Privacy Policy

Blockstar Developments Limited v1 – October 2019

Please read this privacy policy very careful and contact us if you have any queries. This is the privacy policy (this Privacy Policy) of Blockstar Developments Limited, a private limited company registered in Scotland with company number SC583644 (Blockstar/we/us).

This Privacy Policy sets out how we process your (you/user) personal information when you use our app called Zumo (the App) and website, www.zumo.money (the Website), and the lawful basis for such processing.

How to contact us

If you need to contact us, you can do so in either of the following ways: • Email: hello@zumo.money; or

• Write to us at: 5th Floor, 125 Princes Street, Edinburgh, EH2 4AD.

We will communicate with you in English via the App, or through your email, phone or home address (if you provide these details). You should let us know if any of your contact details change.

What type of information do we have?

- Information about you submitted by you through our Website or App. We will obtain the following personal information about you: your email address, and may also obtain a photo if you add one to your ID and your name and any personal information you include in your user ID when you set up your username for the App.

- Information about cryptocurrency transactions undertaken by you using the App. This will include transactions you undertake while using the App.

- Technical information such as information about how you use your phone or device used to access the App.

- We may also from time to time hold information about you that is provided to us by third parties. How do we use your information? We process the information we hold about you for the following purposes: To provide services to you (Contractual reason) We need to use your information to provide you with services you access through the App and Website, and to provide you with support. For example we may use your email address to identify and/or authenticate you and notify you of the status of transactions, your balance or updates relating to features available in the App, or to communicate with you if you get in touch with us to ask a question. To deliver email Communications (Consent based)

Users and non-users of the platform may opt-in for email communications to keep up to date with new developments and relevant upcoming challenges on the platform. We will only send you non-contractual emails if you have opted-in to email communications.

You may opt-out from email communications at any stage via your profile page.

For the purpose of legal obligations Where it is necessary for compliance with our legal obligations, for example laws to prevent criminal activity, fraud and money laundering. In the following circumstances, where we have a Legitimate Interest

We may process data (which may include personal information) in the following ways, as part of our legitimate interests, such as in the following circumstances:

- processing behavioural data on how you interact with the App and/or Website;

- for our operation as a business providing financial services, including for administrative and operational purposes, including for example testing, analysis, statistical and market research;

- processing to prevent fraud, money laundering or unauthorised use of your account;

- in order to enforce or apply any agreement with you or our suppliers, to protect the rights, property or safety of Blockstar, our customers or others; and processing to analyse your activity so that we can provide you with an adequate and reliable service and to offer you the best possible options and functionality for your needs. “Legitimate Interests” means the interests of Blockstar in conducting and managing our business to enable us to give you the best service and the best and most secure experience.

For example, we have an interest in making sure our marketing is relevant for you, so we may process your information to ensure marketing is tailored to your interests. It can also apply to processing that is in your interests as well.

For example, we may process your information to protect you against fraud when transacting on our App, and to ensure our Website, App and other systems are secure. When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests - we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Who do we share your data with?We may from time to time share your data with third parties. However, this will only be done for one of the uses set out above under the heading ‘How do we use your data?’.

We do strive to ensure that your data remains in the UK and EU, however there are occasions where your data is transferred and processed outwith the UK/EU and if that is the case, we will rely upon the Privacy Shield Framework arrangements and will ensure that safeguards are in place as required by law to keep your data secure.

Transactions on the blockchain The nature of blockchain technology is such that whenever a transaction is executed, information relating to that transaction is publicly available on the blockchain.

Information on the internet When we obtain and hold information about you, we will do our best to keep that information safe and secure, however we can not and do not guarantee the security of that information and so any transmission is at your own risk. Your rights You have certain rights in relation to the data we hold about you, for example to withdraw a consent that you previously gave us, to ask what information we hold about you or to ask us to correct information that we hold about you.

To exercise your rights, you can use the details set out below. You may contact us in either of the following ways:

• Email: hello@zumo.money; or

• Write to us at: 5th Floor, 125 Princes Street, Edinburgh, EH2 4AD.

We will communicate with you in English via the App, or through your email, phone or home address (if you provide these details).

You should let us know if any of your contact details change.

Complaints You can complain to the ICO if you are unhappy with how we have used your data. The ICO’s details are as follows: Address:Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Helpline number: 0303 123 1113 Website: https://ico.org.uk/