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Data protection and cookies

Last updated: December 2024

This Privacy and Cookie Policy ("Policy") governs access to and use of all parts of the website and services referred to as the TicoRico platform ("TicoRico", "we", "our") and relates to the domain ticorico.io and ticorico.org (hereinafter referred to as the "Platform") and any documents, data, materials or other information made available on the Platform.

This Policy applies to all visitors and/or users ("User", "you", "your") acting in their personal capacity. Please read this Policy carefully together with our Terms and Conditions and note that by using TicoRico, you consent to the collection, storage, processing and transfer of your personal data as described in this Policy.


DEFINITIONS

1.1 "Account" means the account created on ticorico.io and ticorico.org to use the services offered by the TicoRico platform.

1.2 "TicoRico" is an intermediary platform that functions as a unified login system that allows users to access the services and products of third-party providers offered on their platforms, which includes the TicoRico platform.

1.3 "Personal data" refers to any information relating directly or indirectly to a natural person, whether living or deceased, who is identified from that information or from that and other information.

1.4 "Third-Party Partners" are the service providers and third parties with whom we have service contracts to extend the range of services and products accessible through the TicoRico Platform to its users and community members. However, each is governed by its own terms and policies. TicoRico exercises no control or management over these third party websites. Users should conduct their own due diligence to read and understand each of the legal documents governing these products and services.

1.5 "Third-Party Partner Sites" are the platforms of Third-Party Partners to display their products and services and to provide information about the provision of their products and services available to TicoRico Members.

This policy may be made available in multiple languages for educational purposes only. In the event of any inconsistency between the English version and a translated version, the English version shall prevail.


PURPOSE

2.1 TicoRico knows and understands how important it is for users to understand how we collect, store, process, share and use personal data. We respect and protect the privacy of our users' personal data in our platform.

2.2 The purpose of this policy is to describe how TicoRico collects, processes and manages user personal data through the platform designed to provide our services. For privacy matters relating to third party platforms, services and products, users should contact the service provider involved directly.


ACCEPTANCE

3.1 By using or accessing the Platform, you agree to be bound by this Policy and any supplemental agreements, including the Terms and Conditions, the Delivery, Warranty and Return Policy, and any other subsequent and supplemental agreement related to this document and the operation of TicoRico.


USER LOGIN CREDENTIAL INFORMATION

4.1 In order to properly use our platform, users must create an account under our third party partner website, TicoRico. During this process, your personal data will be shared not only with us, but also with third party partners. Users should recognize that their responsibility includes reading and understanding the privacy policies of each third-party website.

4.2 Each Third Party Partner Site maintains its own privacy policy that governs the collection, use and processing of your personal data. It is your responsibility to read and understand the extent of the terms and practices described in each privacy policy regarding how your personal data is accessed, used and managed on the various platforms in the ecosystem.

4.3 Users grant TicoRico permission to use their personal data in accordance with the provision of services on the platform.


COLLECT PERSONAL INFORMATION

5.1 TicoRico collects and retains the user's personal data in order to facilitate, promote and improve our product range and services. This includes enhancing technical infrastructure, strengthening security measures, adhering to compliance standards, fraud prevention and providing robust customer support. In addition, it is essential to confirm that your personal data is also collected in accordance with the requirements of our third party partner websites.

5.2 The personal data that we collect from our users is:

5.2.1 User - natural person

5.2.1.1 Full name.

5.2.1.2 Date of birth.

5.2.1.3 E-mail address.

5.2.1.4 Gender.

5.2.1.5 Address of residence.

5.2.1.6 Nationality.

5.2.1.7 Country code.

5.2.1.8 Telephone.

5.2.1.9 Purse.

5.2.1.10. Details of the transaction

5.2.1.11 Passport or National ID number

5.2.1.12 Telephone number

5.2.1.13 Credit card details

5.2.1.14 Source of wealth

5.2.1.15 Occupation

5.2.1.16. Details of bank accounts, including institution name, branch, account name, bank identifier

5.2.1.17 Bank account number or IBAN

5.2.2.Browser information

5.2.2.1 IP address.

5.2.2.2 Login

5.2.2.3 Browser type and version.

5.2.2.4 Time zone setting.

5.2.2.5 Platform.

5.2.2.6 Operating system.

5.2.2.7 Transaction history.

5.2.2.8 Pages accessed and links clicked.


USAGES OF PERSONAL DATA

6.1 To communicate with the user.

6.2 To provide our services.

6.3 To comply with legal and regulatory requirements.

6.4 To detect and prevent fraud and credit risks.

6.5 To provide, fix bugs and improve LayerK services.

6.6 To enforce our terms and conditions during our period of use.

6.7 To provide customer service.

6.8 To ensure quality control.

6.9 To ensure network and information security.

6.10. To improve and personalize the user experience.

6.11. To carry out marketing activities.

6.12. Purpose for which we obtain the user's consent.


DATA TRANSFER

7.1 TicoRico may share the user's personal data with certain third parties, which include third party websites, including business providers, merchants and subcontractors. The sharing of personal data becomes essential for the effective provision of our products and services or in cases where a legal basis dictates a legal basis for such sharing. The third-party partner websites may be authorized to collect, use and disclose your information to ensure that the services provided are comprehensive and aligned with our standards.

