Privacy Policy

Introduction

KoboTrade Inc. (hereinafter referred to as the "KoboTrade", "we," "us," and "our") is concerned about privacy issues and wants you to understand how we collect, use, disclose, and process your information. This Privacy Policy describes our practices in connection with information that we collect through our websites from which you are accessing this policy, including KoboTrade.com and its associated WebPages (the "Website"), through the software applications made available by us for use on or through computers and mobile devices (the "Apps"), as well as through HTML-formatted email messages that we send to you that link to this Privacy Policy (collectively, including the Websites and Apps, the "Services").

For the purposes of this Privacy Policy, "Personal Information" means information about an identified or identifiable individual. By providing Personal Information, or other information, to us or using our services, you confirm that you understand and consent to the collection, use, disclosure, and processing of your Personal Information and other information (or the Personal Information or other information of any other individual you provide) in the manner as set forth in this Privacy Policy, and you understand that this Privacy Policy is legally binding when you use our services.

We encourage you to review the privacy policy whenever you interact with us to stay informed about our current practices and the ways you can help protect your privacy. This privacy policy applies to the Services provided by KoboTrade Inc ("we" or "us") and applies to users (referred to as "you") of our websites, mobile applications, and other online services to which this Privacy Policy is posted.

Collection of Information and Data

We collect your Personal Information and other information when you provide it to us, when you use our services and when you register to use the services of KoboTrade. We may collect the following Personal Information from you: your name, mailing address, email address, phone number, occupation, personal description and photograph. The need for collection of this data is:

• to comply with any applicable legal and/or regulatory requirements, including laws outside your country of residence
• to comply with legal process
• to respond to requests from public and government authorities, including public and government authorities outside your country of residence, upon demonstration of lawful authority
• to enforce our Customer Agreement with you
• as part of our efforts to keep our Services safe and secure, including to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others, and to investigate, prevent, detect or suppress fraud

Privacy Policy related to Identity Verification

We have partnered with a reputable identity verification company called Veriff, who will provide personal identity verification services to all KoboTrade customers. Through this medium may collect and Process, among other data, the following Personal Data:

• Your personal information, which mainly consists of information extracted from the identification document, for example name, sex, personal identification code, date of birth, eye color, weight and height, as well as the historic data.
• Your document details, such as the name of the document, issuing country, number, expiration date, information embedded to document barcodes (may vary depending on the document) and security features.
• Facial recognition data, such as photos, videos and sound recording, photographs taken from you and your document and video and sound recording of the verification process.
• Contact details, such as address, e-mail address, telephone numbers, IP address and, if relevant utility bills.
• technical data (Device Signature), including but not limited to information about the date, time and your activity in the Services, your IP address and domain name, your software and hardware attributes as well as your general geographic location (e.g. city, state, country);
• Biometric data, such as facial identifiers;
• Publicly available relevant data, e.g. information about being a politically exposed person (PEP) and checks in public sanction lists.

A broader scope of and breakdown of the Veriff privacy policy (hyper link) can be looked up here. We wish to emphasize that Veriff processing of identification is subject to KoboTrade consent to processing which is in tandem with the Terms of Use of KoboTrade services.

We may also collect Technical Information from you, including: details of the transactions you carry out on our Website or when using our Services, including geographic location from which the transaction originates; technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; information about your visit, including the full Uniform Resource Locators (URL) click stream to, through or from our Website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-over's), and methods used to browse away from the page and any phone number used to call our Customer Support number.

Information from other sources

We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties and may receive information about you from them for example, banks and payment service providers you use to transfer money to us; banks and payment service providers of your recipient; business partners; sub-contractors in technical, payment and delivery services; advertising networks; analytics providers; search information providers; and credit reference agencies; public databases; and social media platforms.

If you log in to our Services using your social media account (for example, Face book or Google) we will receive relevant information that is necessary to enable our Services and authenticate you. The social media network will provide us with access to certain information that you have provided to them, including your name, profile image and e-mail address. We use such information, together with any other information you directly provide to us when registering or using our Services, to create your account and to communicate with you about the information, products and services that you request from us. You may also be able to specifically request that we have access to the contacts in your social media account so that you can send a referral link to your family and friends. We will use, disclose and store all of this information in accordance with this privacy policy.

Use of Cookies and other tracking devices

Our Website uses cookies, some of which may collect your Personal Information or Technical Information, to distinguish you from other users of our Website. This helps us to provide you with a good experience and also allows us to improve our Website. Cookies allow us to collect information such as browser type, time spent on the Website, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while using the Services and to recognize your computer in order to assist your use of the Services. We also gather statistical information about the use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies or other technologies to track responses to our online advertisements.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. For example, we may not be able to recognize your computer, and you may need to login every time you visit our website.

Third Party Advertisers

We may use third-party advertising companies to serve advertisements regarding products and services that may be of interest to you when you access and use the Services and other websites, apps or online services, based on information relating to your access to and use of the Services and other websites, apps or online services on any of your devices. To do so, these companies may place or recognize a unique cookie on your browser (including through use of pixel tags). They may also use these technologies, along with information they and we collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.

Some of our Third-Party Service Providers may be located outside Canada, and may not be subject to Canadian privacy laws. We only share your Personal Data with a Third-Party Service Provider if that provider agrees to our privacy standards as set out in our Non disclosure agreement. Your Personal Data will never be transferred to other third parties without your approval or consent.

