Celsius Privacy Policy
Introduction
Celsius Network LLC (“us“, “we” or “Company“), 50 Harrison St, Suite 209F, Hoboken NJ
07030, respects the privacy of our users (each, “you” or “User“) and is committed to protecting
the privacy of Users who access, download, install or register to our mobile or web application(the “Application“), our website or any other online services we provide (collectively: the“Services“). This Privacy Policy outlines our practices with respect to collecting, using anddisclosing your information when you use the Services. We encourage you to read the Privacy
Policy carefully and use it to make informed decisions. By using the Services, you agree to theterms of this Privacy Policy and your continued use of the Services constitutes your ongoing
agreement to the Privacy Policy. The Privacy Policy is a part of the Terms of Service and isincorporated therein by reference.

This Privacy Policy contains information on our use of your personal information in accordancewith relevant laws and regulations, including, where applicable, the EU General Data Protection
Regulation (2016/679) (the “EU GDPR”), the EU GDPR such as it forms part of the laws of theUnited Kingdom (“UK”) by virtue of section 3 of the European Union (Withdrawal) Act 2018 andas amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.)(EU Exit) Regulations 2019 (the “UK GDPR”), the UK Data Protection Act 2018 and theCalifornia Consumer Privacy Act of 2018 (“CCPA”). The rights discussed in certain sections of
this Privacy Policy may be subject to exemptions or other limitations under applicable law.

For users who are located in the European Economic Area (“EEA”) and/or the UK and subject tothe EU GDPR and/or the UK GDPR (together, the “GDPR”), please review this Privacy Policy

and see the below Section, “EU/UK Based Users and the GDPR” for a description of your rights
and other information related to the GDPR.

For users who are California residents and subject to the CCPA, please review this Privacy Policy
and see the below Section, “Additional Information for California Residents” for a descriptionof your rights with regard to your personal information (as defined by the CCPA), additional
disclosures, and our notice at collection.

In this Privacy Policy you will read about, among other things:
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What Type of Information We Collect
Sources of Personal Information
How We Use the Information
With Whom We Share the Information and For What Purpose
Corporate Transaction
Third-Party Collection of Information
Cookies and Google Analytics
Advertisements and Advertising Tools
For How Long We Retain Your Information
How We Protect Your Information
Minors
EU/UK Based Users and the GDPR
Additional Information for California Residents
Updates or Amendments to the Privacy Policy
How to Contact Us

What Type of Information We Collect
In general, we collect information, including Personal Information, when you communicate with us
and when you use our Services. The information we request from you will be the minimum
required to provide you with our services. When we use the term “Personal Information” wemean any information about an individual from which that person can be identified. Informationthat is anonymous, aggregated, or deidentified is generally not considered Personal Information.

There are instances where we invite or request individuals to provide us with their Personal
Information through our Application, website or otherwise (e.g. by email), and we may also collectsome information automatically. Through your use of our Services and your interactions with us,
you may provide us with Personal Information including:

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Identifiers and similar information such as, name, address, date of birth, email address,social security number, driver’s license number, passport number, online identifiers, orother similar identifiers;
Certain information protected under federal or state laws such as a signature or bankaccount or other financial information;
Characteristics of protected classifications under certain federal or state laws, including
gender, national origin, or marital status;
Commercial information, including records of products or services purchased, obtained,or considered, or other purchasing histories or tendencies;
Internet or other electronic network activity information, including interactions with our
website or use of certain online tools;
Geolocation data, such as information about your location or the location of your device;
Audio, electronic, visual, or similar information, which could be collected during audio orvideo calls (including video conferences and similar functions);
Biometric data, such as images, which may constitute biometric data in certain
jurisdictions. We may use such data for the purpose of identification for fraud andanti-money laundering checks;
Professional or employment-related information, including occupation, compensation,
employer, and title;
Inferences drawn from any of the information identified above to create a profilereflecting your preferences or similar information; andSources of Personal Information
We collect Personal Information about you directly from you and/or your intermediaries throughsources on our website, our Application, when you register or sign-in to the Services via yoursocial network account, including when the following happens:●Signing up for an account: When you sign-up and register for the Services, you will be
asked to provide us certain details about yourself. You may register for the Services

