Effective date: January 20th, 2022

The Privacy Policy describes how Consortium 9 Labs Inc., collects, uses, processes, and discloses your information, including personal information, in conjunction with your access to and use of the website consortium9.co (the “Website”). This Privacy Policy describes the information we may collect from you or that you may provide when you visit the Website and our procedures regarding this information. We collect information:
In email, text and other electronic messages between you and this Website.
Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Policy.

This version of Privacy Policy has incorporated elements from the Regulation (EU) 2016/679 of the European parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation or GDPR) as we act in accordance the personal information processing rules within the European Economic Area (EEA).

When this Privacy Policy mentions “we,” “us,” or “our,” it refers to the Website, under the specified Terms and Conditions, that is responsible for your information under this Privacy Policy (the “Data Controller”).

Pursuant to Art. 4, para 7 of Regulation (EU) 2016/679 (GDPR), ‘Data controller’ means the natural or legal person that determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

If you see an undefined term in this Privacy Policy, it has the same definition as in our General Terms and Conditions of use to which this Privacy Policy is an inseparable part.

For the purposes of this document, the Website consists of products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by us or mobile apps, online platforms, official social media platforms or other online properties through which we provide the service offered by Consortium9 Labs Inc. (the “Service”).

We give utmost importance to the protection of personal data of our customers. In this Privacy Policy, we inform you about the collection, use and processing of your personal data when you apply, register or use Consortium9 Labs Inc. and all functionalities, included in the Service, including the Website.

By using the Website, you consent to the data practices described in this Privacy Policy. On occasion, Consortium9 Labs Inc. may revise this Privacy Policy to reflect changes in law or our personal data collection and use practices. If material changes are made to this Privacy Policy, the changes will be announced by posting on the site. We will ask for your consent before using your information for any purpose that is not covered in this Privacy Policy.

For the purposes of providing online access to the Website, the responsible Data Controller is Consortium9 Labs Inc.

The Website is designed for personal purposes and may be used by individuals or entities. In case you are registering for and/or using the service on behalf of an entity we will treat you as an authorized person and you may be obliged to disclose to us personal data of the legal representatives, the employees, the agents, the beneficial owners or any other third party related to the entity pursuant to the rules described below. You certify that where you have provided information regarding any third person beside yourself, you have received prior consent from that other person to provide their personal information to us.

This Privacy Policy does not apply to information collected by: us offline or through any other means, including on any other website operated by any third party (including our affiliates and subsidiaries) or any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

What Information We Collect.
We ask for and collect from you the following personal information when you use the Website. This information is necessary for us to comply with our regulatory obligations and for the adequate performance of the contract between you and us. Without it, we may not be able to provide you effectively the Service for which you register.

Registration and Use of Account Information
When you sign up for the Website, we may require certain personal information such as:
First name and surname
Date of birth
Email address
Registered address
Mobile telephone number
Identification document and all data from the identification document, including type of identification document, Issue date, ID number, Issuing authority.
Any other data which we may choose to collect in our enrollment forms for identification and verification purposes.

Identity Verification Information
In accordance with our legal obligations under the relevant anti-money laundering and anti-terrorism financing regulations, we are obliged to verify your identity or the identity of the authorized user who is opening the account (in case of a company or other entity, referred to as “user opening the account”).

Risk and Fraud related information
In order to comply with relevant anti-money laundering and anti-terrorism financing regulations, we collect personal data regarding you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Website through partnerships, or about your experiences and interactions from our partners and networks.

Source of income, annual estimate over the account or other activity details In order to comply with relevant anti-money laundering and anti-terrorism financing regulations, we collect personal data regarding you related to your sources of income and any other similar financial information about you which would help us prevent money laundering and/or terrorism financing.

Log data and device information
We automatically collect log data and device information when you access and use the Website, even if you have not created an account or logged in. That information includes, among other things: details about how you’ve used the Website, IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Website. We collect this information in relation to our legal obligation to provide you with secure methods of controlling your assets and your personal data.

