PRIVACY POLICY

1.

About this Privacy Policy

At Unicap we are committed to keeping your (defined below) personal data safe and secure.

Please read this privacy policy (“Privacy Policy”) so that you understand your rights in relation

to your personal data, including how your personal data will be collected, used and processed.

Unicap Labs, a Cayman Island exempted company limited by shares (hereinafter “Unicap”,

w“Company,” “we”, or “us”), is the data controller of the personal data collected in accordance

with this Privacy Policy.

In providing you with our website (https://unicap.finance/) (our “Website”) including our related

products and services made available by us and this Website (together the “Services”) or when

you otherwise interact with us, we naturally collect information about you.

Our Services include the Website and/or any services or products made available through the

Website, that will issue the Unicap Tokens (hereinafter - the “Tokens”). The Tokens will enable

access to nearly instant interledger transfers over multiple assets. The Unicap Software Suite will

facilitate such transfers by incorporating the concepts of neutral protocols and the interledger

technology (“Platform”).

This Privacy Policy sets out what we collect, how we use your personal data, who we might

share it with, and the steps we take to make sure it stays private and secure.

References in this notice to “personal data” describes information that can be associated with a

specific person and can be used to identify that person (including information about that person’s

activities, such as use of the Website, Platform and/or Services. Anyone who uses the Services or

the Platform, shall comprise: (a) any person, who uses the Platform or its Services, without prior

registration and authorization (“You”); (b) any person, who uses the Platform or its Services,

with prior registration and authorization (“User”); and (c) any person, who uses the Platform or

its Services to purchase Tokens (“Purchaser”), together “you”.

Please read the following information carefully to understand our practices regarding your

personal data and usage information and how we will use it.

By continuing to use our Website or Platform or creating an account and/or purchasing Tokens,

you acknowledge that you have read, understood and accepted the information described in this

Privacy Policy. If you do not agree with this Privacy Policy in general or any part of it, you

should not access the Website, Services, Platform and/or purchase Tokens.

2.

Collection, Processing and Use of Your Information

A. How we collect your personal data


The personal data we collect or have about you will come from different sources. Some of it will

be provided by you and others will be collected from your activity on our Website, Platform and

use of our Services.

B. How we use your personal data

We collect and use your personal information to operate our Services and deliver the Services

you have requested as it is in our legitimate interests to be responsive to you and to ensure the

proper functioning of our Services. We use personal data to:

i.

Identify our users;

ii.

Administer and provide the Services and customer support per your request;

iii.

Develop new products and services;

iv.

Send you technical notices and support and administrative messages;

v.

Process transactions and send notices about your transactions;

vi.

Communicate with you about products, services, the Platform itself, promotions, events

and other news and information we think will be of interest to you based on your

communication preferences and where permitted by applicable law;

vii.

monitor and analyze trends, usage and activities in connection with our Services;

viii.

Resolve disputes, collect fees, and troubleshoot problems;

ix.

Prevent potentially prohibited or illegal activities, and enforce our terms and conditions

with you;

x.

Detect, investigate and prevent fraudulent transactions and other illegal activities and

protect the rights and property of Unicap and others;

xi.

Improve the Services and the content and layout of our website and applications;

xii.

Deliver targeted marketing, service update notices, and promotional offers based on

your communication preferences and where permitted by applicable law;

xiii.

Compare information for accuracy and verify it with third parties;

xiv.

Verify your status and/or confirm information You provided to us;

xv.

Distribute and account for Tokens; and/ or

xvi.

Provide third parties with statistical information about our users (but those third parties

will not be able to identify any individual user from that information).

C. What personal data and information we collect and how we use it

We collect and use the following information about you:

❖ Information we collect when you access our Website

When you visit the Website, even if you have not yet created an account with us, we collect the

information sent to us by your computer, mobile phone, or other access device. This information

includes:

a. Your IP address.

b. Device information including, but not limited to, identifier, name, and type of

operating system.


c. Standard web and technical usage information, such as your browser type and the

pages you access on our Website.

We collect this information in order to administer our Website, personalize our Website for you,

monitor and analyze trends, usage and activity in connection with our Website and services and

provide third parties with aggregated and anonymized statistical information about our Users.

When you access the Website or use our Platform or Services, we place small data files called

cookies on your computer or other device. See Cookies definition below for more information.

❖ Information we collect when you create an account, use the Platform and

purchase Tokens

In addition to the information collected when you access our Website, we collect your full name,

telephone number, address, email address, phone number, IP address, survey responses, your

status as accredited or professional investor (if applicable), and any other information you choose

to provide when you:

create an account on our Website;

subscribe to our Platform or register to our Services;

respond to the Purchaser Questionnaire;

fill out any form; and/or

request customer support or communicate with us in any manner.

