Privacy Statement

Privacy Policy Notice

This notice was last updated on January 9, 2023

We, Akurateco Lab, Informatica Unipessoal LDA, - Data Controller: a company incorporated and registeredunder the laws of the Portugal with company number 516406205 whose registered office is at Rua do Breijinho, № 4, 2 dt.2135-099 Samora correia, Portugal, is committed to protecting your privacy.

In accordance with General Data Protection Regulation (GDPR) we have specified in detail what data we are collecting,how we are using your data and all rights you have under the European data protection legislation.

We may change this notice from time to time to stay aligned current with the changes in the GDPR and E-Privacy Directive(PECR).

Please check back on a regular basis to read the latest version of this notice.

Data Protection is regulated and enforced in the Portugal by the appropriate member of European DataProtection Board:

Av. D. Carlos I, 134, 1º

1200-651 Lisboa

Tel. +351 21 392 84 00

Fax +351 21 397 68 32

Email: [email protected]

Website: http://www.cnpd.pt/

Data protection officer:

For all inquiries regarding our usage of your personal data as well as executing your rights, please contact our DataProtection Officer Sergiy Shelukha:

phone: +380(50) 4110300

e-mail: [email protected]

e-mail: [email protected]

Please read this Policy carefully. By accessing, browsing or using our website or Services, you confirm that you have read, understand and agree to the terms of this Privacy Policy Notice.

1. Data Subject Rights

Under the GDPR you, as a data subject, have the right to access all datawe hold of you, correct data which you deem to be incorrect or incomplete, request us to stop processing your data orrequest us to delete all your data from our systems.

You can execute any of these rights by contacting our data protection officer, contact details can be found to the topof this privacy notice.

We will respond to your requests, where required, within 4 weeks of receiving your request.

Please note: to protect your privacy as well as that of our other members, clients and prospects, wemay ask you to provide proof of identity to us. This may be necessary to make sure we do not provide your data tosomebody else or provide you with data that is not your own.

Making use of your rights is free of charge, unless we deem your requests to be excessive, repetitive in nature orotherwise manifestly executed with malicious intent, we reserve the right to not respond to your request in full orcharge you a reasonable fee based on our administrative costs.

In either case, we will inform you of our decision.

2. What information we are collecting from you?

The Akurateco Lab collects information voluntarily given by potential partners. We collect and processseveral bits of your personal information for different reasons, these are depending on the relationship we have withyou directly or through the different partners in accordance with Data Protection Agreements. This processing isnecessary for the performance of a contract to which the data subject is party or in order to take steps at the requestof the data subject prior to entering into a contract.

3. Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

From You

• When you provide such information directly to us
• When you create an account or use our interactive tools and Services
• When you voluntarily provide information in free-form text boxes through the Services or through responses tosurveys or questionnaires
• When you send us an email or otherwise contact us
• When you use the Services and such information is collected automatically
• Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below)
• When you voluntary propose business cards for further communication

From Third Parties

• Business affiliates or agents who collaborate based on Data Processing Agreements
• Analytics service providers (e.g., providing browser device and web analytics data)

Data is only processed for specifically defined purposes based on lawfulnessprocessing is necessary for the performance of your contract to which you are party or in order to take steps atyour request prior to entering into a contract.

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect.

This chart includes Personal Data that we have collected over the past 5 months:

Processing of personal data related to procedures of hiring is not to be recorded due to occasional character (Art. 30 -5) and will be conducted in accordance with explicit consent through candidate's record card or is due to privacyclauses in labor contract.

4. Data Security and Retention

Akurateco uses reasonable security measures to protect your personal information from unauthorized access and use incompliance with applicable law. We also maintain other physical, technical, administrative, and procedural safeguards toprotect personal information, and access to personal information is limited to the employees who require it for theirjob functions.

Please be aware that despite our efforts, no data security measures can guarantee 100% security. You should take stepsto protect against unauthorized access to your password, phone, and computer by, among other things, signing off afterusing a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-inand password private. We cannot be responsible for any lost, stolen, or compromised passwords or for any activity onyour account via unauthorized password activity.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provideyou with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with ourlegal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, ruleor regulation.

Generally, the following retention scheme is use:

• Data from prospects obtained by Application Form is kept no longer than one year after the last contact with theprospect
• Merchant data is kept for 3 years after the contract ends, unless specific requirements including fiscal law orlegal claims mandate us to keep certain information for a longer term
• We may further retain information in a de-identified, anonymous, or aggregated form as archive information forstatistical researching.

We would like to emphasize that aforementioned databases have a restricted access by administrative and adequatetechnical measures in accordance with approved Privacy Policy and Policy of Information Security.

In order to reinforce personal liability of each participant of processing we include personal data as separate point inthe List of Company Trade Secrets.

5. Who do we share your data with?

We only share your data with our partner organizations as well as professionals we contract to supply us with necessaryresources to fulfil your contract or perform business functions on our behalf.

They include:

• Hosting, technology and communication providers
• Security and fraud prevention consultants
• Support and customer service vendors
• Payment processors

We will make sure that any party we share data with is held to the same strict data protection procedures as are used byus in concordance with B2B Principles for business-to-business (B2B, B2C) and business-to-government (B2G) data sharing.

Personal data may not be further processed by our partners and staff for any other reason, except when expresslymandated by us in accordance with relevant Data Protection Agreements or for the defense of legal claims.

6. De-identification as preventive technical measures

We may create aggregated, de-identified, or anonymized data from the Personal Data we collect, including by removinginformation that makes data user personally identifiable. We may use such aggregated, de-identified, or anonymized dataand share it with third parties for our lawful business purposes, including to analyze, build and improve the Servicesand promote our business. In any case all negotiation or further data processing connected with international datatransfers are based on preliminary monitoring third countries which have to ensure an adequate level of data protection.Beside this we use all permissible resources like as binding corporate rules or standardcontractual clauses to enhance the protection of data subject rights.

7. Marketing usage

We will not use data that allows to identify you as natural person. We only will use your e-mail to market innovationsin cross-border B2B technology that Akurateco offers to you under the following conditions:

• You are being considered as legal person have provided us your e-mail by Application Form
• You are legitimate representative of the legal person, in which case we will only market to you related servicesto the ones you already have obtained in accordance with bilateral contract or which we may believe in goodfaith are of interest to you

In all cases, you have the right to opt-out of any marketing usage by using the relevant option present in all marketingcommunications.

8. Further complaints

In order to avoid any suspects or doubts that can provoke to infringement of data subject rights we have to inform youthat any data subject request will be exercised by approved procedure of natural person authentication.

If we can't agree on a resolution to your complaints, you believe we are handling your personal data incorrectly or weare infringing on any of your rights as listed above and we can't come to a mutual satisfactory agreement to solve ourdifferences, you are welcome to contact the appropriate Data Protection Authorities and register your grievances withthem.