Dijitru Inc. (the “Company”, “we”, “us”, or “our”) is committed to protecting your privacy. Your privacy is important to us. It is our policy to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you on our website (the “Website”). This Privacy Policy is designed to help you understand how we collect, use, process, and share your personal information, and to help you understand and exercise your privacy rights.

In the event our Website contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following a link to any third-party content, you should read their posted privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to any of your activities after you leave our Website.

I. Information We Collect

The categories of personal information we collect depend on how you interact with us, our Website, and the requirements of applicable law. We collect information that you provide to us, the information we obtain automatically when you use our Website, and the information from other sources such as third-party services and organizations.

Information you provide to us in order to use our Website may include:

• Identity information, such as your first name, last name, title, date of birth, nationality, country of residence, social security number, passport number, taxpayer or government identification number;
• Contact information, such as your postal address, email address, and telephone number;
• Profile information, such as your username and password, interests, and preferences;
• Information that is about you but individually does not identify you, such as gender, salary, and job;
• Feedback and correspondence, such as information you provide in your responses to surveys when you participate in market research activities, report a problem with our Website, receive customer support, or otherwise correspond with us;
• Transaction information, such as details about transfers you make on our Website;
• Marketing information, such as your preferences for receiving marketing communications and details about how you engage with them;
• Digital Asset Wallet Address that you link to or create on our Website; and
• Other information necessary for Anti-Money Laundering (AML) and Know Your Customer (KYC) compliance purposes

As you use our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including but not limited to, operating system, Internet Protocol (“IP”) address, mobile device ID, blockchain address, wallet type, and date/time stamps, and information collected through cookies, web beacons, and other tracking technologies.

II. Log Data

When you use our Website, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.

Additionally, if you encounter certain errors while using the Website, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even at the moment they occur, that they have occurred, or what the nature of the error is.

Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.

III. Device Data

When you use our Website or interact with our services, we may automatically collect data about your device, such as:

• Device Type
• Operating System

Data we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.

IV. Cookie and Other Tracking Technologies

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.

Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.

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

V. Collection and Use of Information

We may collect information from you when you do any of the following on our Website:

• Register for an account
• Use a mobile device or web browser to access our content
• Contact us via email, social media, or on any similar technologies
• When you mention us on social media

We may collect information about you from third parties, such as identity verification services, and our business partners.

We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:

• to provide you with our Website's core features and services
• to process transactions and send notices about your transactions
• to provide you with information, products, or services that you request from us
• to enable you to customize or personalize your experience of our Website
• to contact and communicate with you
• to comply with our legal obligations and resolve any disputes that we may have
• for security and fraud prevention, and to ensure that our sites and apps are safe, secure, and used in line with our terms of use

We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources. For example, our marketing and market research activities may uncover data and insights, which we may combine with information about how visitors use our Website to improve our Website and your experience with it.

VI. Disclosure of Personal Information to Third Parties

We may disclose personal information to:

• a parent, subsidiary, or affiliate of the Company
• third-party service providers to enable them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, debt collectors, maintenance or problem-solving providers, professional advisors, and payment systems operators
• our employees, contractors, and/or related entities
• our existing or potential agents or business partners
• credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you
• courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or to establish, exercise, or defend our legal rights
• third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you
• if we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property, and safety of us or others;
• in connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company;
• with your consent or at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide such information.

VII. Your Rights and Controlling Your Personal Information

• Your choice: If you provide us with Personal Information, you understand we will collect, hold, use, and disclose your personal information in accordance with this privacy policy. You do not have to provide personal information to us.
• Information from third parties:If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such a person’s consent to provide the personal information to us.
• Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.
• Access: You may request details of the personal information that we hold about you.
• Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.
• Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example providing user support), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.
• Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
• Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
• Unsubscribe: To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details provided in this privacy policy, or opt out using the opt-out facilities provided in the communication. We may need to request specific information from you to help us confirm your identity.

VIII. Security of Your Personal Information

When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification. We use computer safeguards such as firewalls and data encryption, enforce physical access controls to our buildings and files, and authorize access to personal information only for those employees who require it to fulfill their job responsibilities.

Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security.

You are responsible for selecting any password and its overall security strength, ensuring the security of your information within the bounds of our services. For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.

IX. Retention of Your Personal Information

We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including the purposes of satisfying any legal, accounting, or reporting obligations or resolving disputes.

X. Children’s Privacy

We do not aim any of our products or services directly at children under the age of 18, and we do not knowingly collect personal information about children under 18.

XI. Business Transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.

XII. Supplement Notice to California Residents

This notice supplements the information contained in our Privacy Policy and applies solely to residents of the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in the supplemental notice (“CCPA Notice”). The CCPA grants California residents the right to know what personal information we collect, use, and share for our business purposes, during the preceding 12 months. This CCPA Notice does not include (i) publicly available information from government records; or (ii) information excluded from the CCPA’s scope (personal information covered by the Gramm-Leach-Biley Act (GLBA) or the California Financial Information Privacy Act (FIPA)).

For ease of reference, we have compiled the chart below to demonstrate how we use the categories of personal information we have collected, used, and disclosed in the past 12 months. We do not “sell” any personal information, as “selling” is defined under the CCPA.

CATEGORY OF PERSONAL INFORMATION	SOURCE OF PERSONAL INFORMATION	WHY WE COLLECT YOUR PERSONAL INFORMATION	HOW WE SHARE YOUR PERSONAL INFORMATION
Identifier, such as social security number	Section I	Section V	Section VI
Additional personal information described in Section 1798.80(e)	Section I	Section V	Section VI
Characteristics of protected classifications	Section I	Section V	Section VI
Commercial Information	Section I	Section V	Section VI
Biometric Information	N/A
Internet or other electronic network activity information	Section I	Section V	Section VI
Geolocation Data
Audio, electronic, visual, thermal, olfactory, or similar information	N/A
Professional or employment-related information	Section I	Section V	Section VI
Education Information	N/A
Inferences drawn from any of the information listed above	Section I	Section V	Section VI

A. Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the right to know). Once we receive your request and confirm your identity, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources of the personal information we collected about you.
• Our business or commercial purpose for collecting, using, disclosing, or selling that personal information.
• The categories of third parties with whom we share that personal information.
• If we sold or disclosed your personal information for a business purpose in the preceding 12 months.
• The specific pieces of personal information we collected about you in the preceding 12 months.

Right to Delete. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the right to delete). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

B. Exercising Your Rights

Submitting a Request. To exercise your rights to request information, know, or delete, please contact [EMAIL]. Only you or someone legally authorized to act on your behalf may make a request related to your personal information. You may also make a request to know or delete on behalf of your child. We will require that the authorized agent have a written authorization confirming their authority.
Verification. Your request to access or delete personal information must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. We will ask you to verify your identity when you submit a request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. You do not need to create an account with us to submit a request to know or delete.
Opt-out. California residents have the right to opt out. You (or your authorized representative) may submit a request to us by contacting [email]. You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not (i) deny you products or services, (ii) charge you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties, (iii) Provide you a different level or quality of products or services, or (iv) suggest that you may receive a different price or rate for products or services or a different level or quality of products or services.
Accessibility. This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this Privacy Policy, please do so from your web browser or by saving the page as a PDF.

XIII. Limits of Our Policy

Our Website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites and cannot accept responsibility or liability for their respective privacy practices.

XIV. Changes to This Policy

At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link by which you are accessing this privacy policy.

If the changes are significant, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) and all our registered users with the new details and links to the updated or changed policy.

If required by law, we will get your permission or allow you to opt in or opt out, as applicable, of any new uses of your personal information.