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through your social network account or directly through the Application or our website (ifapplicable).
Registering through social network account: When you register or sign-in to theServices via your social network account (e.g., Facebook, Twitter, etc.), we will haveaccess to basic information from your social network account, such as your full name,home address, email address, birthdate, profile picture, friends list, personal description, as
well as any other information you made publicly available on such account or agreed toshare with us. At all times, we will abide by the terms, conditions and restrictions of thesocial network platform.
Registering through the Application or our website (if applicable): When you registerfor the Services through the Application or our website, we may collect from you thefollowing information: full name, email address, home address, hometown, nationality,
birthdate, phone number, as well as information required for our compliance with regulatory
Know Your Customer requirements, such as passport or other identification number, andany other information you agreed to share with us.
Voluntarily provided information: We may collect information which you provide us
voluntarily. For instance, when you respond to communications from us, communicate withus via email or share additional information about yourself through your use of theServices. We may also collect the feedback, suggestions, complaints and reports which
you send to us. Please note that we may also collect complaints about you from other
Users, which may include your Personal Information.
Communication Recording: We may record communications between you and any of ourrepresentatives and/or other participants, including recordings of audio, video and videoconference calls, conversations or communications. We may collect this information for the
purpose of resolving complaints, or for the purpose of improving the overall quality of theServices, for training and/or instructional purposes, record keeping or otherwise in order tocomply with a legal or regulatory requirement to which we are subject.
Device information: We may collect Personal Information from your device. Suchinformation may include geolocation data, IP address, unique identifiers (e.g., MAC
address and UUID) as well as other information which relates to your activity through theServices.

For the avoidance of doubt, if we combine Personal Information with non-personal information,
the combined information will be treated as Personal Information as long as it remains combined.

In addition, we may collect Personal Information from different sources, such as: our affiliates, ourservice providers, or our affiliates’ service providers; public websites or other publicly accessible
directories and sources, including bankruptcy registers, tax authorities, governmental agencies

and departments, and regulatory authorities; and/or from credit reporting agencies, sanctions
screening databases, or from sources designed to detect and prevent fraud or financial crimes.
The relevant source may be responsible for obtaining the relevant consents from you (whereapplicable) to ensure you are happy with the ways in which your Personal Information will be
used.

How We Use the Information
We use and share Personal Information in the manners described in this Privacy Policy. In
addition to the purposes listed above, the information we collect, which may include your
Personal Information, is used for our business or commercial purposes such as:

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To set up your account and to provide the Services.
To identify and authenticate your access to the Services.
To authenticate your identity for the purpose of compliance with regulatory Know Your
Customer requirements.
To send you relevant push notifications, which are based on different activities offered by
the Services.
To communicate with you and to keep you informed of our latest updates and newsletters.
To market our website, products, and the Services.
To serve you personalized advertisements when you use the Services.
To perform research or to conduct analytics in order to improve and customize the Services
to your needs and interests.
To support and troubleshoot the Services and to respond to your queries.
To investigate and resolve disputes in connection with your use of the Services.
To detect and prevent fraudulent and illegal activity or any other type of activity that may
jeopardize or negatively affect the integrity of the Services; andTo investigate violations and enforce our policies, and as required by law, regulation orother governmental authority, or to comply with a subpoena or similar legal process or
respond to a government request.

With Whom We Share the Information and for What Purpose
We do not rent, sell, or share your Personal Information with third-parties except as described inthis Privacy Policy. We may share Personal Information with the following recipients: (i) oursubsidiaries; (ii) affiliated companies; (iii) subcontractors and other third-party service providers;(iv) business partners (such as GEM, Coinify, Simplex and Wyre); (v) auditors or advisers of ourbusiness processes; and (vi) any potential purchasers or third party acquirer(s) of all or any
portion of our business or assets, or investors in the company.

