# Privacy Policy

Last revised: March 2023

# Definitions and legal references

# Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information - including a personal identification number - allows for the identification or identifiability of an individual.

# Data Subject

The natural person to whom the Personal Data refers.

# Leech protocol (or Application)

The means by which the Personal Data of the User is collected and processed.

# User

The individual using the Leech protocol who, unless otherwise specified, coincides with the Data Subject.

# Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of the Leech protocol. The Data Controller, unless otherwise specified, is the Owner of the Leech protocol.

# Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

# Usage Data

Information collected automatically through the Leech protocol (or third-party services employed in the Leech protocol), which can include: the IP addresses or domain names of the computers utilized by the Users who use the Leech protocol, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited and other parameters about the device operating system and/or the User's IT environment.

# Service

The service provided by the Leech protocol as described in the relative terms (if available) and on this site/application.

# Cookies

Small sets of data stored in the User's device.

# European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

# Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679" (General Data Protection Regulation).

This privacy policy relates solely to the Leech protocol, if not stated otherwise within this document.

# Owner and Data Controller

LeechProtocol L.L.C-FZ Address: Business Center 1, M Floor, The Meydan Hotel, Nad Al Sheba, Dubai, U.A.E. Company number: 2204042 Privacy Officer contact: [email protected]

# Introduction

LeechProtocol L.L.C-FZ (“the Company”, “We”, “Our” or “Us”) is providing this Privacy Policy to explain what personal data We collect, how We use it, and your rights if you want to change how We use your personal data.

# Personal data you give Us

You may give Us personal data by:

• Registering to use the Leech protocol;
• Filling in forms online;
• Corresponding with Us by phone, e-mail or Skype; or
• Subscribing to Our newsletter.

In the following, We report the detailed set of data We ask you, mandatorily or optionally, for each process you may be involved in.

# Personal data We collect from your device

We use Usage Data and Cookies to manage Our website, and to make sure that content from Our website is presented in the most effective way for you and your device. For more information about cookies, please see Our Cookies Policy.

# Lawful basis for personal data processing

# How long We keep your personal data?

We will not retain your personal data for longer than is necessary to fulfill the purpose it is being processed for. To determine the appropriate retention period, We consider the amount, nature and sensitivity of the personal data, the purposes for which We process it and whether We can achieve those purposes through other means.

Blockchain relies on a distributed ledger system that is decentralized and immutable. It is intended to be a permanent and a tamper-proof record that sits outside the control of any one governing authority. Information on the blockchain, including personal information of Data Subjects, cannot be modified or deleted.The Company vows data protection transparency. As Data Controller, we are obliged to be transparent with Data Subjects about how we process their personal data. Thus, Data Subjects are informed that the Company must collect a cryptocurrency address to offer a service. Even though the Company deletes personal data as, the cryptocurrency address and all the blockchain transactions linked to it are never deleted from the blockchain due to its immutability property. This is a fact that Data Subject must accept if s/he decides to participate in an open source, public blockchain.

Should you require further information about Our retention periods, please contact Us using the provided Privacy Officer contact email outlining your requirements.

# Do We share your personal data?

The Company may share your personal data with:

• Third parties to the extent necessary to: (I) comply with a government request, a court order or applicable law; (II) prevent illegal uses of Our website, violations of Our website, its terms of use and Our policies; (III) defend Ourselves against third party claims; and (IV) assist in fraud prevention or investigation;
• To any other third party for which you have provided Us with your consent.

# How do we protect your data?

Our site is reviewed on a regular basis for security vulnerabilities in order to make your visit to our site as safe as possible. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. We implement a variety of security measures when a user places an order, enters, submits, or accesses their information to maintain the safety of your personal information.

# What are your rights?

You have the right to request:

• Access to your personal data;
• An electronic copy of your personal data (portability);
• Correction of your personal data if it is incomplete or inaccurate; or
• Deletion or restriction of your personal data in certain circumstances provided by applicable law.

These rights are not absolute. Where We have obtained your consent for the processing of your personal data, you have the right to withdraw your consent at any time.

If you would like to request a copy of your personal data or exercise any of your other rights, kindly contact Us using the provided Privacy Officer contact email.

If you have any questions related to EU GDPR 2016/679 compliance or Data Protection, you can contact Us using the provided Privacy Officer contact email. If you still feel that your personal data has not been handled appropriately according to the Law, you have the right to lodge a complaint against the Company regarding data protection issues with the Data Commissioner’s Office.

# Other local Data Protection Laws

We at Leech protocol take the data privacy of our customers and guests very seriously and are committed to abiding by the applicable Data Protection Laws.

If you have any enquiry or complaint regarding how we handle your personal data or how we comply with your local applicable Data Protection Law, we welcome you to contact us using the provided Privacy Officer contact email.

When submitting an enquiry or a complaint, your indication of the applicable Data Protection Law in the subject would assist us in attending to your complaint effectively.

# Changes to this Privacy policy

We have to make modifications to this document from time to time, which you will be notified about immediately upon visiting our website with the opportunity to review and agree to the new version of the document. We also recommend you to monitor such modifications yourself and if at any point you do not agree with the new changes, we suggest that you stop using Leech protocol.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.