"Likewise, we may also use your data to notify you about changes to our policies or new features of Volet."}),(0,a.jsx)("p",{children:"We take a risk-based approach to assess both the profile of users and the transactions they make, as well as to detect and prevent fraudulent and other illegal activities. We collect, use, and store personal data for these purposes."}),(0,a.jsx)("p",{children:"When you contact Customer Care, we keep a record of the conversation. We do this to improve the quality of Services and products, protect our interests in case of disputes, evaluate the quality of the work of the employees, and train them."}),(0,a.jsx)("h3",{children:"4. Your consent"}),(0,a.jsx)("p",{children:"You may opt in to receive emails about Services, and allow us to measure the performance of marketing emails and analyse product use. You may withdraw your consent at any time."}),(0,a.jsx)("p",{children:"To verify your account, we ask you to go through the liveness test to make sure that you are a living person and the documents submitted really belong to you. To achieve this, you will need to turn on the camera and turn your head s

1o that the neural network can analyse the individual features of your face. Such analysis constitutes the processing of a special category of personal data, and can only be carried out based on your consent. The data collection and processing are carried out by a third party, acting as a data processor on our behalf. You can read more about this in the “Disclosure of personal data to third parties” section."}),(0,a.jsx)("h2",{children:"Automated decision-making"}),(0,a.jsx)("p",{children:"We use an automated risk assessment system to analyse the risk profile of the users and ongoing transactions to prevent illegal and fraudulent activities. However, any significant decisions that may impact you will be taken by our employees based on a manual review."}),(0,a.jsx)("h2",{children:"Cookies"}),(0,a.jsxs)("p",{children:["For information on what cookies are and how we use them, please refer to our"," ",(0,a.jsx)(h(),{"data-underline":!0,href:d.qv.DocCookiePolicy,children:"Cookies Policy"}),"."]}),(0,a.jsx)("h2",{children:"How we keep your data secure"}),(0,a.jsx)("p",{children:"We are committed to making sure that your personal data is protected. We implement a variety of security measures to maintain the safety of your personal data when you enter it on the site or otherwise provide it to us."}),(0,a.jsx)("p",{children:"Furthermore, we use data encryption techniques and authentication procedures to prevent unauthorized access to our systems and your data. Only authorized employees are granted physical access to the premises where data is processed and stored. The premises are being watched."}),(0,a.jsx)("p",{children:"All supplied sensitive information is transmitted via Secure Socket Layer (SSL) technology. Card payment information encryption is compliant to PCI DSS."}),(0,a.jsx)("p",{children:"We authorize access to your personal data only for those employees who need it based on their job requirements (for example, customer support staff). All employees who access personal data are bound by a non-disclosure agreement. We implement continual training for our employees in regard to ensuring the security and confidentiality of personal data."}),(0,a.jsx)("p",{children:"Personal data of the users being subjects to GDPR shall be processed only on the servers physically located within the European Union. Personal information of the Canadians shall be stored in Canada."}),(0,a.jsx)("p",{children:"We continuously improve our security procedures to ensure that we are in line with the best industry standards, thus ensuring a high level of protection of your personal data."}),(0,a.jsxs)("p",{children:["We recommend you also adhere to some simple rules that will help ensure your safety. Never use the same password for multiple accounts on different sites and always use a strong password with mixed case letters, numbers, and symbols. Do not tell anyone your Wallet password. Please remember that our employees never ask for user passwords. If someone pretending to be an Volet employee asks you for your password or other login information, do not give it to them and notify us immediately by email to"," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",target:"_blank",rel:"noopener noreferrer nofollow",children:"[email protected]"}),"."]}),(0,a.jsx)("h2",{children:"How long we keep your data"}),(0,a.jsx)("p",{children:"Your personal data will be retained by us for as long as necessary for the specific purpose for which it was collected, unless a longer retention is required by law. Information collected under AML laws requirements shall be kept for 5 years after you close your account. When your personal data is no longer needed and/or the term prescribed by law expires, we securely delete your data."}),(0,a.jsx)("h2",{children:"Disclosure of personal data to third parties"}),(0,a.jsx)("p",{children:"To provide Services, we may be required to share your data with third parties, such as:"}),(0,a.jsx)("div",{"data-scrollable":"true",children:(0,a.jsx)("table",{children:(0,a.jsxs)("tbody",{children:[(0,a.jsxs)("tr",{children:[(0,a.jsx)("th",{children:"To 