7.2 Your personal data may be subject to transfers between integrated third-party partner platforms based on the needs to provide efficiency and better user experience to our community members. Please note that these transfers may be made without prior notice. Your continued engagement with our services signifies your acknowledgment and acceptance of this data transfer mechanism.

7.3 We will also ensure that we comply with applicable data protection standards and we will only share information in the following circumstances:

7.3.1 With appropriate regulatory and governmental bodies.

7.3.2.With third party KYC/AML service providers to TicoRico (if applicable) or one of the third party partner websites to perform verification services in the user onboarding process.

7.3.3.With service providers under contract to operate the business. For example and not limited to:

7.3.3.1 Cloud storage.

7.3.3.2 Network infrastructure.

7.3.3.3 Security.

7.3.3.4 Customer service.

7.3.3.5 Marketing.

7.3.3.6 Data analysis.

7.3.3.7 Payment.

7.3.4 We will only transfer the minimum data required for a particular outsourced service provider (if applicable) and we will only work with those outsourced service providers that can provide and ensure an adequate level of protection of personal data.

7.4 TicoRico ensures that the service providers and associated partners who process personal data recognize the confidentiality of this information and protect the user's right to privacy by complying with all applicable data protection and privacy laws.

7.5 Each third-party partner website may have its own data transfer clauses, terms of use and privacy policies that govern how your information is handled, processed and shared. By using our Platform to access the services of third-party websites, you acknowledge and agree to abide by the privacy policies of those third-party partner websites.


PROTECTION AND STORAGE OF PERSONAL DATA

8.1 TicoRico maintains physical, technical, administrative and procedural safeguards in connection with the collection, storage and disclosure of the user's personal data. We use firewall barriers, encryption techniques and authentication procedures to ensure the security of the user's online sessions.


DATA RETENTION

9.1 TicoRico is responsible for retaining the original or an accurate copy of all data and information collected from its users. This retention will be in a format that is accessible for seven (7) years following the conclusion of your involvement with our services as well as those of our third party partner websites on which our services operate. All personal data provided by you will be securely retained by us until the point at which you request termination of our association. The variation in this retention period could change due to the nature of each user's interaction with the platform, products and services and compliance with government agency requirements.

9.2 TicoRico will take reasonable steps to ensure that all personal data is destroyed or permanently deleted when it is no longer necessary for the purpose of providing our services for which it was processed and, in certain circumstances, where required by law, we may not destroy any relevant records or personal data once the prescribed period for retention has expired.

9.3 Information or data collected via technical means such as cookies, website counters and other analytics tools will be retained for a period of up to twelve months from the expiry of each specific cookie in accordance with Section 12.


DATA PROTECTION LAW AND EUROPEAN DATA PROTECTION

10.1 This Policy is governed by and construed in accordance with the data protection laws of the British Virgin Islands. In addition, the highest standard of data protection under the General Data Protection Regulation ("GDPR") also applies to the processing of personal data covered by this Policy.

10.2 According to the GDPR, TicoRico provides data protection information:

10.2.1 In a concise, transparent, understandable and easily accessible form.

10.2.2 Written in clear and simple language.

10.2.3. delivered on time; and

10.2.4 Free supplies.

10.3 If the users are located in the European Economic Area (EEA), you have the rights described below.

10.3.1 You may request access to the personal data we maintain about you, request access to and receive information about your personal data, restrict or object to the processing of your personal data, have the information anonymized or deleted, or exercise your right to data portability to easily transfer your personal data to another company.

10.3.2 You can withdraw your consent to the processing of your personal data at any time and free of charge. We will apply your preferences in the future and this will not affect the lawfulness of the processing before you withdraw your consent.

10.3.3 If you are located in the EEA, we will comply with applicable GDPR law and related regulations when you transfer your personal data outside the EEA.


RIGHTS UNDER THE GDPR

11.1 In certain circumstances, users have rights under data protection laws in relation to personal data, as set out below.

11.1.1 Access requests - This enables you to obtain copies of the personal data we hold about you and to check that we are lawfully processing it. This is also commonly known as a "data subject access request". This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.

11.1.2 Request erasure - This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Please note that there may be circumstances where we are legally entitled to retain your personal data.

11.1.3 The request to restrict processing - This enables you to object to the processing of your personal data, which is processed on the basis of our legitimate interests. In the event of such an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.

11.1.4 Request to object to processing - you have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party provider) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.

11.1.5 Request for transfer - Upon prior written request, TicoRico may transfer your personal data to another controller in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you originally provided to us or where we used the information to enter into a contract with you.

