By using this site, you agree to the Privacy Policy of KOINSYA HOLDINGS, INC., hereinafter “KOINSYA”. If you do not agree to the privacy policy (hereinafter the “Policy”), please do not use this site. KOINSYA reviews its Policy periodically and reserves the right, at its discretion, to modify or remove portions of this policy at any time. This page should be reviewed periodically so that you are updated on any changes. If you want to communicate with us about our Policy, please write to us at KOINSYA HOLDINGS, INC., with offices at 240 Crandon Blvd, Suite 275 Key Biscayne, Florida 33149 United States, or e-mail us at privacy@koinsya.com.

KOINSYA, which operates the Internet site located at www.koinsya.com (the "Site"), recognizes the importance of protecting the privacy of personally identifiable information collected about visitors and our clients on our sites. As a general policy, no personally identifiable information, such as your name, address or email address, is automatically collected from visitors to our site. When you become a client, personal identifiable information about yourself is collected when knowingly and voluntarily submitted. We may collect certain non-personal information to optimize our Web pages for your computer (i.e., the identity of your Internet browser, the type of operating system you use, your IP address and the domain name of your Internet service provider). We may use such non-personal information for internal purposes, including but not limited to improving the content of our sites.

Koinsya Holdings, Inc. provides this Privacy Policy to inform users of our policies and procedures regarding the collection, use, and disclosure of personally identifiable information received from users of this website, located at www.koinsya.com and any other website owned and operated by Koinsya Holdings, Inc. and any related Koinsya Holdings, Inc. applications (the “App”) if any, or collected through the products and services available at the Sites, (together with the Sites, the “Service” ).

In this Policy, “you” or “your” means the person using the Service and the company (if any) on whose behalf he/she is acting, and “we,” “us,” “our,” or the “Company” means KOINSYA HOLDINGS, INC. and its affiliates.

By using the Service, you agree to our processing of your information as set forth in this Policy now and as amended by us from time to time. “Processing” means using cookies on a computer or using information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, all of which activities will take place in the United States of America.

If you reside outside the U.S., your personally identifiable information will be transferred to the U.S., and processed and stored there under U.S. privacy standards. By using the Service and providing information to us, you consent to such transfer to, and processing in, the U.S. KOINSYA DOES NO PROVIDE SERVICES TO NON-US RESIDENTS. If you have any questions or comments about this Privacy Policy or our use of your personally identifiable information, please contact us at contact@koinsya.com.

1. Information Collection and Use

   Our primary goals in collecting personally identifiable information are to provide you with the product and services made available through the Service, to communicate with you, and to manage your registered user account, if you have one.

   Information we collect. We may collect the following categories of personal information about you through the our website and through the App, including but not limited to:

   1. Registration information: To use certain features of the Services, you will need to register an account. When you make an account, you will be asked for basic registration information, such as an email address and password.

   2. Identification information: You may also be asked to provide identification information to confirm your identity, including your first and last name, username, address, and phone number, and/or a valid ID number.

   3. Third party credentials: You may also enter in certain passwords, usernames, account numbers, and other account information for websites, apps, products or services provided by third-party service providers (“Third-Party Services”).

   4. Information from Third-Party Services: In order to display information to you through the Service, we may collect, on your behalf, your account and other personal information from Third-Party Services that you register under your account via the Service. For example, if you register your bank account with us, we will aggregate your bank account information via our Service in order to present it to you.

   5. Technical and navigational information: We collect information about your interaction with our Site, and/or our App such as computer browser type, pages visited, average time spent on our App, IP address, unique identifier of the device, operating system version and app version.

   6. Location information: If you choose to use a location enabled Service, we may collect location information from your device and will notify you of this collection. You may control or disable the sharing of location information via your Site setting and/or the App.

   7. Other information: We may request or receive other personal information such as feedback, questions, comments, suggestions, or ideas to provide you with other benefits or to improve upon the Service. In such instances, you will be given the opportunity to provide or decline that information.

   8. Use of Contact Information. If you contact us by email through the App or the Site, we may keep a record of your contact information and correspondence, and may use your email address, phone number and any information that you provide to us in your message, to respond to you. In addition, we may use your contact information to market to you, and provide you with information about, our products and services, including but not limited to our Service. If you decide at any time that you no longer wish to receive such information or communications from us, please follow the unsubscribe instructions provided in any of the communications.

2. Cookies

   Like many websites, we may also use “cookie” technology to collect additional website usage data and to improve the Service. A cookie is a small data file that we transfer to your

   computer’s hard disk. We do not use cookies to collect personally identifiable information. KOINSYA may use both session cookies and persistent cookies to better understand how you interact with the Service, to monitor aggregate usage by our users and web traffic routing on the Service, to serve ads on the Service that are tailored to your interests, and to improve the Service. A session cookie enables certain features of the Site or App and our Service and is deleted from your computer when you disconnect from or leave the Site or App. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the App. Persistent cookies can be removed by following your web browser help file directions. Most Internet browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.