Information That We Collect with Your Consent
You may choose to provide us with additional personal information in order to obtain a better user experience when using the Website. This additional information will be processed based on your consent. You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your online account, respond to surveys, participate in promotions, or use other features of the Website.

Information We Collect from Your Use of the Website
When you use the Website, we may collect information, including personal information, about the services you use and how you use them. This information is necessary given our legitimate interest in being able to provide and improve the functionalities of the Website.

Geo-location Information
When you use certain features of the Website, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. We may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions. The legitimate interests that we pursue with this processing is the identification of location-specific problems (i.e. coverage problems for SMS-sending purposes) and other statistical information, which helps us improve our services.

Usage Information
We collect information about your interactions with the Website such as your usage of any other apps or functionalities, and other interactions with the Website. The legitimate interests that we pursue with this processing is a collection of crash reports and other statistical information, which helps us improve our services.

A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

Web Beacons
Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies
Some content or applications on the Website are served by third-parties, including content providers and application providers. These third-parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with targeted content. We do not control these third-parties’ tracking technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible provider directly.

How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
To present our Website and its contents to you.
To enable your use of the Service and to process transactions and send notices about your transactions.
To provide you with information, products, or services that you request from us.
To fulfill any other purpose for which you provide it.
To provide you with notices about your account.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
Resolve disputes, collect fees, and troubleshoot problems.
To notify you about changes to our Website or or the Service.
To allow you to participate in interactive features on our Website.
In any other way we may describe when you provide the information.
For any other purpose with your consent.
We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you.

If you do not want us to use your information in this way please check the relevant box located on the form on which we collect your data (the registration form) or adjust your user preferences in your account profile. Note that certain information may be required for the operation and functioning of services we deliver to you.

Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described in this Privacy Policy:
To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.
To comply with any court order, law or legal process, including to respond to any government or regulatory request.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Consortium9 Labs Inc., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
Tracking Technologies: You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
Promotional Offers from Us: If you do not wish to have your email address or contact information used by the Consortium9 Labs Inc. to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data (the registration form) or at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to us as a result of a service purchase, service experience, or other transactions.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

How We Use The Information We Collect
We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the Website, create and maintain a secure environment, pursue our legitimate interests and comply with our legal obligations. In addition we use this information for the following purposes:
Providing the Website.
Authenticating and enabling your access to your online account or your payment instrument (Virtual Wallet).
Protecting, improving, personalizing and optimizing the Website and your experience.
Performing analytics and conducting research.
Provide customer support, including sending messages, updates, security alerts and account notifications.
Detecting and preventing fraud, abuse, security incidents, and other harmful activity by blocking the Service or by applying other fraud prevention measures.
Conducting security investigations and risk assessments.
Conducting checks against databases and other information sources.
Complying with legal obligations (such as anti-money laundering regulations).
Enforcing our rights, interests and claims arising from contractual obligations.
Conducting security investigations and risk assessments.
We process this information given our legitimate interest in protecting the Website, to measure the adequate performance of any contractual obligations with you, and to comply with applicable laws.

Provide, Personalize, Measure, and Improve our Advertising and Marketing
We may:
Send you promotional messages, marketing, advertising, and other information related to the Website and the products and services of unaffiliated businesses that may be of interest to you based on your preferences and social media advertising through social media platforms, such as Facebook, Twitter, TikTok, Instagram or Google.
Provide personalized services offered by us on third-party websites and online services.
Provide a targeted display, feature or offer to you on third-party websites.
Use cookies and other tracking technologies to provide these online services and/or work with other third-parties such as advertising or analytics companies to provide these online services;
Provide you with location-specific options, functionality or offers if you elect to share your Geo-location Information through the Services.

