DISCLAIMER

Information regarding the data processing of your personal data

Data processor: Consentio Blockchain, S.L. (“Consentio”)
Purposes: We care about your Privacy and Consentio gives you control over your personal data. As a user of our app and services, we request your mobile number and name to allow you to use them in the most basic way and manage your status as user. To enable additional services, we may ask you to provide additional information, such as your geolocation, which we may only use with your authorization, to provide you a better user experience. We will also seek your authorization to update you on new features.
Legal Ground: In order for you and your company to be able to use Consentio services, Consentio uses your personal data to perform in the best way possible the agreed services and, when necessary, with your consent, as explained in the privacy policy and terms of use.

Recipients: your data will be hosted with partners, depending on the services you contract with or through Consentio. You can find a list of all categories of partners in our privacy policy.
Rights: you can oppose the treatment, limit it, access, rectify, delete the data and exercise your right to portability, and revoke your consent, by means of a written request addressed to gdpr@consentio.co, or alternatively at Marie Curie 8, 08042 Barcelona.

Addition information: You can consult additional and detailed information about data protection in the privacy policy.

 

PRIVACY POLICY OF THE CONSENTIO PLATFORM 1. Introduction

Consentio Blockchain, S.L. is a Spanish company, with registered office at Marie Curie 8, 08042 Barcelona (“Consentio”), with Spanish tax identification number (N.I.F.) B66734690, duly registered in the Commercial Registry of Barcelona.

You can contact Consentio at gdpr@consentio.co.

All the terms that appear written in this Privacy Policy in capital letters will have the meaning established in the Terms of Use (which can be consulted in this link), unless they are expressly defined in this policy.

When using the Consentio Platform and, in particular, the services provided by it, Consentio collects the personal data (the “Personal Data”) of each user (the "User" or, jointly, the “Users”), the treatment of which is governed by this privacy policy ("Privacy Policy").

2. Data controller

Whether you reside in a country of the European Union or outside the European Union, the data controller of the registered Users’ Personal Data shall be the company counting with an account with Consentio to offer its products through the Consentio Platform (the “Client”). The Client has authorized the use by the Users of the Consentio Platform in the terms indicated in the Terms of Use.

Hereinafter, Consentio and the Client will be referred to jointly as the parties (the “Parties”).

3. Data processor

Consentio shall be the data processor of the Personal Data of the Users collected and processed through the Consentio Platform, including the information regarding Users’ geolocation, statics concerning usage of the Consentio Platform.

Notwithstanding the foregoing, Consentio shall collect on behalf of the Client and transfer to the latter the personal information necessary to provide the services related to the Consentio Platform. For avoidance of doubt, Parties agree that those sets of data shall be processed by Consentio.

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When providing Personal Data, Consentio shall be considered a data processor acting on behalf of the Client. In this respect, Consentio shall comply with the following obligations when processing any such data:

  1. a)  Consentio shall process the Personal Data in accordance with the Client’s documented instructions. Consentio shall not transfer them to a country or international organization that does not provide a level of protection similar to the one laid down by European law or adhered itself to the Privacy Shield.

  2. b)  Consentio’s personnel shall only gain access to the Personal Data as long as this access is necessary and any such individuals have undertaken to keep all data confidential. This confidentiality obligation shall be in force after the termination date of this agreement.

  3. c)  Consentio shall not be entitled to sub-contract to a provider the undertaking of any processing of Personal Data for which it has been engaged, unless it has obtained the Client’s prior written consent for doing so.

  4. d)  Following the Client’s instructions, Consentio undertakes to return or destroy the Personal Data of the Client, without retaining any copies of the same and without any legal or natural persons having acquired knowledge of the Personal Data. In any event, Consentio will be entitled to keep the Personal Data, duly blocked in order to impede its treatment, to attend to possible liabilities arising out of the data processing, and only for the period until said liabilities prescribe.

  5. e)  Consentio shall implement the necessary technical and organizational measures to guarantee the security of the Personal Data, and to prevent them from being altered, lost, treated or accessed by non-authorized persons, considering the state of technology, the nature of the stored data and the risks for these data, due to human action or to physical or natural means.

  6. f)  Consentio shall make available to the Client all information necessary to demonstrate compliance with the obligations laid down, and allow for and contribute to audits, including inspections. Consentio shall immediately

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inform the Client if, in its opinion, an instruction infringes regulations on Personal Data processing.

  1. g)  Consentio shall provide all reasonable assistance that the Client may require in ensuring compliance with the obligations set forth in Articles 32 to 36 of the General Data Protection Regulation (EU Regulation no. 679/2016). In addition, and taking into account the nature of the processing, Consentio shall assist the Client by appropriate technical and organizational measures, insofar as this is possible, for the fulfilment of the Client’s obligation to respond to requests for exercising the data subject's rights. In any event, Consentio undertakes to submit to the Client the requests to exercise data subjects’ basic rights it may receive.

