Privacy policy

Privacy policy

Last update: 14 May 2022.

INTRODUCTION

BITEEU EURASIA LTD (“ BITEEU ”) respects User's privacy and is committed to

protecting User's personal information or, as otherwise termed “User’s Personal Data”. In that

regard, BITEEU has launched and offers a service which provides BITEEU`s clients (the “ Users ”) (subject

to prior account registration) with access to certain digital currency on an online trading platform (the

“ Platform ”) which is accessible via the website www.Intebix.kz (the “ Site ”). User agree that User has read,

understood and accepted all of the terms and conditions contained in Privacy Policy (the “ Policy ”), Agreement

on Terms of Use and all policies and related notices which have incorporated Law of the Republic of Kazakhstan

dated May 21, 2013 N 94-V. About personal data and their protection. As this is a legally binding contract,

please carefully read through this Policy and related notices before using any of the services provided

by BITEEU or its affiliates (the “ Services ”). By registering, accessing or using Services , User has agreed to

the terms and conditions as laid out in this Policy . If User disagrees to this Policy , please inform BITEEU by

all available methods (for existing Users ) and stop the usage of BITEEU and any Services . The platform

automatically matches trades with open orders from other registered users on the Platform , in addition the

matching and trading services offered over the Platform , the Platform also offers digital wallet services to

registered Users , allowing them to store the digital currency which is traded over the Platform .

This Privacy Policy explains how information about User is collected, used, and disclosed by BITEEU

and sets out the basis on which BITEEU will process User's Personal Data when User :

• visits and uses the Site and / or the Platform (regardless of where User visits or uses them

from);

• applies for and opens an account in respect of BITEEU Platform ( Account ); and

• applies for, receives or uses any Services .

This includes any data that User may provide for and in relation to BITEEU ’’s or its affiliates newsletters,

updates, events and other marketing and promotional communications.

This Privacy Policy also informs User about: (i) how BITEEU will handle and look after User’s personal data,

(ii) BITEEU ’s obligations in regard to processing User’s Personal Data responsibly and securely, (iii) User ’s

data protection rights as a data subject, and (iv) how the law protects User.

1. IMPORTANT INFORMATION

Purpose of this Privacy Notice

BITEEU processes User's Personal Data in an appropriate and lawful manner, in accordance with

the Law of the Republic of Kazakhstan dated May 21, 2013 N 94-V. About personal data and their protection,

legislation of Republic of Kazakhstan and AFSA rules.

This Policy aims to give information on how BITEEU collects and processes User’s Personal Data in the

scenarios outlined above in the 'Introduction' (namely, about User who uses the Site ,

the Platform ,and Services , including any data that User may provide to BITEEU or which BITEEU may

receive). The Site , the Platform and Services are not intended for minors and BITEEU does not knowingly

collect Personal Data relating to minors.

It is important that User reads this Policy together with Agreement on Terms of Use and other binding

BITEEU policies, notices, agreements and documents related to the Services which BITEEU may provide on

specific occasions when BITEEU is collecting or processing Personal Data about User so that User is fully

aware of how and why BITEEU is using User ’’s data. This Policy supplements the other

notices and is not intended to override them. Controller BITEEU as defined above is the controller and

responsible for User ’s personal data.

If User has any questions or requests, including any requests to exercise User’s legal rights as a data subject,

please contact BITEEU using the details set out below.

Contact Details

Full name of legal entity: BITEEU EURASIA LTD

Email address: support@biteeu.com

It is imperative that the Personal Data BITEEU holds about User is accurate and actual at all times.

Otherwise, this will impair BITEEU ’’s ability to provide User with the availability of BITEEU ’’s

Platform and Services (amongst other potential and salient issues). The User must inform BITEEU if

User ’’s Personal Data changes during User ’’s relationship with BITEEU .

Third-party links.

The Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling

those connections may allow third parties to collect or share data about User . BITEEU does not control these

third-party websites and are not responsible for their privacy notices, statements or policies.

BITEEU encourages User to read the privacy policy of every website User visits.

2. KEY DEFINITIONS

Set out below are key definitions of certain data protection terms which appear in this Policy.

“ consent Form ” refers to separate documents and links on the site which BITEEU might from time to time

provide User with where BITEEU asks for User ’s explicit consent for any processing which is not for purposes

set out in this Policy .

“biometric data” - personal data that characterize the physiological and biological characteristics of the subject

of personal data, on the basis of which it is possible to establish his identity;

“ data controller ” or “ controller ” means any entity or individual who determines the purposes for which, and

the manner in which, any Personal Data is processed.