In addition to the purposes listed in this Privacy Policy, we may share Personal Information with
our recipients for any of the following purposes: (i) storing or processing Personal Information on
our behalf (e.g., cloud computing service providers); (ii) processing such information to assist us
with our business operations; (iii) carrying out your instructions or giving effect to yourpreferences in relation to the Services we provide (including if you wish to use services which ourbusiness partners provide); (iv) performing research, technical diagnostics, personalization andanalytics. We may also disclose Personal Information or any information we may have about you
if we have a good faith belief that disclosure of such information is helpful or reasonably
necessary to: (i) comply with any applicable law, regulation, legal process or governmental
request; (ii) enforce our policies, including investigations of potential violations thereof; (iii)
investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing,suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal
claims; (v) prevent harm to the rights, property or safety of us, our affiliates, our Users, yourself or
any third-party; (vi) for the purpose of collaborating with law enforcement agencies; and (vii) incase we find it necessary in order to enforce intellectual property or other legal rights.

Wherever possible, we will only disclose Personal Information to a third party in circumstanceswhere that third party has agreed to respect the security and confidentiality of Personal
Information and treat it in accordance with applicable law. We will seek to ensure that third parties
to whom any Personal Information may be disclosed will not use Personal Information for theirown purposes and only process Personal Information for specified purposes and otherwise inaccordance with our instructions and/or with applicable laws.

We may also disclose Personal Information about you to a third party at your request or direction
or with your consent.

Corporate Transactions
We may share information, including Personal Information, in the event of a corporate transaction(e.g., sale of a substantial part of our business, merger, consolidation or asset sale of an asset ortransfer in the operation thereof) of the Company. In the event of the above, the acquiring
company or transferee will assume the rights and obligations as described in this Privacy Policy.

Third-Party Collection of Information
Our policy only addresses the use and disclosure of information we obtain about you. To theextent that you disclose your information to other parties via the Services (e.g., by clicking on alink to any other website or location) or via other sites throughout the Internet, different rules may
apply to their use or disclosure of the information you disclose to them. You acknowledge that weare not responsible for the products, services, or descriptions of products or services that you
receive from third-party sites or to the content or privacy practices of those sites, and that thisPrivacy Policy does not apply to any such third-party products and services. You are knowingly
and voluntarily assuming all risks of using third-party sites to purchase products and services.
You agree that we shall have no liability whatsoever with respect to such third-party sites andyour usage of them.

Cookies and Google Analytics
We may use cookies and other technologies or methods of web and mobile analysis to gather,store, and track certain information related with your access to and activity through the Services,
including when you visit our website.

Below, we describe the types of cookies (as defined below) we use, and how you can control ouruse of cookies.

Types of Cookies We Use

As mentioned above, we will collect certain information about you when you visit our website. We
collect such information through the following technologies (collectively, “cookies”):

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Cookies. Cookies are small pieces of information that a website assigns to your device
while you are viewing a website. Cookies may be served by the entity that operates thewebsite you are visiting (“first-party cookies”) or by other companies (“third-party cookies”).
Additionally, some cookies may be temporary and erase when you close your browser(“session cookies”), and others may remain for a set duration (“persistent cookies”).
Log Files. Tools that track actions occurring on the site, and collect data including your IP
address, browser type, Internet service provider, referring/exit pages, and date/timestamps.
Web Beacons. These “tags” and “pixels” are electronic files used to record information
about how you browse our website.
Social Media Widgets. These are tools that allow us to provide certain social media
features such as links to Facebook, Instagram, and Twitter. These social features areeither hosted by a third party or hosted directly on our website. Your interactions with thesefeatures are governed by the privacy policy of the company providing it.

Cookies are very helpful and may be used for various different purposes such as delivering
personalised services. These purposes include, among other things, allowing you to navigate
between pages efficiently, enabling automatic activation of certain features, remembering yourpreferences and making the interaction between you and the Services quicker, easier andsmoother. Our website may use the following types of cookies:●

Strictly Necessary Cookies. These cookies are required for the operation of our website,
and are essential to enable you to login, navigate around and use the features of a
website, or to provide a service requested by you. We do not need to obtain your consent
in order to use these cookies.

