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Privacy Policy

This Privacy Policy explains how Kulce Commodities Sociedad Anonima, together with its affiliated entities and subsidiaries (collectively referred to as “Kulce,” “we,” “our,” or “us”), collects, processes, stores, discloses, and safeguards personal information. It also outlines the rights and choices available to individuals regarding the handling of their information.

This Policy applies to information obtained through our products, services, digital platforms, and business operations, including our website located at www.kulce.io (the “Website”), any applications, partner integrations, third-party platforms utilizing our services, and our official social media channels (collectively, the “Services”).

Scope and Limitations of this Privacy Policy​

This Privacy Policy is intended solely to describe the data protection and privacy practices of Kulce. Where our Services are made available through third-party platforms, applications, websites, integrations, or other partner-operated environments, the collection and processing of information by such third parties remain subject to their own privacy policies and applicable notices. We encourage users to review the relevant privacy disclosures provided by those entities to better understand how their information is handled.

This Privacy Policy is not designed to govern the processing of personal information relating to employment or recruitment activities. Individuals applying for employment opportunities with Kulce should consult the applicable recruitment or candidate privacy notice for details regarding the collection, use, retention, and disclosure of their personal information during the hiring process.

In addition, information that has been irreversibly anonymized, aggregated, de-identified, or otherwise processed in a manner that does not reasonably permit the identification of a particular individual is not regarded as personal information for the purposes of this Privacy Policy.

1) Your Information and How We Collect It​

Kulce may collect personal information from a variety of sources in connection with the provision, operation, security, and improvement of the Services.

Information You Provide to Us​

We may collect information that you voluntarily provide when creating an account, completing verification procedures, communicating with us, or otherwise using the Services. Depending on the nature of the Services and applicable legal requirements, this information may include:

  • Identification and contact details, such as your name, date of birth, nationality, gender, telephone number, email address, and residential address;

  • Documentation and information used to verify your identity or place of residence, including government-issued identification documents and supporting verification records;

  • Financial and payment-related information, including bank account details and other information required to facilitate transactions or provide our Services;

  • Account credentials and account-related information, such as login details, account settings, balances, deposits, withdrawals, and transaction history;

  • Information relating to transactions conducted through the Services, including counterparties, amounts, dates, wallet addresses, and other transaction-related records;

  • Corporate or institutional information, where applicable, including information concerning legal entities, authorized representatives, directors, shareholders, and beneficial owners;

  • Any additional information you choose to provide through communications, support requests, surveys, feedback forms, or other interactions with us.

Information Collected Automatically​

When you access or use the Services, certain information may be collected automatically through technical means. This may include:

  • Device, browser, operating system, and network information;

  • IP address and general location data, such as country of access;

  • Usage data relating to your interactions with the Services;

  • Information collected through cookies and similar technologies, including preferences and personalization settings;

  • Technical and diagnostic information, such as system performance metrics, error reports, and access timestamps.

Information Obtained from Third Parties​

We may also obtain information from trusted third parties where necessary to provide the Services, comply with legal obligations, prevent fraud, or manage risk. Such sources may include:

  • Affiliates and group companies;

  • Financial institutions, liquidity providers, payment service providers, and business partners;

  • Identity verification, compliance, fraud prevention, AML, sanctions screening, and due diligence providers;

  • Public registries, government databases, sanctions lists, and other publicly available sources;

  • Blockchain networks and distributed ledger systems, from which transaction-related information may be obtained;

  • Other persons or organizations authorized by you to share information with us.

Optionality of Information​

You are generally free to decide whether to provide requested information. However, where certain information is required for regulatory, contractual, security, or operational purposes, failure to provide such information may limit or prevent access to certain features or Services.

Sensitive Personal Information​

Certain categories of information processed by Kulce may be classified as sensitive personal information under applicable laws. Where this occurs, such information will be collected, used, stored, and protected in accordance with applicable legal requirements and any additional safeguards required by law.

2) How and Why We Process Personal Information​

Kulce processes personal information for a variety of legitimate business, operational, legal, and regulatory purposes. The specific purposes for which personal information is used may vary depending on the nature of the relationship with Kulce, the Services being utilized, and applicable legal requirements.

In general, we use personal information to establish and maintain customer relationships, create and administer accounts, verify identities, facilitate transactions, process payments, provide customer support, and deliver the products and services requested by our users.

We also use personal information to operate, maintain, monitor, and improve our Services, develop new products and functionalities, analyze user interactions with our platform, and enhance the overall security, reliability, and performance of our systems.

Certain information may be processed for internal business purposes, including financial reporting, accounting, auditing, recordkeeping, business planning, operational management, and corporate governance activities.

Where permitted by applicable law, we may use personal information to communicate with users regarding service-related updates, important notices, product announcements, educational content, and marketing or promotional materials. We may also use information to better understand user preferences and improve the relevance of communications and user experiences.