1whom we may share your data?"}),(0,a.jsx)("th",{children:"Why do we share it?"}),(0,a.jsx)("th",{children:"Third-party name"})]}),(0,a.jsxs)("tr",{children:[(0,a.jsx)("td",{children:"Financial and banking institutions, such as bank card issuers and bank card acquirers, payment networks, including Visa and Mastercard."}),(0,a.jsx)("td",{children:"To perform payment transactions, you may initiate using our network and your bank card and/or your bank account. Depending on the type of payment chosen by the Customer, payer or buyer, we will share the information with the financial institutions that validate and process each means of payment for corresponding approval, validation, and settlement."}),(0,a.jsx)("td",{children:"May vary depending on the payment method, region and requested service."})]}),(0,a.jsxs)("tr",{children:[(0,a.jsx)("td",{children:"Volet card providers."}),(0,a.jsx)("td",{children:"We may share your information with card issuers to issue and ship the Volet card. We also transfer KYC information to the issuers in accordance with AML legislation."}),(0,a.jsx)("td",{children:"May vary depending on the region and requested service."})]}),(0,a.jsxs)("tr",{children:[(0,a.jsx)("td",{children:"Third-party analytics providers."}),(0,a.jsxs)("td",{children:["To collect metrics and information regarding your use of our website, including evaluating how Customers use Services (\xabUsage Data\xbb), to develop new features, improve existing features or inform sales and marketing strategies, based on our legitimate interest to improve the Services. When we process Usage Data, any personal information is anonymized. The Website uses cookies and other tracking technologies to measure performance and collect metrics. We use GTM pixels to analyse how users interact with the Website and measure the effectiveness of our newsletters. You may find more information about the cookies we use in our"," ",(0,a.jsx)(h(),{"data-underline":!0,href:d.qv.DocCookiePolicy,children:"Cookies Policy"}),"."]}),(0,a.jsxs)("td",{children:['Google Inc., 1600 Amphitheatre Parkway Mountain Vie

1w, CA 94043, USA ("',(0,a.jsx)("strong",{children:"Google"}),'"). Our website uses Google Analytics. On the Website, IP anonymization is enabled. For more information, you may read'," ",(0,a.jsx)("a",{"data-underline":!0,href:"https://policies.google.com/privacy?hl=en",target:"_blank",rel:"noopener noreferrer nofollow",children:"Google Privacy policy"}),". ",(0,a.jsx)("br",{}),'Intertech Services AG- Werftestrasse 4, 6005 Luzern, Switzerland ("',(0,a.jsx)("strong",{children:"Yandex"}),'"). For more information, you may read'," ",(0,a.jsx)("a",{"data-underline":!0,href:"https://yandex.com/legal/confidential/",target:"_blank",rel:"noopener noreferrer nofollow",children:"Yandex Privacy policy"}),"."]})]}),(0,a.jsxs)("tr",{children:[(0,a.jsx)("td",{children:"Third-party ticket-system providers."}),(0,a.jsx)("td",{children:"To facilitate our Customer Care service, and group the related requests, we use a ticket service. The ticket-system service provider does not have access to the content of your emails and is contractually bound to maintain the security and integrity of the processed data."}),(0,a.jsxs)("td",{children:["Zendesk International Ltd., 55 Charlemont Place, Saint Kevin’s, Dublin, D02 F985 Ireland (“",(0,a.jsx)("strong",{children:"Zendesk"}),"”) - a ticket system provider. When you submit a query to Volet via the ticket system, a unique identifier is assigned to you and an account with Zendesk is created. For more information, you may read"," ",(0,a.jsx)("a",{"data-underline":!0,href:"https://www.zendesk.co.uk/company/agreements-and-terms/privacy-policy/",target:"_blank",rel:"noopener noreferrer nofollow",children:"Zendesk Privacy policy"}),"."]})]}),(0,a.jsxs)("tr",{children:[(0,a.jsx)("td",{children:"AML analytics and KYC service providers."}),(0,a.jsx)("td",{children:"Fulfilment of our legal obligations under AML laws and fraud prevention monitoring."}),(0,a.jsxs)("td",{children:['Sum and Substance Ltd, 30 St. Mary Axe, London, England, EC3A 8BF ("',(0,a.jsx)("strong",{children:"Sum&Substance"}),'") - a verification and KYC service provider. For more information, you may read'," ",(0,a.jsx)("a",{"data-underline":!0,href:"https://sumsub.com/privacy-notice/",target:"_blank",rel:"noopener noreferrer nofollow",children:"Sumsub Privacy notice"}),"."]})]}),(0,a.jsxs)("tr",{children:[(0,a.jsx)("td",{children:"Email delivery service providers and online-based survey services providers."}),(0,a.jsx)("td",{children:"We may send you special offers and news you may be interested in. Also, we may ask you to share your experience with Services, so we can improve them."