Privacy Policy

Effective Date: December 24

1. ABOUT THIS POLICY

1.1. This is the Privacy Policy for Digvaluable Ltd., a company incorporated in the British Virgin Islands (the “Company”), and references in this Privacy Policy to “we”, “us”, “our” shall be construed as a reference to the Company.

1.2. This Privacy Policy describes how we may collect, use, disclose and process your personal data when you:

1.2.1. access or use our website located at https://ssi.sosovalue.com/ (the “Website”) and services; and/or

1.2.2. provide us with your personal data.

1.3. We will onlyuse your personal data where you have given us your consent or where we have other lawful basis for doing so, and in the manner set out in this Privacy Policy.

1.4. By providing us with personal data, you:

1.4.1. acknowledge that our collection, use, disclosure and processing of personal data will be in accordance with this Privacy Policy, including, for the avoidance of doubt, the cross-jurisdictional transfer of your data; and

1.4.2. consent to such collection, use and processing of personal data by us in accordance with this Privacy Policy.

DO NOT provide any personal data to us if you do not accept this Privacy Policy.

1.5. This Privacy Policy supplements but does not supersede or replace any consents you may have provided to us, or any other agreements or arrangements that you may have with us, in respect of your personal data.

1.6. The Website may contain links to other websites that are not owned or maintained by us. These links are provided only for your convenience. You may also be accessing the Website through third party websites and/or platforms. This Privacy Policy only applies to the Website. When visiting these third party websites, their privacy policies apply. These third parties may collect, use, disclose or process your personal data for their own purposes, and without our involvement or reference to us. We are not liable or responsible for the collection, use, disclosure or processing of your personal data by such third parties.

1.7. If you have any feedback or issues in relation to your personal data, or about this Privacy Policy, or wish to make a complaint to us, you may contact ourData Protection Officer at:

Email: [e-mail]

When you contact us, we may require that you submit certain forms or provide certain information, including verification of your identity, before we are able to respond.

2. AMENDMENTS TO THIS PRIVACY POLICY

2.1. We may amend this Privacy Policy from time to time without notice to you, in compliance with applicable laws or as we update our data usage and handling processes. When making such amendments, we will update the “Effective Date” at the top of this Privacy Policy. The updated Privacy Policy will supersede earlier versions and will apply to personal data provided to us previously. All changes to the Privacy Policy will take effect immediately when we post them. You are expected to check https://sosovalue.gitbook.io/sosovalue-indices/resources/privacy-policy from time to time so that you are aware of any changes to this Privacy Policy as such changes are binding on you.

3. WHAT PERSONAL DATA WE COLLECT

3.1. What is personal data. “Personal data” is data that can be used to identify a natural person. Examples of personal data include name, address, contact details, identification numbers, financial information, transactional information based on your activities on the Website, applications and platforms, telephone numbers, email address, images, and any other information of a personal nature. This includes, but is not limited to, your browser fingerprint, device ID and information you provide when you connect a digital wallet to the Website, such as your digital wallet address, internet protocol (IP) address, geolocation data, information regarding your transaction history, information you provide each time you wish to execute a transaction via your digital wallet through the Website, and usage information, e.g. information about how you use the Website and interact with us.

This information is necessary for the operation of the Website and services, to personalise your experience, and to ensure the security of your transactions. By connecting your wallet to the Website, you acknowledge that your transaction history and other associated information will be accessible to us and may also be publicly available as required by the nature of blockchain networks.

3.2. Voluntary provision of personal data.We may collect personal data (1) that you voluntarily provide to us; or (2) from third parties; or (3) through your use of our (or our services provider’s) digital technologies and services (please see Section 4: How We Collect Personal Data for further details). What personal data we collect depends on the purposes for which the personal data is collected and what you have chosen to provide.

Where our collection is based on consent, you can choose not to provide us with personal data. You also have the right to withdraw your consent for us to continue collecting, using,disclosing and processing your personal data, by contacting us in accordance with Paragraph 1.7. It may also be possible to update, amend and/or delete certain personal data which you had provided to us via the Website. If you withdraw your consent for us to collect your personal data and/or delete the personal data provided to us, it may not be possible for us to fulfil the purposes for which we require the personal data, including processing your transactions or providing you with the products and services that you require. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us.

Please note that withdrawal of your consent will not affect our collection, use and/or disclosure of personal data where such collection, use and/or disclosure without consent is permitted or required under applicable laws.

