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PRIVACY POLICY

Last updated: 9 May 2022

This Privacy Notice describes how Cobo collects and processes your personal
information through the Cobo websites and applications that reference this
Privacy Notice. Cobo refers to an ecosystem comprising Cobo websites (whose
domain names include but are not limited to www.cobo.com, mobile applications,
clients, applets and other applications that are developed to offer Cobo
Services, and includes independently-operated platforms, websites and clients
within the ecosystem (e.g Cobo's Custody, DeFi Yield Fund, DaaS, MaaS, StaaS,
WaaS, Ventures). “Cobo Operators” refer to all parties that run Cobo, including
but not limited to legal persons, unincorporated organizations and teams that
provide Cobo Services and are responsible for such services. “Cobo” as used in
this Policy includes Cobo Operators.

This Privacy Policy applies to all platforms, websites, and departments of Cobo
and Cobo Operators. By using Cobo Services, you are consenting to the
collection, storage, processing and transfer of your personal information as
described in this Privacy Policy.

Cobo is the data controller for personal information collected in connection
with provision of Cobo services.

1. What Personal Information does Cobo collect and process? Why does Cobo
process my personal information ? What are the legal basis for our use of
personal information?

What personal information does Cobo collect and process?

 * email address;

 * name;

 * gender;

 * date of birth;

 * home address;

 * phone number;

 * nationality;

 * device ID;

 * a video recording of you;

 * transactional information;

 * the Internet protocol (IP) address used to connect your computer to the
   Internet;

 * login, e-mail address, password and location of your device or computer;

 * Cobo Services metrics (e.g., the occurrences of technical errors, your
   interactions with service features and content, and your settings
   preferences);

 * version and time zone settings;

 * transaction history;

 * Information from other sources: we may receive information about you from
   other sources such as credit history information from credit bureaus;

 * Information about your behavior: we may process information about you on your
   behavior and your activity for marketing and advertising purposes.

Why does Cobo process my personal information?

 * Transaction services. We use your personal information to process your
   orders, and to communicate with you about orders and services;

 * Communicate with you. We use your personal information to communicate with
   you in relation to Cobo Services;

 * We collect and process identity information and Sensitive Personal Data (as
   detailed in section 1) to comply with our Know Your Customer (“KYC”)
   obligations under applicable laws and regulations, and Anti-Money Laundering
   laws and regulations;

 * Provide, troubleshoot, and improve Cobo Services. We use your personal
   information to provide functionality, analyse performance, fix errors, and
   improve the usability and effectiveness of Cobo Services.

 * Fraud prevention and credit risks. We process personal information to prevent
   and detect fraud and abuse in order to protect the security of our users,
   Cobo Services and others. We may also use scoring methods to assess and
   manage credit risks.

 * Improve our services. We process personal information to improve our services
   and for you to have a better user experience;

 * Recommendations and personalisation. We use your personal information to
   recommend features and services that might be of interest to you, identify
   your preferences, and personalise your experience with Cobo Services;

Legal Basis for our use of personal information (EU and UK GDPR)

 * Performance of a contract when we provide you with products or services, or
   communicate with you about them. This includes when we use your personal
   information to take and handle orders, and process payments.

 * Our legitimate interests and the interests of our users when, for example, we
   detect and prevent fraud and abuse in order to protect the security of our
   users, ourselves, or others;

 * Our legitimate interest to improve our services;Your consent when we ask for
   your consent to process your personal information for a specific purpose that
   we communicate to you. When you consent to processing your personal
   information for a specified purpose, you may withdraw your consent at any
   time and we will stop processing your data for that purpose.

2. Can Children Use Cobo Services? Cobo does not allow anyone under the age of
18 to use Cobo Services.

3. What About Cookies and Other Identifiers? We use cookies and similar tools to
enhance your user experience, provide our services, and understand how customers
use our services so we can make improvements. The cookie banner on your browser
will tell you how to accept or refuse cookies.

4. Does Cobo Share My Personal Information?

Information about our users is an important part of our business and we are not
in the business of selling our users' personal information to others. Cobo
shares users' personal information only as described below and with the
subsidiaries or affiliates of Cobo that are either subject to this Privacy
Notice or follow practices at least as protective as those described in this
Privacy Notice.

Third party service providers: We employ other companies and individuals to
perform functions on our behalf. Examples include analyzing data, providing
marketing assistance, processing payments, transmitting content, and assessing
and managing credit risk. These third-party service providers only have access
to personal information needed to perform their functions, but may not use it
for other purposes. Further, they must process the personal information in
accordance with our contractual agreements and only as permitted by applicable
data protection laws.

