PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT CONTAINS IMPORTANT INFORMATION AND AFFECT YOUR LEGAL RIGHTS.

LAST UPDATED: 27th October 2022

This Privacy Policy is incorporated in our General Terms of Use (the "Terms") by reference, together with the Terms constitutes a binding agreement between you and Bluejay and describes our information handling practices when you access and use our Infrastructure. This Privacy Policy is meant to help you understand what your personal information (the "Personal Information") we collect and process and how we collect, process, use, store, share and protect the Personal Information. Bluejay respects the privacy of its Users and recognizes the need for adequate protection and administration of the Personal Information in accordance with this Privacy Policy.

Bluejay may make changes to this Privacy Policy from time to time. The changes will be effective immediately upon their publication on the Website. Please, review this Privacy Policy on a regular basis. You can determine when this Privacy Policy was last revised by referring to the "LAST UPDATED" legend at the top of the then-current version of this Privacy Policy on the Website. If changes are significant, we will provide a more prominent notice (including, in certain cases, email notification of the Privacy Policy changes).

Capitalized terms used but not defined in this Privacy Policy shall take the meanings assigned to such terms by the Terms.

BY CLICKING "TO ACCEPT" OR ACCESSING OR USING, OR BOTH, OUR INFRASTRUCTURE YOU AGREE TO BE BOUND BY, AND ACCEPT THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU SHALL NOT ACCESS AND USE THE INFRASTRUCTURE.

If you have any questions about this Privacy Policy, please submit your request using the contact information, provided for in section 1.1 hereof.

1. 1. Responsible body for the collection, processing, use, storing and protection of your Personal Information is:
      • Name: Form Up Ltd;
      • Email: legal@bluejay.finance.
   2. For any questions about this Privacy Policy or if you want to make privacy rights requests relating to your Personal Information, you may always contact us using the contact information above.
   3. If you believe that we have infringed your rights, we encourage you to first submit a request by sending an email to: legal@bluejay.finance (subject line: "Privacy Policy Request") so that we can try to resolve the issue or dispute informally.
   4. You have the right to make a complaint at any time to the supervisory authority for data protection issues in the applicable jurisdiction. We would, however, appreciate the chance to deal with your concerns before you approach the relevant supervisory authority so, please, contact us in the first instance.

1. 1. The Personal Information is typically data that identifies an individual or relates to an identifiable individual (the definition of Personal Information depends on the applicable law based on your physical location; only the definition that applies to your physical location will apply to you under this Privacy Policy). This includes: (i) information you provide to us, and (ii) information which is collected about you automatically.
   2. Information you provide to us. To access and use the Infrastructure, you will be required to provide us with certain Personal Information (the "Provided Information"). If you choose not to share the Provided Information with us, we may not be able to serve you as effectively or offer you access to, and use of, the Infrastructure. As we add new features and Services, you may be asked to provide additional Provided Information.
   3. The Provided Information may include:
      1. certain financial information (such as virtual assets wallet address) (the "Financial Information");
      2. information about your transactions, which may include any one or more of the following: information about the transaction, the amount of the transaction and its time (the "Transactions Information");
      3. correspondence information, which may include any one or more of the following: survey responses, information provided to our support team or user research team; records and copies of your email messages together with your email address and our responses, if you choose to correspond with us through email (the "Correspondence Information"); and
      4. information about your User Content, which may include any one or more of the following: User Content you submit to be published or displayed on the Infrastructure or transmitted to other Users or third parties (the "User Information").
   4. Information we collect from you automatically. To the extent permitted by applicable law, we may collect certain types of information automatically, such as whenever you interact with the Infrastructure (the "Automatically Collected Information"). This information helps us address customer support issues, improve the performance of our Infrastructure, provide you with a streamlined and personalized experience, and protect your Account from fraud by detecting unauthorized access. We may use a variety of technologies to collect the Automatically Collected Information, including:
      1. Cookies. A cookie is a small data file stored on the hard drive of your computer either for only the duration of your visit on the Website or for a fixed period (for more information, please, see section 9 below);
      2. Web Beacons. Web beacons are small files that are embedded in the Website and emails. Web beacons allow us, for example, to track who has visited the Website or opened an email, to test the effectiveness of our marketing, and for other related Website statistics;
      3. JavaScripts. JavaScripts are code snippets embedded in various parts of Website that facilitate a variety of operations including accelerating the refresh speed of certain functionality or monitoring usage of various online components;
      4. Entity Tags. Entity Tags are HTTP code mechanisms that allow portions of Website to be stored or "cached" within your browser and validates these caches when the Website is opened, accelerating Website performance since the web server does not need to send a full response if the content has not changed;
      5. HTML5 Local Storage. HTML5 local storage allows data from Website to be stored or "cached" within your browser to store and retrieve data in HTML5 pages when the Website is revisited; and
      6. Resettable Device Identifiers. Resettable device identifiers (also known as "advertising identifiers") are similar to cookies and are found on many mobile devices and tablets (for example, the "Identifier for Advertisers" or "IDFA" on Apple iOS devices and the "Google Advertising ID" on Android devices), and certain streaming media devices. Like cookies, resettable device identifiers are used to make online advertising more relevant.
   5. The Automatically Collected Information may include:
      1. information about how you access and use the Infrastructure;
      2. device type and unique device identification numbers;
      3. device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL);
      4. how your device interacts with the Infrastructure, including pages accessed and links clicked; and
      5. broad geographic location (e.g. country or city-level location).
   6. This Privacy Policy does not cover the use of the mentioned above or similar technologies by third parties. The Infrastructure may contain links, content, advertising, or references to other websites by third parties, including advertisers, servers, content providers and application providers. These third parties may use the above mentioned technologies to collect information about you when you use the Infrastructure including the Personal Information. Please be aware that we do not control these third parties' technologies or when and how they may be used. Therefore, Bluejay does not claim nor accept responsibility for any privacy policies, practices or procedures of any third party. We encourage you to read the privacy statements and terms and conditions of linked or referenced websites you enter.

