Privacy Statement - BasicEx

Last Updated: September 29, 2022

BasicEx ('BasicEx,' 'we,' or 'us') is committed to protecting the privacy of our customers, and we take our data protection responsibilities very seriously.

This Privacy Statement describes how BasicEx collects and processes your personal information through the BasicEx website and applications that reference this Privacy Statement. BasicEx refers to the BasicEx website (including but not limited towww.basicex.com), mobile applications, clients, mini-programs, and other applications developed to provide BasicEx services, including independently operated platforms, websites, and clients within the ecosystem. The term 'BasicEx Operator' refers to the parties operating BasicEx, including but not limited to legal entities, non-legal entities, and teams responsible for providing BasicEx services. The term 'BasicEx' used in this Privacy Statement includes BasicEx Operators.

This Privacy Statement applies to all personal information processing activities carried out by us on the platforms, websites, and departments of BasicEx and BasicEx Operators.

If you are a customer or user of our services, this Privacy Statement applies in conjunction with any business terms and other contractual documents, including but not limited to any agreements we may enter into with you.

If you are not a stakeholder, customer, or user of our services but are using our website, this Privacy Statement also applies to you along with our Cookie Statement.

Therefore, this notice should be read together with our Cookie Notice, which provides more detailed information about the cookies we use on the website. Our Cookie Notice can be accessedhere.

1. BasicEx and Your Relationship

Hola Limited is a company registered at 2004 N Wahsatch Ave, Colorado Springs, and is the data controller for the personal information collected when providing BasicEx services globally.

However, depending on your lawful residence, certain other BasicEx entities may be involved in processing activities necessary for providing services to you, such as understanding your Know Your Customer ('KYC') activities. For example, if you reside in France, BasicEx France SAS will be responsible for conducting KYC checks. These BasicEx entities may act as controllers of your personal information and use this information in accordance with this Privacy Statement.

2. What Personal Information Does BasicEx Collect and Process? Why Does BasicEx Need to Process My Personal Information? What is the Legal Basis for BasicEx's Use of Personal Information?

• What Personal Information Does BasicEx Collect and Process?

  - Email address;

  - Name;

  - Gender;

  - Date of birth;

  - Home address;

  - Phone number;

  - Nationality;

  - Device identifier;

  - Your video recordings and photos;

  - Transaction information;

  - Internet Protocol (IP) address used to connect your computer to the internet;

  - Login name, email address, password, and location of your device or computer;

  - BasicEx service metrics (such as occurrences of technical errors, your interaction with service features and content, and your preference settings);

  - Version and timezone settings;

  - Transaction history;

  - Information from other sources: We may receive information about you from other sources, such as credit history information from credit bureaus;

  - Information about your activities, which we may process for marketing and advertising purposes related to your behavior and activities.

• Why Does BasicEx Need to Process My Personal Information?

  - Transaction services: We use your personal information to process your orders and communicate with you about orders and services;

  - Communication with you: We use your personal information to communicate with you about BasicEx services;

  - We collect and process identity information and sensitive personal data (see Section One), to comply with Know Your Customer ('KYC') obligations imposed by applicable laws and regulations related to anti-money laundering;

  - Providing, troubleshooting, and improving BasicEx services: We use your personal information to provide features, analyze performance, fix errors, and enhance the availability and effectiveness of BasicEx services.

  Fraud prevention and credit risk: We process personal information to prevent and detect fraudulent and abusive behavior, protecting the safety of our users, BasicEx services, and others. We may also use scoring methods to assess and manage credit risk.

  Legal obligations; compliance with our legal obligations under applicable laws and regulations and anti-money laundering laws and regulations.

  Our legitimate interests and the interests of our users, such as when we detect and prevent fraud and abuse to protect the safety of our users, ourselves, or others;

  - Improving our services: We process personal information to improve our services and provide you with a better user experience;

  - Recommendations and personalization: We use your personal information to recommend features and services that you may be interested in, determine your preferences, and provide you with a personalized BasicEx service experience;

• What is the Legal Basis for BasicEx's Use of Personal Information?