  2. h)  For purposes of Article 28.3 of the General Data Protection Regulation, the Parties acknowledge that the Personal Data to be processed will comprise contact details belonging to the Users of the Consentio Platform.

4. Consent

For purposes of Article 14 of the General Data Protection Regulation, the Client as data controller is responsible for informing Users of the processing of their Personal Data.

Regarding Consentio, in no case it is necessary for Users to include in the Consentio Platform information or data of a sensitive nature, such as ethnic or racial origin, political opinions, religious or philosophical convictions, or union affiliation, health data or data related to the sexual life, sexual orientation, or data related to criminal records. Users will solely use the Consentio Platform in their professional capacity and, therefore, you will only provide professional data through the Consentio Platform.

In addition, based on the services used by the User, the purposes of the data processing by Consentio will be the following:

  1. (i)  allowing the use of the Consentio Platform by the Users;

  2. (ii)  manage Users’ account information;

  3. (iii)  analyze any other information gathered through the Consentio Platform; and

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  1. (iv)  If you provide your consent, to process the data about your location in order to offer a more personalized experience of using the Consentio Platform; and

  2. (v)  to provide the User with information about products or services of Consentio, the Client or any third party, if so requested, which includes sending the User commercial information by email or any other similar electronic means of communication.

The legal basis of the data processing is the execution of the contractual relationship between the Parties and the contractual relationship between Consentio and the Users in the terms specified in the Terms of Use, being the processing of the Personal Data strictly necessary to be able to use the Consentio Platform. With respect to electronic commercial communications, resolution of any doubts that may arise and geolocation of the User, the legal basis is the consent given by the User, which may be revoked at any time.

It is a key feature of Consentio to care about its Clients and Users’ Personal Data. In this sense the Consentio Platform will geolocate its Users to improve its efficiency and allow new customized features to all Users by tracking purchasing behaviour, allowing to suggest best prices, and helping when calculating costs and risks. By profiling its Users, the Consentio Platform will customize all information to offer better and more efficient services to its Clients and Users.

Without the User’s consent to geolocation and profiling, it will not be possible to help Users to transform the way they transact and tailor purchasings and sells data.

The precise way in which the Parties use the Personal Data of the Users will depend, ultimately, on the use of services rendered by Consentio that each User makes.

If the User provides the Parties with Personal Data regarding third parties, it is the User’s responsibility to inform them of this Privacy Policy and obtain, prior to the inclusion of their Personal Data, their informed and express consent for data processing by Consentio for the purposes indicated above.

5. Providers

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Consentio may require other companies to provide services on its behalf, including, among others, web analytics, marketing and website maintenance or others like banking, money transfers, payment services or bill creation, as well as insurance services. For the provision of the above services on behalf of the Client, providers may need access to certain Users’ Personal Data. In this regard, the Parties may carry out international data transfers to third countries or international organization outside of the European Union or the European Economic Area. In any case, said providers adhere to the Privacy Shield Agreement that guarantees that all data transferred will be treated with a level of protection according to European regulation.

In addition, Consentio will disclose the Clients and Users’ Personal Data if so required by law, in court proceedings, or to investigate suspicious activities.

6. User’s rights

The Parties take very seriously the privacy and protection of Users’ Personal Data. Hence, the Parties agree to respect the privacy of the User’s personal information and to guarantee, in the terms established by the applicable data protection regulations, the Users’ rights to access, rectify or erase the User’s Personal Data, limit the data processing, oppose to the data processing, as well as the right of portability and the right to revoke the processing of the User’s Personal Data. These rights can be exercised by email to the email address included by each Client in its Client profile in the Consentio Platform or to gdpr@consentio.co. You are informed that the revocation of your consent granted for the processing of your Personal Data may imply the impossibility of continuing using the services provided by Consentio.

The Parties will keep the User’s Personal Data as long as the contractual relationship is in force and, if the User has subscribed to the commercial communications and has provided its consent to geolocation, as long as the User does not express his or her opposition to the processing as well as to comply with the legal obligations corresponding to each type of data.

The User will be entitled to file a complaint with the competent supervisory authority.

7. Representation and guarantees

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The User hereby guarantees that the Personal Data that the User provides is correct and accurate, and agrees to inform of any change to said information. The User will be held solely responsible for any loss or damage caused to Consentio or the Client or to a third party, as a result of providing incorrect, inaccurate, or incomplete information on the registration forms.

