Privacy Policy

Emerald Wallet (defined below under “Our relationship to you”) is committed to protecting the privacy of visitors to our websites and our customers. This Privacy Policy describes how we handle your personal data when you access our services, which include our content on the websites located at EmeraldWallet.com, app. EmeraldWallet.com, or any other websites, pages, features, or content we own or operate (collectively, the “Site(s)”), or any Emerald Wallet API or third-party applications relying on such an API, and related services (referred to collectively hereinafter as “Services”)

If you have any questions about this Policy, please send them to support@emeraldalletapp.com

We may modify this Privacy Policy from time to time. Please check the date at the top or bottom of this notice to see when it was last updated.

Personal information means any data which relates to a living individual who can be identified from that data, or from that data and other information, which is in the possession of, or is likely to come into the possession of, Emerald Wallet (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Emerald Wallet or any other person in respect of an individual. The definition of personal information depends on the relevant law applicable for your physical location.

This includes information you provide to us in order to establish an account and access our Services. This information is either required by law (e.g., to verify your identity), necessary to provide the requested services (e.g., you will need to provide your bank account number if you would like to link that account to Emerald Wallet) or is relevant for our legitimate interests described in greater detail below. The nature of the Services you are requesting will determine the kind of personal information we might ask for, but may include:

• Identification Information: Full name, date of birth, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email.
• Formal Identification Information: Government issued identity document such as Passport, Driver’s License, National Identity Card, State ID Card, Tax ID number, passport number, driver’s license details, national identity card details, visa information, and/or any other information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws.
• Institutional Information: Employer Identification number (or comparable number issued by a government), proof of legal formation (e.g., Articles of Incorporation), personal identification information for all material beneficial owners.
• Financial Information: Bank account information, primary account number (PAN), transaction history, trading data, and/or tax identification.
• Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.
• Employment Information: Office location, job title, and/or description of role.
• Correspondence: Survey responses, information provided to our support team or user research team.

This includes information we collect automatically, such as whenever you interact with the Sites or use the Services. This information helps us address customer support issues, improve the performance of our Sites and applications, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:

• Online Identifiers: Geo location/tracking details, operating system, browser name and version, and/or personal IP addresses.
• Usage Data: Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies.

This includes information we may obtain about you from third party sources. The main types of third parties we receive your personal information from are:

• Public Databases, Credit Bureaus & ID Verification Partners in order to verify your identity in accordance with applicable law. ID verification partners such as Experian use a combination of government records and publicly available information about you to verify your identity. Such information may include your name, address, job role, public employment profile, credit history, status on any sanction’s lists maintained by public authorities, and other relevant data.
• Blockchain Data to ensure parties using our Services are not engaged in illegal or prohibited activity and to analyze transaction trends for research and development purposes.
• Marketing Partners & Resellers so that we can better understand which of our Services may be of interest to you.

In addition to the categories of personal information described above, Emerald Wallet will also process anonymized information and data that is not processed by reference to a specific individual. Types of data we may anonymize include transaction data, clickstream data, performance metrics and fraud indicators

We may use your information in the following ways and for the following purposes:

1) To maintain legal and regulatory compliance Emerald Wallet needs to process your personal information in order to comply with antimoney laundering and security laws. In addition, when you seek to link a bank account to your Emerald Wallet account, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk as required under applicable law. We also process your personal information in order to help detect, prevent, and mitigate fraud and abuse of our Services and to protect you against account compromise or funds loss. If you do not provide personal information required by law, we will have to close your account.

2) To provide Emerald Wallet’s Services We process your personal information to provide Services to you. For example, when you want to store funds on our platform, we require certain information such as your identification, contact and payment information. Third parties that we use such as identity verification services may also access and/or collect your personal information when providing identity verification and/or fraud prevention services. In addition, we may need to collect fees based on your use of our Services. We collect information about your account usage and closely monitor your interactions with our Services. The consequences of not processing your personal information for such purposes is the termination of your account.

3) To provide communications and customer services According to your preferences and in compliance with applicable law, we may send you marketing communications to inform you about events, to deliver targeted marketing and to share promotional offers. If you are a new customer, we will contact you by electronic means for marketing purposes only if you have consented to such communication. If you do not want us to send you marketing communications, please go to your account settings to opt-out or submit a request via support@Emerald Walletapp.com We may send you service updates regarding administrative or account-related information, security issues, or other transaction-related information. These communications are important to share developments relating to your account that may affect how you can use our Services. You cannot opt-out of receiving critical service communications. We also process your personal information when you contact us to resolve any questions, disputes, collect fees, or to troubleshoot problems. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.

