INTRODUCTION AND LEGAL BASIS

This Privacy Policy and Disclaimer (the “Policy”) is issued by NeoMines Ltd (“NeoMines,” “we,” “us,” or “our”), a company duly incorporated and registered under the laws of the United Arab Emirates with registered office at Office 108, Building 10, Bay Square, Business Bay, Dubai, United Arab Emirates.

This Policy is governed by and construed in accordance with the laws of the United Arab Emirates, including but not limited to Federal Decree-Law No. 45 of 2021 regarding the Protection of Personal Data (PDPL) and any regulations promulgated thereunder, as well as applicable international standards including, where relevant, the European Union’s General Data Protection Regulation (EU) 2016/679 (“GDPR”).

1. PRIVACY POLICY

1.1 Scope and Application

This Privacy Policy applies to all personal data that is collected, processed, stored, or otherwise handled in connection with your use of our website located at www.neomines.com (the “Site”), our mobile applications, our products and services (collectively, the “Services”), and any other online or offline interactions with NeoMines.

For the purposes of this Policy, “personal data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

1.2 Data Controller Information

NeoMines Ltd serves as the data controller for the personal data processed under this Policy. Our full contact details are:

NeoMines Ltd
Office 108, Building 10, Bay Square, Business Bay
Dubai, United Arab Emirates
Email: privacy@neomines.com
Telephone: +971 (4) 876 06 27

For data protection inquiries, please contact our Data Protection Officer at dpo@neomines.com.

1.3 Categories of Personal Data We Process

1.3.1 Information You Provide Directly

We collect and process the following categories of personal data that you provide directly to us:

(a) Identity and Contact Information: Including but not limited to your full name, title, postal address, email address, telephone number, date of birth, nationality, and government-issued identification details where required for regulatory compliance.

(b) Account Information: Including username, password, account preferences, and any other information associated with your NeoMines account.

(c) Financial Information: Including bank account details, payment card information, cryptocurrency wallet addresses, transaction histories, and other financial information necessary for the provision of our Services.

(d) KYC/AML Information: Information required to comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations, which may include copies of identification documents, proof of address, source of funds information, and related verification data.

(e) Communication Data: Information contained in or relating to any communication that you send to us, including correspondence, feedback, questions, comments, and survey responses.

1.3.2 Information We Collect Automatically

When you interact with our Site or Services, we may automatically collect:

(a) Technical Data: Including internet protocol (IP) address (stored in a pseudonymized format), browser type and version, operating system and platform, device information, time zone setting, and location data.

(b) Usage Data: Information about how you use our Site and Services, including clickstream data, pages viewed, features used, time spent on pages, navigation paths, frequency and duration of visits, and other diagnostic data.

(c) Cookie Data: Information collected through cookies and similar tracking technologies as further described in Section 1.7 of this Policy.

1.3.3 Information from Third Parties

We may receive personal data about you from various third parties and public sources, including:

(a) Analytics providers (b) Advertising networks (c) Identity verification services (d) Blockchain analytics providers (e) Financial institutions and payment processors (f) Business partners and service providers (g) Publicly available sources

1.4 Purposes and Legal Bases for Processing

We process your personal data for the following purposes and on the following legal bases:

1.4.1 Performance of Contract

We process your personal data as necessary for the performance of our contract with you or to take steps at your request before entering into a contract, including:

(a) Creating and managing your account (b) Providing and personalizing our Services (c) Processing transactions and managing mining operations (d) Providing customer support and addressing inquiries (e) Communicating with you about your account or our Services (f) Facilitating payments and withdrawals

1.4.2 Legitimate Interests

We process your personal data based on our legitimate interests, provided that these interests are not overridden by your rights and freedoms, including:

(a) Improving and optimizing our Site and Services (b) Analyzing usage patterns and trends (c) Detecting and preventing fraudulent activity, security incidents, and other harmful activity (d) Protecting our legal rights and interests (e) Managing our business operations and strategic planning (f) Conducting market research and analysis (g) Marketing our Services to existing customers

1.4.3 Compliance with Legal Obligations

We process your personal data as necessary to comply with our legal obligations, including:

(a) Complying with KYC, AML, and Counter-Terrorism Financing (CTF) regulations (b) Fulfilling tax reporting obligations (c) Responding to legal requests from regulatory authorities (d) Maintaining records as required by applicable laws (e) Conducting compliance audits and investigations

1.4.4 Consent

Where required by law, we will process your personal data based on your consent, including:

(a) Sending marketing communications where not justified by legitimate interests (b) Placing certain non-essential cookies on your device (c) Processing special categories of personal data, where applicable (d) Sharing your personal data with third parties for marketing purposes (which we do not currently do)

You have the right to withdraw your consent at any time by contacting us at privacy@neomines.com or by using the unsubscribe mechanism in marketing communications.