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TERMS OF USE OF THE CONSENTIO PLATFORM

Consentio Blockchain, S.L., with address at Marie Curie 8, 08042 Barcelona (“Consentio” or “We”), having Spanish tax identification number (N.I.F.) B66734690, registered at the Companies House, is the owner of the Consentio mobile application (hereinafter, the “App”) and of the web portal www.consentio.co (hereinafter, the “Web Portal”) (jointly, the “Consentio Platform”).

You can contact Consentio at info@consentio.co and at +34 911 98 84 22 (Spanish), +33 1 76 35 03 74 (French) and +44 20 3808 4602 (English).

The use of the Consentio Platform is subject to the following conditions set out in this document (the “Terms of Use”).

TERMS OF USE

1. PURPOSE AND SCOPE

  1. 1.1.  The acceptance of these Terms of Use attributes to the company you represent (hereinafter, the "Company" or “You/you”) the condition of user of the Consentio Platform. By using the Consentio Platform you expressly agree to be bound by these Terms of Use as well as to the Privacy Policy.

  2. 1.2.  You acknowledge having fully read and accepted these Terms of Use.

2. YOUR ACCOUNT

  1. 2.1.  Using the Consentio Platform requires setting up a Company account with Consentio (hereinafter, the “Account”). A Company Account may have several user accounts.

  2. 2.2.  We may require an initial data validation in order to create a Company Account and, after the Company’s Account has been set up, We may request at any time an additional validation. Particularly, We may require the representative of the Company setting up the account to provide

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evidences of his/her condition of empowered representative of the Company and a validation of the additional users registered under the Company Account. In these cases, We may suspend the use by the Company of the Account or of the Consentio Platform until such evidences have been provided.

  1. 2.3.  You are responsible for ensuring that the account information provided to us (“Account Information”) is correct, complete, and kept up to date at all times. You can access and update your Account Information in the my account section of the app.

  2. 2.4.  You are solely responsible for safeguarding your Account and keeping the confidentiality of your password. You are solely responsible for any activity occurring under your password, including activity made possible by an unauthorized use of your Account that is the result of your fault and negligence. If you have reason to believe that your Account is no longer secure, you must immediately notify us.

  3. 2.5.  You are required to provide a two (2) months’ notice in order to cancel your Company Account.

3. FEATURES AND USERS OF THE CONSENTIO PLATFORM

  1. 3.1.  The Consentio Platform is a communication and sale platform to be used between entities and professionals trading in the same market. You may find a complete description of the functionalities and features of the App in this link and of the Web Portal in the following link.

  2. 3.2.  You shall be entitled to sub-license the use of the App to those third- party users that You may deem strictly necessary for the operation of your activities (the “Users”). Said sub-license will be free for Users.

  3. 3.3.  When downloading the App or registering at the Web Portal, Users will be required to expressly accept the Terms of Sub-License and Privacy Policy which will be binding to them. Note that You will remain as the ultimate responsible for any damages caused to Consentio or any third party as a consequence of the use of the Consentio Platform by the Users.

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4. USE OF THE CONSENTIO PLATFORM

4.1. There is no tolerance for objectionable content or

abusive users, and sharing abusive content and any

abusive behavior must be reported to Consentio staff and/or report@consentio.co, or to the support chat available within the app and/ or the web. Abusive users, users sharing objectionable content can be excluded and blocked from using Consentio at anytime.

The content that is objectionable and cannot be accepted include the following:

 Content that is offensive, insensitive, upsetting, intended to disgust, or in exceptionally poor taste. Examples of such content that is NOT permitted on Consentio includes:

o Defamatory, discriminatory, or mean-spirited content, including references or commentary about religion, race, sexual orientation, gender, national/ethnic origin, or other targeted groups, particularly content that is likely to humiliate, intimidate, or place a targeted individual or group in harm’s way. Professional political satirists and humorists are generally exempt from this requirement.

o Realistic portrayals of people or animals being killed, maimed, tortured, or abused, or content that encourages violence. “Enemies” within the context of a game/photo/published content cannot solely target a specific race, culture, real government, corporation, or any other real entity.

o Depictions that encourage illegal or reckless use of weapons and dangerous objects, or facilitate the purchase of firearms.

o Overtly sexual or pornographic material, defined by Webster’s Dictionary as "explicit descriptions or displays of sexual organs or activities intended to stimulate erotic rather than aesthetic or emotional feelings."

o Inflammatory religious commentary or inaccurate or misleading quotations of religious texts.

4.2. The use of the Consentio Platform by You or your Users will be conditioned upon having duly paid the price agreed with Consentio. The

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price to be paid by the Company will be agreed with Consentio’s Sales and Success Team through written communication by email.