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Functionality Cookies. These cookies allow the website to remember choices you make(such as your user name, language, or the region you are in) and provide enhanced, more
personal features. For instance, a website may be able to provide you with local weather
reports or traffic news by using a cookie to store information about the region in which you
are currently located, remember changes you have made to text size, fonts, and otherparts of web pages that you can customize, and provide services you have asked for suchas watching a video or commenting on a blog. The information these cookies collectremains anonymous and they cannot track your browsing activity on other websites.
Performance/Analytics Cookies. These cookies allow us to recognize and count the
number of visitors and to see how visitors use a website, for example which pages you go
to most often, and record difficulties you may experience while using the Website, forexample error messages. All information collected by these cookies is aggregated andtherefore anonymous. It is only used to improve the efficiency of the website. We also use
a tool called Google Analytics to collect information about your use of the Services. Google
Analytics collects information such as how often users access the Services, what pages
they visit when they do so, etc. We use the information we get from Google Analytics only
to improve our Services. Google Analytics collects the IP address assigned to you on thedate you visit sites, rather than your name or other identifying information. We do not
combine the information collected through the use of Google Analytics with Personal
Information. Google’s ability to use and share information collected by Google Analytics
about your visits to our website is restricted by the Google Analytics Terms of Service and
the Google Privacy Policy.
Targeting/Advertising Cookies. These cookies are used to deliver advertisements
tailored to you and your interests. They are also used to limit the number of times you seean advertisement as well as help measure the effectiveness of the advertising campaign.
They are usually placed by advertising networks with the website operator’s permission.
They remember that you have visited a website and this information is shared with otherorganizations such as advertisers. Quite often targeting or advertising cookies will belinked to site functionality provided by the other organization. For more information about
online behavioral advertising cookies and online privacy, please see the guide produced by
the internet advertising industry available at youronlinechoices.com.

How to Control CookiesYour browser is likely set to accept cookies. However, if you would prefer not to receive them, you
can alter the configuration of your browser to refuse cookies. If you choose to have your browser
refuse cookies (as explained below), it is possible that some areas of our website will not function
properly when you view them.

You can control our uses of cookies through your internet browser or through third party tools:●●Internet Browser. You can control cookies through most browsers by changing yourcookie settings. These settings will typically be found in the “options” or “preferences”
menu of your browser.
Third Party Tools. You can also visit http://www.allaboutcookies.org/ where you will findcomprehensive information on cookie management and blocking which pertains to a wide
variety of cookies. As noted above, our website uses Google Analytics to collectinformation about how visitors are using our website. Google Analytics has its own cookies
that it uses to track and aggregate this information. You can prevent the use of Google
Analytics relating to your use of our website by downloading and installing the browser
plugin available here.

Advertisements and Advertising Tools
Advertisements
We may use a third-party advertising technology to serve advertisements when you use theServices. 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). We may also
use our third-parties and share with them Users’ information to assist us in evaluating the
success of our advertising campaigns and help us retargeting our Users.

Advertising ID and Advertising Identifier
The Google Advertising ID is an anonymous identifier, provided by Google Play services. If yourdevice has an Advertising ID, we may collect and use it for advertising and user analytics
purposes. We may also use Apple’s Advertising Identifier (IDFA), which is a non-permanent
device identifier provided by Apple, and any information obtained through the use of theAdvertising Identifier, for the purpose of advertising. By downloading or using the Application or
the Services you explicitly agree that we may associate your Advertising ID and your Advertising
Identifier with your applicable persistent device identifier. This will facilitate our ability to improveyour personalized experience. Further, we may use other persistent identifiers for non-advertisingpurposes. If your device does not have Advertising ID or Advertising Identifier respectively, we will
use other identifiers.

How to Control Certain Advertising Technology
You may opt-out of many third-party ad networks, including those operated by members of the
Network 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

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DAA

members,

please

visit

their

respective

websites:

https://optout.networkadvertising.org or https://optout.aboutads.info [EU users may opt out ofreceiving targeted advertising through the European Interactive Digital Advertising Alliance] You
may also control your advertising preferences or opt-out of certain Google advertising products byvisitingtheGoogleAds

Preferences

Manager,currently

availableathttps://google.com/ads/preferences.

