1.1. The privacy of your Personal Information is important to us. This policy explains how we collect, retain, process, share, transfer and handle your Personal Information and describes the kinds of Personal Information we collect, use, disclose and our purposes for doing so.

1.2. We use some defined terms in this policy. You can find the meaning of each defined term at the end of this policy.

1.3. This policy applies to your Personal Information when you use our Website, and interact generally with us but does not apply to Third Party Sites. We are not responsible for the privacy policies or content of Third Party Sites. When you visit Third Party Sites, you are agreeing to their privacy policies and terms, and any sharing that may occur between the platforms. Finally, we do not accept responsibility for information released on to, or made available by public blockchains.

1.4. For the avoidance of doubt, unless stated otherwise, this policy will govern our collection of your Personal Information irrespective of the forum.

1.5. This policy may be updated from time to time and the most up to date version will be published on our Website. We encourage you to check our Website periodically to ensure that you are aware of our current policy.

1.6. Your continued usage of our Website and/or services will be taken to indicate your acceptance of the terms of this privacy policy insofar as it relates to our Website.

2.1. When you visit our Website, we collect Personal Information so that we can provide you with products and services and improve and customize your experience with us. We only collect Personal Information if it is reasonably necessary for us to carry out our functions and activities.

2.2. The purposes for which we collect and hold your Personal Information include:

1. (a)to deliver our products and services to you;
2. (b)to improve our products and services;
3. (c)to manage our relationship with you, evaluate our business performance and build our customer database;
4. (d)to respond to your requests and seek your feedback;
5. (e)to provide and improve technical support and customer service;
6. (f)to conduct research, compare information for accuracy and verification purposes, compile or analyze statistics relevant to the operations of our business;
7. (g)to facilitate our internal business operations, including fulfillment of any legal and regulatory requirements and monitoring, analyzing and improving the performance and functionality of our Website and investigating breaches of or enforcement of any legal terms applicable to our Website;
8. (h)to protect our property, the Website or our legal rights including to create backups of our business records;
9. (i)to manage risk and protect our Website from fraud by verifying your identity and helping to detect and prevent fraudulent use of our Website;
10. (j)to perform our contractual obligations, including, but not limited to providing you the products and services or making available the Third Party Sites;
11. (k)for the direct marketing and promotional purposes as set out below; and
12. (l)to manage our business, including analyzing data collected from our Website concerning visits and activities of users on our Website including the Analytics Services. This analysis helps us run our Website more efficiently and improve and personalize your experience online.

3.1. The kinds of Personal Information we collect will depend on the type of interaction you have with us. Generally, the kinds of Personal Information we collect may include:

1. (a)your name, address (postal and residential), email address, telephone number(s), date of birth and gender when you register with us;
2. (b)information from third party sources such as data providers and credit organizations, where permitted by law, including public blockchain data such as your nominated public key for a digital asset wallet (including any wallet address);
3. (c)details of the device you have used to access any part of our Website, including carrier/operating system, connection type, IP address, browser type and referring URLs and other information may be collected and used by us automatically if you use our Website, through the browser on your device or otherwise;
4. (d)demographic information;
5. (e)location data;
6. (f)your connections with others whose personal information we may collect or hold; and
7. (g)transaction details relating to your use of our products, services or rewards including data regarding your feature usage patterns, interactions on our website and interactions with us.

3.2. Telephone calls to us may also be recorded for training and quality assurance purposes.

3.3. We do not collect sensitive personal information and ask that you do not send us any, any sensitive information you provide may become available on public blockchains through metadata matching.