  1. 4.3.  The clients of a paying Company may have free access to use the Consentio Platform subject to the terms agreed with Consentio.

  2. 4.4.  We may change our fees from time to time. In that case, We will previously inform you about the new applicable fees and will require you to accept them in order to allow the Company or its Users to keep using the Consentio Platform.

  3. 4.5.  You agree that You will solely use the Consentio Platform in your professional capacity and, therefore, You will only provide professional data through the Consentio Platform. In addition and without limitation, You agree not to provide Consentio any special categories of personal data, such as racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data or data concerning your health, sex life or sexual orientation.

  4. 4.6.  You agree that you will not use this Consentio Platform for any purpose that is unlawful, prohibited in or contrary to these Terms of Use, harmful to the rights and interests of others, or in a way that may damage our reputation.

  5. 4.7.  You agree that you will not use the Consentio Platform in a way that may disable, overburden, impair or prevent its normal use, integrity, and stability. You agree not to remove, circumvent, and/or disable any security-related feature of the Consentio Platform.

  6. 4.8.  To the maximum extent permitted by applicable law, you will hold Consentio harmless against any third-party claims, complaints, actions, and objections arising from or in connection with the breach of the Terms of Use or the Terms of Sub-License, your or any User’s misuse of the Consentio Platform, or that made from your Account or any User Account. Consequently, you will be liable for the costs of any damages awarded against Consentio resulting from litigation, preliminary proceedings, or any other claims, resulting from such breach or misuse, including all expenses and costs incurred in defending Consentio’s interests and any resulting attorney fees.

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  1. 4.9.  You agree to respect the terms and conditions established in the present Terms of Use at all times. You expressly state that you will diligently use the Consentio Platform and assume any responsibility that may arise from breaches of these conditions.

  2. 4.10.  You undertake, in those cases where information is requested, not to falsify the identity by impersonating another person. You accept that the use of the Consentio Platform will be carried out for strictly legal and legitimate purposes, and without identity fraud, and in full compliance with the laws of your country and of Spain, including the regulations in force regarding money laundering and the financing of terrorism. You cannot use the Consentio Platform for activities contrary to law, morals or public order, as well as for prohibited purposes or that violate or damage third party rights. Furthermore, the dissemination, storage and/or management of data or content that infringes the rights of third parties or any regulation regarding intellectual property rights is prohibited.

  3. 4.11.  Likewise, you may not use the Consentio Platform to transmit, store, disseminate, promote or distribute data or contents that carry viruses or any other computer code, files or programs designed to interrupt, destroy or impair the operation of any computer or telecommunication program or equipment.

  4. 4.12.  We reserve the right to disable the access to a Company Account, either temporarily or permanently, to You if We have grounds to consider that You are violating any of the provisions established in these Terms of Use or applicable law.

If you detect any irregular use of the Consentio Platform by any User or, in general any other person using the Consentio Platform, You shall contact us at info@consentio.co

5. INTELLECTUAL PROPERTY RIGHTS

5.1. The set of all content hosted or made available through the Consentio Platform, including but not limited to software, code, interfaces, processes, text, graphics, logos, button icons, images, audio clips, digital downloads, data collections or other material are the property of Consentio or of its content providers and is protected by national and

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international legislation on intellectual property rights, copyright and database rights.

  1. 5.2.  You acknowledge that there has been qualitatively or quantitatively substantial investment in either the obtaining, verification or presentation of the contents to prevent extraction or re-utilization of the whole or of a substantial part, evaluated qualitatively or quantitatively, of the contents of Consentio’s database. Therefore, You agree that Consentio holds all rights associated to its databases.

  2. 5.3.  Consentio aims at granting You the best user experience possible by thriving efficiency and better pricing through their trading processes. Therefore it is key to have access to your data to customize all services provided to You and allow You to improve and streamline your trading processes. In particular but without limitation, You grant Consentio a non-exclusive, non-limited, transferable and sub-licensable right of use over the non-personal data included by the User through the Consentio Platform, for the maximum term permitted by law and for its use in the broadest terms by Consentio.

  3. 5.4.  In addition, you grant Consentio a general prior written authorization to engage with other companies to host and transfer data in the terms specify in the Privacy Policy to grant the best and most efficient service. Consentio will inform you in due time of any intended changes concerning the addition or replacement of partners.

  4. 5.5.  Consentio will always take special care anonymizing your data and will strictly comply with all the terms agreed in the Privacy Policy.

  5. 5.6.  Except as expressly authorized by Consentio, You agree:

    1. (a)  Not to sell, license, distribute, copy, modify, publicly perform or display, transmit, publish, edit, adapt, create derivative works from, or otherwise make unauthorized use of the Consentio Platfrom or any of its elements.