We will use this information to:
Enhance the security of the Website and provide you with a location-based Service, such as advertising, search results, and other personalized content.
Make it easier for you to find and connect with others. Social functionality and features designed to simplify your use of the Services with others vary by service.
Personalize, measure, and improve our advertising.
Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or its third-party partners.
Provide games, quizzes and completion of questionnaire or a contest entry form for promotional campaigns.
Conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Website, information obtained from third parties) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you.
We will process your personal information for the purposes listed in this section given your consent in undertaking marketing activities to offer you products or services that may be of your interest. You have the right to opt-out from processing your personal information for the purposes described above by withdrawing your consent at any time and free of charge.

With Whom Do We Share personal data
With other members of the corporate family of Consortium9 Labs Inc. We may share your personal data with members of Consortium9 Labs Inc. group of companies or within our extended family of companies that are related by common ownership or control.
With third party service providers: We may share personal information with third party service providers that support us in providing the Service, products and/or services with functions at our decision and our behalf. These third-party service providers may for example:
Verify your identity or authenticate your identification documents.
Check information against public databases.
Conduct background, fraud prevention, and risk assessment.
Perform risk monitoring.
Perform product development, maintenance and debugging.
Allow the provision of theWebsite through third party platforms and software tools.
Provide customer support.
Provide IT support and development services.
Provide technical support for the Website.
Promote the Website as distributors, promoters, sales agents or similar.
Provide cloud, storage or collocations services.
Provide audit and accountancy services.
Provide legal, compliance or other consultancy services.
Provide marketing and public relations services.
These providers have limited access only to your information necessary to perform the tasks for which they were contracted for on our behalf and are contractually bound to protect and to use it only for the purposes for which it was disclosed and which are consistent with this Privacy Policy.

We may share information about you with other parties for our legitimate interest or as permitted or required by law, including:
If we need to do so to comply with a law, legal process or regulations.
To law enforcement authorities or other government officials, or other third parties pursuant to a subpoena, a court order or other legal process or requirement applicable to us.
If we believe, in our sole discretion, that the disclosure of personal data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity.
To protect the vital interests of a person.
To investigate violations of or enforce a user agreement or other legal terms applicable to any service.
To protect our property, services and legal rights.
To facilitate a purchase or sale of all or part of our business.
In relation to promoting the Website to end users by third party business introducers.
To help assess and manage risk and prevent fraud against us, our clients and fraud involving the website, mobile app or use of our service, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals, and merchants.
To companies that we plan to merge with or be acquired by.
To support our audit, compliance, and corporate governance functions.
With your consent: We also will share your personal data and other information with your consent or direction, including if you authorize an account connection with a third-party account or platform.

Aggregated Data
In addition, we may provide aggregated statistical data to third-parties, including other businesses and members of the public, about how, when, and why users visit our website and services. This data will not personally identify you or provide information about your use of the Website. We do not share your personal data with third parties for their marketing purposes without your consent. We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

We may monitor or record telephone calls, emails, web chat or other communications with you for regulatory, security, customer services or training purposes.

Your Rights
You may exercise any of the rights described in this section before the respective Data Controller by sending an email from your registered e-mail for a service to the company providing that service to you under their contractual and legal obligations. Please note that we may ask you to verify your identity before taking further action on your request. Please note that upon receipt of your e-mail we shall try our best to provide you with the requested information and resolve your request in reasonable time, subject to all obligations which we or the related companies have under the applicable laws.

Managing Your Information
You have the right to obtain the following:
Confirmation of whether, and where we are processing your personal data.
Information about the purposes of the processing.
Information about the categories of data being processed.
Information about the categories of recipients with whom the data may be shared.
Information about the period for which the data will be stored (or the criteria used to determine that period).
Information about the existence of the rights to erasure, to rectification, to restriction of processing and to object to processing; Information about the existence of the right to complain to any regulator.
Where the data was not collected from you, information as to the source of the data.
Information about the existence of, and an explanation of the logic involved in, any automated processing.

Rectification of Inaccurate or Incomplete Information
You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself via your online access to your online account).