4.1. We may disclose Personal Information collected from you:

1. (a)to our affiliates, employees, officers, agents, contractors, other companies that provide services to us, sponsors, government agencies or other third parties to satisfy the purposes for which the information was collected (as outlined in clause 2.2 of this policy) or for another purpose if that other purpose is closely related to the primary purpose of collection and an individual would reasonably expect us to disclose the information for that secondary purpose;
2. (b)to third parties who help us to verify the identity of our clients and customers, and other software service providers who assist us to provide the services we provide to you;
3. (c)to third parties who help us analyze the information we collect so that we can administer, support, improve or develop our business and the services we provide to you including cloud hosting services, off-site back ups and customer support;
4. (d)to third parties, including those in the blockchain and fintech industry, marketing and advertising sectors, to use your information in order to let you know about goods and services which may be of interest to you;
5. (e)if the disclosure is requested by law enforcement or government agency, or is required by a law, or legal process, such as a subpoena, court or other legal process with which we are required to;
6. (f)if disclosure is required to enforce the terms of this policy or to enforce any of our terms and conditions with you;
7. (g)to our professional advisers such as consultants and auditors so that we can meet our regulatory obligations, and administer, support, improve or develop our business;
8. (h)to any other person, with your consent (express or implied);
9. (i)to facilitate the sale of all or a substantial part of our assets or business or to companies with which we propose to merge or who propose to acquire us and their advisers;
10. (j)to protect the interests of our users, clients, customers and third parties from cyber security risks or incidents and other risks or incidents; and
11. (k)to maintain the integrity of our Website and protect our rights, interests and property and those of third parties.

4.2. In addition to the above recipients, we will disclose your Personal Information if we are required to do so under law or if the disclosure is made in connection with either the normal operation of our business in a way that you might reasonably expect, for example, if such disclosure is incidental to IT services being provided to our business or for the resolution of any dispute that arises between you and us. This disclosure may involve your Personal Information being transmitted outside of the United States.

4.3. In the event of a proposed restructure or sale of our business (or part of our business) or where a company proposes to acquire or merge with us, we may disclose Personal Information to the buyer and their advisers without your consent subject to compliance with Privacy Laws. If we sell the business and the sale is structured as a share sale, you acknowledge that this transaction will not constitute the 'transfer' of Personal Information.

4.4. We may disclose de-identified, aggregated data with third parties for marketing, advertising, and analytics purposes. We do not sell or trade your personal information to third parties.

5.1. We usually collect and store information including in paper, physical and electronic form provided by you when you communicate with us by telephone, email, web-based form, letter, facsimile or other means, including when:

1. (a)we provide you with our services via email or our Website;
2. (b)we provide you with assistance or support for our products or services;
3. (c)you participate in our functions, events or activities or on our social media pages;
4. (d)you request that we provide you with information concerning our products or services;
5. (e)you upload or submit information to us or our Website; or
6. (f)you complete any forms requesting information from you, including on registration with us, complete any survey or provide feedback to us concerning our products or services.

5.2. Where practicable we will only collect information from you personally. However, we will also collect your Personal Information through our partners and third parties who supply services to us.

5.3. Please note that we use our own and third party computer servers including our Website hosts, and data backups, which may be located outside of the United States, and your Personal Information may be stored and transmitted outside of the United States as part of the normal operation of our business.

5.4. We do not accept responsibility for Personal Information being released to public blockchains through the use of our Website, whether it be through public smart contracts or metadata matching.

5.5. We also collect information from your computer or mobile device automatically when you browse our Website. This information may include:

1. (a)the date and time of your visit;
2. (b)your domain;
3. (c)locality;
4. (d)operating system;
5. (e)the server your computer or mobile is using to access our Website;
6. (f)your browser and version number;
7. (g)search terms you have entered to find our Website or access our Website;
8. (h)pages and links you have accessed both on our Website and on other websites;
9. (i)the last website you visited;
10. (j)the pages of our Website that you access;
11. (k)the device you use to access our Website; and
12. (l)your IP Address.

5.6. While we do not use some of this information to identify you personally, we may record certain information about your use of our Website such as which pages you visit and the time and date of your visit and that information could potentially be used to identify you.

5.7. It may be possible for us to identify you from information collected automatically from your visit(s) to our Website. If you have registered an account with us, we will be able to identify you through your username and password when you log into our Website. Further, if you access our Website via links in an email we have sent you, we will be able to identify you.

