Capitalized Terms used in this Privacy Policy have the meanings given them in the Terms of Service on the Site, unless otherwise defined here.

Whitelin Assets UAB 306239095, its direct and indirect subsidiaries, parents and sister companies (the “Company”) is committed to protecting the privacy of your personal information. This Privacy Policy applies to Your use of the website https://www.saturnpay.io/ (the “Site”) and governs data collection and usage in relation to the services provided on the Site (the “Services”). This Privacy Policy, together with Company’s Terms of Use, governs the Company's collection, processing and use of your Personal Information and provides an explanation as to the treatment of the Personal Information which You provide us or that is collected from You in the course of Your use of the Site or any third party websites, and describes when and how we may change this Policy, and tells You how to contact us with any questions or comments. By using the Site, You consent to the data practices described in this privacy policy

We collect Personal Information about You and the device You use when You use our Services on the Site or otherwise interact with the Company.

Personal Information

We collect the Personal Information you provide directly to us when you open a Company account, perform any transactions on the Company platform, or use the Services, which may include without limitations, name, addresses, telephone numbers, email address, payment information, such as bank account numbers, bank statement, and trading information, unique device ID (the “UDID”), device location, IP address, Site usage date, account information, such as username and password. Identity verification information, such as images of your government issued ID, passport, national ID card, or driving license. Note: You may be asked to provide copies of your passports, social security cards, ID cards and numbers, residence verification information, such as utility bill details or similar information.

We also automatically collect certain computer, device, and browsing information when you access the Site or use the Services. This information is aggregated to provide statistical data about our users' browsing actions and patterns, and does not personally identify individuals. This information may include: Computer or mobile device information, including IP address, operating system, browser type, Site usage information.

Collection of Personal Information

The Company may collect information about You in one or more of the following ways:

• 1. Information You Provide. We collect information that You provide to us when You register for or use the Site, or otherwise communicate with us. Without limitations, provision of information by You may include the following: information provided when You contact us or register to participate in our affiliated products, KYC information, Company may collect personal contact information, billing information and any information shared with payment processors, all as may be necessary for the provision of Company services or the interaction executed by You.
• 2. Upon the establishment or modification of an account with the Company, we may collect user identification information, passwords, security question responses or other elements related account security, or any other means of identification, which You will use for future sign on.
• 3. Upon interaction with our customer service representatives or anyone acting on behalf of the Company, or once You enter information on our Site, submit survey responses, we may also collect Personal Information and other data. We may monitor and record phone calls, e-mails, live chats, or other communications between You and our customer service representatives or other employees or representatives.
• 4. Information Automatically Collected. We automatically collect a variety of Personal Information associated with Your use of the Site or Services. Each time You visit the Site, Personal Information is automatically gathered, which in general, does not identify You personally and may include without limitations: UDID, IP address, Country, City (if available), Connection Speed, Publisher Name, Collection Date, Day of Week, Time of Day (hour), Language settings in addition to any information provided directly by You, all of which allows the Company to evaluate Your use of the Site for the purpose of improving the Site and the Services. In addition, through Your access to the Site, we automatically collect certain Personal Information about Your use of the Site, such as Your IP address, browser type, date and time, the web pages You visited before visiting our Site, your activities and downloads on our Site, and additional analytical information associated with the Site.
• 5. The Use of Cookies. “Cookies” hereby refers to a small text file that a website can place on Your hard drive in order to collect information about Your activities on the Site. The cookie transmits information back to the Site's system, which, generally speaking, is the only computer that can read it. We may use cookies on the Site to enhance users’ experience and avoid multiple logins or password authentication requests.
• 6. Third party Site providers. We use third party service provider(s), to assist us in better understanding the use of the Site. Our service provider(s) will place cookies on the hard drive of Your computer and will receive information that we select that will educate Us on such things as how visitors navigate around Our Site, what products are browsed, and general transaction information. Our service provider(s) analyses this information and provides us with aggregate reports. The information and analysis provided by our service provider(s) will be used to assist Us in better understanding our visitors' interests in Our Site and how to better serve those interests. The information collected by Our service provider(s) may be linked to and combined with information that We collect about You while You are using the Company's Services. Our service provider(s) is/are contractually restricted from using information they receive from Our Site other than to assist us.
• 7. Other Sources. Company may collect information about You from other sources. For example, Company may receive certain credit information from third-party sources before initiating or during the course of execution of any service to You. Company may also purchase or obtain Personal Information (for example, e-mail lists, postal mail lists, demographic and marketing data) from third parties.
• 8. Web Beacons. Company may use web beacons (or "pixels"), which are small graphic images on a web page or an HTML, for the purpose of monitoring interaction with the Site or e-mails. Web beacons, which are very small and the same color as the background, are generally invisible.