Data Access and Portability
In some jurisdictions, you have the right to:
Receive a copy of your personal data in a structured, commonly used, machine-readable format that supports re-use.
Transfer your personal data from one controller to another.
Store your personal data for further personal use on a private device.
Have your personal data transmitted directly between controllers without hindrance. In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us.

Data Retention and Erasure
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our regulatory obligations. If you no longer want us to use your information to provide the Website to you, you can request that we erase your personal information and close your account, providing your account is in good standing, not blocked or somehow limited for compliance, risk or regulatory reasons, or due to your outstanding obligation to us, court order, pledge or order by another regulator or other reason which prevents us by law to close your account or terminate the Service.

Please note that if you request the erasure of your personal information. We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing security. For example, if we suspend your account for fraud or safety reasons, we may retain certain information from that account to prevent that client from opening a new account in the future. We are also obliged to retain personal data which we have collected for the purposes of complying with the relevant anti-money laundering and anti-terrorism financing for a period as defined under the applicable law. We may retain and use your personal information to the extent necessary to comply with our legal obligations. Because we maintain the Website to protect against accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

Withdrawing Consent and Restriction of Processing
Where you have provided your consent to the processing of your personal information by us, you may withdraw your consent at any time by changing your online account settings or by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing and the verification whether our legitimate grounds override your own is pending.

Objection to Processing
In some jurisdictions, applicable law may entitle you to require us not to process your personal information for certain specific purposes (including profiling for marketing purposes) where such processing is based on a legitimate interest. If you object to such processing we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims. Please note that Data Controllers which are regulated financial institutions, such as credit institutions, e- money institutions or similar are obliged under AML laws to make risk profiling of their customers upon opening of the relationship and constantly during the relationship and this is a legitimate reason. In case you do not wish us to process your personal data for certain specific purposes, which are legitimate purposes to us, you shall have to close your account or we may have to stop providing you some or all of the Service, subject to all conditions for the closing of the account, specified above in this section.

Where your personal information is processed for direct marketing purposes, you may, at any time, ask us to cease processing your data for these direct marketing purposes by sending an email to the contact emails below.

Lodging Complaints: You should in the first place try to resolve the matter by sending an e-mail to privacy@consortium9.co.

Operating Globally
To facilitate our global operations, we may be required to transfer, store, and process your information with service providers based in Europe, India, Asia Pacific and North and South America. Laws in these countries may differ from the laws applicable to your Country of Residence. For example, information collected within the EEA may be transferred, stored, and processed outside of the EEA for the purposes described in this Data Protection and Confidentiality Policy. Where we transfer, store and process your personal information outside of the EEA we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection.

International Transfers
In case personal information is shared with corporate affiliates or third-party service providers outside the EEA in the absence of an adequacy decision, we have – prior to sharing your information with such a corporate affiliate or a third-party service provider – established the necessary means to ensure an adequate level of data protection. We will provide further information on the means to ensure an adequate level of data protection on request.

We take the responsibility to ensure that your personal information is secure, kept in an encrypted form on servers, collocated in special data centers. To prevent unauthorized access or disclosure of information we maintain physical, electronic and procedural safeguards that comply with applicable regulations to guard nonpublic personal information. We restrict access to your personally identifiable information only to employees who need to know that information in order to provide products or services to you.

If you know or have reason to believe that the credentials of your online account have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please contact us. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and online account/profile registration information and verifying that the personal data we maintain about you is accurate and current.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

We store our customers’ personal information securely throughout the life of your account. We will retain your personal information for a minimum of five years or as necessary to comply with our legal obligations or to resolve disputes.

Can Children Use Our Services?
The Website is not designed for individuals under the age of 18. We do not knowingly collect information, including personal data, from children or other individuals who are not legally able to use the Service. If we obtain actual knowledge that we have collected personal data from an individual under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from an individual under the age of 18.

Changes To This Privacy Policy
We reserve the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Website for the Service. If you disagree with the revised Privacy Policy, you may cancel your account. If you do not cancel your account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Website will be subject to the revised Privacy Policy.