FAIR PROCESSING NOTICE

About this notice

This fair processing notice (“Notice”) explains how and why The Alternatives Group Limited t/a AssetTribe (a limited company with a registered address 1 Brandon Road, London N7 9AA and ICO registration no. 00019742006) (also referred to as “AssetTribe”, “we”, “our” and “us”) uses personal data about those individuals that either:

• use our services (“Services”)
• buy or sell fund units and/or tokenised assets (“Transactions”);
• communicate with us in relation to Transactions and other related matters; or
• use our platform at assettribe.io (the “Website”) or our desktop or mobile application in relation to the above;
• interact with us via email or social media;

(in each case, referred to as “you”).

1. You should read this Notice, so that you know what we are doing with your personal data. Please also read any other privacy notices that we make available to you, that might apply to our use of your personal data in specific circumstances outside the scope of this Notice, which primarily concerns our processing of your personal data in relation to or in connection with our provision of Services or in relation to Transactions.

Our data protection responsibilities

1. In this notice we refer to the following terms, which have the following meanings:

• “Personal data” is any information that relates to an identifiable natural person. Your name, address and contact details are all examples of your personal data, if they identify you.
• The term “process” means any activity relating to personal data, including, by way of example, collection, storage, use, consultation and transmission.
• Asset Tribe is a so-called “controller” of your personal data. This means that we make decisions about how and why we process your personal data and, because of this, we are responsible for making sure it is used in accordance with applicable data protection laws.

What types of personal data do we collect and where do we get it from?

1. We collect your personal data from various sources. The table below sets out the different types of personal data that we collect and the sources we collect it from. Typically, you provide us with personal data directly when you communicate with us (including via the Website) and when you seek to engage in a Transaction. We also obtain some personal data from other sources, and create some personal data ourselves, as set out in the table.
2. Some of the data we will ask you to provide is so that we can create an account for you.

1. We do not seek to hold sensitive (special categories of) personal data, and will destroy it in a timely manner if received.
2. Please be aware that we cannot communicate with you or administer the Transactions and Services with us without your personal data. Where we don’t need your personal data, we will make this clear, for instance we will explain if any forms you are required to complete are optional or contain sections that can be left blank.

If any of the personal data you have given to us changes, such as your contact details, please inform us without delay by contacting info@assettribe.io.

What do we do with your personal data, and why?

1. We process your personal data for particular purposes in connection with the Services or your Transactions or engagement with us, and the management and administration of our business.
2. We are required by UK and EU law to always have a so-called “lawful basis” (i.e. a reason or justification) for processing your personal data. The table below sets out the purposes for which we process your personal data and the relevant lawful basis on which we rely for that processing.
3. Please note that where we have indicated in the table that our processing of your personal data is either:
   
   • necessary for us to comply with a legal obligation; or
   • necessary for us to take steps, at your request, to potentially enter into a contract (including for Transactions) with you, or to perform it,
4. if you choose not to provide the relevant personal data to us, we may not be able to process your Transactions or otherwise provide our Services to you.

1. We may also convert your personal data into statistical or aggregated form to better protect your privacy, or so that you are not identified or identifiable from it.  Anonymised data cannot be linked back to you.  We may use it to conduct research and analysis, including to produce statistical research and reports.  For example, to help us understand the geographical spread of our customers.
2. Marketing
3. We will only use your data for marketing and promotional purposes if you have opted in to receive this. Where you have opted in, you have the right to opt out at any time by opting out in the app or by informing us of your unsubscribe request by emailing as at info@assettribe.io.

Who do we share your personal data with, and why?

1. Sometimes we need to disclose your personal data to other people, both to internal third parties such as our officers, representatives and contractors, and external providers such as specialist IT providers, communications providers and KYC partners.
2. External third parties
3. From time to time we may ask third parties to carry out certain business functions for us, such as software development or IT support. These third parties will process your personal data on our behalf. In providing the services they may act as our processor (as in the case of our server hosting providers) or as a controller in their own right (as is sometimes the case with our KYC partner). We will disclose your personal data to these parties so that they can perform those functions. Before we disclose your personal data to these third parties, we will seek to ensure that they have appropriate security standards in place to protect your personal data.
4. We have set out below a list of the categories of recipients with whom we are likely to share your personal data:
   • (a) Specialist IT providers for software development, IT support and system administration and management;
   • (b) cloud platform and data hosting providers based in the EU;
   • (c) communications provider based in the US and EU;
   • (d) anti-money laundering and background checking vendors and other compliance providers (based in the UK and US);
   • (e) analytics providers based in the US;
   • (f) other parties involved in your transactions.
5. In certain circumstances, we will also disclose your personal data to third parties who will receive it as controllers of your personal data in their own right, where:

1. 1. we buy, sell or transfer our business (or part of it) in connection with a share or asset sale or outsourcing, we may disclose or transfer your personal data to the prospective seller, buyer or transferor and their advisors; and
   2. we need to disclose your personal data in order to comply with a legal obligation, to enforce a contract or to protect the rights, property or safety of our employees, customers, or others.

Where in the world is your personal data transferred to?

1. We may transfer your personal data to external recipients that are established in jurisdictions other than your own as per the section above regarding data sharing.
2. Please be aware that the data protection laws in some jurisdictions outside the UK and European Economic Area (EEA) may not provide the same level of protection to your personal data as is provided to it under the laws in your jurisdiction.
3. We always seek to ensure that adequate protections are put in place when transferring your personal data from within to outside the UK or EEA and to comply with our legal obligations regarding such transfers. For more information regarding the transfers undertaken by us and the protections put in place, please contact us using the details set out at the end of this Notice.

