Token Sale Privacy Policy
Introduction
This Privacy Policy outlines ​Coalichain ("​we"​​, "​our​​" or "the Company​​") practices with respect toinformation collected from users who access our website at https://coalichain.io ("​Site​​"), registeror participate in our token sale (collectively: "​Users​​").
This Privacy Policy is a part of the ​Terms of Use​ and is incorporated therein by reference.
We encourage Users to carefully read the Privacy Policy and use it to make informed decisions.
In this Privacy Policy you can read about:▪
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What type of information​​ we collectHow​​ ​we receive​​ Users’ information
Cookies
How we use​​ and ​with whom we share​​ the information
For how long we retain​​ the information
How we safeguard​​ the information
Advertising ​and ​Marketing
How to ​contact us

What Information we collect?
We collect two types of data and information from Users who register or participate in the token
sale.
The first type of information is un-identified and non-identifiable information pertaining to aUser(s), which may be made available or gathered via your use of the Site (“​Non-personalInformation​​”), even if you do not participate or register to the token sale. We are not aware of theidentity of a User from which the Non-personal Information was collected. Non-personal
Information which is being collected may include your aggregated usage information and technicalinformation transmitted by your device, including certain software and hardware information (e.g.
the type of browser and operating system your device uses, language preference, access time,etc.) in order to enhance the functionality of our Site. We may also collect information on youractivity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).
The second type of information is individually identifiable information, namely information thatidentifies an individual or may with reasonable effort identify an individual (“​PersonalInformation​​”). Such information includes:● Registration information: When you register to participate in our token sale, you will be
asked to provide us certain details such as: full name; e-mail or physical address, and otherinformation, as further described in our Terms of Use/registration form.
● Device Information: We may also collect Personal Information from your device. Suchinformation includes geolocation data, IP address, unique identifiers (e.g. MAC address andUUID) and other information which relates to your activity through the Site.
● Payment Information: In order for you to participate in the token sale, you may be required
to share personal information within the Site or with our trusted payment processor. Suchpersonal information may include your name, billing address, identity number, financial
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2information (e.g. your credit card number, bank account, etc.) and any other information
which is required in order to complete your participation.
How is the information used? With whom do we share the information?
We do not rent, sell, or share Users’ information with third parties except as described in thisPrivacy Policy.
We may use the information for the following:● Conducting the token sale;● Verifying your identity and determining your eligibility to participate in the token sale;● Communicating with you – sending you notices regarding the token sale, providing you
with technical information and responding to any customer service issue you may have;● To communicate with you and to keep you informed of our latest updates and services;● To serve you advertisements when you use our Site (see more under "Advertisements");● To market our websites and products (see more under "Marketing");● Conducting statistical and analytical purposes, intended to improve the Site.
In addition to the different uses listed above, we may transfer or disclose Personal Information to
our subsidiaries, affiliated companies and subcontractors.
In addition to the purposes listed in this Privacy Policy, we may share Personal Information with
our trusted third party providers, who may be located in different jurisdictions across the world,for any of the following purposes:● Providing you with our Service, including providing a personalized display of our Site;● Storing and processing such information on our behalf;● Serving you with advertisements and assist us in evaluating the success of our advertising
campaigns and help us retarget any of our users;● Providing you with marketing offers and promotional materials related to our Site andservices;● Performing research, technical diagnostics or analytics;
We may also disclose information if we have good faith to believe that disclosure of suchinformation is helpful or reasonably necessary to: (i) comply with any applicable law, regulation,legal process or governmental request; (ii) enforce our policies (including our Agreement),
including investigations of potential violations thereof; (iii) investigate, detect, prevent, or takeaction regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) toestablish or exercise our rights to defend against legal claims; (v) prevent harm to the rights,
property or safety of us, our users, yourself or any third party; or (vi) for the purpose ofcollaborating with law enforcement agencies and/or in case we find it necessary in order toenforce intellectual property or other legal rights.

User Rights
You may request to:a. Receive confirmation as to whether or not personal information concerning you is being
processed, and access your stored personal information, together with supplementary
information.
b. Receive a copy of personal information you directly volunteer to us in a structured,commonly used and machine-readable format.
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d.
e.
f.
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Request rectification of your personal information that is in our control.
Request erasure of your personal information.
Object to the processing of personal information by us.
Request to restrict processing of your personal information by us.
Lodge a complaint with a supervisory authority.

However, please note that these rights are not absolute, and may be subject to our own legitimate
interests and regulatory requirements.
If you wish to exercise any of the aforementioned rights, or receive more information, pleasecontact us at ico@coalichain.io.

Retention
We will retain your personal information for as long as necessary to provide our services, and asnecessary to comply with our legal obligations, resolve disputes, and enforce our policies.
Retention periods will be determined taking into account the type of information that is collected
and the purpose for which it is collected, bearing in mind the requirements applicable to thesituation and the need to destroy outdated, unused information at the earliest reasonable time.
Under applicable regulations, we will keep records containing client personal data, accountopening documents, communications and anything else as required by applicable laws andregulations.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at ourown discretion.