3.3. Providing personal data belonging to others. In certain circumstances, you may also provide us with personal data of persons other than yourself (such as your family members and next-of-kin). If you do so, you represent and warrant that you have brought this Privacy Policy to his/her attention, informed him/her of the purposes for which we are collecting his/her personal data and that he/she has consented to your disclosure of his/her personal data to us for those purposes and accepts this Privacy Policy. You agree to indemnify and hold us harmless from and against any and all claims by such individuals relating to our collection, use and disclosure of such personal data in accordance with the terms of this Privacy Policy.

3.4. Accuracy and completeness of personal data. You are responsible for ensuring that all personal data that you provide to us is true, accurate and complete. You are responsible for informing us of any changes to your personal data.

3.5. Minors. The Website and/or services are not intended to be accessed or used by children, minors or persons who are not of legal age as determined based on jurisdictional laws applicable to these persons. If you are a parent or guardian and you have reason to believe your child or ward has provided us with their personal data without your consent, please contact us. If we become aware that we have collected personal data from anyone who is not of legal age without parental consent, we may take steps to remove that information from our servers.

3.6. Information we will never collect: We will never ask you to share your private keys to your digital wallet or other security information that could be used to access your digital wallet without your explicit consent and action. Never trust anyone or any website that asks you to enter such private keys or similar security information.

4. HOW WE COLLECT PERSONAL DATA

4.1. Personal data you provide. Wecollect personal data that is relevant to our relationship with you.We may collect your personal data directly or indirectly through various channels, such as when:

4.1.1. you register an account with us through the Website;

4.1.2. you access, download or use the Website and services;

4.1.3. you authorise us to obtainyour personal data from a third party;

4.1.4. you enter into agreements with us;

4.1.5. you transact with us, contact us or request that we contact you through various communication channels, for example, through social media platforms, messenger platforms, face-to-face meetings, telephone calls, emails, fax and letters;

4.1.6. you request to be included in an e-mail or our mailing list;

4.1.7. you attend events or functions organised by us;

4.1.8. we seek information about you and receive your personal data in connection with your relationship with us; and

4.1.9. when you submit your personal data to us for any other reason.

4.2. Personal data provided by others. Depending on your relationship with us,we may also collectyour personal data from third party sources, for example, from:

4.2.1. any third parties whom you have authorised us to obtain your personal data from;

4.2.2. entities in which you (or a party connected to you) have an interest;

4.2.3. our business partners such as third parties providing services to us;

4.2.4. your family members or friends who provide your personal data to us on your behalf; and/or

4.2.5. public agencies or other public sources.

5. WHAT WE DO WITH YOUR PERSONAL DATA

5.1. What we do. We collect,use, disclose and process your personal data where:

5.1.1. you have voluntarily provided us with your personal data;

5.1.2. you have given us consent;

5.1.3. you have shared your personal data in the public domain, including on social media or other communication channels that may be publicly viewable;

5.1.4. necessary to comply with our legal or regulatory obligations, e.g. responding to valid requests from public authorities;

5.1.5. necessary to support our legitimate business interests, provided that this does not override your interests or rights; and

5.1.6. necessary to perform a transaction you have entered into with us, or provide a service that you have requested or require from us.

5.2. General purposes. We collect, use, disclose and process your personal data for purposes connected or relevant to our business, to manage your relationship with us. Such purposes would include:

5.2.1. carrying out your transactions with us and our business partners, taking steps as may be directed by you, or to provide products and/or services to you;

5.2.2. facilitating your use of the Website, including verifying your digital wallet and establishing your identity;

5.2.3. monitoring the usage of the Website and services;

5.2.4. organising community events;

5.2.5. facilitating business asset transactions;

5.2.6. evaluating or conducting a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which assets transferred comprise any personal data relating to users of the Website and services;

5.2.7. communicating with you, and assisting you with your queries, requests, applications, complaints, and feedback;

5.2.8. resolving any disputes, investigating any complaint, claim or dispute or any actual or suspected illegal or unlawful conduct and/or investigating and deterring against fraudulent, unauthorised or illegal activities;

5.2.9. administrative purposes, including finance, IT and HR purposes, quality assurance and staff training, and compliance with internal policies and procedures, including audit, accounting, risk management and record keeping;

5.2.10. subject to Paragraphs 5.4 and 5.5 below, notifying you of special promotions, offers and events by way of advertisements and marketing communications sent to you by way of email and other means adopted by us and/or our advertising partners, as permitted by applicable laws;