    2. (b)  Not to reverse-engineer, decompile, disassemble or otherwise attempt to discover the source code of the Consentio Platform, except and only to the extent that such activity is expressly permitted by applicable law notwithstanding this limitation.

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(c) Not to create hypertext links to any element of the Consentio Platform without the authorization of Consentio.

5.7. Consentio itself reserves all the rights not expressly granted in these Terms of Use.

6. LINKS

  1. 6.1.  The Consentio Platform may include links to third party applications or websites or services that are not owned or controlled by Consentio. We have no control over, and assume no responsibility for the content and practices of any third-party sites. Access and use of those linked applications and/or sites and their content is at your own risk. These Terms of Use do not govern your use of any site or service other than the Consentio Platform. You should review applicable terms and policies of any linked site. For instance and without limitation, you shall review the terms of use and sale of the escrow and payment systems available for the Consentio Platform.

  2. 6.2.  By using the App or the Web Portal you expressly acknowledge and agree that, to the maximum extent permitted by applicable law, We will not be liable for any content submitted, posted, linked to, shared or otherwise made available via our App or our Web Portal, including, but not limited to, any inaccuracies, errors or omissions in any content, any intellectual property infringement with relation to the linked content, or any loss or damage of any kind incurred as a result of the use of any content linked in or otherwise made available via the Consentio Platform.

7. NOTICES

7.1. If You have any question regarding any issue stated in these Terms of Use or related with the use of the Consentio Platform, You may provide us with notices to the following address:

info@consentio.co

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  1. 7.2.  All notices, requests, demands and other communications that the Company or the Users wish to make to Consentio must be made in writing by email.

  2. 7.3.  We may provide you with notices by e-mail to the e-mail address provided by you with your Account Information or through any other means. It is your responsibility to update such Account Information regarding any changes. Subject to the Privacy Policy, Consentio may address you commercial communications (even in electronic format) including information about its products that may be of your interest.

8. CONSENTIO PLATFORM’S AVAILABILITY

8.1. We will do our best efforts to ensure that the availability of the Consentio Platform will be uninterrupted and that transmissions will be error-free. However, this cannot be guaranteed in all cases. Your access to the Consentio Platform may also be occasionally restricted or suspended for maintenance purposes. In these case, We will make our best efforts to give 24 hours’ notice of the disconnection.

9. LIABILITY

  1. 9.1.  Consentio does not own any of the items or products offered through the Consentio Platform, nor reviews or validates the products that are promoted through the Consentio Platform. Therefore, Consentio shall not be deemed liable, directly or indirectly, nor subsidiarily, for damages of any kind arising from any use of the App, Web Portal or third party applications as well as of the lack of legality, reliability, usefulness, veracity, accuracy, completeness and timeliness of the same.

  2. 9.2.  Without limitation, Consentio will not be liable for damages of any kind arising from:

    a) The use of the Consentio Platform or by the status, origin, possible inaccuracy, or possible falsification of the data provided by users in general of the Consentio Platform or the products promoted through the Consentio Platform.

    b) The contents, information, opinions and statements that are communicated or displayed through the Consentio Platform.

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c) The use of the Consentio Platform’s materials, whether prohibited or permitted, in violation of the intellectual property rights, confidential information, contents of the App, the Web Portal or third parties.

d) The performance through the Consentio Platform of acts of unfair competition and illegal advertising.

e) The eventual loss of data for reasons not attributable to the Consentio Platform.

f) The unavailability, errors, access failures and lack of continuity of the Consentio Platform.

h) Failures or incidents that may occur in communications, deletion or incomplete transmissions through the Consentio Platform.

i) Non-operation or problems in the e-mail address or other contact details provided by the Company.

  1. 9.3.  Consentio will solely and exclusively be liable to the Company of the Consentio Platform provided by itself and the contents directly originated and identified with its copyright, being limited, at most and where appropriate, to the amounts received directly from the Company by Consentio, excluding all case of liability for indirect damages or loss of profits.

  2. 9.4.  Any claim or controversy that may arise between users in general of the Consentio Platform must be resolved between them.

  3. 9.5.  Consentio will work at all times to improve transaction efficency for its Users. However, it will under no circumstances create market unfairness or inequalities while pursuing this aim. In this sense, Consentio firmly believes in fair markets and will report to the relevant authorities any misbehaviour in the above mentioned sense that it may be aware of.