“personal data” - information relating to a certain or determined on their basis the subject of personal data,

recorded on electronic, paper and (or) other tangible media;

“blocking of personal data” - actions to temporarily stop the collection, accumulation, change, addition, use,

distribution, depersonalization and destruction of personal data;

“accumulation of personal data” - actions to systematize personal data by entering them into a database

containing personal data;

“collection of personal data” - actions aimed at obtaining personal data;

“destruction of personal data” - actions, as a result of which it is impossible to restore personal data;

“depersonalization of personal data” - actions, as a result of which it is impossible to determine the ownership

of personal data by the subject of personal data;

“the base containing personal data” (hereinafter - the base), - a set of ordered personal data;

“the owner of the database containing personal data” (hereinafter referred to as the owner) - a state body,

an individual and (or) legal entity exercising, in accordance with the laws of the Republic of Kazakhstan, the

right to own, use and dispose of the database containing personal data;

“protection of personal data” - a set of measures, including legal, organizational and technical, carried out for

the purposes established by this Policy;

“processing of personal data” - actions aimed at the accumulation, storage, modification, addition, use,

distribution, depersonalization, blocking and destruction of personal data;

“use of personal data” - actions with personal data aimed at achieving the goals of the activity of the owner,

operator and third party;

“storage of personal data” - actions to ensure the integrity, confidentiality and availability of personal data;

“dissemination of personal data” - actions resulting in the transfer of personal data, including through the

media or providing access to personal data in any other way;

“the subject of personal data” (hereinafter - the subject) - the individual to whom the personal data relates;

“third party” - a person who is not the subject, owner and (or) operator, but associated with them (him) by

circumstances or legal relations for the collection, processing and protection of personal data.

Note that Personal Data does not include information relating to entities (for example, a company or other

legal entity's information). In that regard, information such as company name, its company number,

registered address, tax number and any other any other publicly available information do not amount to

Personal Data in terms of the Act. Therefore, the collection and use of information strictly pertaining to

a legal person does not Law of the Republic of Kazakhstan dated May 21, 2013 N 94-V. About personal

data and their protection give rise to data controller obligations at law. Naturally, BITEEU will still treat

any and all such information in a confidential and secure manner.

3. THE PERSONAL DATA BITEEU COLLECTS ABOUT USER

Personal data, or personal information, means any information about an individual by which that person

can be identified (as stated above). It does not include data where the identity has been removed (anonymous

data ). In the course of User's relationship with BITEEU (including during the Account opening

stage), BITEEU may collect, use, store and transfer different kinds of Personal Data about User

which BITEEU has grouped together.

BITEEU collects information User provide directly to BITEEU . For example, BITEEU collects information

when User create an Account , participate in any interactive feature of the Services , fill out a form, participate

in a community or forum discussion, complete an exchange transaction, apply for a job, request user support or

otherwise communicate with BITEEU . The types of information BITEEU may collect include User's name,

social security number or other government ID number, date of birth, email address, postal address, phone

number, certain digital currency information, and any other information User chooses to provide.

BITEEU shall request this information in order to be able to register User on BITEEU Platform.

• Identity Data includes User's first name, maiden name (where applicable), last name, address, username or

similar identifier, marital status, title, nationality, date of birth, gender, photograph, identity card and / or

passport. This will form part of User's Account information on the Platform .

• Contact Data includes User's billing address, email address and contact number (telephone and / or mobile).

• Financial Data includes User's bank account and payment details.

• AML / KYC Data includes the following due diligence, KYC information and documentation about User: (i)

copy of ID card or passport, (ii) proof of residence (eg utility bill), (iii) KYC database checks, (iv) fraud database

checks and (v) any documentation or information which BITEEU may, from time to time:

➢ be required to collect to ensure compliance with any applicable legislation (including applicable foreign

laws) and global AML / KYC practices; and / or

➢ otherwise be mandated to collect by the competent authority or law enforcement agency (local or

overseas) or implementing market's best practices.

• Marketing and Communications Data includes User's preferences in receiving marketing

from BITEEU and BITEEU ’s third parties and User's communication preferences.

The categories of Personal Data are applicable to User holding a registered Account with BITEEU who start

trading over the Platform and otherwise make use use of BITEEU ’s Services .

• Transaction Data includes details about:

➢ the type of digital currency involved, the order volume, price, value and, where applicable, the proceeds

derived;

➢ User's trading and transactional history on the Platform , including withdrawals and order activity; and

➢ the payments which BITEEU receives, or otherwise, charges User (BITEEU fees for User's use of

the Platform ).

• Portfolio Data includes details about the digital currency and amounts credited to User’s Account and User's

Account balances.

• Enhanced KYC Data applies in respect to the instances mandated by BITEEU AML / KYC Policy, which

would include, amongst other scenarios, situations where a higher risk of money laundering and funding of

terrorism has been identified.