}),(0,a.jsxs)("td",{children:['ECOMZ HOLDING LIMITED, 6B Georgiou Karyou, office 6B, Dasoupoli, Strovolos, Nicosia, Cyprus ("',(0,a.jsx)("strong",{children:"Unisender"}),'") - a marketing email delivery service provider. Unisender may apply technologies allowing to track when you receive and open email sent by us. You may opt out from receiving emails by clicking unsubscribe button in the email. For more information, you may read'," ",(0,a.jsx)("a",{"data-underline":!0,href:"https://ecomz.io/en/privacy-notice/",target:"_blank",rel:"noopener noreferrer nofollow",children:"Unisender Privacy notice"}),".",(0,a.jsx)("br",{}),(0,a.jsx)("br",{}),'Motaev Marx Motaev GbR (MMM GbR), Vahrenwalder Str. 253, 30179 Hanover, Germany ("',(0,a.jsx)("strong",{children:"Questionstar"}),'") - a service used by Volet to create online questionnaires and carry out web-based online surveys. For more information, you may read'," ",(0,a.jsx)("a",{"data-underline":!0,href:"https://www.questionstar.com/privacy-policy",target:"_blank",rel:"noopener noreferrer nofollow",children:"QuestionStar Privacy policy"}),"."]})]}),(0,a.jsxs)("tr",{children:[(0,a.jsx)("td",{children:"Other business partners, suppliers (including but not limited to IT suppliers, card manufacturers, delivery services, etc.) and affiliates."}),(0,a.jsx)("td",{children:"To perform the contract we concluded in your interests, maintain the operation of the Services, fulfil our obligations."}),(0,a.jsx)("td",{children:"Determined on a case-by-case basis and may vary depending on your region."})]}),(0,a.jsxs)("tr",{children:[(0,a.jsx)("td",{children:"To prospective buyers of business."}),(0,a.jsx)("td",{children:"If we buy, sell or transfer in other way any business or assets or in case of an actual or potential merger or similar business combination event, we may share your data to the new data controller. The basis for this processing is legitimate interest. In such cases, sharing personal data is required to facilitate the transaction."}),(0,a.jsx)("td",{children:"Determined on a case-by-case basis."})]}),(0,a.jsxs)("tr",{children:[(0,a.jsx)("td",{children:"To third parties such as courts, law enforcement or governmental authorities, or authorized third parties as required and permitted by law if such disclosure is reasonably necessary."}),(0,a.jsx)("td",{children:"We may disclose your information to comply with our legal obligations, to respond to requests relating to criminal investigation, alleged or suspected illegal activities, or any other activities that may expose us or other users to legal liabilities, as well as to enforce our site policies and protect our or others’ rights, property or safety."}),(0,a.jsx)("td",{children:"Determined on case-by-case basis."})]})]})})}),(0,a.jsx)("p",{children:"Certain partners and service providers may change. This section shall be updated in a timely manner if such update is possible and reasonable."}),(0,a.jsx)("h2",{children:"Cross border transfer of data"}),(0,a.jsx)("p",{children:"Some of our partners and employees may be located outside Canada and the European Economic Area (EEA), so we may transfer data to the third countries. Such a transfer may only take place if appropriate guarantees are in place to ensure an adequate level of protection of the rights of the personal data subjects. Our partners and providers are required to provide an adequate level of data protection in accordance with the terms of the contract we enter into with them."}),(0,a.jsx)("h2",{children:"Links to other websites"}),(0,a.jsx)("p",{children:"The Website may contain links to third-party websites. These third-party websites have separate and independent terms of use and privacy policies. Please refer to their policies before submitting any personal data to these websites. Therefore, we have no responsibility or liability for the content and activities of these websites."}),(0,a.jsx)("h2",{children:"Data subject rights"}),(0,a.jsx)("p",{children:"You have the right to exercise control over the way in which your personal data is processed:"}),(0,a.jsxs)("p",{children:[(0,a.jsx)("strong",{children:"Right to be informed."})," You are entitled to know how and why we process personal data. Therefore, we publish this Privacy Notice and are always ready to answer any of your questions."]}),(0,a.jsxs)("p",{children:[(0,a.jsx)("strong",{children:"Right of access."})," You can ask us to confirm whether we are processing your personal data. You can ask for detailed information about how we collect, process, use, store and share your data."]}),(0,a.jsxs)("p",{children:[(0,a.jsx)("strong",{children:"Right to re