  4. 9.6.  To the maximum extent permitted under applicable law, We will not be liable for any damages due to the following circumstances:

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  • -  impossibility of temporarily accessing the Consentio Platform linked to operations for technical maintenance or updating the published information;

  • -  viral attack or any illicit use causing damages to the Consentio Platform. The Company is responsible for any damage to third parties and the consequences of the complaints or actions that might arise insofar caused by the use of the Consentio Platform by the Company or its Users;

  • -  infringement of third party intellectual property rights by the Company or any of its Users or, in general, in the event of violation of third party rights by the Company or any of its Users.

10. MODIFICATION OF THESE TERMS OF USE

  1. 10.1.  We may, at our sole discretion, modify all or part of these Terms of Use

    at any time.

    Without prejudice to this if, in Consentio’s sole discretion, the revision is material you will be required to affirmatively accept the updated Terms of Use in order to keep on using the Consentio Platform.

  2. 10.2.  To the extent permitted by law, the illegality, invalidity or nullity of any of the clauses in these Terms of Use will not affect the validity of their other provisions, which shall be deemed fully in force and effect.

11. GOVERNING LAW AND JURISDICTION

  1. 11.1.  These Terms of Use shall be governed by Spanish common law.

  2. 11.2.  All conflicts arising from or related to these Terms of Use shall be submitted to the non-exclusive jurisdiction of the Spanish courts of the city of Barcelona, Spain.

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TERMS OF SUB-LICENSE OF THE CONSENTIO PLATFORM

Consentio Blockchain, S.L., with address at Marie Curie 8, 08042 Barcelona (“Consentio” or “We”), having Spanish tax identification number (N.I.F.) B66734690, registered at the Companies House is the owner of the Consentio mobile application (hereinafter, the “App”) and of the web portal www.consentio.co (hereinafter, the “Web Portal”) (jointly, the “Consentio Platform”). You can contact Consentio at info@consentio.co and at +34 911 98 84 22 (Spanish), +33 1 76 35 03 74 (French) and +44 20 3808 4602 (English).

The use of the Consentio Platform is subject to the following conditions set out in this document (the “Terms of Sub-License”).

TERMS OF SUB-LICENSE

1. PURPOSE AND SCOPE

  1. 1.1.  The acceptance of these Terms of Sub-License attributes to you the condition of user of the Consentio Platform (“User”). You shall only be entitled to use the Consentio Platform in case a company counting with an account with us authorizes you to do so. By using the Consentio Platform you expressly agree to be bound by these Terms of Sub-License as well as to the Privacy Policy.

  2. 1.2.  You acknowledge having fully read and accepted these Terms of Sub- License.

2. YOUR ACCOUNT

  1. 2.1.  Using the Consentio Platform requires you setting up an account with

    Consentio (hereinafter, the “Account”).

  2. 2.2.  We may require an initial data validation in order to create an Account and, after the Account has been set up, We may request at any time an additional validation. Particularly but without limitation, We may require the representative of a company setting up the account to provide evidences of his/her condition of empowered representative of the

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company and a validation of the additional Users registered under the company Account. In these cases, We may suspend the use by the company of the Account or of the App and the Web Portal until such evidences have been provided.

  1. 2.3.  You are responsible for ensuring that the account information provided to us (“Account Information”) is correct, complete, and kept up to date at all times. You can access and update your Account Information in the Account section.

  2. 2.4.  You are solely responsible for safeguarding your Account and keeping the confidentiality of your password. You are solely responsible for any activity occurring under your password, including activity made possible by an unauthorized use of your Account that is the result of your fault and negligence. If you have reason to believe that your Account is no longer secure, you must immediately notify us.

  3. 2.5.  You are required to provide a two (2) months’ notice in order to cancel your Account.

  1. FEATURES OF THE CONSENTIO PLATFORM

    The Consentio Platform is a communication and sale platform to be used between entities and professionals trading in the same market. You may find a complete description of the functionalities and features of the App and Web portal at www.consentio.co and through exchanges (email, chat, videos and presentations) with Consentio team (Sales, Success and executive team).

    When downloading the App or registering at the Web Portal, You will be required to expressly accept the Privacy Policy.

  2. USE OF THE CONSENTIO PLATFORM

  1. 4.1.  Users may have free access to use the Consentio Platform subject to the

    terms agreed with Consentio.

  2. 4.2.  You agree that you will solely use the Consentio Platform in your professional capacity and, therefore, you will only provide professional data

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through the Consentio Platform. In addition and without limitation, you agree not to provide Consentio any special categories of personal data, such as racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data or data concerning your health, sex life or sexual orientation.

  1. 4.3.  You agree that you will not use this Consentio Platform for any purpose that is unlawful, prohibited in or contrary to these Terms of Sub-License, harmful to the rights and interests of others, or in a way that may damage our reputation.