Additionally, your mobile device operating system may provide mechanisms that allow users to
opt out of the use of information about their usage of mobile apps to deliver targeted ads to theirmobile device. For more information, or to opt out using these mechanisms, consult your device
settings.

For How Long We Retain Your Information
How long we keep your Personal Information will vary depending on the type of Personal
Information and our reasons for collecting it. The retention period will be determined by various
criteria, including the purposes for which we are using it (as it will need to be kept for as long as isnecessary for any of those purposes) and our legal obligations (as laws or regulations may set aminimum period for which we have to keep your Personal Information). In general, we will retain
your Personal Information for as long as we require it to perform our contractual rights andobligations, resolve disputes and enforce our policies and agreements, or for periods required byour legal and regulatory obligations.

How We Protect Your Information
We take great care in implementing and maintaining the security of the Services and yourinformation. We will take reasonable steps and use technical, administrative and physical security
measures appropriate to the nature of the information and that comply with applicable laws toprotect Personal Information against unauthorized access and exfiltration, acquisition, theft, or
disclosure. Although we take enhanced steps to safeguard information, given the nature of
information security, there is no guarantee that such measures will always be successful. We
cannot be responsible for the acts of those who gain unauthorized access or abuse the Services,and we make no warranty, express, implied or otherwise, that such access will be prevented. If
you feel that your privacy was treated not in accordance with our policy, or if any person
attempted to abuse the Services or acted in an inappropriate manner, please contact us directly
at info@celsius.network.

MinorsThe Services are not designated to individuals under the age of 18. If you are under 18 years old,you should not download the Application, use the Services, or provide any Personal Information
to us. We reserve the right to access and verify any Personal Information collected from you. In
the event that we become aware that an individual under the age of 18 has shared any
information, we will delete such information within a reasonable time. If you have any reason tobelieve that an individual under the age of 18 has shared any information with us, please contact
us at info@celsius.network.

EU/UK Based Users and the GDPR

If you are an EU or UK data subject and the processing of your Personal Information is subject to
the GDPR, please review this section in addition to the entire Policy.

(I) Grounds for Processing

We will only process your Personal Information in circumstances where we have established alawful basis to do so. Our lawful bases for processing that Personal Information include:

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Legitimate Interests. We process Personal Information for our legitimate business interestin managing and promoting our business, provided that our interest is not overridden by
your interest. In identifying and relying on this basis for certain processing, we haveweighed our legitimate interest as a business against your rights and freedoms and havedetermined that such processing will not unfairly impact your rights. If you would like further
information on how we balanced these interests, you can contact us using the details
below. Please note that you have a right to object to the processing of your Personal
Information where that processing is carried on for our legitimate interest.
Legal Requirements. We may need to process your Personal Information in order tocomply with certain legal and regulatory requirements, including to establish, exercise or
defend legal claims, respond to a judicial process, law enforcement or governmental
agency.
Contract. Depending on the circumstances, we may need to process your Personal
Information for the performance of a contract to which you are a party, or related
pre-contractual steps.
Consent. We may process your Personal Information with your consent, as required by the
GDPR. You have the right to withdraw this consent at any time where we are relying onconsent to process your Personal Information. However, this will not affect the lawfulnessof any processing carried out before you withdraw your consent.

(II) Your Rights under the GDPR

We respect your privacy rights and therefore you may contact us at any time and request:• Access. You have the right to know we collect certain Personal Information about you and to ask
us for copies of your Personal Information. Please use the contact details provided at the end of
this Policy.

• Rectification. You have the right to request that we correct your Personal Information you think is
inaccurate or incomplete.

• Objection to processing. You have the right to object to processing in some circumstances,including where we are using your Personal Information for our legitimate interests and for direct
marketing purposes, including by opting-out of marketing communications by contacting us using
the contact details provided at the end of this Policy.