3. In those instances when we do collect personally identifiable information, the following policies apply:

   1. Notice

      KOINSYA will notify you when we are collecting personally identifiable information about you and how we intend to use it. For example, we may need to collect such information to provide you with information or a product you requested, in connection with contest entry forms or for billing purposes, or in connection with community postings such as chat and bulletin boards.

      Sometimes KOINSYA engages in activities with business partners and sponsors with whom personal information is jointly collected or shared, this information will only be used for operational purposes and will not be shared for . We will try to make it clear at the time of collection who is asking for and/or sharing your information. In situations where your information will be shared, it is recommended that you also review the privacy policy of our business partner or sponsor.

   2. Use and Security

      1. Personally identifiable information that visitors submit to our sites is used only for the purpose for which it is submitted unless we disclose other uses in this Policy or at the time of collection. Such other uses may include sending you information or materials we think you will find interesting or sharing the information with KOINSYA's advertisers and reputable business partners. However, at the time of collection, you will have the option of instructing us not to send you additional information or share your personal information with third parties. KOINSYA is not responsible for the privacy policies or practices of our business partners.

         KOINSYA may use reputable third parties to manage activities available on our sites including, but not limited to, maintenance, hosting, statistical analysis, or chats. These parties may have access to personally identifiable information submitted by visitors who participate in those activities. Similarly, we may contract with third parties to handle the fulfillment of subscriptions or requests for information you submit to our sites, such as sending you a newsletter. In most instances, KOINSYA instructs these third parties to use personally

         identifiable information only for the specific purpose for which it is collected, and not to sell, market or transfer such information to other entities. If KOINSYA obtains personal information that has been collected from you by a third party, including our business partners, this Privacy Policy nonetheless governs KOINSYA’s use of that information.

         We may use your Device ID for security purposes. For example, if you have activated a feature that limits access to a Service from a specific device, our systems will access the Device ID from each device you attempt to access the Service with to determine if the device is the specific authorized device. Additionally, we may use Device IDs to monitor suspicious activity. For example, if we detect that a single account on a Site or App is being accessed from multiple devices, as determined by tracking the Device IDs that access an account, we may contact the user to ensure that such access has been authorized by the user.

         Please remember that any information posted on bulletin boards and/or communicated in chat areas becomes public information. You should use caution when sharing information as any of it can be collected and used by people you may not know. Users under the age of 18 should be particularly careful not to divulge any personal information. While KOINSYA strives to protect and respect your privacy, we can not guarantee the security of any information you disclose in a chat room or bulletin board and you do so at your own risk.

         KOINSYA may use personally identifiable information in aggregate form to make our sites better and more responsive to the needs of our visitors. This statistical compilation and analysis of information may also be used by KOINSYA or provided to others, in aggregate, for marketing, advertising or research purposes.

         If at any time after submitting your personal information to our sites you would no longer like to receive information from us, simply follow the "unsubscribe" directions at the end of any email communication you receive.

         KOINSYA does not knowingly collect personally identifiable information from children under the age of 18.

      2. Security

         KOINSYA is very concerned about safeguarding the confidentiality of your personally identifiable information. We employ administrative, physical and electronic measures designed to protect your information from unauthorized access, including but not limited to commercially available data encryption, but we cannot and do not assure that these measures will be sufficient to protect against all efforts to gain unauthorized access to the information. We will make any legally-required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored personal data to you via email or conspicuous posting on this App or Site.

         Although KOINSYA strives to protect your personal information, we can not ensure or warranty the security of any information you may transmit to us or from our online products and services. This is done so at your own risk. Once we do receive your transmission, however, we make our best effort to ensure its security on our systems. When credit card information is transmitted, industry standard encryption is used.

         You are solely responsible for ensuring that your use of the Service is in compliance with all laws applicable to you. You are responsible for securely maintaining your KOINSYA authentication credentials. You must notify us immediately in the event of any breach of security or unauthorized use of your Account or any End User Data. You must never publish, distribute, or share your Client ID or secret, and must encrypt this information in storage and during transit.

4. Compliance with Laws and Law Enforcement and Information Disclosure.

   1. Compliance with Applicable Law. When using the Service, you must abide by all applicable local, state, national, and international laws. You also confirm that you, your business, your employees, your service providers, and any others acting on your behalf adhere to all applicable laws, especially those pertaining to financial data and to data protection, privacy and data security.

