1. INTRODUCTION

a. This Privacy Policy (“Policy") is a legal agreement between BYTEPAD and its affiliates

and subsidiaries worldwide (“BYTEPAD”, “we”, “us” or "our", "Platform",”Bytedex”) and you, an end

user of the Services (“you” or “User”) in relation to the Services.

b. This Policy (together with our Terms of Use) explains and sets out the basis for why and

when we collect Personal Information about the people who use BYTEPAD, how we use

it, the conditions under which we may disclose it to others and the measures we take to

keep it secure.

c. By using BYTEPAD, you are accepting and consenting to the practices described in this

Policy. Please note that this includes consenting to the collection and processing of any

Personal Information you provide, as described below. We may amend this Policy from

time to time so please check it occasionally to ensure that you agree with any changes.

Your continued use of BYTEPAD will constitute your acceptance of, and agreement to,

any changes.

d. BYTEPAD values privacy and we make a concerted effort to minimize and, to the extent

possible, eliminate the exposure of personal data during the use of our interface.

e. We do not collect any special categories of personal information about you (this

includes details about your race or ethnicity, religious or philosophical beliefs, sex life,

sexual orientation, political opinions, trade union membership, information about your

health and genetic and biometric data) except KYC process.

f. We do not collect, hold, or store any information relating to your wallet, including private

keys, keystore files, passwords, mnemonic phrases.

g. To the extent we collect any Personal Information, this Policy describes how BYTEPAD

collects, uses, and shares Personal Information of people who use BYTEPAD.

h. This Policy applies to anyone who accesses BYTEPAD. Please read the Policy carefully

to understand our practices regarding your information and how we will treat it. By

visiting the Platform, and/or using the Platform, you acknowledge that the collection,

use, and sharing of your information will take place as described in this Policy.

i. So that we are clear about the terminology we are using, when we use the phrase

“Personal Information” in this Policy, we mean information about an individual that

(either by itself or when combined with information from other available sources) allows

that individual to be identified, including but not limited, the individual’s name, telephone

number, or e-mail address.

2. THE BLOCKCHAIN

Due to the inherent transparency of many blockchains, transactions that individuals broadcast

via any blockchain may be publicly accessible. This includes, but is not limited to, your public

sending address, the public address of the receiver, the amount sent or received, and any other

data a user has chosen to include in a given transaction. Information stored on a blockchain

may be public, immutable, and difficult or even impossible to remove or delete. Transactions

and addresses may reveal information about the user’s identity and information can potentially

be correlated now or in the future by any party who chooses to do so, including law

enforcement. Users are encouraged to review how privacy and transparency on the blockchain

works.

3. HOW WE COLLECT INFORMATION

We obtain information about you when you use BYTEPAD, when you contact us via email or a

web form or if you register to receive one of our regular newsletters. We may collect and

process the following types of information about you:

a. Information you provide us You may provide us with Personal Information by filling in

forms on the Platform or by corresponding with us by e-mail or live-chat. The Personal

Information you provide may include your name, email, address, phone number,

language preference and information regarding the pages you access. By providing us

with this information, you expressly consent to our use of your Personal Information in

accordance with this Policy.

b. Information we collect about you When you use Platform, we may automatically collect

information about your IP address, information about your visit, browser plug-in types

and versions, your browsing activity, time zone setting, how you use Platform, and

information about your visit, including the dates and times you use the Platform length

of visits to certain pages, page interaction information (such as scrolling, clicks, and

mouse-overs), methods used to browse away from the page.

c. Information we receive from other sources We may receive information about you if you

use any other services we, or our partners, operate. We also work with third parties

(including, contractors, project partners, service providers, analytics providers) and may

receive information about you from them. This may be combined with other information

you provide to use to collect information about you as described below. We use this

information to enhance your experience with the Platform.

4. HOW WE USE INFORMATION

a. We use the information that we have about you to provide support and certain services

to you.

b. We may use the Personal Information we collect from and about you to:

• provide you with information or services that you request from us, including to

respond to your comments, questions, and/or provide customer service;

• provide information to you about developments and new products, features,

including changes and enhancements to the Platform;

• monitor and analyze usage and trends and personalize and improve Platform

and your experience using Platform;

• conduct surveys and get feedback from you

• develop, enhance, and market products and services, and provide products and

services to you;

• meet BYTEPAD’s legal and regulatory requirements, and

• for any other purpose with your consent.

c. We use IP addresses to analyze trends, administer the Platform, track user movements,

and gather broad demographic information for aggregate use. For systems

administration and detecting usage patterns and troubleshooting purposes, BYTEPAD’s

web servers also automatically log standard access information including browser type,

access times/open mail, URL requested, and referral URL. This information is not shared

with third parties and is used only within BYTEPAD on a need-to-know basis. We reserve

the right to block access for any user accessing BYTEPAD via a proxy service intending

to conceal originating identity.

d. We review our retention periods for Personal Information on a regular basis. We will hold

your Personal Information on our systems for as long as is necessary for the relevant

activity.