• Erasure. You have the right to request that we erase the Personal Information we have collected
about you in certain circumstances. The right to erasure is not absolute, and only applies if we nolonger need your Personal Information to carry out the purpose that we collected it for, whilst incompliance with laws applicable to us; you have withdrawn your consent to our use of your
Personal Information; you have objected to our use of your Personal Information and yourinterests outweigh our interests in using it; you believe we have processed your Personal
Information unlawfully; or we have a legal obligation to erase your data. Subject to our retention
policies, we will consider any request to erase Personal Information for any of the above reasonsand endeavour to comply with the request to the extent permitted by law, but we may not always
be able to comply with your request. We may be required to retain the Personal Information forcertain retention periods in order to comply with legal and regulatory requirements underapplicable laws and regulations to which we are subject. If we are unable to comply with yourrequest, we will contact you in writing. If you wish to exercise this right, please contact us at:
app@celsius.network.

• Restrict processing. You have the right to ask us to restrict the processing of your Personal
Information in certain circumstances, including if you have concerns regarding the accuracy of
your Personal Information, where you have made an objection to our use of your personal data;
or if you believe we processed your Personal Information unlawfully, but you do not want us todelete it.

• Data portability. You have the right to receive a copy of the Personal Information that we collectabout you in a way that is accessible and in a machine-readable format where the processing isbased on your consent, the performance of a contract with you, or carried out by automatedmeans. You have the right to request that such Personal Information be transmitted directly fromus to another data controller, where technically feasible.

• Withdrawal of consent. You can withdraw your consent at any time where we are relying onconsent to process your Personal Information. However, this will not affect the lawfulness of any
processing carried out before you withdraw your consent.

However, please note that these rights are not absolute, and may be subject to our own legitimate
interests and regulatory requirements.

We will store your Personal Information only for as long as necessary for the purposes for which it
was collected, including to provide the Services and to comply with our legal obligations, resolve
disputes and enforce our policies and agreements. 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 the situation and the need to destroy outdated,unused information at the earliest reasonable time. Under applicable regulations, we will keep
records containing client Personal Information, account opening documents, communications andanything else as required by applicable laws and regulations.

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at ourown discretion. If you wish to make a complaint regarding our handling of your Personal
Information, you can contact us at info@celsius.network. You may also make a complaint to therelevant supervisory authority for data protection issues. In the UK this is the Information
Commissioner’s Office (“ICO”). Contact details for the ICO may be found at www.ico.org.uk.

(III) Transfer of Information Outside the UK and/or the EEA

Please note that some data recipients may be located outside the EEA and/or the UK. In suchcases we will seek to ensure a similar degree of protection is afforded to it by ensuring that,
where possible, Personal Information is generally transferred only to persons in countries outside
the EU or the UK in one of the following circumstances:

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transfers only to such countries as approved by the European Commission or theequivalent entity in the UK as providing adequate level of data protection;
to persons and undertakings to whom the transfer of such Personal Information is madepursuant to a contract that is compliant with the model contracts for the transfer of
Personal Information to third countries from time to time approved by the European
Commission (as supplemented where and if required) or the equivalent body in the UK;to persons and undertakings outside of the EU or the UK pursuant to other appropriate
safeguards for the transfer of Personal Information; andonly on one of the conditions allowed under the GDPR in the absence of (i) a decision by
the European Commission or the equivalent entity in the UK that has deemed a country toprovide an adequate level of protection for Personal Information (i.e. an adequacy
decision) or (ii) appropriate safeguards such as a contract that is compliant with the model
contracts for the transfer of Personal Information to third countries approved by theEuropean Commission or the equivalent entity in the UK.

You can contact us through the information provided below for further information on specificmechanisms we utilise for transferring Personal Information outside the EU or the UK and thecountries to which such transfer may be made.

Additional Information for California Residents
The CCPA imposes certain obligations on us and grants certain rights to California residents(“California Resident,” “you” or “your”) with regard to “personal information” as defined by the
CCPA. If you are a California Resident, please review the following information about our privacy
practices surrounding how and why we collect, use, disclose, and share your personal
information and your potential rights with regard to your personal information under the CCPA.
The rights described in this section are subject to exemptions and other limitations underapplicable law.

Terms used in this section have the meaning ascribed to them in the CCPA. We are a “business.”“Personal information” as used in this section has the same meaning as in the CCPA. It does notinclude deidentified information, aggregate consumer information or publicly available
information, as those terms are defined in the CCPA.