1ctification."})," We strive to maintain the integrity of the data we store and keep it up to date. Therefore, you can always ask us to clarify and correct outdated or inaccurate information."]}),(0,a.jsxs)("p",{children:[(0,a.jsx)("strong",{children:"Right to erasure."})," You may request to delete your personal data. You may file a request by creating a ticket in a Help area or by sending an e-mail to"," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",target:"_blank",rel:"noopener noreferrer nofollow",children:"[email protected]"}),". Bear in mind that as a regulated entity, we are required by law to store some of your personal data, so we can’t remove all of your info from the system. The right to erasure will not apply to such processing. But we’ll delete information that’s no longer needed."]}),(0,a.jsxs)("p",{children:[(0,a.jsx)("strong",{children:"Restrict and object to processing."})," You have the right to restrict or object to the processing of your personal data."]}),(0,a.jsxs)("p",{children:[(0,a.jsx)("strong",{children:"Right to data portability."})," You may ask us to transfer your data to another entity providing similar services, if it is technically possible to do so and unless it is not restricted by law. The data will be transmitted in a structured, commonly used and machine-readable format."]}),(0,a.jsxs)("p",{children:[(0,a.jsx)("strong",{children:"Right to withdraw consent."})," Where we have specifically requested your consent to process your personal data, you have the right to withdraw your consent at any time by changing your account settings or by sending an e-mail to"," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",target:"_blank",rel:"noopener noreferrer nofollow",children:"[email protected]"})," ","specifying which consent you are withdrawing. You can opt out of receiving materials from us electronically by clicking the \xabunsubscribe\xbb link in any e-mail communications we might send you."]}),(0,a.jsxs)("p",{children:[(0,a.jsx)("strong",{children:"Right to complain."})," You may lodge a complaint if you feel like your rights have been violated. Please refer to Section 14 for further details."]}),(0,a.jsx)("p",{children:"We will reply to your request within 30 days once we receive it. If we expect that responding to you will take longer, we will let you know."}),(0,a.jsxs)("p",{children:["You may exercise your rights described above by sending an e-mail to"," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",target:"_blank",rel:"noopener noreferrer nofollow",children:"[email protected]"}),". Before we provide you with any confidential information, we must ensure that you are indeed the person you claim to be. For example, we will ask you to send a request from the mail associated with your Volet account, or in rare cases to pass SumSub verification."]}),(0,a.jsx)("p",{children:"We will provide you with the requested data free of charge. However, if the requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee considering the administrative costs of providing the information or communication or taking the action requested."}),(0,a.jsx)("p",{children:"Kindly note that there may be legal reasons when we will not be able to fulfil your request."}),(0,a.jsx)("h2",{children:"Filing a complaint"}),(0,a.jsxs)("p",{children:["If you believe that your rights have been violated, you may file a complaint to the Office of the"," ",(0,a.jsx)("a",{"data-underline":!0,href:"https://www.priv.gc.ca/en/",target:"_blank",rel:"noopener noreferrer nofollow",children:"Privacy Commissioner of Canada"}),". You may also file a complaint with the supervisory authority in your country of residence, place of work or place of the alleged violation. If you are in the EU, you can find the relevant supervisory authority on the"," ",(0,a.jsx)("a",{"data-underline":!0,href:"https://edpb.europa.eu/about-edpb/about-edpb/members_en",target:"_blank",rel:"noopener noreferrer nofollow",children:"European Data Protection Board"})," ","website."]}),(0,a.jsx)("h2",{children:"Changes to our Privacy Notice"}),(0,a.jsx)("p",{children:"Any changes we make to our Privacy Notice in the future will be posted directly on this page and, where appropriate, notified to you by e-mail."}),(0,a.jsx)("h2",{children:"Contact"}),(0,a.jsxs)("p",{children:["Questions, comments and requests regarding our Privacy Notice are welcomed and should be addressed to our Data protection officer at"," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",target:"_blank",rel:"noopener noreferrer nofollow",children:"[email protected]"}),"."]})]})}},latest:"v1"},"privacy-notice-costa-rica":{versions:{v1:function(){return(0,a.jsxs)("div",{"data-template":"default",children:[(0,a.jsx)("h2",{children:"Introduction"}),(0,a.jsxs)("p",{children:["The Privacy Notice together with Volet Terms and Conditions (and any other document referred to therein) describes how we 