How do we keep your personal data secure?

1. We will take specific steps (as required by applicable data protection laws) to ensure we take appropriate security measures to protect your personal data from unlawful or unauthorised processing and accidental loss, destruction or damage.

How long do we keep your personal data for?

1. We will only retain your personal data for a limited period of time (for example, for so long as is necessary to provide Services to you, retain records of Transactions and the tokenised assets or fund units you have plus a reasonable period of time after that, based on the factors below).  This will depend on a number of factors, including:

1. • any laws or regulations that we are required to follow;
   • whether we are in a legal or other type of dispute with each other or any third party;
   • the type of information that we hold about you; and
   • whether we are asked by you or a regulatory authority to keep your personal data for a valid reason.

How do we communicate with you?

1. We will use your personal data to communicate with you:

• • in relation to any Transaction you undertake and any Services you register for;
  • to administer our relationship with you;
  • to respond to any questions or complaints that you may have; and
  • to invite you to take part in market research or request feedback on our Services.

From time to time and with your consent (where required), we will provide you with information about assets, Services, promotions and/or offers which may be of interest to you.

Where you have subscribed to our online newsletter, we will also provide a copy by email.

Please note that you may opt-out of receiving the newsletter and any other marketing materials that we send you, by unsubscribing.

Cookies

1. When you visit the Website, we generate one or more “cookies.”
2. If you do not agree to our use of cookies, you should set your browser settings accordingly or not use the Website. Please be aware that if you disable the cookies that we use, this may impact your user experience while using the Website.
3. The table below summarizes the different types of cookie we use on the Website, together with their respective purpose and duration (i.e. how long each cookie will remain on your device).
4. Two types of cookies may be used on the Website – “session cookies” and “persistent cookies”. Session cookies are temporary cookies that remain on your device until you leave the Website. A persistent cookie remains on your device for much longer or until you manually delete it (how long the cookie remains on your device will depend on the duration or “lifetime” of the specific cookie and your browser settings).
5. Cookies used on the Website:
   
   

What are cookies?

1. Cookies are files or pieces of information that may be stored on your computer (or other internet-enabled devices, such as a smartphone or tablet) when you visit the Website. A cookie will usually contain the name of the website from which the cookie has come from, the “lifetime” of the cookie (i.e. how long it will remain on your device) and a value, which is usually a randomly generated unique number.

What do we use cookies for?

1. We use cookies to make the Website easier to use and to better tailor our web presence and products to your interests and needs. Cookies may also be used to help speed up your future activities and experience on the Website. We also use cookies to compile anonymous, aggregated statistics that allow us to understand how people use our web properties and to help us improve web structure and content. We cannot identify you personally from this information.
2. How can I control or delete cookies?
3. Most internet browsers are initially set up to automatically accept cookies. You can change the settings to block cookies or to alert you when cookies are being sent to your device. There are a number of ways to manage cookies. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings.
4. If you disable the cookies that we use, this may impact your experience while on the Website. For example, you may not be able to visit certain areas of the Website.
5. If you use different devices to view and access the Website (e.g. your computer, smartphone, tablet etc.), you will need to ensure that each browser on each device is adjusted to suit your cookie preferences.

What are your privacy rights and how can you exercise them?

1. Where you are based in the UK or EEA and our processing of your personal data is based on your consent (please see the tables above), you have the right to withdraw your consent at any time. If you do decide to withdraw your consent we will stop processing your personal data for that purpose, unless there is another lawful basis we can rely on – in which case, we will let you know.
2. Where our processing of your personal data is based on the legitimate interests (please see the tables above), you can object to this processing at any time. If you do this, we will need to show either a compelling reason why our processing should continue, which overrides your interests, rights and freedoms or that the processing is necessary for us to establish, exercise or defend a legal claim.
3. Where we are processing your personal data for direct marketing purposes, you have the right to object to that processing.
4. You have the right to (subject to applicable laws and certain limitations):
   • access your personal data and to be provided with certain information in relation to it, such as the purpose for which it is processed, the persons to whom it is disclosed and the period for which it will be stored;
   • require us to correct any inaccuracies in your personal data without undue delay;
   • require us to erase your personal data;
   • require us to restrict processing of your personal data;
   • receive the personal data which you have provided to us, in a machine readable format, where we are processing it on the basis of your consent or because it is necessary for your contract with us (please see the tables above) and where the processing is automated; and
   • object to a decision that we make which is based solely on automated processing of your personal data (however, we do not currently conduct any such decision making).
5. If you wish to exercise any of these rights please contact info@assettribe.io in the first instance.
6. You may also have the right to lodge a complaint with the relevant data protection regulator (for example the Information Commissioner’s Office in the UK).

California Statutory Rights.

Under California Civil Code sections 1798.83 – 1798.84, California residents who have an established business relationship with us are entitled to ask us for a notice describing what categories of personal customer information we share with third parties for those third parties’ direct marketing purposes and to opt-out of sharing your personal information with third parties for direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties with which it was shared, along with their names and addresses. If you choose to opt-out or would like a copy of this notice, please submit a written request to the following address: The Alternatives Group Limited, 1 Brandon Road, London N7 9AA, United Kingdom. Please allow 30 business days for a response.

• Updates to this Notice

1. We may update this notice from time to time to reflect changes to the type of personal data that we process and/or the way in which it is processed. We will update you on material changes to this notice. We also encourage you to check this notice on a regular basis – updated copies can be found here.
   
   

• Where can you find out more?

1. If you want more information about any of the subjects covered in this Notice or if you would like to discuss any issues or concerns with us, you can contact info@assettribe.io.