Business transfers: As we continue to develop our business, we might sell or buy
other businesses or services. In such transactions, user information generally
is one of the transferred business assets but remains subject to the promises
made in any pre-existing Privacy Notice (unless, of course, the user consents
otherwise). Also, in the unlikely event that Cobo or substantially all of its
assets are acquired, user information will be one of the transferred assets.

Protection of Cobo and others: We release accounts and other personal
information when we believe release is appropriate to comply with the law or
with our regulatory obligations; enforce or apply our Terms of Use and other
agreements; or protect the rights, property or safety of Cobo, our users or
others. This includes exchanging information with other companies and
organizations for fraud protection and credit risk reduction.

5. International transfers of personal data

Cobo may transfer your data outside of the European Economic Area (“EEA”). Cobo
puts in place suitable technical, organizational and contractual safeguards
(including Standard Contractual Clauses), to ensure that such transfer is
carried out in compliance with applicable data protection rules, except where
the country to which the data is transferred has already been determined by the
European Commission to provide an adequate level of protection.

6. How Secure is My Information?

We design our systems with your security and privacy in mind. We work to protect
the security of your personal information during transmission by using
encryption protocols and software.

We maintain physical, electronic and procedural safeguards in connection with
the collection, storage and disclosure of your personal information. Our
security procedures mean that we may ask you to verify your identity to protect
you against unauthorized access to your account password. We recommend using a
unique password for your Cobo account that is not utilized for other online
accounts and to sign off when you finish using a shared computer.

7. What About Advertising?

In order for us to provide you with the best user experience, we may share your
personal information with our marketing partners for the purposes of targeting,
modeling, and/or analytics as well as marketing and advertising. You may opt-out
of sharing personal information with our marketing partners, unless we have a
legitimate interest to do so.

8. What Information Can I Access? You can access your information, including
your name, address, payment options, profile information, and transaction
history in the "Your Account" section of the website.

9. What Rights Do I Have?

If you have any questions or objections as to how we collect and process your
personal information, please contact dpo@cobo.com.

When you consent to our processing your personal information for a specified
purpose, you may withdraw your consent at any time.

In addition, subject to applicable law, you have the right to request access to,
correct, and delete your personal data, and to ask for data portability. You may
also object to our processing of your personal data or ask that we restrict the
processing of your personal data in certain instances, by contacting
dpo@cobo.com.

 * Right to access: you have the right to obtain confirmation that your Data are
   processed and to obtain a copy of it as well as certain information related
   to its processing;

 * Right to rectify: you can request the rectification of your Data which are
   inaccurate, and also add to it. You can also change your personal information
   in your Account at any time

 * Right to delete: you can, in some cases, have your Data deleted;

 * Right to object: you can object, for reasons relating to your particular
   situation, to the processing of your Data. For instance, you have the right
   to object to commercial prospection;

 * Right to limit the processing: in certain circumstances, you have the right
   to limit the processing of your Data;

 * Right to portability: in some cases, you can ask to receive your Data which
   you have provided to us in a structured, commonly used and machine-readable
   format, or, when this is possible, that we communicate your Data on your
   behalf directly to another data controller;

 * Right to withdraw your consent: for processing requiring your consent, you
   have the right to withdraw your consent at any time. Exercising this right
   does not affect the lawfulness of the processing based on the consent given
   before the withdrawal of the latter;

 * Right to define the instructions relating to the use of your personal data
   post mortem: you have the right to define instructions relating to the
   retention, deletion and communication of your Data after your death;

 * Right to lodge complaints to the relevant data protection authority.

10.How Long Does Cobo Keep My Personal Information?

We keep your personal information to enable your continued use of Cobo Services,
for as long as it is required in order to fulfil the relevant purposes described
in this Privacy Notice, and as may be required by law such as for tax and
accounting purposes, compliance with Anti-Money Laundering laws, or as otherwise
communicated to you.

11.Contact Information

Our data protection officer can be contacted at dpo@Cobo.com, and will work to
address any questions or issues that you have with respect to the collection and
processing of your personal information.

12.Conditions of Use, Notices and Revisions

If you choose to use Cobo Services, your use and any dispute over privacy is
subject to this Notice and our Terms of Use. If you have any concerns about
privacy at Cobo, please contact us with a thorough description, and we will try
to resolve it. You also have the right to contact your local Data Protection
Authority.

Our business changes constantly, and our Privacy Notice will change also. You
should check our websites frequently to see recent changes. If you do not agree
with the revised content, you shall stop accessing Cobo immediately. When an
updated version of the Privacy Policy is released, your continued access to Cobo
means that you agree to the updated content and agree to abide by the updated
Privacy Notice. Unless stated otherwise, our current Privacy Notice applies to
all information that we have about you and your account.

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