  When we provide products or services to you or communicate with you about these products or services,Contractual performance;. This includes our use of your personal information to accept and process orders and handle payments.

  Legal obligations;Compliance with our legal obligations under applicable laws and regulations and anti-money laundering laws and regulations.

  When we seek your consent to process your personal information for specific purposes communicated to you, your consent is obtained. You can withdraw your consent at any time when you agree to the processing of your personal information for a specific purpose, and we will cease processing your personal information for that purpose. The withdrawal of consent does not affect the lawfulness of processing based on consent before withdrawal.

  Our legitimate interestsand the interests of our users, for example, when we detect and prevent fraud and abuse to protect the safety of our users, ourselves, or others;

  When we provide products or services to you or communicate with you about these products or services,Contractual performance;this includes the use of your personal information to accept and process orders and handle payments.

  Legal obligations;Compliance with our legal obligations under applicable laws and anti-money laundering laws and regulations

  Our legitimate interestsand the interests of our users, for example, when we detect and prevent fraud and abuse to protect the safety of our users, ourselves, or others;

  Improving our servicesfor legitimate interests;

  When we seek your consent to process your personal information for specific purposes communicated to you, your consent is obtained. You can withdraw your consent at any time when you agree to the processing of your personal information for a specific purpose, and we will cease processing your personal information for that purpose. The withdrawal of consent does not affect the lawfulness of processing based on consent before withdrawal

3. Can children use BasicEx services?

BasicEx does not allow anyone under the age of 18 to use BasicEx services and does not intentionally collect personal information from children under 18 years of age.

4. What about cookies and other identifiers?

We use cookies and similar tools to enhance your user experience, provide our services, strengthen our marketing efforts, and understand how customers use our services for improvement. According to applicable laws in your region, cookie banners on browsers will inform you how to accept or reject cookies. A copy of our cookie policy can be obtainedhere.

5. Will BasicEx share my personal information?

If we believe that sharing your personal data complies with any contractual relationship between you or us, applicable laws, regulations, or legal procedures, or if required, we may share your personal data with third parties, including other BasicEx entities. When sharing your personal information with other BasicEx entities, we will make every effort to ensure that such entities are bound by this privacy statement or follow practices at least equivalent to the protection measures described in this privacy statement. For example, if you reside in France, basicex France SAS will be responsible for conducting KYC checks.

We may also share personal information with the following parties:

i. Third-party service providers:We engage other companies and individuals to represent us in performing functions. Examples include analyzing data, providing marketing assistance, processing payments, transmitting content, and assessing and managing credit risks. These third-party service providers may only access the personal information necessary to perform their functions and are prohibited from using it for other purposes. Additionally, they must process personal information in accordance with our contractual agreements and only to the extent permitted by applicable data protection laws.

ii. Legal institutions:Legal or courts may require us to disclose certain information about you or any agreements we may have with you to relevant regulatory authorities, law enforcement agencies, and/or other regulatory bodies. We will disclose information about you to legal authorities to the extent required by law. We may also need to share your information to enforce or apply our legitimate rights or prevent fraud.

iii. Business transfers:As we continue to develop our business, we may sell or purchase other businesses or services. In such transactions, user information is usually one of the transferred business assets, but it remains subject to any commitments made in any previous privacy statements unless users agree otherwise. Additionally, in the unlikely event that basicex or almost all of its assets are acquired by a third party, user information will be one of the transferred assets.

iiii. Protecting BasicEx and others:When we believe that disclosing accounts and other personal information is appropriate to comply with the law or our regulatory obligations, we will disclose accounts and other personal information; enforce or apply our terms of use and other agreements; or protect BasicEx, our users, or others' rights, property, or safety. This includes exchanging information with other companies and organizations to prevent fraud and reduce credit risk.

6. International transfer of personal information

To facilitate our global operations, BasicEx may transfer your personal information to areas outside the European Economic Area ('EEA'), the UK, and Switzerland. The European Economic Area includes EU countries and Iceland, Liechtenstein, and Norway. Transfers outside the European Economic Area are sometimes referred to as 'third-country transfers'.