1. Our primary purpose in collecting Personal Information is to provide you with a secure, smooth, efficient and customized experience. We generally use Personal Information to create, develop, operate, deliver, and improve our Infrastructure, content and advertising; and for loss prevention and anti-fraud purposes. We may use the Personal Information in the following ways and for the following purposes:
   1. to provide you with the Infrastructure, to deal with any requests or inquiries you may have with respect to the Infrastructure and to provide customer service and support;
   2. to maintain legal and regulatory compliance and to enforce or apply any agreement or to protect our (or others') property or rights and to defend any potential claim;
   3. communicate with you about your transactions;
   4. inform you about important changes to, or other news about, the Infrastructure;
   5. to prevent and detect money-laundering, terrorism, fraud or other crimes or abuses of the Infrastructure;
   6. to operate, maintain, improve, personalize, and analyze the Infrastructure, to monitor and analyze trends, usage, and activities for marketing or advertising purposes, to enhance your experience, to allow you to participate in interactive features on the Infrastructure and to send promotional communications, such as information about features, newsletters, offers, promotions, contests and events;
   7. to conduct our recruiting processes, to maintain appropriate records for internal administrative purposes; for statistical purposes, for market research and product analysis and to protect the health and safety of our employees and visitors, our facilities and our property and other rights;
   8. to develop, test and improve new products or services, including by testing and troubleshooting new products and features; and
   9. for any purpose that you provide your consent. We will not use your Personal Information for purposes other than those purposes we have disclosed to you, without your permission. From time to time, and as required under the applicable law, we may request your permission to allow us to share your Personal Information with third parties. In such instances, you may opt-out of having your Personal Information shared with third parties, or allowing us to use your Personal Information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to limit the use of your Personal Information, certain features of the Infrastructure may not be available to you.

