PRIVACY POLICY
Updated: 18.06.2024
Estx Sp. z o.o., referred to herein also as “CryptoWallet” or “we” is committed to protectinguser (also referred as “you”) privacy as outlined below. This document, along with the Terms of Use, outlines
different ways that CryptoWallet will interact with user data and was written in accordance with General Data
Protection Regulation (EU) 2016/679. CryptoWallet performs the actions with data from those who visit or
use our website https://cryptowallet.com, applications and other products. User acknowledges and gives
consent to this data collection and to our Privacy Policy by using our Website, Services and Products.
PERSONAL INFORMATION: GATHERING AND USE
We collect the following categories of personal data:● Information necessary for compliance “Know your customer” procedure:
your name, nationality, citizenship, home address, email address, personal ID code; copies of identityand other documents, selfie photo, date of birth etc;
● Information necessary for compliance with Anti-Money Laundering Regulations and Procedures :financial data, ownership and source of funds and/or wealth, transaction data and the nature of using
the service, e.g. transaction sums, transaction history, counter-parties, bank account, and card
number(s) and account holders and other information which we may request in order to provide ourservices and comply with regulations.
● Data that identifies you such as your IP address, language, country, browser type, and version, timezone setting, browser plug-in types, some location information about where you might be, operating
system and version, page response times, download errors, how long you stay on web pages, what you
do on those pages, how often, and other actions;● Other personal data you share with us or personal data that we may legally obtain from some othersources.
Personal data may be used to:● Authorize user to open an account with CryptoWallet;● Respond to user queries or complaints;● Contact user;● Process and facilitate financial transactions and services;● Maintain account security through measures such as 2FA;●●
●Analyze user behavior and trends on our website to improve its performance;
Comply with regulations such as for anti-money laundering and fraud prevention purposes;
Anonymized market research that allows us to improve our services and optimize our performance foruser experience. The user may opt for their data to be non-anonymized.

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Inform user of products and offers that may interest him, including from third-party organizations ifuser has agreed to allow for this type of information to be sent to him;
If we want to sell our business, or our CryptoWallet, we can disclose data to the potential buyer;
Personal data may be processed by third parties to supply services to you on our behalf. These may●●

include payment processing, search engine facilities, advertising and marketing.

LEGAL GROUND FOR COLLECTING● Consent the freely given, informed, and unambiguous indication of your wishes to the processing ofyour personal data for a specific purpose which signifies agreement to the processing of personal data.
● Contract- if data necessary for us to perform a contract or terms of use to which you are a party or totake steps at your request prior to entering into the contract or terms and conditions.
● Legal obligations- if data is necessary for compliance with a legal obligation to which CryptoWallet is asubject;● Legitimate Interests- a legal ground for the processing of your personal data when it is based on ourlegitimate interests or the legitimate interests of a third party, provided that those interests are notoutweighed by your rights and interests and those interests have a specific purpose, they are necessary,and they are balanced.
WHO ELSE WILL SEE USER DATA
CryptoWallet uses personal information gathered from our users in accordance with legal regulations. We may
distribute personal information to third parties such as affiliates, financial institutions, representatives, legal
staff, partners, and contractors. Users acknowledge and agree that data storage, collecting and processing might
be performed with third party service providers.
Information may also be shared with law enforcement or regulatory bodies in accordance with local laws.
Third parties are required to protect your personal information and use it only for the purposes stated,such as performing a service for our CryptoWallet. All third parties are bound to comply with our privacy
policy, except for law enforcement and regulatory bodies.
Partners and Other Third Parties. CryptoWallet is a controller responsible for processing and obligated tolegally keep and use your personal information. Partners may include CryptoWallet representatives or affiliate
parties. Payment processors, financial institutions, and services responsible for verifying your identification for
security purposes are examples of other possible data processors involved in our personal data processing system.
CryptoWallet uses Sum&Substance: (https://sumsub.com) for KYC/AML verification; Twilio:(https://www.twilio.com/) for email authentication; Nexpay (https://nexpay.com/) for fiat transactions,
Crystal Blockchain (https://crystalintelligence.com/.com) for transaction monitoring, Maxmind(https://www.maxmind.com) for services providing fraud-preventing and risk modeling tools; Freshdesk(https://freshdesk.com/) for customer support, advertising companies (e.g. Google AdWords) for marketing
purposes, social media and website analytics companies, CW LAB OU data sharing agreement.
CryptoWallet websites and applications may link to other sites and online third-party tools and resources.
Our privacy policy does not apply to these third-party entities, but to our websites and applications only.
Third-party sites and resources are not under our control, and we accept no liability for the use of thesesites and resources including losses, technical failures, damages, or any other undesirable outcomes. Users areadvised to familiarize themselves with the terms of use and privacy policies for third party sites and resources.
Please read their privacy policies before you submit any data to them.
TRANSFER OF COLLECTED PERSONAL DATA FROM CW LAB TO ESTX sp. z o.o.