  2. 4.4.  You agree that you will not use the Consentio Platform in a way that may disable, overburden, impair or prevent its normal use, integrity, and stability. You agree not to remove, circumvent, and/or disable any security-related feature of the Consentio Platform.

  3. 4.5.  To the maximum extent permitted by applicable law, you will hold Consentio harmless against any third-party claims, complaints, actions, and objections arising from or in connection with the breach of the Terms of Use or the Terms of Sub-License, your or any User’s misuse of the Consentio Platform, or that made from your Account or any User Account. Consequently, you will be liable for the costs of any damages awarded against Consentio resulting from litigation, preliminary proceedings, or any other claims, resulting from such breach or misuse, including all expenses and costs incurred in defending Consentio’s interests and any resulting attorney fees.

  4. 4.6.  You agree to respect the terms and conditions established in the present Terms of Use at all times. You expressly state that you will diligently use the Consentio Platform and assume any responsibility that may arise from breaches of these conditions.

  5. 4.7.  You undertake, in those cases where information is requested, not to falsify the identity by impersonating another person. You accept that the use of the Consentio Platform will be carried out for strictly legal and legitimate purposes, and without identity fraud, and in full compliance with the laws of your country and of Spain, including the regulations in force regarding money laundering and the financing of terrorism. You cannot use the Consentio Platform for activities contrary to law, morals or public order, as

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well as for prohibited purposes or that violate or damage third party rights. Furthermore, the dissemination, storage and/or management of data or content that infringes the rights of third parties or any regulation regarding intellectual property rights is prohibited.

  1. 4.8.  Likewise, you may not use the Consentio Platform to transmit, store, disseminate, promote or distribute data or contents that carry viruses or any other computer code, files or programs designed to interrupt, destroy or impair the operation of any computer or telecommunication program or equipment.

  2. 4.9.  We reserve the right to disable the access to your Account, either temporarily or permanently, to you if We have grounds to consider that You are violating any of the provisions established in these Terms of Use or applicable law.

If you detect any irregular use of the Consentio Platform by any User or, in general any other person using the Consentio Platform, you shall contact us at report@consentio.co.

5. INTELLECTUAL PROPERTY RIGHTS

  1. 5.1.  The set of all content hosted or made available through the Consentio Platform, including but not limited to software, code, interfaces, processes, text, graphics, logos, button icons, images, audio clips, digital downloads, data collections or other material are the property of Consentio or of its content providers and is protected by national and international legislation on intellectual property rights, copyright and database rights.

  2. 5.2.  You acknowledge that there has been qualitatively or quantitatively substantial investment in either the obtaining, verification or presentation of the contents to prevent extraction or re-utilization of the whole or of a substantial part, evaluated qualitatively or quantitatively, of the contents of Consentio’s database. Therefore, you agree that Consentio holds all rights associated to its databases.

  3. 5.3.  Consentio aims to grant you the best User experience possible by thriving efficiency and better pricing through their trading processes. Therefore it is key to have access to your data to customize all services provided to you

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and allow you to improve and streamline your trading processes. In particular but without limitation, you grant Consentio a non-exclusive, not limited, transferable and sub-licensable right of use over the non-personal data included by the User through the Consentio Platform, for the maximum term permitted by law and for its use in the broadest terms by Consentio.

  1. 5.4.  Consentio will always take special care anonymizing your data and will comply strictly with all the terms agreed in the Privacy Policy.

  2. 5.5.  Except as expressly authorized by Consentio, you agree:

    1. (1)  Not to sell, license, distribute, copy, modify, publicly perform or display, transmit, publish, edit, adapt, create derivative works from, or otherwise make unauthorized use of the Consentio Platform or any of its elements. Consentio reserves all the rights not expressly granted in these Terms of Use.

    2. (2)  Not to reverse-engineer, decompile, disassemble or otherwise attempt to discover the source code of the Consentio Platform, except and only to the extent that such activity is expressly permitted by applicable law notwithstanding this limitation.

    3. (3)  Not to create hypertext links to any element of the Consentio Platform without the authorization of Consentio.

  3. 5.6.  Consentio reserves all the rights not expressly granted in these Terms of Use.

6. LINKS

6.1. The Consentio Platform may include links to third party applications or websites or services that are not owned or controlled by Consentio. We have no control over, and assume no responsibility for the content and practices of any third-party sites. Access and use of those linked applications and/or sites and their content is at your own risk. These Terms of Use do not govern your use of any site or service other than the Consentio Platform. You should review applicable terms and policies of any linked site. For instance and without limitation, you shall review the terms

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of use and sale of the escrow and payment systems available for the Consentio Platform.