1. 1. We take care to allow your Personal Information to be shared only with third parties who have a legitimate purpose for accessing it. Bluejay will never sell or rent your Personal Information to third parties without your explicit consent. We will only share your Personal Information in the following circumstances:
      1. when we are required by applicable law;
      2. with our subsidiaries and Affiliates for business purposes and as a normal part of conducting business and offering Infrastructure to you;
      3. within our cooperation with our service providers and suppliers, including network infrastructure providers, cloud providers, customer support service providers, marketing services providers, security services providers, data analysis service providers, software developers, as well as with our professional advisors who provide banking, legal, compliance, insurance, accounting, or other consulting services in order to complete third party financial, technical, compliance and legal audits of our operations or otherwise comply with our legal obligations. The mentioned service providers and advisors are bound by contractual obligations with us to keep Personal Information confidential and use it only for the purposes for which we disclose it to them;
      4. with companies providing services in the areas of fraud and crime prevention and with companies providing similar services, including financial institutions such as credit reference agencies and regulatory bodies, courts, law enforcement authorities, regulators or attorneys or other parties for the establishment, exercise or defense of a legal or equitable claim or for the purposes of a confidential alternative dispute resolution process;
      5. aggregated Personal Information and statistics for the purpose of monitoring Infrastructure usage in order to help us develop our Infrastructure; and
      6. with companies or other entities that we plan to merge with or be acquired by.
   2. You hereby acknowledge and agree that information that you post on or through the public areas of the Infrastructure are generally accessible to, and may be collected and used by, others and may result in unsolicited messages or other contact from others. Users of the Infrastructure are encouraged to exercise caution when providing Personal Information about themselves in public or interactive areas.
   3. Otherwise, we will only disclose your Personal Information when you direct us or give us a consent to do so, when we are allowed or required by applicable law or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.

1. 1. Our Infrastructure are built with strong security features that continuously protect your Personal Information. Bluejay maintains (and contractually requires third parties it shares your Personal Information with to maintain) appropriate physical, electronic and procedural safeguards to protect the security and confidentiality of the Personal Information you entrust to us. And if we do detect something risky that we think you should know about, we will notify you and help guide you through steps to stay better protected.
   2. We protect your Personal Information by maintaining physical, electronic and procedural safeguards in compliance with the applicable laws and regulations, including:
      1. physical safeguards: enforcing physical access control to our buildings and files;
      2. electronic safeguards: firewalls and data encryption; and
      3. procedural safeguards: authorization of access to Personal Information only for those employees, contractors, and agents who require it to fulfill their contractual responsibilities (we have strict confidentiality obligations for anyone with access to Personal Information); reviewing the information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to the Personal Information.
   3. However, you hereby acknowledge and agree that safety and security of your Personal Information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Infrastructure you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

1. 1. You hereby agree to indemnify any one or more of the following: Bluejay, any of its Affiliate, and its and their respective owners, directors, officers, employees, representatives and advisors, and to hold each of them harmless, from and against any loss, damage, liability, cost or expense, including reasonable attorneys' fees and costs of investigation, to which they may be put or which they may reasonably incur or sustain due to or arising out of; (i) any inaccuracy in or breach of any your representation or warranty or your Affiliate or agents, whether contained in these Terms or any other document provided by you to Bluejay in connection with these Terms; (ii) any nonfulfillment or breach of any covenant, agreement, or other provision by you or your Affiliate or agents, whether contained in these Terms or any other document provided by you to Bluejay in connection with these Terms, or (iii) the receiving by you of Tokens in violation of the applicable law or these Terms. Notwithstanding any provision of these Terms, you do not waive any right granted to you under any applicable Law. All indemnification provisions shall survive the termination of these Terms.

      Purpose	Kind of Personal Information	Legal Basis
      Purpose, provided for in section 3.1(1)	Financial Information Transactions Information Correspondence Information User Information	performance of a contract
      Purpose, provided for in section 3.1(2)	Financial Information Transactions Information Correspondence Information User Information	performance of a contract compliance with legal obligations legitimate interests
      Purpose, provided for in section 3.1(3)	Financial Information Transactions Information Correspondence Information	performance of a contract legitimate interests
      Purpose, provided for in section 3.1(4)	Correspondence Information	performance of a contract legitimate interests compliance with legal obligations
      Purpose, provided for in section 3.1(5)	Financial Information Transactions Information Correspondence Information User Information	compliance with legal obligations
      Purpose, provided for in section 3.1(6)	Transactions Information Correspondence Information User Information	performance of a contract legitimate interests your consent
      Purpose, provided for in section 3.1(7)	Correspondence Information User Information	performance of a contract legitimate interests your consent
      Purpose, provided for in section 3.1(8)	Correspondence Information Transactions Information User Information	performance of a contract legitimate interests your consent

   2. Please, contact us if you need details about the specific legal basis we are relying on to process your Personal Information where there is more than one legal basis for processing.
   3. We will only ever process your Personal Information for the purposes we collected it, unless we reasonably consider that we need to process it for another purpose and that purpose is compatible with the original purpose. If you wish to get an explanation as to how the processing for a new purpose is compatible with the original purpose, please, contact us.
   4. If we need to process your Personal Information for an unrelated purpose, we will notify you and we will explain the legal or other basis which allows us to do so.
   5. Please, note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by applicable law.