CW LAB has transferred the personal data collected from Cryptowallet clients to ESTX sp. z o.o. This transfer
is necessary to ensure compliance with AML regulations, which aim to prevent money laundering and terrorist
financing. As a result of this transfer, ESTX sp. z o.o. will be the new owner of your personal data.
Details of the Transfer:
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Data Transferred: The personal data transferred includes personal, account activity and financial data.
Purpose: The transfer of your personal data to ESTX sp. z o.o. is solely for the purpose of complying
with the Polish AML Act. This includes the verification of identities, monitoring of transactions, andreporting of suspicious activities as required by law. CW LAB OU is responsible for sharing clients
personal data with Estx based on contractual obligations. Each client should give a consent to sharepersonal and financial data with ESTX sp. z o.o.
New Data Owner: Following this transfer, ESTX sp. z o.o. will be the new data owner responsible formanaging and safeguarding your personal data.
Data Security: Both CW LAB and ESTX sp. z o.o. are committed to ensuring the security andconfidentiality of your personal data. Appropriate technical and organizational measures have been
implemented to protect your data from unauthorized access, use, or disclosure.
Client Rights: You have the right to access, correct, and request the deletion of your personal data.

LEGAL RIGHTS OF USERS
CryptoWallet users may request access to their personal data which we store. You may request that we
make accurate adjustments to your data, or that we erase your data. You have the right to object to us
processing your data or to change your mind regarding the permissions we must interact with your data. You
can contact us at help@cryptowallet.app for any of the above. In some cases, we may charge a fee to make theseadjustments to data or agreements with specific customers, depending on the nature of the request.
SECURITY
Crypto Wallet protects user data using encryption as well as restricting access to authorized employees and takes
all possible steps within our means to protect user data. We use Secure Sockets Layered (SSL) encryption among
other features, such as firewalls, virus detection, and others. The user has a possibility to activate 2FA
authentication and use it as an additional security measure for authentication. Data submission is at users own
risk and they are responsible for their own data. We work with affiliate organizations and partners, and they may
receive your data overseas depending on our own operations.
RETENTION AND STORAGE OF DATA
CryptoWallet creates and keeps information records regarding customer accounts, activities, andtransactions. These records may be stored digitally or on paper, and in most cases, digital methods areused. These records are necessary to allow us to offer our services and handle user queries, as well as for thepurposes of legal compliance. If you terminate your account in CryptoWallet, we will mark youraccount in our database as “Terminated”, but we will keep your account information in our database forat least five years. This is necessary to prevent fraud and prevent people who try to commit fraud
from being able to avoid their detection by merely terminating their account and opening another one. We
keep data for this period to comply with international and local laws and regulations around money
laundering. We may keep data for over ten years in some cases for tax, bookkeeping and regulatory purposes.
CryptoWallet will not attempt to collect sensitive data not necessary for our operations, and we will notprocess information belonging to minors under the age of 18.
FRAUD, PHISHING AND EMAIL SCAMS
Please be notified that CryptoWallet is not in any partnership with entities who represent themselves ascustomer support agents, providing customer support services via email and/or social media andpromising to help solve your issues for money. If you discovered what you believe is a fraud, phishing, orscam which impersonates CryptoWallet, please contact us as soon as possible
CHANGES AND QUERIESThis Privacy Policy is subject to change at the sole discretion of CryptoWallet. Users will be informed ofany major changes to the policy, and we encourage users to check the policy from time to time for minorchanges as they see fit. Changes will typically be due to operational, legal, or regulatory circumstances.
To make an inquiry about any of the information listed within this privacy policy, please contact
help@cryptowallet.app