Janvier 2022 - Version 0.1

MENTIONS LEGALES

Hyperweb, a simplified joint stock company with a share capital of €10,000, registered in the Paris Trade and Companies Register under number 890 774 136 and domiciled at 66 avenue des Champs Elysées, 75008 Paris (the "Company").

The Company is registered with the Autorité des Marchés Financiers ("AMF") as a Digital Asset Service Provider ("DASP") for the business of buying, selling and exchanging digital assets for legal tender or other digital assets, as well as for digital asset activities, under number E2021-025.

Le directeur de la publication est M. Convard

Contact : help@pleenk.com

Le Plateforme Internet est principalement hébergée par SCALEWAY SAS BP 438 75366 PARIS CEDEX 08 FRANCE

1. Foreword

1.1. The Company believes that trust is the key to successful and lasting relationships. In this respect, the protection of the personal data and privacy of its current or potential clients ("Users") is no exception.

1.2. This is why the Company takes great care to collect and process their personal data only with the utmost care and in strict compliance with the applicable legal framework.

1.3. In order to provide the most transparent information possible, the Company has prepared the following privacy notice. This is intended to explain in detail why and how Users' personal data are processed when they browse the Pleenk website pleenk.com and/or the mobile application Pleenk (collectively, the "Platform") or use the services offered by the Company (the "Services").

2. Scope and purpose of this privacy notice

2.1. This privacy policy (hereinafter the "Privacy Policy") aims to inform you, as a User, about how the Company, as the data controller, treats information that can identify you, directly or indirectly ("Personal Data"), when you use the Platform.

2.2. This policy, which can be accessed at any time on the Platform, is the only policy applicable and supersedes all previous versions.

3. Categories of data, purposes of processing and legal basis

3.1. When a User uses the Services, the Company processes his/her Personal Data for various purposes detailed below, each of which is duly legitimized by a valid legal basis.

3.2. Browsing information. In order to enhance the User experience, the Company wishes to understand users' interactions with the Services. Therefore, the Company needs to analyze various browsing information collected through Cookies in order to analyze the performance related to the use of the Services.

3.3. To do so, the Company adduces its legitimate interest to (i) understand how its Platform is browsed by Users; and to (ii) improve the Platform if necessary.

3.4. Correspondence and communications. The Company collects and processes Personal Data in order to respond to any questions, requests or feedback that Users may submit to the Company, whether or not initiated by the Company.

3.5. Thus, the collection and processing of Personal Data by this means can only take place following a question, request or feedback that is directly addressed by post or e-mail to the Company. Apart from this situation, Personal Data will never be collected in this way.

3.6. This processing involves the collection of the following categories of Personal Data: (i) identification data (i.e. information provided, including name and e-mail address) and (ii) the content of the message(s) you send to the Company.

3.7. This processing is based on the Company's legitimate interest in managing its relations with Users.

3.8. Account management. Users have to create an account on the Platform to access the Services, implying that they have to go through a significant Know Your Client (KYC) procedure. In order to manage this account, and in particular to allow Users to access content reserved for account holders only, the Company collects and processes a certain amount of Personal Data as follows :

• concerning the data of natural persons : first names and surnames ; date and place of birth ; age ; nationality ; socio-professional category ; sector of activity ; income ; tax notice ; domicile ; e-mail address ; IP address ; details of the wallet of digital assets ; copy of an official identity document ; login and password for access to the account ;
• concerning the data of legal entities : business name ; company name ; registration number ; registered office address ; e-mail address of the natural person representing the legal entity ; details of the wallet ; e-mail address ; IP address ; details of the wallet of the legal entity ; mobile telephone number of the natural person representing the legal entity ; copy of its updated Articles of Association ; copy of a document allowing the identification of the legal entity, namely, in the case of French companies : a Kbis extract dating back no more than 3 months, in the case of foreign companies : a certificate of incorporation or a certificate of legal validity and in the case of an association : an extract from the Official Journal stating that it has been declared to the prefecture ; the surnames, first names, address of the natural person representing the legal entity if this natural person is not a legal representative ; the first names, surnames, date and place of birth of the legal representative ; a copy of an official identity document of the natural person representing the legal entity and of the beneficial owners ; sector of activity ; turnover ; tax return or accounting statement ; login and password to access the account.

3.9. The legal basis for this processing is the need for the Company (i) to form a contract to which the User is a party and (ii) to comply with its anti-money laundering and anti-terrorist financing (AML/CFT) obligations.

3.10. Order management. The Company collects Personal Data necessary for the management of orders and invoicing, under the following conditions :

• concerning the data of natural persons : bank details, account number, first names and surnames ; e-mail address ; IP address ; and digital asset wallet details ;
• concerning the data of legal entities : bank details, account number, name, registration number, e-mail address ; IP address ; and digital asset wallet details.

3.11. The legal basis for this processing is the need to execute a contract to which the User is a party.

3.12. Management of payments and withdrawals. The management of payments and withdrawals is carried out by a service provider external to the company, under the conditions specified below (4. Recipients of the Personal Data). For the operation of the Services, Users will have to consent to the collection of Personal Data by the Company's external service providers. These data are the bank details of the User as well as his/her name and surname, in accordance with the general terms and conditions of the Company.

3.13. The legal basis for this processing lies in (i) the need to execute a contract to which Users are party as soon as they become clients of the Company (management of purchases, withdrawals) as well as in (ii) compliance with legal obligations related to the fight against payment card fraud.