• In all cases, BITEEU collects the following information upon access to BITEEU ’’s Site:

• Technical / LOG Data includes the IP address, User's login data to the Platform (username and password),

device type, browser type and version, time zone setting and location, browser plug-in types and versions,

operating system and other technology on the devices User use to access the Site and Platform . This also

includes information about User's use of the Services including the type of browser User uses, access times,

pages viewed, User's IP address, and the page User visited before navigating to BITEEU Services .

• Device Data includes information about the computer or mobile device User uses to access

BITEEU Services , including the hardware model, operating system and version, unique

device identifiers, and mobile network information.

• Usage Data includes information about how User uses the Platform.

BITEEU also collects, uses and shares Aggregated Data such as statistical or demographic data for any

purpose. Aggregated Data may be derived from User's Personal Data but is not considered Personal Data in

law as this data does not directly or indirectly reveal User's identity. For example, BITEEU may

aggregate User's Usage Data to calculate the percentage of users accessing a specific feature of the Site and /

or the Platform . However, if BITEEU combines or connects Aggregated Data with User’s Personal Data so

that it can directly or indirectly identifies User, BITEEU treats the combined data as Personal Data which will

be used in accordance with this Policy .

If User fail to provide Personal Data Where BITEEU needs to collect Personal Data about User:

• By law; or

• under the terms of, or in connection with, the contract that BITEEU has with User (as

discussed in Section 1 above); or

• as part of BITEEU legitimate (business) interests to verify the identity of BITEEU applicants and Users,

mitigate against risks (such as potential or suspected fraud) and in particular, to assess and take a decision on

whether BITEEU will or should enter into a relationship with User (as subject to User acceptance criteria and

policies);

and User either fail to provide that data when requested, or else provide incomplete or insufficient data,

BITEEU may not be able to perform or conclude the contract which BITEEU has or is otherwise trying to enter

into with User (namely regarding User's Account opening on the Platform and provision of BITEEU

Services ).

In certain instances, particularly where it relates to AML/KYC Data, BITEEU may even need to

exercise BITEEU prerogative to terminate BITEEU contract with User , and thus withdraw the availability

of BITEEU Services to User , or else, if still at application stage, BITEEU may have to decline to enter into a

relationship with User . BITEEU will however notify User if this is the case at that point in time.

Sensitive Personal Data BITEEU does not knowingly collect Special Categories of Personal Data (or

Sensitive Personal Data) about User . Should BITEEU receive sensitive Personal

Data about User , BITEEU will only process that data where there is a legitimate reason to do so and, in all

circumstances, in accordance with BITEEU obligations at law and under the appropriate safeguards.

As set out below in Section 5, BITEEU collects and processes AML / KYC Data in order to be able to (i)

comply with legal and regulatory obligations, as applicable (ii) conduct BITEEU AML and KYC checks, and

other due diligence checks, on User , (iii) verify User's identity or claimed identity and identify and / or

verify User's source of funds and source of wealth, as appropriate (iv) take an informed decision on

whether BITEEU wants to enter into a relationship with User , and, if positive, to conduct initial and ongoing

screening and monitoring and (iv) to comply with any legal or regulatory obligation that BITEEU may have and

/ or any Court, regulatory or enforcement order that may be issued upon BITEEU.

4. HOW IS USER'S PERSONAL DATA COLLECTED?

(A) Account Registration and Opening.

BITEEU will ask User to provide BITEEU with User's Identity, Contact, Financial and AML / KYC

Data when User apply to register and open an Account with BITEEU on BITEEU Platform (including at

account finalization stage). User provide these personal details and information to BITEEU , which

BITEEU collects and processes, when User fill in and submit BITEEU application form (together with other

related forms), and complete BITEEU required application steps.

User's Account Data will be generated on the basis of User's application, and is also processed and stored

by BITEEU .

(B) Service Use.

This may encompass all of the data categories listed in Section 3 (namely, Identity, Contact, AML and KYC

Data, Enhanced KYC Data and Transaction Data).

(C) Direct Interactions.

User mays also give BITEEU User's Identity, Contact, Financial, AML / KYC Data and Transaction

Data by filling in BITEEU other forms ( i.e. separate to BITEEU account opening and registration form), or

by corresponding with BITEEU by post, phone, e-mail or otherwise. This includes Personal Data that

User provides when User , as applicable:

• applies to open an Account ;

• updates or edit User's Account details;

• subscribes to BITEEU Platform ;

• requests withdrawals from User's Account ;

• contacts BITEEU with complaints or queries;

• reports issues;

• submits the (additional or supplementary) AML / KYC Data that BITEEU may request from the User;

• requests marketing to be sent to User ;

• participates in a survey; or

• provides BITEEU with feedback.

(D) Automated Technologies or Interactions.