1collect, process, use and disclose your information, including any personal data we collect from you, or which you provide to us through the website"," ",(0,a.jsx)("a",{"data-underline":!0,href:d.qv._Promo,target:"_blank",rel:"noopener noreferrer nofollow",children:"www.volet.com"})," ","(hereinafter referred to as the Website). When you contact us via the Website, complete any forms or submit any details using the Website, we will collect, use and disclose your personal information as described in this Privacy Notice."]}),(0,a.jsx)("h2",{children:"Details of the Data Controller and the Data Protection Officer"}),(0,a.jsx)("p",{children:"The Data Controller is the company that determines the purpose and means of personal data processing:"}),(0,a.jsx)("p",{children:"Second February Limitada, registration number: 3-102-918773, registered address: Costa Rica, San Jos\xe9, Mata Redonda, Sabana Oeste, twelfth avenue, ninetieth street, ERP Lawyers Law Firm offices."}),(0,a.jsxs)("p",{children:["Privacy related questions may be addressed to"," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",target:"_blank",rel:"noopener noreferrer nofollow",children:"[email protected]"}),"."]}),(0,a.jsx)("h2",{children:"What is personal data?"}),(0,a.jsx)("p",{children:"Personal information is data about an “identifiable individual”. It is information that on its own or combined with other pieces of data, can identify you as an individual."}),(0,a.jsx)("p",{children:"The General Data Protection Regulation (GDPR) (EU Regulation 2016/679) defines personal data as \xabany information relating to an identified or identifiable natural person (data subject), directly or indirectly, by reference to an identifier, such as name, an identification number, location data, an online identifier\xbb. Simply put, personal information is any information about you that enables your identification."}),(0,a.jsx)("p",{children:"The personal data we collect and use is described in this Privacy Notice."}),(0,a.jsx)("h2",{children:"Personal data we collect and process"}),(0,a.jsx)("p",{children:"We obtain certain personal data from you directly:"}),(0,a.jsx)("h3",{children:"1. Information you provide when you register:"}),(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"Name, surname;"}),(0,a.jsx)("li",{children:"Email, hashed password."})]}),(0,a.jsx)("h3",{children:"2. When you verify your account:"}),(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"Mobile phone number;"}),(0,a.jsx)("li",{children:"Identity document data, such as document type, issuing country, number, expiry date, MRZ, information embedded into document barcodes (may vary depending on the document), and security features;"}),(0,a.jsx)("li",{children:"Facial image data, such as photos of the face (including selfie images), a photo or scan of the face on the identification document, video screenshots and sound recordings;"}),(0,a.jsx)("li",{children:"Biometric data such as facial features."})]}),(0,a.jsx)("h3",{children:"3. When we inquire about your transactions to prevent fraud and misuse of your account:"}),(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"Information required to prove the source of funds, such as documents, bank statements, verbal explanations, and screenshots;"}),(0,a.jsx)("li",{children:"Information needed to indicate the purpose and economic sense of a financial transaction;"}),(0,a.jsx)("li",{children:"Information you fill in the questionnaire to prove your capacity and understanding of the consequences of your actions."})]}),(0,a.jsx)("h3",{children:"4. When you communicate with us:"}),(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"Your contact email;"}),(0,a.jsx)("li",{children:"Content of your communication, messages, and files you attach to your messages;"}),(0,a.jsx)("li",{children:"Unique ticket system identifier;"}),(0,a.jsx)("li",{children:"Technical data related to your messages (including date, time zone, environment, etc.)."})]}),(0,a.jsx)("h3",{children:"5. Transaction information:"}),(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"Details of your Wallets, a unique identifier in System, Volet debit card details;"}),(0,a.jsx)("li",{children:"Payments performed within your account, including date, time, amount, currencies, participants associated with the transaction, messages sent and received with the payment, merchant information, payment methods used, technical usage data, and geolocation information;"}),(0,a.jsx)("li",{children:"Bank card details that you may connect to your account, such as cardholder name, expiry date, first 6 and last 4 digits of the card number."})]}),(0,a.jsx)("h3",{children:"6. Information from your device:"}),(0,a.jsx)("ul",{children:(0,a.jsx)("li",{children:"IP address, environment, log-in information, browser type and settings, time zone, the operating system, the type of device you use, a unique device identifier, screen size, mobile network information, mobile operating system and type of mobile browser you are using, date, time and length of your visit."})}),(0,a.jsx)("p",{children:"We could receive your personal data from the following third parties:"}),(0,a.jsxs)("ul",{children:[(0,a.jsx)("li",{children:"Information received by one of our affiliates;"}),(0,a.jsx)("li",{children:"Information from payment providers;"}),(0,a.jsx)("li",{children:"Information received by the card schemes (e.g., Visa, Mastercard, UnionPay, etc.), fraud prevention agencies, credit reference agencies, government and law enforcement agencies;"}),(0,a.jsx)("li",{children:"Information received via public sources like company registers, websites for enhanced due diligence checks."