We may transfer your personal data within our global affiliates, third-party partners, and service providers. If we intend to transfer personal data to a third country or international organization outside the EEA. BasicEx takes appropriate technical, organizational, and contractual safeguards (including standard contractual clauses) to ensure that such transfers comply with applicable data protection rules, unless the destination country/region for the transfer of personal information has been provided with an adequate level of protection by the European Commission.

We also rely on decisions of the European Commission that recognize certain countries and regions outside the European Economic Area as providing adequate protection for personal information. These decisions are called 'adequacy decisions'. We transfer personal data to Japan based on the adequacy decision for Japan.

7. How secure is my information?

We consider your security and privacy when designing systems. We have taken appropriate security measures to prevent your information from being accidentally lost, used or accessed in an unauthorized manner, altered, or disclosed. We are committed to protecting the security of your personal information during transmission and storage by using encryption protocols and software. We maintain physical, electronic, and procedural safeguards related to the collection, storage, and disclosure of your personal information. In addition, we limit access to your personal information to employees, agents, contractors, and other third parties who need to know for business purposes.

Our security procedures mean that we may ask you to verify your identity to protect you from unauthorized access to your account password. We recommend using a unique password for your BasicEx account that is not used for other online accounts, and log out after using a shared computer.

8. About advertising

To provide you with the best user experience, we may share your personal information with our marketing partners for targeting, modeling and/or analysis, as well as marketing and advertising purposes. You have the right to object to the processing of your personal information for direct marketing purposes at any time (see section 9 below).

9. What rights do I have?

Under applicable law, you have several rights related to your privacy and personal information protection. You have the right to request access, correction, and deletion of your personal information, and to request data portability. You can also object to our processing of your personal information or request us to restrict processing in certain circumstances. Additionally, when you consent to the processing of your personal information for specific purposes, you can withdraw your consent at any time. If you want to exercise any of your rights, please contact us throughservice@basicex.comContact us. These rights may be limited in certain circumstances, for example, if we can demonstrate a legal requirement to process your personal data.

Access right:You have the right to obtain confirmation information about whether your personal information has been processed and the right to obtain a copy of it and certain information related to its processing;

Right of rectification:You can request correction of inaccurate personal information and make supplements. You can also change your personal information in your account at any time.

Right of deletion:In certain circumstances, you can request the deletion of your personal information;

Right to object:For reasons related to your specific situation, you can object to the processing of your personal information. For example, you have the right to object to our reliance on legitimate interests or the processing of your data for direct marketing;

Right to restrict processing:In certain circumstances, you have the right to temporarily restrict our processing of your personal information, provided there are valid reasons. If necessary for legal defense of claims or any other exceptions allowed by applicable law, we may continue to process your personal information;

Right to portability:In certain circumstances, you can request to receive your personal information provided to us in a structured, commonly used, and machine-readable format, or, where possible, we can transmit your personal information directly to another data controller on your behalf;

Right to withdraw your consent:For processing that requires your consent, you have the right to withdraw your consent at any time. Exercising this right does not affect the lawfulness of processing based on consent before its withdrawal;

Right to complain to relevant data protection authorities:We hope to address any questions about how we handle your personal information. However, if you have unresolved concerns, you also have the right to lodge a complaint with the Irish Data Protection Commission or the data protection authority in your residence, workplace, or the location where you believe the data protection violation occurred.

If you have any questions or objections about how we collect and process your personal information, please contact service@basicex.com。

10. How long will BasicEx keep my personal information?

We will retain your personal information for as long as you continue to use BasicEx services, as long as it is necessary to achieve the purposes described in this privacy statement, and as required by law, such as for tax and accounting purposes, compliance with anti-money laundering laws, or other communications to you.

11. Contact information

You can contact our Data Protection Officer throughservice@basicex.com12. Notification and Revision

If you have any concerns about BasicEx's privacy, please contact us, and we will do our best to resolve them. You also have the right to contact your local data protection authority.

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Our business changes regularly, and our privacy statement may change as well. You should check our website regularly for the most recent changes. Unless otherwise indicated, our current privacy statement applies to all information we have about you and your account.