In certain cases (when additional verification by a bank or compliance authority is needed to

comply with governmental rules, anti-money laundering (“AML”) or “know-your-customer”

(“KYC”) policies, we require you to provide additional information including: scanned or

depicted documents from you, such as photo of your passport of other identity card to show

proof of identity as well as documentation that evidences your proof of address or documents or

online database information to confirm the status.

We also may collect information about your computer or other access devices for fraud

prevention, KYC or AML purposes and other information where required by terms of the Unicap

Token Purchase Agreement.

We are sometimes required to compare the personal data you provide with third party databases

in order to verify its accuracy and confirm your identity to comply with relevant AML

regulations and KYC regulations.

We collect this information so:


We can verify your identify;

We can comply with law; and

We can facilitate and record the purchase of Tokens.

Please note, that all such data and documentation is gathered in accordance with applicable law

and international security practices and regulations.

We do not collect any sensitive personal information, such as information about your religion,

race, ethnicity and/or political views.

❖ Information we collect only when you use the Platform

If you use the Platform, we or our third party service provider may collect your payment method

and other payment information for use in connection with your payments for storage or

payments processing. Please read their terms and conditions and privacy policy available on their

website.

❖ Location data

When you use a location-enabled device to access our Website and services, we may collect

geographical location data or use various means to determine the location, such as sensor data

from your device that may, for instance, provide data on nearby cell towers and wi-fi access

spots.

We do this so that we can verify your location to ensure compliance with applicable laws

including AML and KYC rules. This may include the blocking from certain countries where the

usage of our Website, Platform, Services and/or buying of Tokens are prohibited by that country.

❖ Information We Collect Automatically

Information about your hardware and software will be automatically collected by us. This

information includes usage information that includes your interactions with Services, device

information, such as unique device identifiers, operating system information, internet service

provider, IP address, screen resolution, language, the date and time of each of your log-ins and

requests. This information is used for the operation of Services, to maintain quality of the

service, and to provide general statistics regarding use of Services and can be received otherwise.

❖ Cookies

We use cookies and other similar technologies

(e.g., web beacons, flash cookies, etc.,)

(“cookies”) to enhance your experience using the Website and Platform. Cookies may be either

"persistent" cookies or "session" cookies. A persistent cookie consists of a text file sent by a web

server to a web browser, which will be stored by the browser and will remain valid until its set

expiry date (unless deleted by the user before the expiry date). A session cookie, on the other

hand, will expire at the end of the user session, when the web browser is closed.


In addition to cookies that are strictly necessary to operate the Website and Platform, we use the

following cookies:

Functional Cookies. We use these cookies to enhance your experience on our

website, for example, to remember what language you speak and your previous

searches.

Analytical/performance Cookies which are set by us and Google Analytics. We use

these cookies to collect information about your browsing activities over time and across

different websites following your use of our Services. They allow us to recognize and

count the number of users and to see how users move around the Website when they are

using it. This helps us to improve the way the Website, Services and/or Platform works.

We use Google Analytics which is a web analytics tool that helps us understand how

Users engage with the Website. Like many services, Google Analytics uses first-party

cookies to track user interactions as in our case, where they are used to collect

information about how users use our Website. This information is used to compile reports

and to help us improve our Website. The reports disclose website trends without

identifying individual visitors. You can opt out of Google Analytics without affecting

how you visit our Website - for more information on opting out of being tracked by

Google Analytics across all websites you use including our Website, visit this Google

page.

Social Media Cookies, which are set by the following third parties: Facebook and

Twitter and allow you to share what you’ve been doing on our Website on social media.

You may withdraw your consent to cookies at any time once you have entered the Website or

Platform by changing your cookie settings through your web browser.

D. How we might share your personal data

❖ Why we share your personal data:

● We need to in order to operate the Website, Platform, provide the Services and facilitate

the purchase of Tokens.

● We have a public or legal duty to do so (e.g., to assist with detecting fraud, tax evasion,

financial crime prevention, regulatory reporting, litigation or defending legal rights).

● We have asked for your permission to share your information for a specified purpose and

you have agreed.

● When we believe, in accordance with applicable law, that the disclosure of personal

information is necessary to report suspected illegal activity or to investigate violations of

our terms and conditions or Token Agreement.

● We may also share aggregated or de-identified information, which cannot reasonably be

used to identify you.


❖ Who we share your personal data with

● With other Unicap affiliated entities located in the United States, United Kingdom, and

Cayman Islands in order to help detect and prevent potentially illegal acts and violations

of our policies, and to guide decisions about our products, services and communications.

● With service providers located in United States and United Kingdom that provide hosting

and email services, identity verification services, investor status verification, support

services, payment services and tokens accounting..