As User interact with the Platform and the Site , BITEEU may automatically collect Technical Data

about User's equipment, browsing actions and patterns. BITEEU collects this Personal Data by using cookies,

server logs and other similar technologies.

Cookies are small data files stored on User's hard drive or in device memory that helps BITEEU

improve BITEEU Services and User's experience, see which areas and features of BITEEU Services are

popular and count visits, manage the registration process for accounts, remember User's site preferences, retain

certain information to process orders for exchange transactions, and retain information to provide User with

support. Web beacons are electronic images that may be used on BITEEU Platform or emails and help deliver

cookies, count visits, and understand usage and campaign effectiveness.

Most web browsers are set to accept cookies by default. If User prefer, User could usually choose to set

User's browser to remove or reject browser cookies. Please note that choosing to remove or reject cookies could

affect the availability and functionality of BITEEU Services.

Please see BITEEU's Cookie Policy for further details on website www.Intebix.kz

(E) Third Parties or Publicly Available Sources.

BITEEU may also obtain information from other sources and combine that with information BITEEU collects

through BITEEU Services . For example, BITEEU may collect information about User from third parties,

including but not limited to social media platforms and publicly available sources. BITEEU may also

receive Personal Data about User from various third parties and public sources, as set out below:

• Technical Data from the following parties:

➢ analytic providers such as Google Analytics;

➢ advertising networks;

➢ search information providers.

• Identity, contact , AML / KYC Data from publicly available sources such as public court documents and the

company houses and registers of other jurisdictions, and from electronic data searches, online KYC search tools

(which may be subscription or license based), anti-fraud databases and other third party databases, sanctions

lists, outsourced third-party KYC providers and from general searches carried out via online search engines (eg

Google).

5. HOW BITEEU USES PERSONAL DATA

BITEEU will only use User's Personal Data when law of Republic of Kazakhstan and International Acts

allow BITEEU to. Most commonly, BITEEU will use User's Personal Data in the following circumstances:

• Where BITEEU needs to perform the contract BITEEU is about to enter into or has entered into with User in

respect of User's relationship with BITEEU .

• Where it is necessary for BITEEU legitimate interests (or those of a third party) and User’s interests and

fundamental rights do not override those interests.

• Where BITEEU needs to comply with a legal or regulatory obligation. Purposes for which BITEEU will

use User's Personal Data BITEEU has set out below, in a table format, a description of all the

ways BITEEU plans to use User’s Personal Data, and which of the legal basis BITEEU relies on to do

so. BITEEU has also identified what BITEEU legitimate interests are where appropriate. BITEEU may

process User's Personal Data for more than one lawful ground depending on the specific purpose for

which BITEEU is using User's data.

Please contact BITEEU at support@biteeu.com if User needs details about the specific legal ground

BITEEU is relying on to process User's Personal Data where more than one ground has been set out in the

table below.

Purpose / activity Type of data Lawful Basis for Processing (including Basis of Legitimate Interest)

(i) To conduct due diligence checks on User (following User's application to open and register an account).

(ii) To determine if BITEEU will enter into a relationship with User and, if positive, to register User's account

and on-board new User

(a) Identity;

(b) Contact;

(c) Financial;

(d) AML / KYC

Data:

(a) Performance of a contract with User.

(b) Necessity for compliance with BITEEU legal obligations

(c) Necessity for BITEEU legitimate interests, including to establish and verify:

• User's identity and suitability for BITEEU Platform,

• the existence of any risks that User may present as a prospective User ,

• User's ability to meet financial commitments,

• and ultimately, to enable BITEEU to take an informed decision on whether BITEEU should enter into a

relationship with User .

(i) To establish and verify User's identity.

(ii) To fulfill BITEEU other internal AML / KYC policies and requirements.

(iii) To fulfill any external mandatory reporting obligations that BITEEU may have to the Regulator in the

Republic of Kazakhstan, the Police and any other (including overseas) public, regulatory, law enforcement or

tax authority.

(a) Identity;

(b) Contact;

(c) AML / KYC

Data:

(d) Transaction;

(e) Enhanced KYC

Data:

(a) Necessity to comply with a legal obligation.

(b) Necessity for BITEEU legitimate interests (for risk assessment purposes, to prevent and mitigate against

fraud, to safeguard the reputation of BITEEU business).

To provide the Services , in particular:

(i) to match any orders for digital currency in order to find an appropriate trade with another registered the User;

(ii) manage payments, fees, charges and subscription costs; and

(iii) collect and recover money as may be appropriate; and

(iv) investigate any suspected fraudulent transactions

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Portfolio

(a) Performance of a contract with User

(b) Necessity for BITEEU legitimate interest to collect and recover debts and prevent fraudulent transactions

For legal, tax and accounting purposes (reporting to tax authorities, and accounting record requirements).

(a) Financial; and

(b) Transaction.