})]}),(0,a.jsx)("h2",{children:"Legal basis and use of your personal data"}),(0,a.jsx)("p",{children:"We only process your personal data where a lawful basis exists. 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You can find out more about this in the "Disclosure of personal data to third parties" section.'}),(0,a.jsx)("p",{children:"We may send you important information about the System, login confirmation, suspicious authorization attempts and completed transactions notifications, as well as provide technical support."}),(0,a.jsx)("p",{children:"We process personal data to assist you in resolving issues related to the use of System, when you contact Customer Care via ticket, email, or phone."}),(0,a.jsx)("h3",{children:"2. Our legal obligation"}),(0,a.jsx)("p",{children:"We process your personal data to comply with our legal obligations, in particular the requirements of anti-money laundering and terrorist financing legislation, to verify and confirm your identity as part of the KYC procedure."}),(0,a.jsx)("p",{children:"When you initiate a crypto transaction, we also analyze your data to meet AML requirements and follow KYC rules."}),(0,a.jsx)("p",{children:"We may use your data to assist any law enforcement authority with their investigation or disclose data required by a court order as we may be obliged to by law."}),(0,a.jsx)("h3",{children:"3. Our legitimate interests"}),(0,a.jsx)("p",{children:"We may use anonymized and aggregated data to analyze how Customers use our Services and evaluate the quality and convenience of our product, site operation and functionality."}),(0,a.jsx)("p",{children:"Likewise, we may also use your data to notify you about changes to our policies or new features of Volet."}),(0,a.jsx)("p",{children:"We take a risk-based approach to assess both the profile of users and the transactions they make, as well as to detect and prevent fraudulent and other illegal activities. We collect, use, and store personal data for these purposes."}),(0,a.jsx)("p",{children:"When you contact Customer Care, we keep a record of the conversation. We do this to improve the quality of Services and products, protect our interests in case of disputes, evaluate the quality of the work of the employees, and train them."}),(0,a.jsx)("h3",{children:"4. Your consent"}),(0,a.jsx)("p",{children:"You may opt in to receive emails about Services, and allow us to measure the performance of marketing emails and analyze product use. You may withdraw your consent at any time."}),(0,a.jsx)("p",{children:"To verify your account, we ask you to go through the liveness test to make sure that you are a living person and the documents submitted really belong to you. To achieve this, you will need to turn on the camera and turn your head s

1o that the neural network can analyze the individual features of your face. Such analysis constitutes the processing of a special category of personal data, and can only be carried out based on your consent. The data collection and processing are carried out by a third party, acting as a data processor on our behalf. You can read more about this in the “Disclosure of personal data to third parties” section."}),(0,a.jsx)("h2",{children:"Cookies"}),(0,a.jsxs)("p",{children:["For information on what cookies are and how we use them, please refer to our"," ",(0,a.jsx)(h(),{"data-underline":!0,href:d.qv.DocCookiePolicy,children:"Cookies Policy"}),"."]}),(0,a.jsx)("h2",{children:"How we keep your data secure"}),(0,a.jsx)("p",{children:"We are committed to making sure that your personal data is protected. We implement a variety of security measures to maintain the safety of your personal data when you enter it on the site or otherwise provide it to us."}),(0,a.jsx)("p",{children:"Furthermore, we use data encryption techniques and authentication procedures to prevent unauthorized access to our systems and your data. Only authorized employees are granted physical access to the premises where data is processed and stored. The premises are being watched."}),(0,a.jsx)("p",{children:"All supplied sensitive information is transmitted via Secure Socket Layer (SSL) technology. Card payment information encryption is compliant to PCI DSS."}),(0,a.jsx)("p",{children:"We authorize access to your personal data only for those employees who need it based on their job requirements (for example, customer support staff). All employees who access personal data are bound by a non-disclosure agreement. We implement continual training for our employees in regard to ensuring the security and confidentiality of personal data."}),(0,a.jsx)("p",{children:"Personal data of the users being subjects to GDPR shall be processed only on the servers physically located within the European Union."}),(0,a.jsx)("p",{children:"We continuously improve our security procedures to ensure that we are in line with the best industry standards, thus ensuring a high level of protection of your personal data."