Company’s Use of the Personal Information

Company may use the Personal Information collected about You for a variety of purposes, including the following:

• 1. For providing the Services to You;
• 2. For identifying and suggesting products or services that might interest You;
• 3. For verifying Your identity and maintaining a record of Your transactions and interactions with Us;
• 4. For processing any transaction as applicable;
• 5. For making internal business decisions about current and future service offerings;
• 6. For creating, modifying, improving, enhancing, removing or fixing Our Services and their performance;
• 7. For providing You customized user experiences, including personalized services offerings;
• 8. For protecting our rights, interests, safety and property and that of our customers, service providers and other third parties and affiliates;
• 9. For verification of Your identity in accordance with applicable anti-money laundering laws and regulations, as well as address other law enforcement needs as more fully described in Our Terms of Use. When required by applicable law and regulations, we also may share your information with other financial institutions, with tax authorities, with banking and securities authorities and with any other governmental agency or body. Site.
• 10. For Fraud Prevention. We may use Personal Information for investigations or for prevention of fraud, AML, CTF, for Consumer Protection or network abuse and to protect our users.
• 11. For Business Transfer. Company may disclose, or transfer information about You as part of a corporate business transaction, such as a merger or acquisition, joint venture, corporate reorganization, financing, or sale of company assets, or in the unlikely event of insolvency, bankruptcy, or receivership, in which such information could be transferred to third-parties as a business asset in the transaction.
• 12. For Legal Process & Protection. Company may disclose Personal Information, and other information about You, or Your communications, where disclosure of such information is reasonably necessary: (i) In order to satisfy any applicable law, regulation, legal process or enforceable governmental request, including AML, CTF, Anti-Fraud and Consumer Protection requirements; or (ii) In order to enforce or apply agreements, or initiate, render, bill, and collect for services and products (including to collection agencies in order to obtain paymentfor our products and services); (iii) In order to protect our rights or interests, property or safety or that of others; or (iv) In order to assist with claims disputes, or litigation – in court or elsewhere; or (v) In order to facilitate or to verify the appropriate calculation of taxes, fees, or other obligations or in an emergency situation.

Company may use Your personally identifiable information, mainly to provide the Services, and to send communications and/or administrative emails and/or promotional emails messages relating to Services that may be of interest to You. You may tell Us at any time if you do not wish to receive marketing message from Us by contacting Us at support@saturnpay.io. Note that, if You opt-out of Our promotional communications, we may still e-mail or communicate with You from time-to-time, if We need to provide You with information or for other commercially, non-marketing reasons.

We may retain Your Personal Information in conformance with applicable laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce the Terms of Use as described in https://www.saturnpay.io/terms.html and take other actions otherwise permitted by law. There may be residual Personal Information that remains within Our databases, access logs, and other records.

Disclosing of Personal Information

Company may use third-party vendors, subcontractors, network advertisers and other businesses to deliver various services to You on Company’s behalf. These providers may be supplied with or have access to Your information, including Your non-personally identifiable information (such as Your IP address and Your UDID) for the purposes of performing the functions for which Company has engaged them. Provided that such providers have access to your personally identifiable information, they are bound by confidentiality obligation; and Company may disclose and use personally identifiable information in the course of resolving disputes, problems troubleshoot, enforcement of the Terms of Use or other legal rights (for example, when necessary to protect Company or a third party's intellectual property or proprietary rights), or to alert You to changes in our policies or Terms of Use that may affect Your use of the Site.