3

5. SHARING OF PERSONAL INFORMATION

a. We will not disclose your Personal Information other than as described below, and we do

not and will not sell your Personal Information to anyone.

b. You agree that we have the right to share the Personal Information we collect from and

about you:

• to fulfill the purpose for which you provided it;

• with your consent;

• for legal, protection, and safety purposes;

• to comply with any court order, law, or legal process, including to respond to any

government or regulatory request;

• to protect the rights of BYTEPAD, our agents, customers, and others, including by

enforcing our agreements, policies, and terms of service;

• with third parties, if BYTEPAD or substantially all our assets are acquired by a

third party, in which case Personal Information held by us about the users will be

one of the transferred assets and,

• with those who need it to do work for us (our service providers, as defined

below). Service providers: We may contract with third parties to perform

functions related to Platform. In general, service providers will have access to

your Personal Information only to the extent needed to perform their business

functions but may not use or share that Personal Information for purposes

outside the scope of their functions related to Platform.

c. We reserve the right to share historical wrap and/or unwrap transactions, estimated and

actual trade volumes; settlement prices; and other aggregate data and information

related to the digital assets available on BYTEPAD.

6. LEGAL BASIS FOR PROCESSING

The following legal bases apply to the ways in which we use and share your Personal

Information:

• when it is necessary for us to perform pursuant to our contract with you or in your

interests; 

● in our legitimate interests in ensuring our business is conducted legitimately

and to a high standard. Legitimate interests mean the interests of our organization to

conduct and manage our business to enable us to better serve you and provide you with

a secure experience on BYTEPAD;

• generally, we do not rely on consent as a legal basis for processing your Personal

Information;

• we will retain the information you provide in order to process your request, provide

support, and/or carry out and fulfill our Promotions.

7. OTHER SITES AND LINKS TO OTHER SITES

a. BYTEPAD may contain links to other third-party websites or applications. Once you click

on such a link and leave BYTEPAD or are redirected to a third-party website or

application, you are no longer governed by this Policy. Any information you provide on

those sites is subject to that third party’s privacy policy and we are not responsible for

the privacy and security practices and policies of those third-party sites or applications.

b. This Policy and the use of your Personal Information only applies to the information you

provide. You are cautioned that if you disclose Personal Information or personally

sensitive data through the use of the Internet, such as through chat rooms, communities,

4

bulletin boards, or other public online forums, this information may be collected and

used by other persons or companies over which BYTEPAD has no control. It is your

responsibility to review the privacy statements, policies, terms, and conditions of any

person or company to whom you choose to link or with whom you choose to contract.

We are not responsible for the privacy statements, policies, terms, conditions, or other

content of any Site not owned or managed by us.

8. OUR COMMITMENT TOWARDS CHILDREN'S PRIVACY

We do not direct BYTEPAD to, nor do we knowingly collect any Personal Information from

children under 18. Children under 18 are not eligible to use BYTEPAD. If we learn that someone

using BYTEPAD is under 18 years of age, we will take steps to remove any Personal Information

from our database and to prevent them from utilizing BYTEPAD.

9. SECURITY OF YOUR PERSONAL INFORMATION & RIGHTS

a. We are committed to protecting the security of Personal Information. We have taken

certain physical, administrative, and technical steps to help safeguard the information

we collect from and about you. While we take steps to help ensure the integrity and

security of our network and systems, we cannot guarantee the security of your data

transmitted to us over the email or through BYTEPAD; any transmission is at your own

risk. Once we have received your data, we will use strict procedures and security

features to try to prevent unauthorized access

b. Personal Information and other data may be exported outside of the jurisdiction in which

you reside. Your Personal Information may be processed and stored in a foreign country

or countries. Under those circumstances, the governments, courts, law enforcement, or

regulatory agencies of that country or those countries may be able to obtain access to

your Personal Information through foreign laws. You need to be aware that the privacy

standards of those countries may be lower than those of the jurisdiction in which you

reside.

10. CONTACT US

Any questions regarding this policy and our privacy practices should be sent by email to

[email protected]

11. CHANGES TO PRIVACY POLICY

a. BYTEPAD shall be permitted to make amendments to the Policy from time to time. You

will be deemed to have accepted such amended Policy by indicating your acceptance on

BYTEPAD. Any further actions which you make will be subject to the Policy in effect at

that time. If you object to any changes, you may stop using BYTEPAD. Your continued

use of BYTEPAD after we publish or otherwise provide notice about our changes to the

Policy means that you are consenting to the updated Policy.

b. We keep this Policy under regular review. This Policy was last updated November 07,

2022.