      In addition, you certify that you, your officers, directors, shareholders, direct and indirect parent entities, subsidiaries, and affiliates:

      1. are and will remain in compliance with all applicable import, re-import, sanctions, anti-boycott, export, and re-export control laws and regulations (including all such laws and regulations that apply to a U.S. company, such as the Export Administration Regulations, the International Traffic in Arms Regulations, and economic sanctions programs implemented by the Office of Foreign Assets Control (OFAC));

      2. are not subject to, or owned by parties that are subject to, sanctions or otherwise identified on any sanctions-related list, including but not limited to lists maintained by the United States government (such as the List of Specially Designated Nationals and Blocked Persons, maintained by OFAC, the Entity List maintained by the U.S. Commerce Department’s Bureau of Industry and Security, and the CAATSA section 231(d) list maintained by the U.S. State Department), the United Nations Security Council, the United Kingdom, the European Union or its Member States, or other applicable government authority; and

      3. are not engaging, and will not engage, in activities which may require or permit any applicable government authority to pursue an enforcement action against, or impose economic sanctions on you or us.

      4. The certifications immediately above are not sought, and are not provided, if and to the extent such request or certification would constitute a violation of

         the EU Blocking Statute, of laws or regulations implementing the EU Blocking Statute in the EU Member States or in the United Kingdom, or any similar anti-boycott, non-discrimination, or blocking provisions foreseen in applicable local laws.

   2. Personal information may be disclosed in special situations where KOINSYA has reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with KOINSYA’s rights, property, users, or anyone else who could be harmed by such activities. Also, KOINSYA may reveal information when we believe in good faith that the law requires it. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims, legal process (including subpoenas), to protect the property and rights of KOINSYA or a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.

   3. We reserve the right, in our sole discretion, to share or disclose your personal information with law enforcement, government officials, and other third parties:

      1. to respond to subpoenas, court orders, or legal process;

      2. in order to investigate, prevent, defend against, or take other action regarding violations of our Terms of Service, illegal activities, suspected fraud, or situations involving potential threats to the legal rights or physical safety of any person or the security of our network, Sites or Services;

      3. to respond to claims that any posting or other content violates the rights of third parties;

      4. in an emergency, to protect the health and safety of our Sites’ users or the general public; or

      5. as otherwise required by any applicable law.

      6. We may share your personal information with other third parties with your consent or instructions to do so.

5. Corporate Transfers. KOINSYA may sell, transfer or otherwise share some or all of its assets, including your personally identifiable information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

6. Links to Third Parties and Co-branded Sites. KOINSYA has established relationships with reputable business partners that allow visitors to our Internet sites to link directly to sites operated by these partners. Some of these sites, such as [insert name of merchant account services provider] or sites dedicated to clearing services, or wed developing tools (i.e. www.wow.com) may be "co-branded" with a KOINSYA logo; however, these sites are not operated or maintained by KOINSYA. These sites may collect personal information from you that may be shared with KOINSYA. As noted above, this Privacy Policy will apply to any personal information we obtain in this manner.

   Third parties acting on our behalf that are given access to your personal information are contractually obligated to abide by our privacy practices and are not allowed to use the information for any other purposes.

   1. Opt-in Consent Information. Subject to the exceptions of Article 8 hereunder, KOINSYA shall not share any “opt-in consent information” (including phone number or email address) with any affiliates or third parties.

7. Access and Deletion Rights

   You have the right to access, correct or delete Personal Information held about you by Koinsya. To the extent allowed, any requests to exercise such rights may be subject to a small fee to meet our costs in providing you with details of the Personal Information we hold about you. Should you wish to access the Personal Information held about you, please let us know by contacting us at the contact information provided below. KOINSYA reserves the right to keep confidential backups of all of its user information, including yours, for legal compliance purposes.

   KOINSYA chooses its advertisers and business partners carefully. However, KOINSYA is not responsible for the content or practices of Web sites operated by third parties that are linked to our sites. These links are meant for the user's convenience only. Links to third party sites do not constitute sponsorship, endorsement or approval by KOINSYA of the content, policies or practices of such third party sites. Once you have left a KOINSYA site via such a link, you should check the applicable privacy policy of the third party site.

   KOINSYA sites may also be linked to Web sites operated by companies affiliated with KOINSYA. Visitors to those sites should refer to their separate privacy policies and practices.

   Any violation of this Policy may result in suspension or termination of your access to the Service and/or access to end users’ personal and financial information (“End User Data”).

8. Account Deactivation

Once you stop using the Service in accordance with any applicable agreement you may have with us, you may deactivate your Account by following the instructions on the Site. We may also deactivate your Account if you have ceased using the Service for three months; your applicable agreement with us terminates or expires; or as reasonably necessary under applicable law. After your Account deactivation, we will deprovision your access to all End User Data associated with your integration.

Even after your Account deactivation, and to the extent permitted under applicable law, we may still retain any information we collected about you for as long as necessary to fulfill the purposes outlined in our privacy policy/statement, or for a longer retention period if required or permitted under applicable law.

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