International Transfer. For the purpose of providing You with the Services under the Site, the Company store and process Your Personal Information in data centers around the world, wherever Our facilities or service providers are located. As such we may transfer your Personal Information outside to different countries. Such transfers will be undertaken in accordance with our legal and regulatory obligations. . By using the Site, You consent to the transfer of Your information outside of Your country .

External Sites

Company may make content or services from other websites available to You through links located on the Site. These other sources are not subject to this Privacy Policy, and Company has no control over how such sources may use the personal information collected on their Sites. Similarly, the Sites You choose to access through the use of the Site are owned by third parties and we have no control over what information is collected or used by such third parties as a result of Your use of third parties’ sites. We recommend that You review the privacy policy and users’ terms associated with each of these third-party sites to determine their privacy policies. At any event, Company will not be heldresponsible for the privacy related practices, use of Your information by third parties or the content of third party providers.

Furthermore, the payment processing services on the Site are provided by third party payment processing providers, which may also provide fraud management services and are disclosed of Your information once You execute a Transaction. Such payment processing service provider may further collect additional information and documents from You for the assessment of fraud risks. You should make yourself aware of any third-party privacy policy which governs the use and collection of Your information by such third-party provider. Company will not be held liable or responsible for such third- party practices and use of Your information

Access to Your Personal Information

Should You be required to choose a username or password while using the Site or Company’s products, you should refrain from sharing Your login information with any third party. If You provide any of Your login information to third parties, such third parties will gain access to all Your Personal Information upon accessing Your Digital Waller with Your login information. Furthermore, sharing Your login information with third parties is forbidden under AML restrictions, CTF, Fraud and identity theft provisions.

You have a right to access your Personal Information to correct, update and block inaccurate and/or incorrect data. To exercise this right please contact Us at support@saturnpay.io.

Security of Personal Information

We use a variety of security measures to ensure the confidentiality of your Personal Information, and to protect your Personal Information from loss, theft, unauthorized access, misuse, alteration or destruction. These security measures include, but are not limited to:

• 1. Password protected directories and databases.
• 2. Secure Sockets Layered (SSL) technology to ensure that your information is fully encrypted and sent across the Internet securely.
• 3. PCI Scanning to actively protect our servers from hackers and other vulnerabilities.

All financially sensitive and/or credit information is transmitted via SSL technology and encrypted in our database. Only authorized personnel are permitted access to your Personal Information, and these personnel are required to treat the information as highly confidential. The security measures will be reviewed regularly in light of new and relevant legal and technical developments.

Children’s Online Privacy Protection

Protecting the privacy of children and/or minors is very important to Us. If We obtains knowledge that a user is under the age of 18, We will take steps to remove that user's personal information from its databases.

Storage and Protection of Personal Information

Company uses a variety of physical, electronic, and procedural safeguards to protect Personal Information from unauthorized access, use, or disclosure while it is under our control. Unfortunately,no data transmission over the internet can be guaranteed to be completely secure. As a result, although Company utilizes security measures, Company may not guarantee You against the loss, misuse, or alteration of Personal Information under our control, and You provide Personal Information to us at Your own risk. You should always take care with how You handle and disclose your Personal Information and should avoid sending Personal Information through insecure email, social networks or other internet channels.

Retention and Disposal. Company retains Personal Information for as long as necessary to fulfil purposes described in this Privacy Policy and for as long as we have a business or tax need or as required under the applicable laws, regulations and/or government orders from time to time. In accordance with our record keeping obligations, we will retain Digital Wallet and other Personal Information for at least five (5) years after an account is closed.

Privacy Policy Updates

Company may amend revise, modify, update and/or supplement this Privacy Policy at any time, without prior notice, at the sole discretion of the Company. You should always refer to this Policy posted on the Site for the latest information and the effective date of any changes.

Terms and Conditions

Please also review the Terms of use establishing the use, disclaimers, and limitations of liability governing the use of the Services, at https://www.saturnpay.io/terms.html .

Contact Us

Any questions about this Privacy Policy should be referred to support@saturnpay.io .

Last Revised: August 8th, 2023