Notice at Collection and Use of Personal Information
What Type of Information We CollectDepending on how you interact with us, we may collect the categories of personal information
listed above in the section “What Type of Information We Collect” above.

How We Use Collected Information

We may use your personal information for the business or commercial purpose listed above in thesection “How We Use The Information” and “With Whom We Share The Information and For
What Purpose” above.

Our Collection, Use, Disclosure, and Sharing of Personal Information

What Information We Have Collected and the Sources from Which We Collected It

In the preceding 12 months, and depending on how you interact with us, we may have collected
all or some of the personal information listed above in “What Type of Information We Collect”
above. We may have collected personal information from all or some of the categories of sources
listed in the above section, “Sources of Personal Information”

Purposes for Collecting Personal Information

We may collect the personal information for one or more of the following business or commercial
purposes described in the above section, “How We Use The Information” and “With Whom We
Share The Information and For What Purpose” above.

Our Disclosure, Sharing of Personal Information

We do not sell your personal information. We do not knowingly sell the personal information of
California residents under 16 years old. We may disclose your personal information to certain
third parties for a business purpose. In the preceding 12 months, we may have disclosed for abusiness purpose the following categories of personal information to the following categories ofthird parties:

Category of Personal Information

Category of Third Party Information Disclosed to for a
Business Purpose

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Identifiers and Similar Information(such as name, email or IP
address)●●●●

Entities who assist with fraud prevention,
detection and mitigation, including credit
agencies and to assist with anti-money
laundering or anti-terrorism checks
Judicial courts, regulators, or othergovernment agents purporting to havejurisdiction over the group or opposing
counsel and parties to litigation
Providers or partners that support ourbusiness operations (such as banking
partners; wallet providers; etc)
Affiliates
Marketing partners
Providers or partners that support ourbusiness operations (such as payment
services providers, etc.)●Additional Information Protectedby Certain Federal or State Laws
(for example, financial information)

Entities who assist with fraud prevention,
detection and mitigation, including credit
agencies and to assist with anti-money
laundering or anti-terrorism checks● Judicial courts, regulators, or othergovernment agents purporting to havejurisdiction over the group or opposing
counsel and parties to litigation

●Characteristics Information (suchas age or gender)

Entities who assist with fraud prevention,
detection and mitigation, including credit
agencies and to assist with anti-money
laundering or anti-terrorism checks● Judicial courts, regulators, or othergovernment agents purporting to havejurisdiction over the group or opposing
counsel and parties to litigation●Commercial Information (forexample, products purchased)

Affiliates● Entities who assist with fraud prevention,
detection and mitigation, including credit
agencies and to assist with anti-money
laundering or anti-terrorism checks● Judicial courts, regulators, or othergovernment agents purporting to havejurisdiction over the group or opposing
counsel and parties to litigation

Internet and Electronic Network
Activity Information (such asbrowsing history and yourinteractions with our website)●
Analytics providers

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Geolocation Information (such asdevice location)

Entities who assist with fraud prevention,
detection and mitigation, including credit
agencies and to assist with anti-money
laundering or anti-terrorism checks● Judicial courts, regulators, or othergovernment agents purporting to havejurisdiction over the group or opposing
counsel and parties to litigation

●

Audio, electronic, or visual
information (for example,
recordings of audio or video calls,
conversations or communications)

Providers or partners that support ourbusiness operations (such as telephonesystem providers and messaging systems)● Entities who assist with fraud prevention,
detection and mitigation, including credit
agencies and to assist with anti-money
laundering or anti-terrorism checks● Judicial courts, regulators, or othergovernment agents purporting to havejurisdiction over the group or opposing
counsel and parties to litigation

●
Inferences drawn from otherinformation to create a profilereflecting a client’s preferences orcharacteristics.

Entities who assist with fraud prevention,
detection and mitigation, including credit
agencies and to assist with anti-money
laundering or anti-terrorism checks● Judicial courts, regulators, or othergovernment agents purporting to havejurisdiction over the group or opposing
counsel and parties to litigation

We may share your personal information with our service providers, other entities that haveagreed to limitations on the use of your personal information, or entities that fit within otherexemptions or exceptions in or as otherwise permitted by the CCPA.