5.2.11. sending communications to you (including surveys) for the purpose of developing new products and services or evaluation and improvement of our existing products and services;

5.2.12. security purposes, e.g. protecting the Website from unauthorised access or usage and to monitor for security threats;

5.2.13. compliance with any legal or regulatory obligations, applicable laws, regulations, codes of practices, guidelines, or rules (including anti-money laundering, know-your-client and countering the financing of terrorism laws and rules), or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

5.2.14. managing and engaging third parties or data processors that provide services to us, e.g. IT services, technological services, delivery services, and other professional services;

5.2.15. contacting you in respect of any matters relating to your use of the Website, your transactions with us and our business partners;

5.2.16. carrying out our legitimate business interests;

5.2.17. such purposes that may be informed to you when your personal data is collected and any other purposes for which you have provided your personal data;

5.2.18. conducting data analytics and research for various purposes (including but not limited to identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving the Website, services, marketing and your experience);

5.2.19. transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in the British Virgin Islands or abroad, for the aforementioned purposes; and/or

5.2.20. any other reasonable purposes related to the aforesaid.

Where personal data is used for a new purpose and where required under applicable law, we shall obtain your consent.

5.3. Legitimate business interests. We may also collect, use,disclose and process your personal data for the following purposes to support our legitimate business interests, provided that this does not override your interests or rights, which include:

5.3.1. operation and improvement of our business, products and the Website;

5.3.2. managing our business and relationship with you, and providing services to our customers;

5.3.3. assistance of carrying out corporate restructuring plans;

5.3.4. complying with internal policies and procedures;

5.3.5. protecting our rights and interests, and those of our customers;

5.3.6. enforcing our terms and conditions, and obligations owed to us, or protecting ourselves from legal liability;

5.3.7. managing our investor and shareholder relations; and

5.3.8. process or share your personal data to facilitate acquisitions, mergers, or transfers of our business.

Marketing purposes. In order for us to market products, events and services which are of specific interest and relevance to you, we may analyse and rely on your personal data provided to us, or data collected from your interactions with us. However, no marketing, using your personal data in non-aggregated and/or identifiable form, would be carried out unless you have provided us with your consent (whether express or deemed) to use your personal data for such marketing purposes. If you do not want us to use your personal data for the purposes of marketing you can withdraw your consent at any time by contacting us in accordance with Paragraph 1.7 above.

5.4. Use permitted under applicable laws. We may also collect, use, disclose and process your personal data for other purposes, without your knowledge or consent, where this is required or permitted by law. Your personal data may be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defence of a legal claim. We will not delete personal data if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

5.5. Contacting you. When we contact or send you information for the above purposes and purposes for which you have consented, we may do so by post, e-mail, text message, telephone or such other means provided by you.If you do not wish to receive any communication or information from us, or wish to restrict the manner by which we may contact or send you information, you may contact us in accordance with Paragraph 1.7 above.

6. USE OF AUTOMATED DATA COLLECTION TECHNOLOGIES

6.1. Cookies. In order to improve our products or services, we collect data by way of “cookies”. A cookie is a small file of letters and numbers that we store via your browser on the hard drive of your computer or mobile device. There are three main types of cookies:

6.1.1. Session cookies: specific to a particular visit and limited to sending session identifiers (random numbers generated by the server) so you do not have to re-enter information when you navigate to a new page or check out. Session cookies are not permanently stored on your device and are deleted when the browser closes;

6.1.2. Persistent cookies: record information about your preferences and are stored in your browser cache or mobile device; and

6.1.3. Third party cookies: placed by someone other than us which may gather data across multiple websites or sessions

6.2. How we use cookies. We use cookies for the following purposes:

6.2.1. Strictly necessary: These cookies are essential for you to browse the Website and use its features. The information collected relates to the operation of the Website (e.g. website scripting language and security tokens) and enables us to provide you with the service you have requested.

6.2.2. Functionality: These cookies remember the choices you have made, for example the country you visit the Website from, your language and any changes you have made to text size and other parts of the web pages that you can customise to improve your user experience and to make your visits more tailored and enjoyable.

6.2.3. Performance/analytics: These cookies collect information on how users use the Website, for example which pages you visit most often, whether you receive any error messages and how you arrived at the Website. Information collected by these cookies is used only to improve your use of the Website. These cookies are sometimes placed by third party providers of web traffic and analysis services, such as Google Analytics. For information on how Google processes and collects your information and how you can opt out, please click here.