Necessity to comply with a legal obligation. To detect, prevent and report fraudulent or suspicious orders /

transactions.

(a) Identity;

(b) Contact

(c) Applicant

(d) AML / KYC

Data:

(e) Enhanced KYC Data

(f) Financial;

(g) Portfolio;

(h) Transaction.

Necessity for BITEEU legitimate interests, including in particular to:

• protect the reputation of BITEEU business;

• avoid any complicity or association with fraud;

• report fraudulent or otherwise suspicious orders that BITEEU receives (or which later came

to BITEEU knowledge) to relevant public authorities.

To manage BITEEU relationship with User , including in particular to:

(i) notify User about changes to BITEEU terms and conditions or privacy notices;

(ii) inform User about changes to BITEEU Platform (including the addition of new digital currency that is

available to trading);

(iii) deal with User’s inquiries, requests, Complaints or reported issues;

(iv) provide User with support and assistance;

(v) contact User in relation to User’s the Account, portfolio and other related matters;

(vi) ask User to participate in a survey;

(vii) request feedback from the User;

(viii) advise User of industry and legislative updates;

(ix) inform User about BITEEU events;

(x) provide User with information about BITEEU Platform;

(xi) administer User’s the Account;

(xii) provide User with any other information or materials that User has requested to receive from BITEEU;

(a) Identity;

(b) Contact;

(c) Financial;

(d) Account;

(e) Portfolio;

(f) Transaction;

(g) Usage;

(h) Profile;

(i) Marketing and Communications.

(a) Performance of a contract with User .

(b) Necessity for BITEEU legitimate interests (for User care and service matters, to study how Users

use BITEEU Platform , to assess BITEEU operations, to develop them and grow BITEEU business).

BITEEU makes sure BITEEU considers and balances any potential impact on User (both positive and

negative) and User's rights before BITEEU processes User's Personal Data for BITEEU legitimate

interests. BITEEU does not use User's Personal Data for activities where BITEEU interests are overridden by

the impact on User (unless BITEEU has User`s consent or is otherwise required or permitted to by law of

Republic of Kazakhstan and International Acts). Marketing BITEEU strives to provide User with choices

regarding certain Personal Data uses in relation to User’s The Account . Through User's Account, Identity,

Contact, Technical, Usage and Marketing and Communications Data , BITEEU can form a view on

what BITEEU thinks User may want or need.

BITEEU will send details as to how User may enhance User's trading activity in relation to the User’s

The Account . User may receive marketing communications from BITEEU (which may consist of newsletters,

industry updates, mailshots, publications, promotional materials and / or information about BITEEU events)

where:

• User provides User's consent to receiving such marketing material; or

• User has an ongoing commercial or contractual relationship with BITEEU (eg where

BITEEU considers User to be an active User of the Platform ); and

• provided User has not opted out of receiving marketing from BITEEU.

To administer and protect BITEEU business, including the Platform and the Site , (including troubleshooting,

data analysis, testing, system maintenance, support, safety and security testing, reporting and hosting of data).

(a) Identity;

(b) Contact;

(c) Technical;

(d) Account.

(a) Necessity for BITEEU legitimate interests (for running and administering BITEEU business, network

security, to prevent fraud, and in the context of a business reorganization or group restructuring exercise).

(b) Necessity to comply with a legal obligation.

(c) Performance of a contract with User. To deliver relevant website content and advertisements to user and

measure or understand the effectiveness of the advertising which BITEEU serves to User. To ensure

that BITEEU content is presented in the most effective manner to User and User's computer and devices, and

in a user friendly manner.

(a) Identity;

(b) Contact;

(c) Account;

(d) Usage;

(e) Marketing and Communications

(f) Technical.

Necessity for BITEEU legitimate interests (to study how Users use BITEEU Platform , to develop them, to

grow BITEEU business and to inform BITEEU marketing strategy). To use data analytics to improve

the Site and Platform , marketing, User relationships and experiences.

(a) Technical;

(b) Usage.

Necessity for BITEEU legitimate interests (to define types of Users that have registered an

Account on BITEEU Platform , to keep the Site and the Platform updated and relevant, to develop

BITEEU business and to inform BITEEU marketing strategy).

Third-party marketing

BITEEU will get User's express opt-in consent before BITEEU shares User's Personal Data with any third

parties (including BITEEU associated or related corporate entities) for marketing purposes.

Opting out User can ask BITEEU to stop sending such advertising and marketing communications at any time

by:

• following the opt-out links on any marketing messages sent to User ;

• contacting BITEEU at any time at support@biteeu.com .

Where User opt out of receiving such communications, this will not apply to Personal Data processed or

provided to BITEEU as a result of User's entry into relationship with BITEEU and BITEEU Platform .