}),(0,a.jsxs)("p",{children:["We recommend you also adhere to some simple rules that will help ensure your safety. Never use the same password for multiple accounts on different sites and always use a strong password with mixed case letters, numbers, and symbols. Do not tell anyone your Wallet password. Please remember that our employees never ask for user passwords. If someone pretending to be a Volet employee asks you for your password or other login information, do not give it to them and notify us immediately by email to"," ",(0,a.jsx)("a",{"data-underline":!0,href:"mailto:[email protected]",target:"_blank",rel:"noopener noreferrer nofollow",children:"[email protected]"}),"."]}),(0,a.jsx)("h2",{children:"How long we keep your data"}),(0,a.jsx)("p",{children:"Your personal data will be retained by us for as long as necessary for the specific purpose for which it was collected, unless a longer retention is required by law. Information collected under AML laws requirements shall be kept for 5 years after you close your account. When your personal data is no longer needed and/or the term prescribed by law expires, we securely delete your data."}),(0,a.jsx)("h2",{children:"Disclosure of personal data to third parties"}),(0,a.jsx)("p",{children:"To provide Services, we may be required to share your data with third parties, such as:"}),(0,a.jsx)("div",{"data-scrollable":"true",children:(0,a.jsx)("table",{children:(0,a.jsxs)("tbody",{children:[(0,a.jsxs)("tr",{children:[(0,a.jsx)("th",{children:"To whom we may share your data?"}),(0,a.jsx)("th",{children:"Why do we share it?"}),(0,a.jsx)("th",{children:"Third-party name"})]}),(0,a.jsxs)("tr",{children:[(0,a.jsx)("td",{children:"Financial and banking institutions, such as bank card issuers and bank card acquirers, payment networks, including Visa and Mastercard."}),(0,a.jsx)("td",{children:"To perform payment transactions, you may initiate using our network and your bank card and/

1or your bank account. Depending on the type of payment chosen by the Customer, payer or buyer, we will share the information with the financial institutions that validate and process each means of payment for corresponding approval, validation, and settlement."}),(0,a.jsx)("td",{children:"May vary depending on the payment method, region and requested service."})]}),(0,a.jsxs)("tr",{children:[(0,a.jsx)("td",{children:"Volet card providers."}),(0,a.jsx)("td",{children:"We may share your information with card issuers to issue and ship the Volet card. We also transfer KYC information to the issuers in accordance with AML legislation."}),(0,a.jsx)("td",{children:"May vary depending on the region and requested service."})]}),(0,a.jsxs)("tr",{children:[(0,a.jsx)("td",{children:"Third-party analytics providers."}),(0,a.jsxs)("td",{children:["To collect metrics and information regarding your use of our website, including evaluating how Customers use Services (\xabUsage Data\xbb), to develop new features, improve existing features or inform sales and marketing strategies, based on our legitimate interest to improve the Services. When we process Usage Data, any personal information is anonymized. The Website uses cookies and other tracking technologies to measure performance and collect metrics. We use GTM pixels to analyze how users interact with the Website and measure the effectiveness of our newsletters. You may find more information about the cookies we use in our"," ",(0,a.jsx)(h(),{"data-underline":!0,href:d.qv.DocCookiePolicy,children:"Cookies Policy"}),"."]}),(0,a.jsxs)("td",{children:['Google Inc., 1600 Amphitheatre Parkway Mountain Vie

1w, CA 94043, USA ("',(0,a.jsx)("strong",{children:"Google"}),'"). Our website uses Google Analytics. On the Website, IP anonymization is enabled. For more information, you may read'," ",(0,a.jsx)("a",{"data-underline":!0,href:"https://policies.google.com/privacy?hl=en",target:"_blank",rel:"noopener noreferrer nofollow",children:"Google Privacy policy"}),"."]})]}),(0,a.jsxs)("tr",{children:[(0,a.jsx)("td",{children:"Third-party ticket-system providers."}),(0,a.jsx)("td",{children:"To facilitate our Customer Care service, and group the related requests, we use a ticket service. The ticket-system service provider does not have access to the content of your emails and is contractually bound to maintain the security and integrity of the processed data."}),(0,a.jsxs)("td",{children:["Zendesk International Ltd., 55 Charlemont Place, Saint Kevin’s, Dublin, D02 F985 Ireland (“",(0,a.jsx)("strong",{children:"Zendesk"}),"”) - a ticket system provider. When you submit a query to Volet via the ticket system, a unique identifier is assigned to you and an account with Zendesk is created. For more information, you may read"," ",(0,a.jsx)("a",{"data-underline":!0,href:"https://www.zendesk.co.uk/company/agreements-and-terms/privacy-policy/",target:"_blank",rel:"noopener noreferrer nofollow",children:"Zendesk Privacy policy"}),"."]})]}),(0,a.jsxs)("tr",{children:[(0,a.jsx)("td",{children:"AML analytics and KYC service providers."