● With law enforcement, government officials or other state bodies in response to a request

for information, if we believe disclosure is in accordance with, or required by, any

applicable law, regulation or legal process.

● With our lawyers and professional advisors if we believe your actions are inconsistent with

our user agreements or policies, or to protect the rights, property and safety of Unicap or

others.

● With companies that we plan to merge with or substantially all or part of our assets are

to be acquired by, or where we are financing all or a portion of our business by another

company.

3.

Links to Third Party Websites

• Our Website may, from time to time, contain links to and from the websites of our partner

networks, advertisers, and affiliates (including, but not limited to, websites on which the

Website is advertised).

• If you follow a link to any of these websites, please note that these websites and any

services that may be accessible through them have their own privacy policies and that we

do not accept any responsibility or liability for these policies or for any personal data that

may be collected through these websites or services, such as contact and location data.

Please check these policies before you submit any personal data to these websites or use

these services.

4. International Transfers of Data

We store and process your information using cloud services in the following jurisdictions: the

United States of America and United Kingdom.

If you are located within the European Union, the information that we collect from you may be

transferred to, and stored in the countries listed above which may be outside of your country of

residence and outside the European Economic Area ("EEA”). The laws on processing such

information, including where such information is classed as “personal data”, in these locations

may be less stringent than in your country. It may also be processed by staff operating outside of

your country or the EEA who work for us, for one of our service providers or one of our business

partners. We will take all steps reasonably necessary to ensure that your information is treated

securely and in accordance with this policy.


In compliance with the Privacy Shield Principles, Unicap Labs commits to resolve complaints

about your privacy and our collection or use of your personal information transferred to the

United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy

Shield inquiries or complaints should first contact Unicap Labs at: [email protected]

Unicap Labs has further committed to refer unresolved privacy complaints under the Privacy

Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY

SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely

acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please

visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a

complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under

certain conditions, you may invoke binding arbitration for some residual claims not resolved

by other redress mechanisms. See Privacy Shield Annex 1

at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

5. Retention of information

In accordance with applicable laws and as needed to provide services to our Users and

Purchasers, we will retain your personal data (and other information) as follows:

● if you contact us via email we will keep your data for 3 years after; and

● your technical usage information for 3 years.

● location data: if helpful to determining jurisdiction requirements for compliance and

improved customer experience, we will keep the data for 3 years;

● data on your use of the Website, Services and Platform: for up to 5 years.

After you have terminated your use of the Services or Platform, we will store your information in

an aggregated and anonymised format.

6. Marketing

We do not sell, rent or lease your personal data to third parties without your explicit consent.

At any time you have the right to object to our processing of data about you in order to send you

promotions and special offers, marketing, including where we build profiles for such purposes,

and we will stop processing the data for that purpose. Please email us at [email protected] for any

questions or to object to our processing.

You may modify your email preferences by clicking on an unsubscribe link at the bottom of

certain emails sent from Unicap.


You can withdraw your consent to marketing/promotions and special offers at any time by

contacting Unicap Labs at [email protected]


7. Security - How we Keep Your Personal Data Safe

We use relevant electronic and procedural safeguards to protect the privacy of the information

you provide to Unicap from loss, misuse, disclosure, alteration and destruction. Please note that

transmission of data or information (including communications by e-mail) over the Internet or

other publicly accessible networks is not one hundred percent secure.

All Token operations on the Platform, including but not limited to those between user accounts,

are written into a blockchain register with compulsory and automated hash entry into the chain of

blocks.

Blockchain security is provided by data records of all Token movements from one account to

another, with the obligatory and automatic hash recording into the Blockchain. The flow-of-

funds record is open to the public. However, the registry information is unchangeable and

anonymous.

8. Children - Notice to parents

Our Website is not designed or targeted toward users who might be under the age of 18 years

old.

To Parents or guardians: We need help to guard your children’s privacy. We encourage you to

talk to your children about safe and responsible use of their and your personal information while

using Internet.

Our web-resources and web-resources of our affiliates, licensees, agents etc. in the part they use

under our license or assignment does not publish any data that is targeted to children. We

advise you to refrain your children from using web-resources, mentioned in this paragraph and

ask them not to use them.

9.

Changes to this Policy

We may amend this policy at any time by posting a revised version on our Website. The revised

version will be effective at the time we post it. In addition, if the revised version includes any

substantial changes to the manner in which your personal information will be processed, we will

provide you with prior notice by posting notification of the change on the “Privacy Policy” area

of our website or any Services made available through our Websites.

We encourage you to periodically check this page for the latest information on our Privacy

Policy.

10. Rights of Users located within the EU

If you are located within the European Union, in certain circumstances you may have additional

rights under applicable privacy laws. We set out below an outline of these rights and how to


exercise them. Please note that we will require you to verify your identity before responding to

any requests to exercise your rights. To exercise these rights, please contact us at [email protected]

Please note that for each of the rights below we may have valid legal reasons to refuse your

request; in such we will let you know if that is the case.