As a regulated business, Kulce processes personal information to comply with applicable legal, regulatory, and compliance obligations. This may include conducting customer due diligence, Know Your Customer (“KYC”) and identity verification procedures, sanctions screening, Anti- Money Laundering (“AML”) and Counter-Terrorist Financing (“CTF”) controls, Travel Rule compliance, transaction monitoring, fraud prevention measures, risk assessments, and responding to lawful requests from regulatory authorities, law enforcement agencies, courts, or other governmental bodies.

Personal information may also be used to investigate suspicious activity, protect the integrity of our platform, detect and prevent fraud, cybersecurity incidents, unauthorized access, market abuse, or other unlawful activities, and to protect the rights, property, and security of Kulce, its users, business partners, and other stakeholders.

In addition, we may process personal information where necessary to establish, exercise, or defend legal claims, enforce our agreements and policies, resolve disputes, and protect our legitimate business interests.

Where relevant, personal information may also be disclosed or transferred as part of a merger, acquisition, financing transaction, corporate restructuring, sale of assets, or other similar business transaction, subject to appropriate confidentiality and security safeguards.

Kulce relies on one or more lawful bases for processing personal information, including the performance of contractual obligations, compliance with legal and regulatory requirements, legitimate business interests, and, where required by applicable law, the consent of the individual concerned.

Where processing is based on consent, individuals may withdraw their consent at any time, subject to applicable legal restrictions. We will not process personal information for purposes that are materially incompatible with those described in this Privacy Policy unless otherwise permitted or required by law.

3) Disclosure of Personal Information​

Kulce may disclose personal information where necessary to operate its business, provide its Services, comply with legal obligations, protect its legitimate interests, or as otherwise permitted by applicable law.

Depending on the circumstances, personal information may be shared with:

  1. Affiliates and group companies within the Kulce organization; 2. Banking partners, payment service providers, custodians, liquidity providers, and other financial institutions involved in the provision of our Services; 3. Compliance, identity verification, AML/KYC, sanctions screening, cybersecurity, fraud prevention, analytics, cloud hosting, and other service providers that support our operations; 4. Regulatory authorities, courts, law enforcement agencies, tax authorities, self- regulatory organizations, and other governmental bodies where disclosure is required or permitted by law; 5. Professional advisers, auditors, insurers, brokers, and other consultants acting on our behalf; 6. Third parties participating in transaction monitoring, Travel Rule compliance, risk management, or fraud prevention activities; 7. Other parties authorized by you or to whom you direct us to disclose information.

Please note that certain blockchain-based transactions may involve information being recorded on public distributed ledger networks. As a result, wallet addresses, transaction

identifiers, timestamps, and other transaction-related information may become publicly accessible and cannot generally be altered or deleted.

We may also disclose personal information in connection with a merger, acquisition, financing, restructuring, sale of assets, or other corporate transaction. In such circumstances, personal information may be shared with prospective investors, purchasers, advisers, or counterparties for due diligence, evaluation, and transaction-completion purposes, subject to appropriate confidentiality and security measures.

4) How Long We Keep Personal Information​

Kulce retains personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, provide its Services, manage its business operations, and satisfy applicable legal, regulatory, accounting, compliance, and reporting requirements.

The length of time for which personal information is retained depends on the nature of the information, the purpose for which it was collected, and the legal or operational obligations applicable to Kulce. In certain circumstances, personal information may be retained for longer periods where necessary to comply with regulatory requirements, respond to lawful requests from competent authorities, resolve disputes, investigate potential misconduct, prevent fraud, or establish, exercise, or defend legal claims.

As a business operating in the digital asset and financial services sector, Kulce is subject to various recordkeeping, compliance, and regulatory obligations, including requirements relating to Anti-Money Laundering (“AML”), Know Your Customer (“KYC”), sanctions compliance, transaction monitoring, and other applicable legal frameworks. Accordingly, certain records and personal information may be retained for the minimum periods required by applicable laws and regulations, even after a customer relationship has ended.

Once retention is no longer necessary, personal information will be securely deleted, anonymized, or otherwise disposed of in accordance with applicable legal requirements and internal data governance practices.

5) How We Protect Your Information​

Kulce maintains administrative, technical, and organizational security measures designed to protect personal information against unauthorized access, disclosure, alteration, loss, misuse, or destruction. These measures are intended to support the confidentiality, integrity, availability, and security of the information processed through our Services.

We regularly review and enhance our security practices in light of technological developments, operational requirements, and applicable legal and regulatory standards. Access to personal information is limited to authorized personnel and service providers who require such access for legitimate business purposes.

Despite our efforts to implement and maintain appropriate safeguards, no information technology system, network, or method of electronic transmission can be guaranteed to be completely secure. Accordingly, while Kulce takes reasonable steps to protect personal

information, we cannot guarantee the absolute security of any information transmitted to, from, or through our Services.

Users should also take appropriate precautions when sharing information online and recognize that communications transmitted over the internet may be subject to risks beyond our control.