}),(0,a.jsx)("td",{children:"Fulfilment of our legal obligations under AML laws and fraud prevention monitoring."}),(0,a.jsxs)("td",{children:['Sum and Substance Ltd, 30 St. Mary Axe, London, England, EC3A 8BF ("',(0,a.jsx)("strong",{children:"Sum&Substance"}),'") - a verification and KYC service provider. For more information, you may read'," ",(0,a.jsx)("a",{"data-underline":!0,href:"https://sumsub.com/privacy-notice/",target:"_blank",rel:"noopener noreferrer nofollow",children:"Sumsub Privacy notice"}),".",(0,a.jsx)("br",{}),(0,a.jsx)("br",{}),'Crystal Blockchain B.V., Strawinskylaan 3051, 1077ZX Amsterdam, the Netherlands ("',(0,a.jsx)("strong",{children:"Crystal"}),'") - a cryptocurrency transaction analysis and monitoring provider. For more information, you may read'," ",(0,a.jsx)("a",{"data-underline":!0,href:"https://crystalintelligence.com/privacy-notice/",target:"_blank",rel:"noopener noreferrer nofollow",children:"Crystal Privacy policy"}),"."]})]}),(0,a.jsxs)("tr",{children:[(0,a.jsx)("td",{children:"Email delivery service providers and online-based survey services providers."}),(0,a.jsx)("td",{children:"We may send you special offers and news you may be interested in. Also, we may ask you to share your experience with Services, so we can improve them."}),(0,a.jsxs)("td",{children:['ECOMZ HOLDING LIMITED, 6B Georgiou Karyou, office 6B, Dasoupoli, Strovolos, Nicosia, Cyprus ("',(0,a.jsx)("strong",{children:"Unisender"}),'") - a marketing email delivery service provider. Unisender may apply technologies allowing to track when you receive and open email sent by us. You may opt out from receiving emails by clicking unsubscribe button in the email. For more information, you may read'," ",(0,a.jsx)("a",{"data-underline":!0,href:"https://ecomz.io/en/privacy-notice/",target:"_blank",rel:"noopener noreferrer nofollow",children:"Unisender Privacy notice"}),".",(0,a.jsx)("br",{}),(0,a.jsx)("br",{}),'Motaev Marx Motaev GbR (MMM GbR), Vahrenwalder Str. 253, 30179 Hanover, Germany ("',(0,a.jsx)("strong",{children:"Questionstar"}),'") - a service used by Volet to create online questionnaires and carry out web-based online surveys. For more information, you may read'," ",(0,a.jsx)("a",{"data-underline":!0,href:"https://www.questionstar.com/privacy-policy",target:"_blank",rel:"noopener noreferrer nofollow",children:"QuestionStar Privacy policy"}),"."]})]}),(0,a.jsxs)("tr",{children:[(0,a.jsx)("td",{children:"Other business partners, suppliers (including but not limited to IT suppliers, card manufacturers, delivery services, etc.) and affiliates."}),(0,a.jsx)("td",{children:"To perform the contract we concluded in your interests, maintain the operation of the Services, fulfil our obligations."}),(0,a.jsx)("td",{children:"Determined on a case-by-case basis and may vary depending on your region."})]}),(0,a.jsxs)("tr",{children:[(0,a.jsx)("td",{children:"To prospective buyers of business."}),(0,a.jsx)("td",{children:"If we buy, sell or transfer in other way any business or assets or in case of an actual or potential merger or similar business combination event, we may share your data to the new data controller. The basis for this processing is legitimate interest. In such cases, sharing personal data is required to facilitate the transaction."}),(0,a.jsx)("td",{children:"Determined on a case-by-case basis."})]}),(0,a.jsxs)("tr",{children:[(0,a.jsx)("td",{children:"To third parties such as courts, law enforcement or governmental authorities, or authorized third parties as required and permitted by law if such disclosure is reasonably necessary."}),(0,a.jsx)("td",{children:"We may disclose your information to comply with our legal obligations, to respond to requests relating to criminal investigation, alleged or suspected illegal activities, or any other activities that may expose us or other users to legal liabilities, as well as to enforce our site policies and protect our or others’ rights, property or safety."}),(0,a.jsx)("td",{children:"Determined on case-by-case basis."})]})]})})}),(0,a.jsx)("p",{children:"Certain partners and service providers may change. This section shall be updated in a timely manner if such update is possible and reasonable."}),(0,a.jsx)("h2",{children:"Links to other websites"}),(0,a.jsx)("p",{children:"The Website may contain links to third-party websites. These third-party websites have separate and independent terms of use and privacy policies. Please refer to their policies before submitting any personal data to these websites. Therefore, we have no responsibility or liability for the content and activities of these websites."}),(0,a.jsx)("h2",{children:"Data subject rights"}),(0,a.jsx)("p",{children:"You have the right to exercise control over the way in which your personal data is processed:"}),(0,a.jsxs)("p",{children:[(0,a.jsx)("strong",{children:"Right to be informed."})," You are entitled to know how and why we process personal data. 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