PRIVACY POLICY

GENERAL:

This ‘Privacy Policy’ is a privacy statement that was created by TCG International Ltd, St. Vincent and the Grenadines (together with its affiliates) (referred to as “we”, “us” or “Company”) and aims to inform you as a client and user of the Company’s services and products, on how we collect, use and disclose your personal data and the purpose for processing as data subjects pursuant to the General Data Protection Regulation (EU) 2016/679 (GDPR).

TCG International Ltd, provide you the product and/or service called the Growth Program Service (hereinafter the “Growth Program” or “Growth Program Service”), under the Terms of Use (for more information regarding the Terms of Use please click here). The Growth Program gives you the option to contribute and earn rewards on eligible, available and idle account balances you otherwise maintain in your Teroxx Wallet offered and operated through the third-party Teroxx Worldwide UAB (hereinafter “Teroxx”).

This policy informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Growth Program and the experiences you have while using the related services. By using the Growth Program, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Use.

Service: Service means the Growth Program Service created by the Company and operated by Teroxx.

Personal Data: In accordance with the GDPR, Personal Data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;.

Processing: means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Controller: means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; The Company acts as the Controller of your personal data;

Processor: means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller; Teroxx acts as the Controller of your personal data;

Third party: means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;

Consent: of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

Usage Data: Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself e.g. the duration of a page visit.

Cookies: Cookies are small pieces of data stored on your device (computer or mobile device).

We collect several different types of information for various purposes to provide and improve our Service to you.

Specifically, we collect your personal data a) when you enter in a contract with us, b) when contacting us for information, c) when you open an account or use any of our products or services, c) when you speak with a member of our customer service team, e) when you contact us for any other reason.

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (hereinafter referred to as the “Personal Data”). Personally identifiable information may include, but is not limited to:

Email address,

First name and last name,

Phone number,

Date of Birth,

Address, State, Province, ZIP/Postal code, City,

Cookies and Usage Data,

IP address of the requesting computer,

Date and time of access,

Name and URL of the retrieved file,

The browser used,

If applicable, the operating system of your computer,

The name of your access provider,

Location data,

The type of device you use, mobile network information, mobile operating system, the type of your mobile browser you use,

Preferences such as Language, favourite products,

Identification Details and access data such as passwords, email, etc.

Your image through video for KYC purposes and for compliance with the relevant KYC laws and Regulations.

Transaction details, payments (including time, beneficiary details, currencies, time, date, account, IP address of sender and receiver, sender’s and receiver’s information) etc.

Historic of Sales etc.

We only use your personal data for the purposes referred in this Privacy Notice. However, if we intend to use your data for another purpose, we will ask for your prior consent.

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (hereinafter referred to as the “Usage Data”).

This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our Service.

Session Cookies: We use Session Cookies to operate our Service.

Preference Cookies: We use Preference Cookies to remember your preferences and various settings.

Security Cookies: We use Security Cookies for security purposes.

We use and process your personal data for the following purposes:

To provide and maintain our Service

To notify you about changes to our Service

To allow you to participate in interactive features of our Service when you choose to do so

To provide customer support

To gather analysis or valuable information so that we can improve our Service

To monitor the usage of our Service

To detect, prevent and address technical issues

To conduct our business activities,

To fulfil our contractual obligations,

To communicate with you,

To comply with the relevant KYC laws and Regulations,

To provide you with our products and services which require the use of personal data, and

For any other administrative purposes

GDPR provides that all processing activities of personal data must be based at least on one legal basis. The Company use your personal data when the law allows it and process your personal data lawfully using the following legal grounds:

a) where we ask your consent, and you choose freely to provide us with your consent;

b) In case where we have a contract with you and the processing is based on our contractual obligations.

c) Where we need to comply with our legal obligations.

d) Where the processing it is necessary for our legitimate interest or of a third party and your fundamental rights and interests do not override our interest or those of the third party.

e) Where we have a legitimate interest

Your Personal Data may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Your personal data will not be transmitted to third parties for purposes other than those listed in this document. We will only pass on your personal data to third parties in order to assert, exercise or defend legal claims and there is no reason to assume that you have an overriding interest worthy of protection in not disclosing your data.

In case where we need to transfer your personal data to a third party we will only transfer the personal data that is necessary and not the whole amount of your personal data we hold. In addition, where it is necessary to transfer your data to third countries outside EU, we will proceed with the transfer only if the conditions set out in the Regulation are met, where there is an adequacy decision, or where we use appropriate safeguards such as binding contracts with those parties.

In case that the Company is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government department).

The Company retain your personal data for as long as it is necessary to fulfil the purposes for which the personal data are processed for. In addition, we hold your personal data in order to meet our legal obligations, to deal with potential complaints and to protect our legal rights in the event of a claim being made.

For the determination of the appropriate retention period, we always take in mind the amount, nature, and sensitivity of personal data, the purposes for which we process it and whether we can achieve those purposes through other means.

In any case your personal data will be deleted in a secure way or will be destroyed when no longer needed.

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

However, we use suitable technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or unauthorized access by third parties. Our security measures are continuously improved in line with technological developments. For that purpose, our associates are also implementing security measures that safeguard the personal data they process.

We may employ third party companies and individuals to facilitate our Service (hereinafter referred to as the “Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. The relationship between the Company and the Services Providers is governed by a specific contract for the secure processing of personal data.

We may provide paid products and/or services within the Service. In that case, we use third-party service for payment processing (e.g. payment processor).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processor whose use of your personal information is governed by their Privacy Policy. This payment processor adheres to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

YOUR DATA PROTECTION RIGHTS:

Right to be informed – You have the right to be informed about the collection and use of your Personal Data.

Right of access – You may ask for a free copy of your Personal Data that is being used.

Right of rectification – You may ask to erase or rectify inaccurate or incomplete Personal Data.

Right to erasure (right to be forgotten) – You may ask us to erase your Personal Data, as long as there is no justifiable reason for us to continue to do so.

Right to restrict processing – You can ask us to restrict the purposes of your Personal Data processing.

Right to object to processing – You have the right to object to processing when we rely on a legitimate interest. In such a case we shall stop processing your Personal Data unless we prove that compelling legitimate grounds override your rights and freedoms.

Right to data portability – You have the right also ask us to transfer your Personal Data directly to another business.

Right to withdraw consent – You may withdraw the consent you have given us at any time.

Right to report a complaint – If you have concerns about the way we use your Personal Data, you may contact our Data Protection Officer (DPO), if applicable. You also have the right to report us to the Commissioner of Personal Data Protection through the website www.dataprotection.gov.cy.

We may update our Privacy Policy from time to time. We will notify you of any changes by providing you the new Privacy Policy.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “Effective Date” at the bottom of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

If you have any questions about this Privacy Policy, please contact us:

Effective date: 28 November 2022