4) In our legitimate business interests Sometimes the processing of your personal information is necessary for our legitimate business interests, such as:

• quality control and staff training;
• to enhance security, monitor and verify identity or service access, and to combat spam or other malware or security risks;
• research and development purposes;
• to enhance your experience of our Services and Sites; or
• to facilitate corporate acquisitions, mergers, or transactions.

We rely on legal bases for processing your information under the relevant data protection legislation. These bases mean we will only process your data where we are legally required to, where processing is necessary to perform any contracts, we entered with you (or to take steps at your request prior to entering into a contract with you), for our legitimate interests to operate our business, to protect Emerald Wallet’s or your property rights, or where we have obtained your consent to do so. We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission.

We allow your personal information to be accessed only by those who require access to perform their work and share it only with third parties who have a legitimate purpose for accessing it. Emerald Wallet will never sell or rent your personal information to third parties without your explicit consent. We will only share your personal information with the following types of third parties:

• Identity verification services to prevent fraud. This allows Emerald Wallet to confirm your identity by comparing the information you provide us to public records and other third-party databases.
• Financial institutions which we partner with to process payments you have authorized.
• Service providers and professional advisors under contract who help with parts of our business operations. Our contracts require these service providers to only use your information in connection with the services they perform for us and prohibit them from sharing your information with anyone else. • Companies or other third parties in connection with business transfers or bankruptcy proceedings.
• Companies or other entities that purchase Emerald Wallet assets.
• Law enforcement, regulators, or any other third parties when we are compelled to do so by applicable law or if we have a good faith belief that such use is reasonably necessary, including to: protect the rights, property, or safety of Emerald Wallet, Emerald Wallet customers, third party, or the public; comply with legal obligations or requests; enforce our terms and other agreements; or detect or otherwise address security, fraud, or technical issues.

If you authorize one or more third-party applications to access your Emerald Wallet Services, then information you have provided to Emerald Wallet may be shared with those third parties. A connection you authorize or enable between your Emerald Wallet account and a non-Emerald Wallet account, payment instrument, or platform is considered an “account connection.” Unless you provide further permissions, Emerald Wallet will not authorize these third parties to use this information for any purpose other than to facilitate your transactions using Emerald Wallet Services. Please note that third parties you interact with, should have their own privacy policies and Emerald Wallet is not responsible for their operations or their use of data they collect.

Examples of account connections include:

• Merchants: If you use your Emerald Wallet account to conduct a transaction with a third-party merchant, the merchant may provide data about you and your transaction to us.
• Your financial services providers: For example, if you send us funds from your bank account, your bank will provide us with identifying information in addition to information about your account in order to complete the transaction.

Electronic Fund Transfers (EFTs) and Account Balances. Promotional Software Solutions, LLC d.b.a. Emerald
Wallet partners with financial services software company Sila Inc. (Sila) and banking services provider Evolve
Bank & Trust (Evolve), member FDIC, to offer you electronic fund transfers and provide you with an Account. By
registering for our platform, linking your external bank account, and authorizing any electronic payment, you
authorize us to share your identity and banking information with Sila and Evolve to support your Account. You
also agree to the terms and conditions of Sila’s privacy policy,
https://www.silamoney.com/legal/sila-privacy-policy, and Evolve’s privacy policy,
https://www.silamoney.com/legal/evolve-privacy-policy (the “Partner Privacy Terms”). It is your responsibility to
ensure the data you provide to us is accurate and complete, which is necessary for our partners to process
electronic fund transfers on your behalf and provide you with continued access to the Account. The Partner
Privacy Terms may be modified from time to time, and the governing versions are incorporated by reference as
part of this Privacy Policy. IT IS YOUR RESPONSIBILITY TO READ AND UNDERSTAND THE PARTNER PRIVACY TERMS
BECAUSE THEY CONTAIN TERMS AND CONDITIONS CONCERNING YOUR ACCOUNT WITH US, INCLUDING BUT
NOT LIMITED TO USE OF YOUR PERSONAL INFORMATION.

Emerald Wallet implements and maintains reasonable measures to protect our information and information systems. Customer files are protected with safeguards according to the sensitivity of the relevant information. Reasonable controls (such as restricted access) are placed on our computer systems. Physical access to areas where personal information is gathered, processed, or stored is limited to authorized employees.

We may store and process all or part of your personal and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers, in the US and elsewhere in the world where our facilities or service providers are located. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.

As a condition of employment, Emerald Wallet’s employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive personal information is limited to those employees who need to it to perform their roles. Unauthorized use or disclosure of confidential customer information by an Emerald Wallet employee is prohibited and may result in disciplinary measures.

When you contact an Emerald Wallet employee about your file, you may be asked for some personal details. This type of safeguard is designed to ensure that only you, or someone authorized by you, has access to your file. You also play a vital role in protecting your own personal information. When registering with our Services, choose a password of sufficient length and complexity, don’t reveal it to any third parties and immediately notify us if you become aware of any unauthorized access to or use of your account.