Cookies
When you use our Site, we may store cookies on your computer in order to facilitate andcustomize your use of our Site. A cookie is a small data text file, which a website stores on yourcomputer's hard drive (if your web browser permits) that can later be retrieved to identify you tous. Our cookies may store information regarding your registration to the token sale and Accountinformation. You are always free to decline our cookies if your browser permits, but such disabling
may cause some of the features of our Site to not operate properly and your online experience
may be limited
We also use a tool called “Google Analytics” to collect information about your use of the Site.
Google Analytics collects information such as how often users access the Site, what pages theyvisit when they do so, etc. We use the information we get from Google Analytics only to improve
our Site and services. Google Analytics collects the IP address assigned to you on the date you visit
sites, rather than your name or other identifying information. We do not combine the informationcollected through the use of Google Analytics with personally identifiable information. Google’sability to use and share information collected by Google Analytics about your visits to this Site isrestricted by the Google Analytics ​Terms of Use ​and the ​Google Privacy Policy​.
Third party collection of information
Our policy only addresses the use and disclosure of information we collect from you. To the extent
you disclose your information to other parties or sites throughout the internet, different rules may
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encourage you to read the terms and conditions and privacy policy of each third party that you
choose to disclose information to.
This Privacy Policy does not apply to the practices of companies that we do not own or control, orto individuals whom we do not employ or manage, including any of the third parties which we may
disclose information as set forth in this Privacy Policy.
How do we safeguard your information?
We take great care in implementing and maintaining the security of the Site and your information.
We employ industry standard procedures and policies to ensure the safety of the information wecollect and retain, and prevent unauthorized use of any such information, and we require any
third party to comply with similar security requirements, in accordance with this Privacy Policy.
Although we take reasonable steps to safeguard information, we cannot be responsible for theacts of those who gain unauthorized access or abuse our Site, and we make no warranty, express,
implied or otherwise, that we will prevent such access.
Transfer of data outside the EEA
Please note that some data recipients may be located outside the EEA. In such cases we willtransfer your data only to such countries as approved by the European Commission as providing
adequate level of data protection, or enter into legal agreements ensuring an adequate level ofdata protection.
Advertisements
We may use a third-party advertising technology to serve advertisements when you access theSite. This technology uses your information with regards to your use of the Services to serve
advertisements to you (e.g., by placing third-party cookies on your web browser).
You may opt-out of many third-party ad networks, including those operated by members of theNetwork Advertising Initiative ("​NAI​​") and the Digital Advertising Alliance ("​DAA​​"). For more
information about this practice by NAI and DAA members, and your choices regarding having thisinformation used by these companies, including how to opt-out of third-party ad networks
operated by NAI and DAA members, please visit their respective websites:
http://optout.networkadvertising.org/#!/​ and ​http://optout.aboutads.info/#!/​.
Marketing
We may use your Personal Information, such as your name, email address, telephone number, etc.
ourselves or by using our third party subcontractors for the purpose of providing you withpromotional materials, concerning our services, which we believe may interest you.
Out of respect to your right to privacy we provide you within such marketing materials with means
to decline receiving further marketing offers from us. If you unsubscribe we will remove youremail address or telephone number from our marketing distribution lists.
Please note that even if you have unsubscribed from receiving marketing emails from us, we may
send you other types of important e-mail communications without offering you the opportunity toopt out of receiving them. These may include customer service announcements or administrative
notices.

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5Corporate transaction
We may share information in the event of a corporate transaction (e.g. sale of a substantial part ofour business, merger, consolidation or asset sale). In the event of the above, the transferee oracquiring company will assume the rights and obligations as described in this Privacy Policy.
MinorsWe forbid users under the age of 18 to register or participate in the token sale. In the event thatwe become aware that a user under the age of 18 has shared any information, we will discard suchinformation. If have any reason to believe that a child under 18 has shared any information withus, please contact us at ico@coalichain.io​.
Updates or amendments to this Privacy Policy
We reserve the right to periodically amend or revise the Privacy Policy; material changes will beeffective immediately upon the display of the revised Privacy policy. The last revision will bereflected in the "Last modified" section. Your continued use of the Platform, following thenotification of such amendments on our website, constitutes your acknowledgment and consent
of such amendments to the Privacy Policy and your agreement to be bound by the terms of suchamendments.
How to contact us
If you have any general questions about the Site or the information we collect about you and how
we use it, you can contact us at ico@coalichain.io.
Coalichain Ltd
Gladstonos, 116
M. KYPRIANOU HOUSE, 3&4th floor,
3032 Limassol,
CyprusLast Modified ​November 15th 2018

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