1. 1. Bluejay only retains the Personal Information for no longer than is necessary for the purposes for which the relevant Personal Information is processed, including for the purposes of satisfying any Bluejay's legal, regulatory, tax, accounting or reporting requirements. Bluejay may retain your Personal Information for a longer period in the event of a complaint or if it reasonably believes, there is a prospect of litigation in respect to relationships between you and Bluejay.
   2. To determine the appropriate retention period for the Personal Information, Bluejay considers the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of the Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means.
   3. In all cases where we keep the Personal Information, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

1. 1. Depending on applicable laws and regulations of jurisdictions where the relevant User resides, the User may be able to assert certain rights related to the Personal Information identified below:
      1. to obtain from Bluejay confirmation whether Bluejay process any of your Personal Information;
      2. to request for access to your Personal Information processed by Bluejay;
      3. to withdraw of the consent to processing of your Personal Information at any time (provided that the relevant Personal Information processing is based on your consent);
      4. to obtain from Bluejay the rectification (correction) of inaccurate Personal Information;
      5. to obtain from Bluejay the erasure (deletion) of the Personal Information;
      6. to obtain from Bluejay the restriction of processing;
      7. to receive your Personal Information, which have been provided to Bluejay, in a structured, commonly used and machine-readable format and to transmit that Personal Information to another controller without hindrance from Bluejay;
      8. to object to processing;
      9. not to be subject to a decision based solely on automated processing; and
      10. to complain to the local data protection authority if your privacy rights are violated, or if you have suffered as a result of unlawful processing of your Personal Information.
   2. These rights will only apply in certain circumstances. If you wish to exercise any of these rights or become acquainted with circumstances, in which the relevant right is applied, please, contact us. That being the case, Bluejay may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
   3. If any of the rights listed above are not provided under law for the relevant user's jurisdiction, Bluejay has sole and absolute discretion in providing the relevant user with those rights.

1. 1. To make our Website work properly, we place small data files called "cookies" on your device. Most big websites do this too.
   2. A cookie is a small data file that the Website saves on your computer or mobile device when you visit the Website either for only the duration of your visit on the Website or for a fixed period . These collect and store certain information, and these typically involve pieces of information or code that the Website transfers to or accesses from your computer hard drive or mobile device to store and sometimes track information about you. Cookies and similar technologies enable you to be remembered when using that computer or device to interact with the Website and can be used to manage a range of features and content as well as storing searches and presenting personalized content.
   3. We use cookies to observe how many users access and use our Websites, when users access and use our Website and what pages users access. Our Website uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you use our Website and also allows us to improve our Website, Infrastructure.
   4. Most web browsers automatically accept cookies and similar technologies, but if you prefer, you can change your browser to prevent that and your help screen or manual will tell you how to do this. However, you may not be able to take full advantage of the Website and Services if you do so.
   5. A number of cookies and similar technologies we use last only for the duration of your web session and expire when you close your browser. Others are used to remember you when you return to the Website and are stored in your browser until you delete them or your browser deletes them based on the expiration date defined by the cookie's file.
   6. We use these cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your data protection interests or fundamental rights and freedoms), and, in some cases, where required by law, where you have consented to their use.
   7. We use the following types of cookies:
      1. strictly necessary cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into your Account;
      2. analytical and performance cookies. They allow us to recognize and count the number of users and to see how users move around our Website when they are using it. This helps us for our legitimate interests of improving the way our Website works, for example, by ensuring that users are finding what they are looking for easily;
      3. functionality cookies. These are used to recognize you when you return to our Website. This enables us, subject to your choices and preferences, to personalize our content, greet you by name and remember your preferences (for example, your choice of language or region); and
      4. targeting and advertising cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information subject to your choices and preferences to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
   8. The effect of disabling cookies depends on which cookies you disable but, in general, the Website may not operate properly if all cookies are switched off.
   9. If you want to disable cookies on our Website, you need to change your browser settings to reject cookies. How you can do this will depend on the browser you use, therefore, please, check with your browser provider to find out how to disable cookies.

1. If you choose to access or use, or both, the Infrastructure such actions and any dispute over privacy is subject to this Privacy Policy and the Terms, including limitations on damages, resolution of disputes and application of the laws of the British Virgin Islands.