Change of purpose

BITEEU will only use User's Personal Data for the purposes for which BITEEU collected it, unless

BITEEU reasonably considers that BITEEU needs to use it for another reason and that reason is compatible

with the original purpose, or BITEEU is obliged to process User's data by laws of Republic of Kazakhstan or

court or other enforceable orders.

Please note that BITEEU may process User's Personal Data without the need to obtain User's consent, in

compliance with the above rules, where this is required or permitted by law of Republic of Kazakhstan and

International Acts.

6. DISCLOSURES OF USER'S PERSONAL DATA

BITEEU may have to share User's Personal Data with the parties set out below for the purposes set out

in the table in Section 5 above.

• External third parties.

• Suppliers and external agencies that BITEEU engages to process information on BITEEU and /

or User's behalf, including to provide User with the information and / or materials that User has requested.

• Our subsidiaries, associates and agents where necessary to facilitate User's relationship with BITEEU .

• The regulators, law enforcement agencies and other authorities who require reporting of processing activities,

or may request information from BITEEU , in terms of law of Republic of Kazakhstan and in certain

circumstances.

• Professional advisers such as consultants, bankers, professional indemnity insurers, brokers and auditors.

• Other organizations where exchange of information is for the purpose of fraud protection or credit risk

reduction.

• Debt recovery agencies who assist BITEEU with the recovery of debts owed to BITEEU .

• Third parties to whom BITEEU may choose to sell, transfer, or merge parts of BITEEU business

or BITEEU assets (successors in title). Alternatively, BITEEU may seek to acquire other businesses or merge

with them. If a change happens to BITEEU business, then the new owners may use User's Personal Data in

the same way as set out in this notice.

BITEEU requires all third parties to respect the security of User's Personal Data and to treat it in compliance

with the law of Republic of Kazakhstan and International Acts (including applicable data protection). BITEEU

does not allow BITEEU third party business partners or service providers to use User's Personal Data for their

own purposes and only permit them to process User's Personal Data for specified purposes and in accordance

with BITEEU documented instructions. Furthermore, these third parties access and process User's Personal

Data on the basis of strict confidentiality and subject to the appropriate security measures and safeguards.

BITEEU may also disclose User's Personal Data :

• If BITEEU is under a duty to disclose or share User's Personal Data to comply with any legal obligation,

judgment or under an order from a court, tribunal or authority, or

• If BITEEU believes User's actions are inconsistent with BITEEU believes user agreements or policies, or to

protect the rights, property and safety of BITEEU or others, or

• in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of

all or a portion of BITEEU business by another company; or

• if BITEEU has User's consent or at User's direction.

BITEEU may also share aggregated or de-identified information, which cannot reasonably be used to

identify User .

7. INTERNATIONAL TRANSFERS (APPLICABLE TO EU RESIDENTS ONLY)

User consents to the transfer of data to entities outside the Republic of Kazakhstan including,

and acknowledges such transfers, which will only take place for the purposes set forth in Section 5, are necessary

for the performance of a contract between the data subject and the controller or the implementation of pre-

contractual measures taken at the data subject's request. Such transfers may take place to countries for which

there is no adequate decision pursuant to Law of the Republic of Kazakhstan dated May 21, 2013 N 94-V. About

personal data and their protection and may lack privacy protections.

8. DATA SECURITY

While no online or electronic system is guaranteed to be secure, BITEEU takes reasonable measures to help

protect information about User from loss, theft, misuse, and unauthorized access, disclosure, alteration and

destruction.

BITEEU has put in place appropriate security measures to prevent User's Personal Data from being

accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, BITEEU limits

access to User's Personal Data to those employees, agents, contractors and other third parties who have a

business need to know. They will only process User's Personal Data on BITEEU instructions and they are

subject to a duty of confidentiality.

BITEEU has put in place procedures to deal with any suspected Personal Data breach and will notify User and

any applicable regulator of a breach where BITEEU is legally required to do so.

GETTING ACQUAINTED AND AGREEING TO THE TERMS OF THIS POLICY, USER ACCEPT

ALL RISKS ASSOCIATED WITH DATA LOSS AS A RESULT OF FRAUD BY THIRD PARTIES AND

FORCE MAJEURE (NATURAL DISASTERS, TERRORISM, WAR, HACKING, ETC.). IF USER

DOES NOT AGREE TO THE TERMS OF THIS POLICY OR DOES NOT ACCEPT RISKS

ASSOCIATED WITH DATA LOSS USER SHOULD STOP TO USE ANY BITEEU SERVICES.

“ Confidential Information ” means any non-public information of the discloser, whether of a financial,

business or other nature (including, but not limited to, trade secrets, and information relating to the Users ,

business plans, promotional and marketing activities, IT, finances and other business affairs of the discloser) that

is disclosed to or obtained by the recipient and that the recipient knows or has reason to know is confidential,

proprietary or trade secret information of discloser.