3.14. Users are never compelled to provide Personal Data that the Company may request. Nevertheless, the Company draws their attention to the fact that if they refuse, access to the Services may be limited, suspended or impossible.

3.15. In any case, and regardless of the purpose of the processing in question, the Company will adhere to a strict principle of data minimization and will therefore only collect and process Personal Data necessary for the above-mentioned purposes.

4. Recipients of the Personal Data

4.1. The Company shares Personal Data with third party service providers and suppliers who assist the Company in fulfilling the purposes specified in this Privacy Policy. As subcontractors of the Company, service providers and suppliers may have access to Personal Data for the sole purpose of carrying out the tasks entrusted to them. The Company ensures that service providers and suppliers provide sufficient guarantees for the execution of the mission and comply with applicable laws and regulations.

4.2. Where applicable, the Company shares Personal Data with the relevant courts and any other governmental and/or public authority requesting access to Personal Data, to the extent legally permitted.

4.3. In any case, the Company only communicates Personal Data to the above-mentioned recipients on a strict need-to-know basis and only to the extent necessary to achieve the duly identified processing purposes.

4.4. If the Company considers that it is not necessary to keep the User's Personal Data in its active database, the Company will archive it and ensure that access to it is limited to a restricted number of persons with a genuine need to access the Personal Data.

5. Retention period

5.1. The Company retains Personal Data for a limited period of time, which in all circumstances may not exceed the time necessary to fulfill the purposes described in Section 3 of this Privacy Policy.

5.2. Browsing information. The length of time that Cookies are held is specified below in accordance with the provisions of Article 9 of this Privacy Policy.

5.3. Correspondence and communications. Personal Data resulting from questions, requests or feedback from Users are not kept for more than five (5) years after the last contact at the User's initiative.

5.4. Account management. The Company will retain the Personal Data until the account is closed. However, if the Company needs to retain Personal Data for evidentiary purposes beyond the date of closure of your online account, then the maximum applicable retention period will be in accordance with the statutory limitation periods.

5.5. Order management. As regards the management of orders, Personal Data will be kept for the duration of the commercial relationship and ten (10) years after this period due to accounting obligations.

5.6. Payment management. The Personal Data are kept :

• in the case of purchase and sale transactions, until the service is performed ;
• in the case of a subscription, until the last payment due date, if the subscription does not provide for tacit renewal ;

5.7. Concerning the retention of means of proof in order to manage possible complaints, the data are kept for a duration of 13 months, following the date of debit. The Data thus kept for evidentiary purposes must be kept in an intermediate archive and only be used in the event of a dispute about the transaction.

5.8. If the Company determines that it is not necessary to keep Personal Data in the Company's active database, the Personal Data will be archived and the Company will ensure that access to it is limited to a restricted number of persons with a demonstrated need to access the Personal Data.

6. Transfer of Personal Data

6.1. Personal data may be processed outside the territory of the European Union. In this situation, the Company takes all necessary precautions and ensures alternatively or cumulatively that (i) an adequacy decision has been taken by the European Commission regarding the country of destination; (ii) contractual clauses adopted by the European Commission or the supervisory authority have been signed with the recipient; (iii) the recipient adheres to an approved code of conduct or certification mechanism.

7. Users' rights

7.1. Users have various rights regarding the processing of their Personal Data. These are as follows :

• the right to ask the Company for access to their Personal Data and their rectification or deletion ;
• the right to request the Company to restrict the processing that concerns the User ;
• the right to object to the processing of Personal Data ;
• the right to the portability of Personal Data ;
• the right to give instructions regarding the use of Personal Data after the User's death ; and
• the right to lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL), the competent supervisory authority.

7.2. To exercise their rights or for any question on the protection of Personal Data, Users must make the request accompanied by proof of identity by mail addressed to the Company at HYPERWEB, 66 avenue des Champs Elysées, 75008 Paris, France, or by email at help@pleenk.com.

7.3. The Company shall endeavor to respond without undue delay and at the latest within one (1) month after receipt of the request. The Company reserves the right to extend this period to three (3) months in the case of a complex request.

7.4. The Company is committed to protecting Personal Data and complying with the applicable legal framework for data protection.

7.5. This is why the Company collaborates with Users. Thus, Users undertake to inform the Company if the Personal Data they have shared with the Company becomes obsolete or inaccurate.

7.6. In addition, in the event that Users provide the Company with information that directly or indirectly identifies any other natural person (for example, Users have sent a request to the Company and shared Personal Data about another natural person in the email), they represent and warrant that, prior to sharing such information with the Company, such other natural persons have received this Privacy Policy and, to the extent applicable, have consented to the processing of their Data.

8. Security

8.1. The Company undertakes to take appropriate technical and organizational measures to ensure the security and confidentiality of the Personal Data processed.

9. Cookies

9.1. Users are informed that information called Cookies may be transmitted to their browser or equipment by the Service when using the Platform. When browsing the Platform for the first time, a "Cookies" banner may appear requesting acceptance, refusal or configuration of Cookies.

9.2. The maximum retention period for Cookies is thirteen (13) months from the time they are placed on the User's browser or equipment. At the end of this period, new consent will be required.

9.3. Users may accept, decline and/or delete some or all Cookies.

9.4. Users are informed that the refusal of certain Cookies may affect the provision of the Service and the browsing on the Platform, as these Cookies are necessary for the Company to provide the Platform and/or the Service.

9.5. Cookies can be configured in the browser's help menu at the following URLs: Google; Mozilla Firefox; Safari; Edge and Opera.