1.5 Recipients of Personal Data

We may disclose your personal data to the following categories of recipients:

1.5.1 Service Providers and Processors

We engage trusted third-party service providers to perform functions and provide services to us, including:

(a) Cloud hosting providers (b) Payment processors (c) Analytics providers (d) Customer support services (e) Fraud prevention and identity verification services (f) Marketing and communication platforms (g) Professional advisors (e.g., lawyers, accountants, auditors)

These service providers have access to personal data only as needed to perform their functions and are contractually obligated to maintain the confidentiality and security of the data.

1.5.2 Affiliated Entities

We may share your personal data with our parent company, subsidiaries, and affiliated entities for purposes consistent with this Privacy Policy.

1.5.3 Legal and Regulatory Authorities

We may disclose your personal data to regulatory authorities, government agencies, law enforcement bodies, courts, or other third parties where we believe disclosure is necessary:

(a) To comply with applicable laws or regulations (b) To exercise, establish, or defend our legal rights (c) To protect your vital interests or those of another person (d) To detect, prevent, or otherwise address fraud, security, or technical issues (e) In connection with an investigation of suspected or actual illegal activity

1.5.4 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, your personal data may be transferred to our successor or assign, subject to the same protections described in this Policy.

1.6 International Transfers of Personal Data

The personal data we collect may be transferred to, stored, and processed in countries other than the country in which you reside. These countries may have data protection laws that differ from the laws of your country.

When we transfer personal data to countries outside the UAE or the European Economic Area (EEA), we implement appropriate safeguards in accordance with applicable data protection laws, which may include:

(a) Entering into Standard Contractual Clauses approved by the European Commission or equivalent data protection authorities (b) Transferring to countries recognized as providing an adequate level of data protection (c) Implementing binding corporate rules (d) Relying on derogations for specific situations, such as your explicit consent

You may contact us to obtain more information about the safeguards we have implemented to protect your personal data in these contexts.

1.7 Cookies and Similar Technologies

1.7.1 Types of Cookies We Use

Our Site uses cookies and similar tracking technologies to differentiate you from other users and to enhance your user experience. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree.

We use the following types of cookies:

(a) Strictly Necessary Cookies: Essential for the operation of our Site, enabling core functionality such as security, network management, and authentication.

(b) Analytical/Performance Cookies: Allow us to recognize and count the number of visitors and to see how visitors move around our Site. This helps us to improve the way our Site works by ensuring that users are finding what they are looking for easily.

(c) Functionality Cookies: Used to recognize you when you return to our Site, enabling us to personalize our content, greet you by name, and remember your preferences.

(d) Targeting Cookies: Record your visit to our Site, the pages you have visited, and the links you have followed to deliver advertisements more relevant to your interests.

1.7.2 Cookie Management

You can manage cookie preferences through your browser settings. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

Please note that if you choose to disable cookies, some parts of our Site may not function properly, and you may not be able to access all the features and functionality of our Services.

1.8 Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider:

(a) The amount, nature, and sensitivity of the personal data (b) The potential risk of harm from unauthorized use or disclosure (c) The purposes for which we process the data (d) Whether we can achieve those purposes through other means (e) Applicable legal, regulatory, tax, accounting, or other requirements

In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

1.9 Data Security

We have implemented appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing, accidental loss, destruction, or damage. These measures include:

(a) Encryption of sensitive data (b) Pseudonymization where appropriate (c) Firewalls and intrusion detection systems (d) Access controls and authentication procedures (e) Regular security assessments and penetration testing (f) Staff training on data protection and security (g) Incident response procedures

While we strive to protect your personal data, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.

1.10 Your Data Protection Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

(a) Right of Access: The right to request a copy of your personal data.

(b) Right to Rectification: The right to request correction of inaccurate personal data or completion of incomplete personal data.

(c) Right to Erasure: The right to request deletion of your personal data in certain circumstances.

(d) Right to Restriction of Processing: The right to request restriction of processing of your personal data in certain circumstances.

(e) Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller.

(f) Right to Object: The right to object to processing of your personal data in certain circumstances, including profiling and direct marketing.

(g) Right to Withdraw Consent: The right to withdraw consent at any time where we rely on consent to process your personal data.

(h) Right to Lodge a Complaint: The right to lodge a complaint with a supervisory authority.

To exercise these rights, please contact us at privacy@neomines.com. We may require specific information from you to help us confirm your identity and ensure your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

We will respond to all legitimate requests within the timeframes required by applicable data protection laws.

1.11 Changes to the Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material changes if and where required by applicable data protection laws.

You can see when this Privacy Policy was last updated by checking the “Last Updated” date at the bottom of this Policy.