6.2.4. Targeting or advertising: These cookies collect information about your browsing habits and inferred interests to make advertising more relevant to you. They are also used to limit the number of times you see an advert as well as to measure the effectiveness of an advertising campaign. These cookies are usually placed by third party advertising networks. They remember the other websites you visit and this information is shared with third party organisations, for example advertisers.

6.2.5. Social media: These cookies allow users to share content on the Website on social media such as Twitter/X. These cookies are not within our control. Please refer to the respective privacy policies of the social media providers for how their cookies work.

We may also automatically collect and store certain information about your interaction with the Website, including IP address, browser type and version, internet service provider, referring/exit pages, operating system, date/time stamps, unique device identifiers and related data.

6.3. Other technologies. In addition to cookies, we may use some other similar technologies as follows:

6.3.1. Web beacons: small graphic images included on the Website or emails or those of third parties to provide analytics information.

6.3.2. Social widgets: buttons or icons provided by third party social media networks which may collect browsing data and will be received by such third party and are controlled by such third party.

6.3.3. SDKs: these are mobile application third party software development kits used in the Website. They enable us to collect information about app activity and the device it runs on.

6.3.4. Local shared objects: these are sometimes called flash cookies and can be stored on your browser. They are used to maintain preferences and usage records.

6.4. Refusing or deleting cookies. Most internet browsers are set up by default to accept cookies. However, if you want to refuse or delete them (or similar technologies) please refer to the help and support area on your browser for instructions on how to block or delete cookies (for example: Internet Explorer, Google Chrome, Mozilla Firefox, Microsfoft Edge and Safari). Please note you may not be able to take advantage of all the features of the Website, including certain personalised features, if you delete or refuse cookies.

6.5. Mobile Opt-out. If you access the Website through mobile devices, you can enable a “do not track” feature so as to control interest-based advertising on an iOS or Android mobile device by selecting the Limit Ad Tracking option in the privacy section of your Settings on iOS or via advertising preferences on Android devices (e.g. in Google Settings). This will not prevent the display of advertisements but will mean that they will no longer be personalised to your interests.

6.5.1. To opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout.

6.5.2. For more information on managing cookies, please go to www.allaboutcookies.org.

We make no promises about how third parties react when you enable such “do not track” feature, including any third-party websites we may link to for your convenience or information. You should always review the privacy policies and specifically, the “do not track” policies, of such third-party websites to understand how they will respond to “do not track” requests

6.6. Changes to our uses of cookies. We may amend this Paragraph 6 on cookies from time to time without notice to you, in compliance with applicable laws or as we update our data usage and handling processes. You are expected to check https://sosovalue.gitbook.io/sosovalue-indices/resources/privacy-policy from time to time so that you are aware of any changes to this Privacy Policy (including this Paragraph 6) on the use of cookies as such changes are binding on you.

7. DISCLOSURE OF PERSONAL DATA

7.1. Disclosure to third parties. We may alsodisclose your personal data to third parties in connection with purposes described in Paragraph 5, including without limitation the following circumstances:

7.1.1. disclosing your personal data to third parties who provide services to us (including, but not limited to, data providers, technology providers, insurance providers, and other professional services (including accountants, lawyers and auditors));

7.1.2. disclosing your personal data to third parties in order to fulfil such third party products and/or services as may be requested or directed by you;

7.1.3. disclosing your personal data to third parties that we conduct marketing and cross promotions with;

7.1.4. disclosing your personal data to authorities, governments, law enforcement agencies or public agencies (including to comply with any court order or direction by any regulatory authority);

7.1.5. if we are discussing selling or transferring part or all of our business, the information may be transferred to prospective purchasers under suitable terms as to confidentiality;

7.1.6. if we are reorganised or sold, information may be transferred to a buyer who can continue to provide continued relationship with you; and/or

7.1.7. if we are investigating or preventing possible wrongdoing in connection with the Website and/or services, or if required to protect our rights, property, or safety or the rights, property, or safety of our employees, the other users of the Website and/or the general public, we may disclose your information as required in connection with such investigations, preventive actions, or safety measures.

7.2. Whendisclosing personal data to third parties, we will (where appropriate and permissible) enter into contracts with these third parties to protect your personal data in a manner that is consistent with all applicable laws and/or ensure that they only process your personal data in accordance with our instructions.