Confidential Information also includes any information that has been made available to discloser by third

parties that discloser is obligated to keep confidential. Confidential Information does not include any

information that:

(a) was known to the recipient before receiving the same from the discloser in connection with this the Policy ;

(b) is independently developed by the recipient without reliance on any Confidential Information of the

discloser;

(c) is acquired by the recipient from another source without restriction as to use or disclosure; or

(d) is or becomes generally known to the public through no fault or action of the recipient.

Each party guarantees:

(a) use the other's Confidential Information solely for the purposes of performing this Policy ,

(b) disclose the other party's Confidential Information only to those employees and contractors that need to

know the same for purposes of performing this Policy , and

(c) inform its employees and contractors with access to the other party's Confidential Information that

such Confidential Information is confidential and proprietary to the other party and is subject to this policy .

BITEEU and User will preserve and protect each other`s Confidential Information and will not divert or

misappropriate any Confidential Information for its own or any third party's benefit. Without limiting the

generality of the foregoing, BITEEU and User will keep Confidential Information confidential and accessible

and use restrictions at least as stringent as those applied to protect its own information of similar type.

9. DATA RETENTION

How long will use my Personal Data for?

Please note that BITEEU considers BITEEU relationship with User to be an ongoing and continuous User

relationship, until terminated.

BITEEU will only retain User's Personal Data for as long as necessary to fulfill the purposes BITEEU

collected it for (ie the ongoing service provision) and, thereafter, for the purpose of satisfying any legal,

accounting, tax and reporting requirements or obligations to which BITEEU may be subject and / or to the extent

that BITEEU may also need to retain User's Personal Data to be able to assert, exercise or defend possible

future legal claims against or otherwise involving User .

By and large, BITEEU retention of User's Personal Data shall not exceed the period of seven (7) years from

the date of the termination of User's relationship with BITEEU (which would typically arise from the closure /

de-registration of User's Account on the Platform ). This period of retention enables BITEEU to use the data

in question for the possible filing, exercise or defense of legal claims (taking into account the timeframe of

applicable statutes of limitation and prescriptive periods).

In the event that BITEEU ’’s activities are held by competent legislators and regulators in amount to a 'relevant

activity' at law of Republic of Kazakhstan, BITEEU will retain User's AML and KYC Data for the duration of

User's business relationship with BITEEU and for a further period of seven years following its termination and,

in certain instances, for a maximum period of seven (7) years post-termination if mandated by the competent

authority. BITEEU may need to revise this AML retention period in the event of applicable legal or regulatory

developments, but BITEEU will notify User if this is the case at the time.

In some circumstances, User can ask BITEEU to delete User's Personal Data. See below for further

information.

Kindly, contact BITEEU for further details about the retention periods that BITEEU applies.

Data minimization

Whenever and to the extent possible, BITEEU anonymous data which BITEEU holds about User when it is no

longer necessary to identify User from the data which BITEEU holds about User ( anonymous data ).

In some circumstances, BITEEU may even anonymize User's Personal Data (so that it can no longer be

associated with User ) for research or statistical purposes, in which case BITEEU may use this information

indefinitely without further notice.

10. USER'S LEGAL RIGHTS

Under certain circumstances, User has rights under data protection laws in relation to User's Personal

Data according with law of Republic of Kazakhstan and International Acts.

• Request access to User's Personal Data .

• Request correction of User's Personal Data .

• Request erasure of User's Personal Data .

• Object to processing of User's Personal Data .

• Request restriction of processing User's Personal Data .

• Request transfer of User's Personal Data .

• Right to withdraw consent.

If User wish to exercise any of the rights set out above, please contact BITEEU at support@biteeu.com .

These rights are explained below.

No Fee usually required User will not normally have to pay a fee to exercise User's Personal Data subject

rights. However, BITEEU may charge a reasonable fee if User's request is clearly unfounded, repetitive or

excessive. Alternatively, BITEEU may refuse to comply with User's request in the above circumstances.

What BITEEU may need from User BITEEU may need to request specific information from User to

help BITEEU confirm User's identity and ensure User's right to access User's Personal Data (or to exercise

any of User's other data subject rights). This is a security measure to ensure that Personal Data is not disclosed

to any person who has no right to receive it. BITEEU may also contact User to ask for further information in

relation to User’s request to speed up BITEEU response.

Time limit to Respond

BITEEU tries to respond to all legitimate requests within the period of one month from receipt of the request.

Occasionally it may take BITEEU longer than a month if User's request is particularly complex or User has

made a number of requests. In this case, BITEEU will notify User and keep User updated. User's Legal Rights

User has the right to:

1. Request access to User's Personal Data (commonly known as a “ data subject access request ”). This

enables User to receive a copy of the Personal Data BITEEU holds about User and to check that BITEEU is

lawfully processing it. User may send an email to support@biteeu.com requesting information how

the Personal Data is processed by BITEEU .