6) International Data Transfers​

As Kulce operates internationally, personal information may be transferred to, stored, or processed in countries outside the jurisdiction in which it was originally collected, including countries that may have different data protection standards.

Where required by applicable law, Kulce implements appropriate safeguards to protect personal information during international transfers. Such safeguards may include reliance on adequacy decisions, contractual protections, or other legally recognized transfer mechanisms designed to ensure an adequate level of protection for personal information.

For individuals located in the European Economic Area (“EEA”), the United Kingdom, or other jurisdictions with specific cross-border transfer requirements, Kulce will take appropriate measures to ensure that international transfers are carried out in accordance with applicable data protection laws.

Additional information regarding the safeguards used for international data transfers may be requested by contacting us.

7) Your Privacy Rights​

Your Privacy Rights​

Depending on your jurisdiction and the applicable data protection laws, you may have certain rights in relation to the personal information that Kulce processes about you. These rights may be subject to legal limitations, exceptions, or verification requirements.

Where applicable, you may have the right to:

  • Request information regarding the personal information we collect, use, disclose, or otherwise process about you;

  • Access and obtain a copy of your personal information;

  • Request the correction or update of inaccurate or incomplete personal information;

  • Request the deletion of your personal information, subject to applicable legal and regulatory retention requirements;

  • Object to or request restrictions on certain processing activities;

  • Request the transfer of your personal information to you or another party in a structured and commonly used format, where technically feasible;

  • Withdraw consent at any time where processing is based on your consent; and

  • Submit a complaint to a competent data protection authority if you believe your rights have been violated.

To exercise any applicable privacy rights, you may contact us at info@kulce.io. Before responding to a request, we may take reasonable steps to verify your identity and, where applicable, the authority of any person acting on your behalf. We may also request additional information necessary to understand, evaluate, and process your request.

10) Your Privacy Preferences​

You may choose whether to provide certain personal information to Kulce. However, where specific information is required for regulatory, security, operational, or contractual purposes, failure to provide such information may limit your ability to access or use certain features of the Services.

You may also manage certain privacy preferences through your browser, device, or application settings. For example, you can configure your browser to restrict cookies or similar technologies, although doing so may affect the functionality of certain parts of the Services.

Location Data

If location-based features are available, you may control the collection of location information through your device or application settings. In most cases, location permissions can be modified, restricted, or disabled at any time through the settings of your device or operating system. Please refer to your device provider's instructions for further information on managing location preferences.

11) Cookies, Web Tracking, and Advertising​

Cookies, Analytics, and Tracking Technologies

Kulce and its service providers may use cookies, pixels, local storage technologies, and similar tools to support the operation, security, and functionality of the Services. These technologies help us understand how users interact with our platform, maintain user preferences, improve performance, enhance user experience, and analyze the effectiveness of our products, services, and communications.

Information collected through these technologies may include device information, browser information, usage patterns, pages visited, interactions with the Services, and other technical data. Such information may be used for analytics, security monitoring, performance optimization, and, where permitted by applicable law, marketing and advertising purposes.

Users may manage or restrict certain cookies and similar technologies through browser settings or other available consent management tools. Please note that disabling certain cookies may affect the availability or functionality of portions of the Services.

Our Services may contain links to third-party websites, applications, platforms, or content. Where you interact with such third parties, they may independently collect and process information in accordance with their own privacy practices. Kulce does not control and is not

responsible for the privacy, security, or data handling practices of third-party services. We encourage users to review the privacy policies and terms applicable to any third-party services they choose to access.

Browser Tracking Preferences

Kulce may use analytics and similar technologies to understand how users interact with the Services and to improve functionality and performance.

At this time, Kulce does not respond to browser-based “Do Not Track” signals or similar tracking preference mechanisms.

12) Important Notices​

Kulce's Services are intended solely for individuals who are at least 18 years of age. We do not knowingly collect, solicit, or process personal information from individuals under the age of 18. By accessing or using the Services, you confirm that you meet the applicable age requirement.

The Services may contain links to, or integrations with, websites, applications, platforms, or services operated by third parties. Such third-party services are independent from Kulce and are governed by their own terms, privacy policies, and data handling practices.

Kulce does not control and is not responsible for the content, security, availability, or privacy practices of any third-party services. Users who choose to access third-party services do so at their own discretion and should review the applicable privacy notices and terms before providing any personal information.

13) Changes to this Privacy Policy​

Kulce may revise or update this Privacy Policy from time to time to reflect changes in our business practices, legal requirements, technologies, or services. Any updated version will be published on our website and will become effective as of the date indicated in the revised Privacy Policy.

Where required by applicable law or where material changes are made, we may provide additional notice through the Services, by email, or through other appropriate communication channels.

We encourage users to review this Privacy Policy periodically to stay informed about how we collect, use, and protect personal information. Continued use of the Services following the publication of an updated Privacy Policy constitutes acknowledgment of the revised terms, to the extent permitted by applicable law.