8. TRANSFER OF PERSONAL DATA TO OTHER COUNTRIES

8.1. Transfers. We maytransfer your personal data to different jurisdictions in connection with the purposes described in Paragraph 5:

8.1.1. from the jurisdiction where it is collected (or where you are located) to any other jurisdictions that we operate in; and

8.1.2. to third parties in other jurisdictions.

8.2. Safeguards. Where we transfer your personal data across jurisdictions, we will ensure that your personal data is protected in accordance with this Privacy Policy and applicable laws regardless of the jurisdictions they are transferred to, but in any event to a level that is no less stringent than the jurisdiction from which the personal data is transferred. When we transfer your personal data internationally and where required by applicable law, we put in place appropriate safeguards. You may obtain details of these safeguards by contacting us.

9. SECURITY AND RETENTION OF PERSONAL DATA

9.1. Unauthorised access. While we take reasonable precautions (including but not limited to implementing certain technological security measures including encryption, firewalls and secure socket layer technology) to safeguard your personal data in our possession or under our control, these precautions do not guarantee that such personal data will not be accessed, disclosed, altered or destroyed from unauthorised or unintended access that is beyond our control, such as hacking or cybercrimes. You acknowledge that you understand and agree to assume these risks, and you agree not to hold us liable or responsible for any loss or damage resulting from unauthorised or unintended access that is beyond our control.

The safety and security of your personal data also depends on you. Your digital wallet is protected by your password, private key, and/or seed phrase, and we urge you to take steps to keep this and your other personal data safe by not disclosing your security credentials to others or leaving your digital wallet open in an insecure manner. If you do share your private key or your personal data with others, you remain responsible for all actions taken in the name of your digital wallet. If you lose control of your private key, you may lose control over your digital wallet or other personal data and may be subject to legally binding actions taken of your behalf.

WE DO NOT STORE YOUR PASSWORD, PRIVATE KEY, OR SEED PHRASE TO YOUR DIGITAL WALLET.

9.2. Vulnerabilities. We do not make any warranty, guarantee, or representation that your use of our systems or applications is safe and protected from malware, and other vulnerabilities. We also do not guarantee the security of data that you choose to send us electronically. Sending such data is entirely at your own risk.

9.3. Period of retention. We retain your personal data only for as long as is necessary to fulfil the purposes we collected it for, and to satisfy our business and/or legal purposes, including data analytics, audit, accounting or reporting purposes. How long we keep your personal data depends on the nature of the data, e.g. we keep personal data for at least the duration of the limitation period for bringing claims if the personal data may be required to commence or defend legal proceedings. Some information may also be retained for longer, e.g. where we are required to do so by law or have a legal obligation to do so.

9.4. Anonymised data. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we are entitled to retain and use such data without restriction.

10. YOUR RIGHTS

10.1. Rights you may enjoy. Depending on the jurisdiction that you are in or where we operate, you may enjoy certain rights under applicable law in relation to our collection,use, disclosure and processing of your personal data. Such rights may include:

10.1.1. Access: you may ask us if we hold your personal data and, if we are, you can request access to your personal data. This enables you to receive a copy of and information on the personal data we hold about you.

10.1.2. Correction: you may request that any incomplete or inaccurate personal data we hold about you is corrected.

10.1.3. Erasure: you may ask us to delete or remove personal data that we hold about you in certain circumstances.

10.1.4. Restriction: you may withdraw consent for ouruse of your personal data, or ask us to suspend theprocessing of certain of your personal data about you, for example if you want us to establish its accuracy.

10.1.5. Portability: you may request thetransfer of certain of your personal data to another party under certain conditions.

10.1.6. Objection: where we are processing your personal data based on a legitimate interest (or those of a third party) you may object to processing on this ground.

10.1.7. Complaint: you have the right to lodge a complaint about our practices with respect to your personal data with the Office of the Information Commissioner of the British Virgin Islands.

If you wish to exercise any of your rights, you may contact us in accordance with Paragraph 1.7. We may require that you submit certain forms or provide certain information to process your request. Where permitted by law, we may also charge you a fee to process your request.

10.2. Limitations. We may be permitted under applicable laws to refuse a request, for example, we may refuse (a) a request for erasure where the personal data is required for in connection with claims; or (b) an objection request and continueprocessing your personal data based on compelling legitimate grounds for the processing.