5.8. The device you use to access our Website may collect information about you including your location using longitude and latitude coordinates obtained through GPS, Wi-Fi or cell site triangulation. For information about your ability to restrict the collection and use of such information, please use the settings available on your device.

5.9. We may use statistical analytics software tools and software known as cookies which transmit data to third party servers located outside of the United States. To our knowledge, our analytic providers do not identify individual users or associate your IP Address with any other data held by them.

5.10. We will retain your Personal Information for any time period we consider necessary to provide our products and services to you and to comply with our legal obligations. The period may vary depending on the type of Personal Information we hold. If we no longer need your personal information for these purposes we will take steps to destroy the information or ensure it is de-identified.

6.1. We will endeavor to take all reasonable steps to keep secure and protect any Personal Information that we hold about you, including:

1. (a)securing our physical premises and digital storage media;
2. (b)using computer safeguards such as Secure Socket Layer (SSL) technology to ensure that your information is encrypted and sent across the Internet securely;
3. (c)placing password protection and access control over our information technology systems and databases to limit access and protect electronic information from unauthorized interference, access, modification and disclosure; and
4. (d)taking regular back-ups of our electronic systems.

6.2. Notwithstanding that we will take all reasonable steps to keep your Personal Information secure, data transmission over the internet is never guaranteed to be completely secure. We do not and cannot warrant the security of any information you transmit to us or from any online services.

7.1. When you visit our Website or the website of any of our partners, we and our partners may use cookies, beacons, and other tracking technology (Cookies) to recognize you and customize your online experience. Cookies are small files that store information on your computer, mobile phone or other device. They enable us to recognize you across different websites, services, devices and/or browsing sessions. Cookies also assist us to customize online content and advertising, save your preferences for future visits to the Website, measure the effectiveness of our promotions, prevent potential fraud, and analyze your and other users' interactions with the Website.

7.2. If you do not wish to grant us the right to use cookies to gather information about you while you are using our Website, then you may set your browser settings to delete, disable or block certain Cookies. The following browsers have publicly available information about how to adjust cookie preferences: Microsoft Edge, Mozilla Firefox, Google Chrome and Apple Safari.

7.3. You may be requested to consent to use of Cookies when you access certain parts of our Website, for example, when you are asked if you want the Website to "remember" certain things about you.

7.4. Certain aspects and features of the Website are only available through use of Cookies. If you disable Cookies, your use of the Website may be limited or not possible or parts of our Website may not function properly when you use them.

7.5. Upon your first visit to our Website (or the first visit after you delete your Cookies), you may be prompted by a banner to accept our use of Cookies and other tracking technology (Cookies Policy). Unless you have adjusted your browser setting so that it will refuse cookies and or decline to accept our Cookies policy, our system will issue Cookies when you access our Website.

8.1. We may communicate with you by email, SMS or push notification, to inform you about existing and new products and services that may be of interest to you including administering contests, promotions, surveys or other site features.

8.2. We will ensure that any email we send as direct marketing complies applicable laws and contains an 'unsubscribe' option so that you can remove yourself from any further marketing communications. To opt out of communications via SMS, reply with "STOP". You may decline marketing messages sent by push notifications by refusing the relevant permission in your phone or tablet settings, however, this setting will prevent you from receiving other messages from us via push notification. You may also opt-out of receiving marketing materials from us using the contact details set out below or adjusting your user dashboard on our Website.

8.3. You can also call or write to us to request that your details be removed from our direct marketing list. We will endeavor to remove your details from our direct marketing list within a reasonable time.

8.4. Our direct marketing list may be operated by software and servers located outside of the United States and your Personal Information may be sent outside of the United States as part of our marketing.

8.5. We will also send communications that are required or necessary to send to users of our Website that contain information about important changes or developments to or the operation of the Website as well as other communications you request from us.

9.1. It may be impracticable to deal with you on an anonymous basis or using a pseudonym.

9.2. We may be able to provide you with limited information in the absence of your identifying yourself but generally we will be unable to provide you with any information, goods and/or services unless you have identified yourself.

