PRIVACY POLICY

(LAST UPDATE 11-02-2022)

This policy expresses how the personal information of all the people who are related to Action Monkey, a brand of Aglaia Capital DeFi Platform S.L. (hereinafter referred to indistinctly as  "Action Monkey" or "Aglaia Capital DeFi Platform") will be treated and protected. through this website. Please, read all the sections of the Legal Notice, the Cookies Policy, where appropriate, and this Privacy Policy before using this website.

In accordance with the provisions of EU Regulation 2016/679, of the European Parliament and of the Council of April 27, 2016 (RGPD) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of the digital rights, Aglaia Capital DeFi Platform SL, informs you that, by accepting this Privacy Policy, you give your express, informed, free and unequivocal consent so that the data you provide, and on which the security measures and the technical and organizational provisions provided for in current regulations are applied are processed by Aglaia Capital DeFi Platform SL, as the data controller.

The personal data that we may collect directly from the interested party through www.actionmonkey.io and will be treated confidentially and will be incorporated into the corresponding treatment activity owned by Action Monkey (Aglaia Capital DeFi Platform S.L.)

ADDITIONAL INFORMATION ABOUT OUR DATA PROTECTION POLICY

Common questions for all treatment activities:

Who is responsible for the processing of your data?

Responsible for the data: Aglaia Capital DeFi Platform S.L.

Document number: B67642132

Fiscal address: Calle Hermosilla, 48, 1º Dcha., CP 28001 Madrid, Spain

Email: onboard@actionmonkey.io

WHAT PERSONAL DATA IS COLLECTED ON THIS WEBSITE?

For the purposes established in this Privacy Policy, Aglaia Capital DeFi Platform S.L. collects and processes the personal data detailed below, which will depend on the different products or services requested on this Website:

Identification data: name, surname, facial biometric verification (one-to-one correspondence).

Contact details: postal address, email, mobile phone number.

Contractual data: data of contractual operations, DNI, products and services acquired, financial operations, payment data.

Navigation data: IP address, type and identification of the device, type of browser, domain through which you access the Website, browsing data, activity on the Website.

ON WHAT LEGAL BASIS ARE THESE DATA PROCESSED?

We treat your personal data with the following legal bases:

• The execution of a contract with Aglaia Capital DeFi Platform S.L., for the contracting of services and / or products and management of the requested services .

• The user's consent in relation to contact, subscription to content and sending commercial communications, via mail, cookies or messaging systems.

• The legitimate interest of the person responsible for the treatment to protect the users of the Aglaia Capital DeFi Platform S.L. website from abuse and fraud in the use of our services.

FOR WHAT PURPOSES WILL WE TREAT YOUR DATA?

On this website, there may be different forms. In each of them, the information we collect will be used as follows:

Content subscription forms: The data provided will be used exclusively to activate the subscription, send newsletters and keep you updated on news and specific offers, exclusive to our subscribers.

Comments form: The personal data entered in the form to insert these comments will be used exclusively to moderate and publish them.

Contact form: In the forms for making queries, suggestions or professional contact, the email address will be used to respond and send the information that the user requires through the web.

Registration form: In this case, we will request your personal data so that you can create an account in our system and be able to access its functionalities.

Sales form: We will process your data to manage the purchase of our products and / or services, including the management of the order, payment and all operations related to the contracting of the chosen service or product. This includes sending follow-up emails, responses, invoices, receipts, etc.

TIME OF CONSERVATION OF PERSONAL DATA

The personal data provided will be kept for the shortest possible time taking into account the reasons why the processing of the data is needed, as well as the legal obligations to keep the data for a certain time, such as labour, tax or anti-fraud legislation that require the retention of personal data for a certain period or as long as the data subject does not withdraw his consent.

Subsequently, the data will be deleted in accordance with the provisions of the data protection regulations, which implies their blocking, being available only at the request of Judges and Courts, the Public Prosecutor's Office or the competent Public Administrations during the limitation period of the actions that may arise and, after this, they will be completely eliminated.

Customer data: The period of conservation of personal data will vary depending on the service that the client contracts. In any case, it will be the minimum necessary, and can be maintained until:

- 4 years: Arts. 66 et seq. General Tax Law (accounting books...).

- 5 years: Art. 1964 of the Civil Code (personal actions without special term).

- 6 years: Art. 30 of the Commercial Code (accounting books, invoices.).

- 10 years: Art. 25 of the Law on the Prevention of Money Laundering and Financing of Terrorism. Subscriber or registration data: From the moment the user gives his consent until he withdraws it.