11.1.6 Right to data rectification: This gives you the power to request the rectification of your personal data that we process or hold. This right ensures that the personal data is accurate, up to date and complete. If you discover that your personal data is incorrect, incomplete or out of date, you can exercise this right by making a formal request to us. We are then obliged to rectify the incorrect data without undue delay if the purposes of the processing are taken into account. This right supports the accuracy and fairness of data processing and contributes to the overall integrity and reliability of the personal data we collect and process.


COOKIES POLICY

12.1 Cookies are small text files that are placed on your device such as a computer, cell phone or other device on a website that contains details of your browsing history ("Cookies"). In simple words it is explained as it contains information about your browsing activities. Whenever the user visits our platform, the website sends cookies to the device you use to access our platform. Your device automatically stores the cookies in a file located in your website browser.

12.2 Cookies allow our platform to recognize the user's device. When you revisit a website, the website will respond in a more personalized way and remember your preferences, and it will make your page load faster. Cookies set by our operators are set by parties other than the cookies set by our companies as part of our platform to provide third party features or functionality on or through the website such as advertising, interactive content and analytics.

12.3 We use the following cookies to operate our Platform, such as:

12.3.1 Session cookies are temporary and expire when you close your browser. It stores information for the time or session when you are on our platform.

12.3.2 Persistent cookies include all cookies that remain on your hard disk until you delete them or your browser does so. It depends on the expiration date of the cookie. All persistent cookies have an expiration date written into their code, but their duration may vary.

12.3.3 First-party cookies are placed on your device directly by our platform.

12.3.4 Third-party cookies are placed on your device, not by our Platform, but by a third party such as an advertiser or analytics system. In general, third-party cookies consist of tracking cookies that are used to identify online behavior, understand interests and then customize advertising for the user on other websites. All information obtained from third-party cookies is processed by the respective cooperation partners.

12.3.5 Google Analytics cookies to measure our user's interactions with the content on our Platform. These cookies collect information about your interactions with our platform, such as unique visits, repeat visits, session duration and website activity.

12.3.6 Essential cookies are known as strictly necessary cookies to enable you to browse our Platform and use its features, such as accessing secure areas of our Platform. These cookies are usually first-party session cookies. These cookies do not require your consent. Essential cookies help make our platform easy to use by providing basic functions such as page navigation, language selection, authorization and form filling. Our platform does not work without these cookies and they cannot be disabled. These cookies do not reveal the identity of the user or collect any information. They are stored on the user's device until the browser is closed.

12.3.7 Functionality cookies allow our platform to remember choices you have made in the past, such as the language you prefer, which region you want to visit or which username and password you can log in with automatically. We use cookies to navigate and make it easier for you to access and use this site. These cookies are necessary to transmit communication on the network or to provide services you request. They also help us to know which pages are the most and least popular and to see how visitors move around the site.

12.3.8 Performance cookies collect information about how you use our platform, such as the page you visited and the link you clicked on. None of this type of information can be used to identify you. The purpose of performance cookies is to improve our platform features. Analytics may collect information about log data, such as (i) IP address, (ii) type of browser and device, (iii) operating system, (iv) name of internet service provider, (v) country information, (vi) date and time of visit, (i) web page origin and exit.

12.3.9 Marketing cookies track your online activity to help advertisers deliver more relevant ads or limit the number of times you see an ad. These cookies may share information with other organizations or advertisers. However, these are persistent cookies that are tried out by third parties themselves. These cookies may be set via our advertising partners' websites. If you do not allow these cookies, you will experience less targeted advertising.

12.4 You reserve the right to decide whether to accept or reject cookies from our Platform. You can exercise your cookie rights by setting your preferences in the Cookie Consent Manager. However, you cannot refuse Essential Cookies as they are strictly necessary to provide you with products and services available through the TicoRico Platform. In the event that you reject cookies, you will still be able to use our platform, although your access to some features and areas of our platform may be restricted. You can also set or change your web browser controls to accept or decline cookies. Be aware, refusing or disabling cookies may affect the functionality of our Platform. It is therefore recommended that you do not disable cookies.


13 DATA PROTECTION IN USING DIGITAL ASSETS AND BLOCKCHAIN

13.1 The digital assets and/or digital tokens are recorded on a public blockchain. It is a ledger meaning a chain of blocks in which each block contains the record of each data transfer. Blockchains are decentralized or external networks that are not controlled or operated by third parties or TicoRico's business partners or affiliates, and we have no access or authority to delete, modify or alter any personal data that may be available on such networks.


MODIFICATIONS

14.1 We reserve the right, at our sole discretion, to modify, amend, supplement or replace this Policy at any time and such update details are set out at the top of this page. Our Platform policies and terms may be revised or updated periodically to meet necessary requirements and standards. We encourage you to periodically visit our Platform to stay informed of changes to these policies and terms. Your continued access to the Platform means that you agree to the updated content and to abide by the updated policies.


CONTACT

15.1 In the event of comments, questions, queries or complaints about this Policy, the User has the right to ask questions and/or raise concerns

Contact us at legal@ticorico.io

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