6.2. By using the Consentio Platform you expressly acknowledge and agree that, to the maximum extent permitted by applicable law, We will not be liable for any content submitted, posted, linked to, shared or otherwise made available via our Consentio Platform, including, but not limited to, any inaccuracies, errors or omissions in any content, any intellectual property infringement with relation to the linked content, or any loss or damage of any kind incurred as a result of the use of any content linked in or otherwise made available via the Consentio Platform.

7. NOTICES

  1. 7.1.  If You have any question regarding any issue stated in this Terms of Use or related with the use of the Consentio Platform, You may provide us with notices to the following address:

    info@consentio.co

  2. 7.2.  All notices, requests, demands and other communications that you wish to make to Consentio must be made in writing.

  3. 7.3.  We may provide you with notices by e-mail to the e-mail address provided by you with your Account Information or through any other means. It is your responsibility to update such Account Information regarding any changes. Subject to the Privacy Policy, Consentio may address you commercial communications (even in electronic format) including information about its products that may be of your interest.

8. CONSENTIO PLATFORM’S AVAILABILITY

8.1. We will do our best efforts to ensure that the availability of the Consentio Platform will be uninterrupted and that transmissions will be error-free. However, this cannot be guaranteed in all cases. Your access to the Consentio Platform may also be occasionally restricted or suspended for maintenance purposes. In these case, We will make our best efforts to give 24 hours’ notice of the disconnection.

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9. LIABILITY

  1. 9.1.  Consentio does not own any of the items or products offered through the Consentio Platform, nor reviews or validates the products that are promoted. Therefore, Consentio shall not be deemed liable, directly or indirectly, nor subsidiarily, for damages of any kind arising from any use of the Consentio Platform or third party applications as well as of the lack of legality, reliability, usefulness, veracity, accuracy, completeness and timeliness of the same.

  2. 9.2.  Without limitation, Consentio will not be liable for damages of any kind arising from:

    a) The use of the Consentio Platform or by the status, origin, possible inaccuracy, or possible falsification of the data provided by Users in general of the Consentio Platform or the products promoted through the Consentio Platform.

    b) The contents, information, opinions and statements that are communicated or displayed through the Consentio Platform.

    c) The use of the Consentio Platform’s materials, whether prohibited or permitted, in violation of the intellectual property rights, confidential information, contents of the App, the Web Portal or third parties.

    d) The performance through the Consentio Platform of acts of unfair competition and illegal advertising.

    e) The eventual loss of data for reasons not attributable to the Consentio Platform.

    f) The unavailability, errors, access failures and lack of continuity of the Consentio Platform.

    h) Failures or incidents that may occur in communications, deletion or incomplete transmissions through the Consentio Platform.

    i) Non-operation or problems in the e-mail address or other contact details provided by you.

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  1. 9.3.  Consentio will solely and exclusively be liable of the Consentio Platform provided by itself and the contents directly originated and identified with its copyright, excluding all case of liability for indirect damages or loss of profits.

  2. 9.4.  Any claim or controversy that may arise between Users in general of the App or the Web Portal must be resolved between them.

  3. 9.5.  Consentio will work at all times to improve transaction efficency for its Users. However, it will under no circumstances create market unfairness or inequalities while pursuing this aim. In this sense, Consentio firmly believes in fair markets and will report to the relevant authorities any misbehaviour in the above mentioned sense that it may be aware of.

  4. 9.6.  To the maximum extent permitted under applicable law, We will not be liable of any damages due to the following circumstances:

    • -  impossibility of temporarily accessing the Consentio Platform linked to operations for technical maintenance or updating the published information;

    • -  viral attack or any illicit use causing damages to the Consentio Platform. You are responsible for any damage to third parties and the consequences of the complaints or actions that might arise insofar caused by your use of the Consentio Platform;

    • -  infringement of third party intellectual property rights by the Users or, in general, in the event of violation of third party rights by you;

10. MODIFICATION OF THESE TERMS OF USE

We may, at our sole discretion, modify all or part of these Terms of Use at any time. Without prejudice to this if, in Consentio’s sole discretion, the revision is material you will be required to affirmatively accept the updated Terms of Use in order to keep on using the Consentio Platform.

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10.1. To the extent permitted by law, the illegality, invalidity or nullity of any of the clauses in these Terms of Use will not affect the validity of their other provisions, which shall be deemed fully in force and effect.

11. GOVERNING LAW AND JURISDICTION

  1. 11.1.  These Terms of Use shall be governed by Spanish common law.

  2. 11.2.  All conflicts arising from or related to these Terms of Use shall be submitted to the non-exclusive jurisdiction of the Spanish courts of the city of Barcelona, Spain.

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