WHAT ARE YOUR RIGHTS REGARDING THE USE OF YOUR DATA?

Anyone has the right to obtain confirmation as to whether Aglaia Capital DeFi Platform S.L. is processing personal data concerning them or not.

Interested persons have the right to:

• Request access to personal data relating to the interested party.

• Request its rectification or deletion.

• Request cancellation.

• Request the limitation of your treatment.

• Object to the processing.

• Request data portability.

If you have given your consent for a specific purpose, you have the right to withdraw the consent granted at any time, without affecting the legality of the treatment based on the consent prior to its withdrawal.

In the event that you feel that your rights regarding the protection of your personal data have been violated, especially when you have not obtained satisfaction in the exercise of your rights, you can file a claim with the Control Authority in matters of Data Protection. To exercise these rights, you can write to onboard@actionmonkey.io. The forms can also be submitted in person or sent by letter to the contact addresses of the person indicated above.

In the event of acting through legal representation, you must also provide a DNI and a document accrediting the representation of the representative.

It will be necessary to provide a photocopy of the DNI or equivalent document that proves the identity and is considered valid in law, in those cases in which the person responsible for the treatment has doubts about your identity.

NOTIFICATION AND DECLARATION OF GAPS

In Aglaia Capital DeFi Platform S.L. we assume security measures appropriate to the level of risk to protect personal information against loss, misuse and unauthorized access, its disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of personal information; however, if Aglaia Capital DeFi Platform S.L. determines that the personal data it processes has been misappropriated, exposed by a security breach or acquired incorrectly by a third party, Aglaia Capital DeFi Platform S.L. will act immediately taking into account the provisions of the GDPR and the competent data protection authorities.

TO WHICH RECIPIENTS WILL YOUR DATA BE COMMUNICATED?

To perform certain tasks strictly necessary for the development of the activity, Aglaia Capital DeFi Platform S.L. may share data with different external service providers, for example, the web development and maintenance or hosting company, payment processing services, order processing, marketing campaign management, website management, and distribution of e-mail, courier and transport companies, so that they can perform commercial functions on behalf of Aglaia Capital DeFi Platform S.L.

All of them will have signed a contract for the provision of services that obliges them to maintain the same level of privacy that applies to the treatments carried out on this website in accordance with current data protection regulations.

DATA SECRECY AND SECURITY

Aglaia Capital DeFi Platform S.L. undertakes to use and process the user's personal data, respecting their confidentiality, in accordance with the purpose of those; as well as to comply with its obligation to save them and adopt all measures to avoid alteration, loss, treatment or unauthorized access , in accordance with the provisions of current data protection regulations.

Aglaia Capital DeFi Platform S.L. cannot guarantee the absolute impregnability of the Internet, nor, therefore, the violation of data through fraudulent access to them by third parties. With regard to the confidentiality of the processing, Aglaia Capital DeFi Platform S.L. will ensure that any person who is authorized by Aglaia Capital DeFi Platform S.L. to process customer data (including its staff, collaborators and providers), is under the due obligation of confidentiality (whether a contractual or legal duty).

ACCURACY AND VERACITY OF THE DATA

As a user, you are solely responsible for the veracity and correctness of the data you send us, exonerating Aglaia Capital DeFi Platform S.L. from any responsibility in this regard. Users guarantee and are responsible, in any case, for the accuracy, validity and authenticity of the personal data provided, and undertake to keep them duly updated.

PERSONAL DATA OF THIRD PARTIES

In the event that the personal data provided belonged to a third party, as a user you guarantee that you have informed said third party of this Privacy Policy and have obtained their authorization to provide their data to Aglaia Capital DeFi Platform S.L. for the purposes indicated. Likewise, you guarantee that the data provided are accurate and updated, being responsible for any damage, direct or indirect, that may be caused as a result of the breach of such obligation.

CHANGES TO THE PRIVACY POLICY

Aglaia Capital DeFi Platform S.L. reserves the right to modify this policy to adapt it to new legislation or jurisprudential, as well as industry practices. In such cases, it will announce on this page the changes introduced with reasonable anticipation of its implementation.

ADDITIONAL INFORMATION ON DATA PROTECTION

If you need additional information on data protection, you can send us an email to onboard@actionmonkey.io or a communication addressed to Calle Hermosilla , 48, 1º Dcha., CP 28001 Madrid, Spain and, depending on the type of relationship you have with our entity and the processing of personal data we carry out, we will provide you with the additional information that corresponds to it.

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