Use and disclosure of the information

We may use your Personal Information in the following ways:

• To carry out our obligations relating to your contracts and transactions with us and to provide you with the information, products and services that you request from us, as well as related customer service;
• To notify you about changes to our Services or to send you other administrative information;
• As part of our efforts to keep our Services safe and secure;
• to administer our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• To improve our Website and to ensure other Services are presented in the most effective manner.
• to measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you;
• To allow you to participate in interactive features of our Services, if you desire.
• To facilitate social sharing functionality;
• consistent with choices that may be available to you, to provide you with information about other similar goods and services we offer; and
• To provide you, or permit selected third parties to provide you, with information about products or services we feel may interest you.

We may use and disclose Technical Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Technical Information as Personal Information under applicable law, then we may use it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy. If we combine Technical Information with Personal Information, we will treat the combined information as Personal Information as long as it is combined.

We may disclose and share your Personal Information with selected third parties including:

• affiliates, business partners, joint marketers, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• advertisers and advertising networks solely to select and serve relevant advertisements to you and others;
• to third party service providers that connect to your bank account(s) with bank account login credentials provided by you in order for us to perform Services and confirm availability of funds; and
• Analytics and search engine providers that assist us in the improvement and optimization of our site.

Your Personal Information may also be disclosed:

• consistent with choices that may be available to you, to our affiliates for the purposes described in this Privacy Policy;
• consistent with choices that may be available to you, to permit selected third parties to provide you with information about goods or services;
• By you, on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public;
• to your friends associated with your social media account, to other users of the Services and to your social media account provider, in connection with your social sharing activity, such as if you connect your social media account to your KoboTrade account or log into your KoboTrade account from your social media account. By connecting your KoboTrade account and your social media account, you authorize us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media site's privacy policy;
• if you open or access your KoboTrade Account directly on a third-party website or via a third-party application, with the provider of the third party website or application;
• to explore and/or undertake a corporate transaction, including any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our User agreement and other applicable agreements; or to protect the rights, property, or safety of KoboTrade, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
• to assist us in conducting or co-operating in investigations of fraud or other illegal activity, or to respond to requests from public and government authorities (including those outside your country of residence), upon demonstration of lawful authority;
• To prevent and detect fraud or crime.
• In response to a subpoena, warrant, court order, or as otherwise required by law.
• to assess financial and insurance risks, and to protect our operations and those of any of our affiliates;
• to allow us to pursue available remedies or limit the damages that we may sustain; to recover debt or in relation to your insolvency; and
• To develop customer relationships, services and systems.

Updating Your Personal Information

It is important that the information contained in our records is both accurate and current. You can access, modify, delete, or update your Personal Information submitted to our website by [logging in to account your account, emailing customer support and customer profile.

Access to Your Personal Information

You have the following rights regarding your Personal Information in our possession or under our control:

• Upon request, be informed of the existence, use and disclosure of your Personal Information and be given access to that information.
• Challenge the accuracy and completeness of your Personal Information and have it amended as appropriate. Depending on the nature of the information, amendment may involve the correction, deletion or addition of information.
• Withdraw your consent to the collection, use or disclosure of your Personal Information.

You may contact us at support@kobotrade.com to make a request. The Privacy Officer will respond to a request as soon as reasonably practicable. We may need to verify your identity before addressing your request. An access request may be subject to a fee. If the request is unfounded, unlawful or excessive, we may refuse the request.

Please note that we may need to retain certain information for recordkeeping purposes, to comply with our obligations under applicable laws and regulations, including but not limited to our anti-money laundering obligations, and/or to complete any transactions that you began prior to requesting a change or deletion.

Storage and Security of Data

• Your Personal Information is protected by security safeguards appropriate to the level of sensitivity of the information through data encryption, secure servers and organizational measures such as due diligence in transferring Personal Information to third-party processors.Kobotrade may transfer your Personal Information to a third-party service provider for processing and storage.All customer information are stored in a secured world class cloud data base vault of our Data storage and security partners in Los Angeles California USA.As we engage a third-party service provider, we ensure that the information is properly safeguarded at all times at a comparable level of protection.
• Customer Information, retention, deletion and sharing is subject to provisions in our Privacy Policy and Terms of Use of kobotrade which we advise you read carefully and consent to before initiating any transactions on the kobotrade website, web application and Mobile app. Our identity verification partners Veriff, only stores personal Data only for as long as the retention of data is required by law. At the end of the retention period, we shall permanently erase the Personal Data or anonymize it. Based on Canadian regulatory scope these data will be permanently deleted in 48 months. Click here to read more on Veriff privacy policy.
• Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the services you consent to the transfer of information to countries outside of Canada, including the United States, which may have different data protection rules. In the event that your Personal Information is transferred outside of Canada, the government, courts or law enforcement or regulatory agencies of that jurisdiction may be able to obtain disclosure of your Personal Information through the laws of that jurisdiction if need be.

Privacy Policy Updates and Privacy Officer

From time to time, we may make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our website www.kobotrade.com and we shall also send communications by email to you when any updates are done.

If you have any questions about this Privacy Policy or have any concerns about how we manage your personal information, please contact our Privacy Officer by telephone, in writing or by email. We will endeavour to answer your questions and advise you of any steps taken to address your concerns. If you are dissatisfied with our response, you may be entitled to make a written submission to the Office of the privacy commissioner of Canada at https://www.priv.gc.ca/en/.

This privacy policy conforms to The Personal Information Protection and Electronic Document Act (PIPEDA) for fair personal Information use, See here https://www.priv.gc.ca/en/privacy-topics/privacy-laws-in-canada/the-personal-information-protection-and-electronic-documents-act-pipeda/.

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:

• Name of Privacy Officer: Okwy Ozowalu
• Email of Privacy Officer: okwy@kobotrade.com
• Phone Number: +1 780-718-5025

Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples.

This Privacy Policy does not create or confer upon any individual any rights, or impose upon KoboTrade any obligations outside of, or in addition to, any rights or obligations imposed by Canada's federal and provincial privacy laws, as applicable.