User shall receive one copy free of charge via email of the Personal Data which is undergoing processing. Any

further copies of the information processed may incur a charge of € 30.00.

2. Right to information when collecting and processing Personal Data about User from publicly accessible or

third party sources. When this take places, BITEEU will inform User, within a reasonable and practicable

timeframe, about the third party or publicly accessible source from which BITEEU has collected User's

Personal Data .

3. Request correction or rectification of the Personal Data that BITEEU holds about User. This

enables User to have any incomplete or inaccurate data BITEEU holds about User corrected and / or updated,

though BITEEU may need to verify the accuracy of the new data User provide to BITEEU . As mentioned, it

is in User's interest to keep BITEEU informed of any changes or updates to User's Personal Data which occur

during the course of User’s relationship with BITEEU .

4. Request erasure of User's Personal Data . This enables User to ask BITEEU to delete or remove Personal

Data where:

➢ there is no good reason for BITEEU continuing to process it;

➢ User has successfully exercised User's right to object to processing (see below);

➢ BITEEU may have processed User's information unlawfully; or

➢ BITEEU is required to erase User's Personal Data to comply with law of Republic of Kazakhstan.

Note, however, that BITEEU may not always be able to comply with User's request of erasure for specific legal

reasons which will be notified to User , if applicable, at the time of User's request. These may include instances

where continued processing is necessary in order to be able to:

➢ comply with a legal or regulatory obligation to which BITEEU is subject; or

➢ file, exercise or defense of legal claims.

5. Object to processing of User's Personal Data where BITEEU is relying on a legitimate interest (or those

of a third party) and there is something about User's particular situation which makes User want to object to

processing on this ground as User feel it impacts User’s fundamental rights and freedoms. User also has the

right to object where BITEEU is processing User's Personal Data for direct marketing purposes (see

Marketing in Section 5 above).

In some cases, BITEEU may demonstrate that BITEEU has compelling legitimate grounds to process

User's information which overrides User's rights and freedoms.

6. Request restriction of processing of User's Personal Data . This enables User to ask BITEEU to suspend

the processing of User's Personal Data in the following scenarios:

➢ if User want BITEEU to establish the data's accuracy;

➢ where BITEEU uses of the data is unlawful but User do not want BITEEU to erase it;

➢ where User needs BITEEU to hold the data even if BITEEU no longer requires it as User need it to

establish, exercise or defend legal claims; or

➢ User has objected to BITEEU use of User's data but BITEEU needs to verify whether BITEEU has

overriding legitimate grounds to use it.

7. Request the transfer (data portability) of User's Personal Data to User or to a third party.

BITEEU will provide User , or a third party User has chosen, with User's Personal Data in a structured,

commonly used, machine-readable format. Note that this right only applies to automated information

which User initially provided consent for BITEEU to use or where BITEEU used the information to perform a

contract with User in accordance with Policy together with Agreement on Terms of Use and other

binding BITEEU policies, notices, agreements and documents related to the Services .

8. Withdraw consent at any time where BITEEU is relying on consent to process User’s Personal

Data (which will not generally be the case). This will not however affect the lawfulness of any processing

which BITEEU carried out before User withdrew User’s consent. Any processing activities that are not based

on User's consent will remain unaffected.

Kindly, note that none of these data subject rights are absolute, and must generally be weighed against

BITEEU own legal obligations and legitimate interests. If a decision is taken to override User's data

subject request, User will be informed of this by BITEEU data protection team along with the reasons for

BITEEU decision.

User's Choices Regarding User's Account Information User may update, correct, or delete information

about User at any time by logging into User's BITEEU The Account . If User wish to delete or

deactivate User's Account , please send request or question to support@biteeu.com , but note

that BITEEU may retain certain information as required by law of Republic of Kazakhstan or for legitimate

business purposes, as further highlighted above.

11. CHANGES TO THIS PRIVACY POLICY

BITEEU may change this Policy or tariffs or another information from time to time, particularly where

BITEEU needs to take into account and cater for any (i) business developments and / or (ii) legal or regulatory

developments to the issuance or trading of digital currency and digital currency under law of Republic of

Kazakhstan and International Acts. If BITEEU makes changes, BITEEU will notify User by revising the date

at the top of the Policy and, in some cases, BITEEU may provide User with additional notice (such as adding a

statement to BITEEU homepage or sending User notification). BITEEU encourages User to review

the Privacy Policy whenever User access the Services or otherwise interact with BITEEU to stay informed

about BITEEU information practices and the ways User can help protect User's privacy.

The language of the original documents is English.