MERJ Group Privacy Policy

Security and Integrity of Personal Information

At MERJ Exchange Limited ("MERJ," "the Company," or "we"), the safeguarding of your Personal Information is a priority. We are dedicated to upholding the privacy, confidentiality, and security of the Personal Information you entrust to us. We encourage you to thoroughly review this Privacy Policy, which contains vital details regarding the handling of your Personal Information.

Ownership and Operation

MERJ owns and operates the online platform accessible at www.merj.exchange (referred to as "our Website").

Scope of Policy

This Privacy Policy is expressly limited to personally identifiable information collected through our Website by MERJ and its affiliates, which include MERJ Clearing and Settlement Limited and MERJ Depository and Registry Limited. References to "our Website" within this Privacy Policy pertain exclusively to the webpages of www.merj.exchange that are directly linked to this policy.

Definition of Personal Information

"Personal Information," as used in this document, denotes 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, or an online identifier.

"Processing" of your Personal Information encompasses all actions related to the handling, collection, protection, and storage of such data.

Inquiries and Contact Information

Should you have any inquiries or concerns regarding this Privacy Policy or your Personal Information, please contact us using the details provided in the "Contact Us" section below.

Our Commitment and Your Engagement

By outlining our practices, this Privacy Policy clarifies how we collect, process, store, share, and protect your Personal Information during your engagement with us, specifically when you:

• Apply to become a Platform Participant of MERJ by completing the "MERJ Platform Participant Agreement" form on our Website to create your trading account;
• Apply to serve as a Service Provider for MERJ by submitting the "Member Application Form" or "Sponsor Advisor Application Form" through our Website;
• Engage with us in any capacity that establishes you as a MERJ client;
• Utilize our Website for information or services; and
• Contact us, whether for media, investor relations, stakeholder outreach, or other communications.

Collectively, we refer to the above points as the "Activities."

Voluntary Provision of Information

Visiting our Website does not necessitate the provision of your Personal Information. However, engaging in certain Activities, as specified above, may require such information.

Collection of Personal Information

We typically acquire your Personal Information directly from you (for example, through your voluntary engagement in the Activities) or from publicly available sources.

Data Collection and Processing

Active Collection: We gather and process your Personal Information under the following circumstances:

• When you register on our Website, apply to become a participant on a MERJ platform, or seek to become a sponsor advisor, a member as defined in the MERJ Listing Rules, or engage in other activities resulting in a client relationship with MERJ.

Passive Collection: As you navigate through and interact with our Website, we may use automatic data collection technologies, such as cookies, to collect certain information.

Understanding Cookies: Cookies are small files placed on your device that enable us to recognize your browser and capture and remember certain information. They help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

Your Consent and Control: By using our Website, you consent to our use of cookies as described in this policy. We respect your privacy and provide you with the option to refuse the setting of cookies at any time via your web browser settings. However, please note that disabling cookies may affect the functionality of this and many other websites that you visit.

Compliance with Applicable Law: In compliance with the applicable law, we ensure that your Personal Information is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only collect and process your Personal Information where we have a legal basis to do so, which includes consent, necessary for the performance of a contract with you, necessary to comply with a legal obligation, necessary to protect your vital interests, or necessary for the pursuit of legitimate interests pursued by us or a third party.

For more detailed information on our use of cookies and your data protection rights, please refer to our dedicated "Cookie Policy" and "Your Data Protection Rights" sections, respectively.

If you have any questions about how we handle your Personal Information or your data protection rights, please do not hesitate to get in touch with us using the contact details provided.

Utilization of Personal Information

 Purpose of Use: Your Personal Information is utilized exclusively for the following purposes:

• Processing applications related to the Activities you wish to engage in with MERJ.
• Enhancing and personalizing your experience on our Website.
• Continuous improvement of the services provided through our Website.

Consent and Policy Integration: By engaging in the Activities and using our Website, you consent to the collection and use of your Personal Information as detailed in this Privacy Policy. Furthermore, this Privacy Policy forms an integral part of the MERJ Platform Participant Agreement and the Service Provider Agreement, which collectively outline the terms of your engagement with us.

Types of Personal Information Collected: We may collect and process various categories of your Personal Information, which typically include:

• Identifiers: Name, date of birth, gender, photograph, identification documents such as passports or driver's licenses, birth certificates, ethnicity, language preferences, and physical or mental health data.
• Contact Information: Email addresses, residential addresses, telephone numbers, and other related contact details, including those related to your country of residence.
• Personal History: Family status, educational background, employment and criminal history where applicable.
• Financial Details: Income, banking, and taxation information as per relevant documentation.
• Digital Identifiers: Blockchain addresses, public keys, and related identifiers.
• Account Information: Usernames, passwords, and other security-related information for account access.
• Communications: Correspondence and records of communications with us, including interactions on social media platforms and services we provide.
• Usage Data: Preferences and interaction patterns with our Website.

Collection of Non-Personal Information: We also record Non-Personal Information which does not identify you specifically. This includes, but is not limited to:

• Technical Data: IP addresses, domain names of internet service providers, and approximate geographic locations.
• Usage Statistics: Website navigation patterns, visitation times, and page views.

This data, passively collected, is solely for statistical analysis and traffic pattern assessment on our Website.