Access: You have the right to know whether we process your personal data, and if we do,

to access the personal data we hold about you and certain information about how we use

it and who we share it with.

Portability: You have the right to receive a subset of the personal data you provide if we

process it on the bases of our contract with you or with your consent in a structured,

commonly used and machine-readable format and a right to request that we transfer this

personal data to another party. If you wish for us to transfer your personal data to another

party, please ensure you detail that party and note that we can only do so where it is

technically feasible. We are not responsible for the security of the personal data or its

processing once received by the third party.

Correction: You have the right to require us to correct any personal data held about you

that is inaccurate and have incomplete data completed. Where you request correction,

please explain in detail why you believe the personal data we hold about you is

inaccurate or incomplete so that we can assess whether a correction is required. Please

note that whilst we assess whether the personal data we hold about you is inaccurate or

incomplete, you may exercise your right to restrict our processing of the applicable data

as described below.

Erasure: You may request that we erase the personal data we hold about you in the

following circumstances:

o where you believe it is no longer necessary for us to hold the personal data;

o we are processing it on the basis of your consent and you wish to withdraw your

consent;

o we are processing your data on the basis of our legitimate interest and you object

to such processing;

o you no longer wish us to use your data to send you marketing; or

o you believe we are unlawfully processing your personal data,

please provide as much detail as possible on your reasons for the request to assist us in

determining whether you have a valid basis for erasure.

Restriction of Processing to Storage Only: You have a right to require us to stop

processing the personal data we hold about you other than for storage purposes in the

following circumstances: you believe the personal data is not accurate for the period it

takes for us to verify whether the data is accurate, we wish to erase the personal data as

the processing we are doing is unlawful but you want us to simply restrict the use of that

data; we no longer need the personal data for the purposes of the processing but you


require us to retain the data for the establishment, exercise or defence of legal claims; and

you have objected to us processing personal data we hold about you on the basis of our

legitimate interest and you wish us to stop processing the personal data whilst we

determine whether there is an overriding interest in us retaining such personal data.

● Objection: You have the right to object to our processing of data about you and we will

consider your request. Please provide us with detail as to your reasoning so that we can

assess whether there is a compelling overriding interest in us continuing to process such

data or we need to process it in relation to legal claims.

Withdrawal of Consent

If we have collected your personal data by obtaining your consent, you also have the right

at any time to withdraw that consent by contacting us.

11.

Contact us

If you have questions concerning this Privacy Policy, or you notice any bugs, errors or violations

please feel free to send us an email at [email protected]

NOTICE TO CALIFORNIA RESIDENTS

We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide this CCPA

Notice to California residents to explain how we collect, use and share their personal Information,

and the rights and choices we offer California residents regarding our handling of their personal

information.

CCPA Scope and Exclusions

This CCPA Notice, including the description of our Privacy Practices and your Privacy Rights,

apply only to California residents whose interactions with us are limited to:

Visiting our consumer websites,

Signing up for email alerts,

Commenting on or contributing to our blogs,

Establishing an account that does not include financial products or services, or

Applying for our job openings on our websites (however, note that the CCPA does not extend

Privacy Rights to job applicants).

This CCPA Notice does not apply to the personal information we collect, use or disclose about:

Consumers who initiate or complete the process of applying for financial products or services. This

is because this information is subject to the federal Gramm-Leach-Bliley Act (“GLBA”) and

implementing regulations, or the California Financial Information Privacy Act (“FIPA”),

orRepresentatives of businesses that seek to obtain our products or services, or to provide products

or services to us.

Privacy Practices


We do not sell personal information. Privacy Rights

The CCPA grants individuals the following rights:

Information. You can request information about how we have collected, used and shared your

Personal Information during the past 12 months.

Access. You can request a copy of the personal information that we maintain about you.

Deletion. You can ask us to delete the personal information that we collected or maintain about you.

Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain

sensitive information in response to an access request and limiting the circumstances in which we

must comply with a deletion request. We will also respond to requests for information and access

only to the extent we are able to associate with a reasonable effort the information we maintain with

the identifying details you provide in your request. If we deny your request, we will communicate

our decision to you.

You are entitled to exercise the rights described above free from discrimination.

How to Submit a Request

To request access to or deletion of personal information:

Email: mailto: [email protected]

Identity verification. The CCPA requires us to verify the identity of the individual submitting a

request to access or delete personal information before providing a substantive response to the

request. We will ask you to verify your identity when you submit a request.

Authorized agents.California residents can empower an “authorized agent” to submit requests on

their behalf. We will require the authorized agent to have a written authorization confirming that

authority.