10.1. If you have any queries in relation to this policy or wish to exercise any privacy rights applicable to you, please contact us in writing at:

10.2. We aim to acknowledge receipt of all privacy complaints from you within a reasonable period of time, but no less than required by applicable law. Where we cannot resolve a complaint within that period, we will notify you of the reason for the delay as well as advising the time by which we expect to resolve the complaint.

10.3. We may request additional information to verify your identity before processing your request and may deny or limit a request as permitted by applicable law (for example, where we cannot verify your identity, where disclosure would create a security or privacy risk, or where we have a legal obligation or privilege that prevents disclosure).

10.4. We may (depending on the request and applicable law) charge you a fee to access the Personal Information. We will inform you of any fees payable in respect of accessing your Personal Information prior to actioning your request. All requests for Personal Information will be handled in a reasonable period of time.

10.5. If you wish to have your Personal Information deleted, please contact us using the details above and we will take reasonable steps to delete the information (unless we are unable). To the extent that any Personal Information is stored on a blockchain, it may be impracticable, unfeasible, or impossible to delete.

10.6. In the event that you believe that there has been a breach of Privacy Laws, please contact us as soon as possible.

10.7. You may also view, access, edit, or delete (to the extent possible) your Personal Information through your user account (if any) on our Website. There will be certain data or information that may not be edited or deleted for you to be able to access our Website, for example, your digital wallet address.

11.1. We comply with applicable U.S. data-breach notification laws. If we determine that a breach of security has occurred involving Personal Information, we will notify affected individuals and, when required, relevant authorities (e.g., state attorneys general, regulators) and/or consumer reporting agencies, in each case within the timeframes required by law.

11.2. Our notice will include, to the extent required by law, a description of what happened, the categories of information involved, the steps we have taken, recommendations you can take to protect yourself, and how to contact us for more information. We may delay notice if requested by law enforcement or as necessary to determine the scope of the incident and restore system integrity.

12.1. We may amend this privacy policy from time to time at our sole discretion. If we make changes, we will notify you by revising the date at the top of the Privacy Policy and, in some cases, may provide you with additional notice (such as adding a statement to the Website homepage or sending you a notification). We recommend you review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the ways you can help us to protect your privacy.

13.1. United States. This section applies to individuals based in the U.S. and supplements our Privacy Policy with respect to the processing of your personal information in accordance with all applicable privacy and data protection laws and regulations and in each case, as amended, superseded, or replaced from time to time, collectively "Privacy Laws". If you are from the U.S. please review the above to understand how we collect and share Personal Information. Under U.S Privacy Laws, you may have additional rights, you can exercise these rights by submitting a request as described above.

13.2. California. Under California Civil Code Section 1798 ("California's Shine the Light"), California residents with an established business relationship with us can request information once a year about sharing their Personal Information with third parties for the third parties' direct marketing purposes. After thorough analysis, we have determined that we are exempt from the California Consumer Privacy Act of 2018, and the later, California Privacy Rights Act of 2020 (collectively, "CCPA"). If you have any questions, please contact us as described above.

13.3. Nevada. If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us as described below with the subject line "Nevada Do Not Sell Request" and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth above.

1. (a)Analytics Services means any third party website analytics provider and includes third party website analytics companies such as Google Analytics.
2. (b)IP Address means a number automatically assigned to your computer which is required when you are using the internet and which may be able to be used to identify you.
3. (c)Personal Information has the meaning set out in any such applicable Privacy Laws.
4. (d)Third Party Sites means online websites or services that we do not own or control, including websites of our partners
5. (e)Website means www.piertwo.com and/or any other website as we may operate from time to time.
6. (f)we, our, us and similar terms means Pier Two US Inc and all of our parents, subsidiaries, affiliates.
7. (g)you, your and similar terms means, as the context requires (1) you, when you use our Website; and/or (2) you, during your dealings with us as a customer; and/or (3) any agent providing your Personal information to us; and/or (4) any agent dealing with us on your behalf.