Your Data Protection Rights: You are afforded specific rights concerning your Personal Information:

• Right to Access: You can request copies of your Personal Information. A nominal fee might be charged for this service.
• Right to Rectification: If you find data inaccuracies, you have the right to have them corrected.
• Right to Erasure: You can request the deletion of your Personal Information under certain conditions.
• Right to Restrict Processing: You have the option to limit how your Personal Information is processed.
• Right to Object to Processing: Under certain conditions, you can object to the processing of your Personal Information.
• Right to Data Portability: You can ask for the transfer of your data to another entity or directly to you under certain conditions.

We are committed to responding to any requests within one month. To exercise any of these rights, please reach out to us at the contact details listed in the "Contact Us" section below.

Cookies and Online Tracking Technologies

 How We Use Cookies:

• Website Functionality: We utilize cookies to enhance website functionality, personalize your online experience, and improve navigation.
• Analytics: Cookies help us analyze user behavior on our Website to identify popular areas and improve content delivery.
• Non-Personal Data: Cookies used on our Website do not capture your personal identification details.

 Your Choices Regarding Cookies:

• Acceptance: By using our Website, you consent to our use of cookies.
• Managing Cookies: If you prefer not to accept cookies, you can:
  • Not use our Website,
  • Adjust your browser settings to refuse cookies from us,
  • Use your browser’s privacy feature (e.g., Incognito, InPrivate, Private Browsing).

 Aggregated Information: We aggregate personal data to understand user trends and patterns. This aggregated information is non-personal and is used for statistical analysis only.

Primary Uses of Personal Information: Your Personal Information is essential for:

• Identity verification and eligibility for services,
• Service delivery and relationship management,
• Website enhancement based on feedback,
• Educational purposes,
• Handling complaints and issues,
• Marketing and informational communications,
• Content personalization to better suit your interests.

 Assurance: We do not sell or supply your Personal Information to third parties outside of providing our services.

 Personal Information in Business Operations: We use your Personal Information for:

• Legal and regulatory compliance,
• Communications with authorities,
• Invoicing and financial records,
• Business development,
• IT security and management.

 Retention and Deletion:

• Retention: Personal data shall only be retained for as long as necessary to fulfill the specific purposes outlined in this Privacy Policy and to comply with our legal and regulatory obligations. The criteria used to determine the retention period include:
• The length of time we have an ongoing relationship with you and provide our services to you.
• Whether there is a legal obligation to which we are subject (such as certain laws requiring us to keep records of your transactions for a certain period of time before we can delete them).
• Whether retention is advisable considering our legal position (such as regarding applicable statutes of limitations, litigation, or regulatory investigations).
• Deletion Process: Once data is no longer needed, the following deletion processes will be initiated:
• Electronic Data: Data stored in electronic format will be securely erased using methods that ensure it cannot be reconstructed or read. We employ industry-standard deletion methods such as cryptographic wiping and physical destruction of storage devices when necessary.
• Physical Records: Any physical documents containing personal data will be securely shredded or otherwise destroyed in a manner that guarantees the data cannot be recovered or reconstructed.
• Third-Party Data Processors: We will also ensure that any third-party processors acting on our behalf enact equivalent measures to securely delete or anonymize personal data when it is no longer required.
• Special Circumstances for Deletion: Upon your request for deletion of your personal data, we will ensure that your data is removed from our systems and any backups in accordance with GDPR requirements, subject to any overriding legal obligations that require the retention of certain data.
• Verification of Deletion: Upon completion of the deletion process, we will conduct checks to verify that the data has been irretrievably deleted and provide you with confirmation upon request.

Business Transfers and Legal Disclosures:

• Transfers: Personal Information may be transferred in business transactions like mergers or acquisitions.
• Subsidiaries and Affiliates: We may share your data with subsidiaries and affiliates, who will be bound to honor this Privacy Policy.
• Legal Obligations: We may disclose Personal Information when (i) legally required, (ii) to protect or defend our rights or property, or (iii) to protect us against legal liability.

Non-Personal Information Sharing: Since it does not identify you, we may share non-personal data for any lawful purpose.

How We Protect Your Information

 Security Measures:

• We employ appropriate security measures to safeguard your Personal Information from unauthorized access, loss, misuse, inadvertent disclosure, alteration, and destruction.
• Our staff are trained and required to uphold your privacy and we restrict their access to what is necessary for their job functions.
• Your data is stored in secure electronic databases, with some possibly managed by third-party data storage providers. We also maintain physical records when necessary.
• All Personal Information is protected through a range of security processes.

 Internet Transmission Risks: While we strive to protect your information, the security of data transmitted over the Internet cannot be guaranteed, and thus, any transmission is at your own risk.

 Account Security for MERJ Platform Participants:

• Protect your personal data, especially identity information and passwords.
• Do not share your secure access credentials.
• Immediately change your password and notify us at support@merj.exchange.com if you suspect unauthorized access to your account.

 Access and Correction:

• We may deny access to information when it affects the privacy of others or breaches confidentiality, and we will inform you of the reasons.
• We may correct your Personal Information without your request if we find it to be inaccurate, incomplete, or misleading.

 Your Consent:

• By using our Website, you consent to the terms of this Privacy Policy, which may be updated periodically.

 Governing Law and Legislation:

• Our Website and transactions are governed by the laws of the Republic of Seychelles.
• In the absence of specific data protection legislation in Seychelles, this policy aligns with international best practices and may be amended to comply with future local laws.

 Changes to This Privacy Policy:

• We reserve the right to modify this Privacy Policy and will inform you of significant changes.
• Review this policy regularly, and understand that continued use after changes signifies acceptance of the revised policy.

Hyperlinks and Third-Party Websites: We are not responsible for the privacy policies of websites linked to our site. Review the policies of these third-party websites before sharing your Personal Information.