Who we are?

Minter One Limited ("we", "our", or "us") may process certain personal data about you, depending on the scope of your specific relationship with us. This processing of personal data is regulated under the General Data Protection Regulation (2016/679) ("GDPR"). We are responsible as controller of your personal data for these purposes.

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Who does this Privacy Notice cover?

This Privacy Policy applies to the following circumstances:

1. personal data processed when you visit and use our website ("Website"); and
2. personal data processed to service our potential and existing customers ("Customers").

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What personal data do we collect?

Website

When you visit our Website, we collect limited personal data, including:

• information about your computer or device, including browser type and settings;
• log data — the webpage you visited before arriving at our site, pages visited on our site, time spent on those pages, IP address, access times and dates, and other usage statistics;
• history of interaction with our webpages, including traffic data relating to your internet connection; and
• other data that does not directly identify you, such as actions taken on our Website.

Providing your data is optional, but may be necessary for certain services or to qualify your suitability as a potential customer.

Customers

As part of customer onboarding, we collect the following personal data on directors and ultimate beneficial owners of the relevant legal entity:

• full name;
• date of birth;
• passport number;
• nationality;
• contact number;
• email address;
• occupation;
• correspondence and residential address;
• security credentials;
• professional data; and
• identification documents and their attached personal data.

Throughout the business relationship, we also collect:

• account activity, including payment instructions;
• communications with our staff; and
• usage of online portals.

Personal data from other sources

We may receive personal data about your directors and ultimate beneficial owners from third-party sources, including:

• credit information and credit references;
• criminal background checks; and
• legal and compliance checks.

This information is used to check fitness and probity, detect possible fraudulent activity, comply with legal obligations, and improve our service. We will seek your explicit consent before any credit search is performed.

Technologies used

Our Website uses cookies and similar technologies. Cookies are small files stored on your device that help us understand how visitors use the Website. Session cookies are deleted after your session ends; persistent cookies remain until their expiration date or until deleted manually.

Most browsers accept cookies by default. You may adjust your browser settings to reject cookies, though this may affect the functionality of the Website.

How do we use personal data?

Website

We use personal data collected through the Website to:

• communicate with you regarding support services and provide critical service updates;
• enable you to register for our services;
• provide technical and customer support; and
• improve our Website and services.

Customers

We use personal data collected during onboarding and the business relationship to:

• identify you and manage any accounts you hold with us;
• comply with regulatory and legal obligations;
• process payment instructions;
• send contract notes; and
• conduct statistical and behavioural analysis for service improvement.

We may monitor and record communications such as emails for quality assurance, training, fraud prevention, and compliance purposes.

Who your personal data may be shared with

We may share your personal data with:

• agents, depending on your requested products and services;
• contractors and service providers that support our day-to-day operations, including identity verification providers, secure document transfer services, and compliance consultants;
• law enforcement agencies in connection with any investigation to help prevent unlawful activity;
• legal representatives and consultants where expert advice is required; and
• processors that maintain our IT systems.

Personal data is never sold or passed to third parties for the purpose of marketing services not offered by us.

Legal basis for processing

We collect and use personal data:

• where necessary to provide a service or product you have requested, or to perform a contract with you;
• where necessary to comply with a legal obligation;
• where we have a legitimate interest that is not overridden by your data protection rights; and
• where you have given your consent, which you may withdraw at any time.

How long your personal data will be kept

We retain personal data in line with our Record Keeping Policy for as long as necessary to perform the activities described in this Privacy Policy. We may retain data for longer periods where required by legal or regulatory obligations, or to prevent fraud and financial crime. Where retention is no longer required, we will destroy, delete, or anonymise the data.

Keeping your personal data secure

We store personal data in a secure environment and have appropriate technical and organisational measures in place to prevent unauthorised access, loss, or misuse, including encryption and access controls. Those processing your personal data do so only in an authorised manner and are subject to a duty of confidentiality.

We have procedures in place to address suspected data security breaches and will notify you and any applicable regulator where we are legally required to do so.

Whilst we use all reasonable efforts to secure your personal data, you acknowledge that transmission of data over the internet is not entirely secure and we cannot guarantee the security of data transmitted to us.

Transfers of your personal data outside of the EEA

Your personal data may be transferred to and stored in locations outside the European Economic Area ("EEA"), including to service providers located in the British Virgin Islands and the United Kingdom. We ensure that all such transfers are subject to appropriate safeguards in accordance with applicable data protection law, which may include standard contractual clauses or other lawful transfer mechanisms. We will only share personal data with those who have the right to access it.

Marketing

We may contact you with information about products, services, and developments that may be of interest to you. We will ask for your consent before sending marketing communications and you may withdraw consent at any time by contacting us using the details below.

Your rights

Under applicable data protection law, you have the following rights:

• Right of access — to request copies of your personal data and information about how we process it.
• Right to rectification — to request correction of inaccurate or incomplete personal data.
• Right to erasure — to request deletion of your personal data, subject to certain conditions.
• Right to restrict processing — to request that we limit how we use your personal data, subject to certain conditions.
• Right to object — to object to our processing of your personal data.
• Right to data portability — to request transfer of your personal data to another organisation or directly to you, subject to certain conditions.

We will respond to any request within one month. To exercise any of these rights, please contact us using the details below.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will notify users of material changes by email (where you have opted to receive emails) or by a notice on the Website. Please check this page periodically for the most current version.

Contacting us

If you have any questions, concerns, or complaints about this Privacy Policy or the personal data we hold about you, please contact us at:

Email: legal@mxon.co

Minter One Ltd Rodus Building, P.O. Box 3093 Road Town, Tortola VG1110 British Virgin Islands

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