California Resident’s Rights Under the CCPA

If your personal information is subject to the CCPA, you may have certain rights with regard tosuch personal information, including the right to:●●

Notice at Collection. Be informed, at or before the point of collection, of the categories of
personal information to be collected and the purposes for which the categories of personal
information shall be used.
Request to Delete. Request that we delete any personal information about you that wehave collected or maintained, subject to certain exceptions. For example, we may be

●

●

●

required to retain the personal information for certain retention periods in order to comply
with legal and regulatory requirements under applicable laws and regulations to which weare subject. If you wish to exercise this right, please contact us at: app@celsius.network.
Request to Know. Request that we provide you with: (i) the categories of personal
information we have collected about you; (ii) the categories of sources from which wecollected the personal information; (iii) the business or commercial purpose for collecting or
selling the personal information; (iv) the categories of third parties with whom we sharepersonal information; (v) the specific pieces of personal information we have collected
about you; and (vi) the categories of personal information about you we have disclosed fora business purpose.
Not to Be Discriminated Against. Not be discriminated against because you exercised
any of your rights under the CCPA.
Opt-Out of Sale. Request that we not sell your personal information if a business sells
your personal information (we do not).

The CCPA does not restrict our ability to do certain things like comply with other laws or comply
with regulatory investigations. We also reserve the right to retain, and not to delete, certain
personal information after receipt of a Request to Delete from you where permitted or required by
the CCPA or another law or regulation.

How to Submit a CCPA Rights Request
You can submit a Request to Know or Request to Delete, as described above, by calling
800-654-9386, through our website www.celsius.network, or via email to info@celsius.network.
When you submit a Request to Know, Request to Delete, or Request to Opt-Out, we may ask thatyou provide clarifying or identifying information to verify your request. Such information may
include, at a minimum, depending on the sensitivity of the information you are requesting and thetype of request you are making, your name, email address and a copy of government issued
identification. Any information gathered as part of the verification for a Request to Know, Request
to Delete, or Request to Opt-Out will be used for verification or opt-out purposes only.

If you would like to use an authorized agent to submit a Request to Know or a Request to Delete,
we may request proof that they are authorized to act on your behalf, or have a power of attorney.

We may also require that you directly verify your own identity with us and directly confirm with usthat you provided the authorized agent permission to submit the request.

We will deliver responses to verifiable consumer requests, free of charge by mail or electronically,
at your election.

We will try to respond to your Requests to Know or to Delete within forty-five (45) days of receiptof the request. If we require more time, we will try to inform you of our need for an extension.
Even with an extension, we will try to provide a response within ninety (90) days of initial receiptof the request.

Keep in mind that we are not required to provide information in response to Requests to Know
more than twice in a 12-month period. Any response to a Request to Know will only cover the
12-month period preceding the verifiable request.

Additional California Privacy Rights
You have the right to ask us one time each year if we have shared personal information with third
parties for their direct marketing purposes. Please note, however, that we do not currently
disclose any of your personal information to third parties for their direct marketing purposes.

Some web browsers have a “Do Not Track” feature. This feature lets you tell websites you visit
that you do not want to have your online activity tracked. These features are not yet uniform
across browsers. Our website is not currently set up to respond to those signals.

Updates or Amendments To The Privacy PolicyWe may revise this Privacy Policy from time to time, in our sole discretion, and the most current
version will always be posted on our website or Application (as reflected in the “Last Revised”
heading). In the event of a material change to the Privacy Policy, we will notify you through theServices or via email, or you may be notified within the Application. We encourage you to review
this Privacy Policy regularly for any changes. Your continued use of the Services, following thenotification of such amendments, constitutes your acknowledgement and consent of such
amendments to the Privacy Policy and your agreement to be bound by the terms of such
amendments.

How To Contact Us

If you have any general questions regarding the Services or the information that we collect about
you and how we use it, please contact us at info@celsius.network.

Last Revised: September, 2022