How long we hold your personal information for will vary. The retention period will be determined by the following criteria:

• the purpose for which we are using your personal information – we will need to keep the information for as long as is necessary for that purpose; and
• legal obligations – laws or regulation may set a minimum period for which we have to keep your personal information.

If you have further questions about our data retention practices, please contact us at support@emeraldwalletapp.com If we anonymize your personal information so that it can no longer be associated with you, it will no longer be considered personal information, and we can use it without further notice to you.

We do not knowingly request to collect personal information from any person under the age of 18. If a user submitting personal information is suspected of being younger than 18 years of age, Emerald Wallet will require the user to close his or her account and will not allow the user to continue using our Services. We will also take steps to delete the information as soon as possible. Please notify us if you know of any individuals under the age of 18 using our Services so we can take action to prevent access to our Services.

Depending on applicable law of where you reside, you may be able to assert certain rights related to your personal information.

These rights include:

• the right to obtain information regarding the processing of your personal information and access to the personal information which we hold about you;
• the right to withdraw your consent to the processing of your personal information at any time. Please note, however, that we may still be entitled to process your personal information if we have another legitimate reason for doing so. For example, we may need to retain personal information to comply with a legal obligation;
• in some circumstances, the right to receive some personal information in a structured, commonly used, and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided directly to Emerald Wallet;
• the right to request that we rectify your personal information if it is inaccurate or incomplete;
• the right to request that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information, but we are legally entitled to retain it;
• the right to object to, or request that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request; and
• the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details listed below. Further information about your rights may be obtained by contacting the supervisory data protection authority located in your jurisdiction.

If you are a resident of the State of California, under the California Consumer Privacy Act (CCPA), you have the right to request information on how to exercise your disclosure choice options from companies conducting business in California. Specifically:

• Exercising the Right to Know. You may request, up to twice in a 12-month period, the following about the personal information collected on you in the past 12 months: – the categories and specific pieces of personal information we have collected; – the categories of sources from which we collected the personal information; o the business or commercial purpose for which we collected it; -the categories of third parties with whom we shared the personal information; and – the categories of personal information about you that we disclosed for a business purpose.
• Exercising the right to delete. You may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law.
• Exercising the right to opt-out from a sale. You may request to opt out of any “sale” of your personal information that may take place.
• Non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights. To submit a request to exercise any of the rights described above, you may contact Emerald Wallet either via email to support@EmeraldWalletapp.com or contact us via postal mail, proper postage prepaid, at:Emerald WalletAttn: Your California Privacy Rights722 Cedar Point Blvd, #34, Cedar Point, NC 28584.

Please indicate your preference as to how you would like us to respond to your request (i.e., email or postal mail). All requests sent via postal mail must be labeled “Your California Privacy Rights” on the envelope or postcard and clearly stated on the actual request. For all requests, please include your name, street address (if you would like a response via postal mail), city, state, and zip code. We may need to verify your identity before responding to your request, such as verifying that the email address or contact information from which you send the request matches your email address or contact information that we have on file. Authentication based on a government-issued and valid identification document may be required. We will not accept requests via telephone or fax. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, please contact us at support@emeraldwalletapp.com, or by writing to us at the Emerald Wallet entity addresses provided above.

Privacy Policy last updated: January 19, 2022

This Consumer Privacy Notice applies to you if you are an individual who resides in the United States and uses Emerald Wallet’s services for your own personal, family or household purposes.

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect, and share depends on how you use our services. This information can include, but is not limited to:

• Social Security number, or driver’s license number
• Bank account information, trading data, or transaction history
• Identification information such as your name, date of birth, nationality, or signature

When you are no longer our customer, we continue to share your information as described in this notice.

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Emerald Wallet chooses to share; and whether you can limit this sharing.

Emerald Wallet

How does Emerald Wallet protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does Emerald Wallet collect my personal information?

We collect your personal information, for example, when you: • Create an account with Emerald Wallet

• Place or complete an order with Emerald Wallet
• Use your debit or credit card or any other permissible payment method to purchase or sell digital currency

We also collect your personal information from others, such as from affiliates or other companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only:

• Sharing for affiliates’ everyday business purposes—information about your creditworthiness
• Affiliates from using your information to market to you
• Sharing for non-affiliates to market to you State laws and individual companies may give you additional rights to limit sharing.

See below for more on your rights under state law.

Affiliates – Companies related by common ownership or control. They can be financial and non-financial companies.

Non-affiliates – Companies not related by common ownership or control. They can be financial and non-financial companies.

Joint Marketing – A formal agreement between nonaffiliated financial companies that together market financial products or services to you.