NOTE ON PERSONAL DATA PROTECTION

Iceblock places great importance on protecting your privacy. In accordance with the EU Regulation of 27 April 2016, Iceblock has adopted common principles in its Personal Data Processing Policy, which is available on Iceblock.net.

Iceblock, a société par actions simplifiée, whose registered office is at 19 rue de la Sablière, Paris (75014) ("we" or "us") is responsible for processing your personal data. The purpose of this document is to inform you about how we use and protect your personal data and why we process it.

It applies uniformly to all Iceblock products and services, although additional information may be provided to you as necessary when you subscribe to a particular product or service.

1. What personal data do we process?

We only collect and use the personal data that we need for our business in order to provide you with quality and personalised services.

We may collect various categories of personal data from you, including

• Identification and contact information (surname, first name, place and date of birth, photo, identity card and passport numbers, postal and e-mail address, telephone number, gender, age or signature);
• Identification and authentication data (technical logs, computer traces, information on the security and use of the terminal, IP address);
• Tax data (tax number, tax status, country of residence) ;
• Family situation (marital status, marital regime, number of children) ;
• Employment information (job, employer's name, remuneration, pay slip);
• Various legal documents (deed of transfer, deed of succession, deed of resale of stock exchange securities)
• Banking, financial and transactional information (bank details, card number, transaction data including transfer information, investor profile, value of your assets);
• Data on your habits and preferences :

• data related to the use of products and services subscribed to in relation to banking, financial and transactional data;
• data relating to interactions with us: in our offices, on our website, on our app, on our pages, on social networks, during telephone or video interviews and conversations, in emails);

The data we use may be collected directly from you or obtained from the following sources for the purpose of verifying or enhancing our databases:

• Publications/databases made available by official authorities (Official Journal);
• Third parties such as business intelligence, anti-fraud agencies, in compliance with data protection regulations;
• Websites/social network pages containing information you have made public and databases made public by third parties.

2. Special cases of data collection, including indirect collection

Iceblock may collect information about you even though you are not an Iceblock customer.

The following (non-exhaustive) list are examples of personal data collected by Iceblock from non-customers, such as

• prospects, guarantors, agents ;
• legal representatives, corporate officers and authorised persons of a legal entity that is a customer of Iceblock;
• beneficial owners and shareholders of a legal entity that is a client of Iceblock;
• principals or beneficiaries in transactions made in relation to an Iceblock customer;

3. Why and on what basis do we use your personal data?

A. To comply with our legal and regulatory obligations

We use your personal data, including data that may be included in national, regional and international asset freeze/sanction lists, to fulfil various legal and regulatory obligations:

• the fight against money laundering and terrorist financing;
• compliance with applicable legislation on international sanctions and embargoes (Treasury and European Commission lists);
• the fight against tax fraud, compliance with tax audit and reporting obligations;
• responses to official requests from duly authorised public or judicial authorities.

B. To perform a contract with you or provide you with pre-contractual information

We use your personal data to enter into and perform our contracts for :

• provide you with information about our products and services;
• assist you with transaction requests;
• in the context of customer relationship management, in particular :

• assessment of your needs and knowledge, for example of crypto assets;
• the security of the payment services you use.

C. To serve our legitimate interests

We use your personal data to implement and develop our products or services, to optimise our risk management and to defend our legal interests, including for the purposes of :

• proof of transactions or operations;
• IT management including infrastructure management (e.g. trading platforms) and business continuity including personal security;
• prevention of fraud and abuse (security measures, control of unusual transactions);
• Establishment of anonymised statistical models, tests, for research and development, in order to optimise Iceblock's risk management or to improve our offer;

D. To respect your choice when we ask for your consent for a particular processing operation

In some cases, consent is required to process your data. For example, where the purposes described above result in an automated decision being taken that has legal effect, concerns you or significantly affects you.

4. To which categories of entities may your personal data be disclosed?

In order to fulfil the above purposes, we disclose your personal data only to :

• financial authorities, judicial authorities or state agencies, public bodies upon request and to the extent permitted by regulation;
• certain regulated professions such as lawyers, notaries and auditors.

5. Transfer of data outside the European Economic Area

In case of international transfers from the European Economic Area (EEA) :

• if the European Commission has issued an adequacy decision recognising that country as having a level of protection of personal data equivalent to that provided by EEA law, your personal data will be transferred on that basis;
• To obtain a copy of these texts or to find out how to access them, you can send a written request by mail to Iceblock - 19 rue de la Sablière - 75014 Paris.

6. How long do we keep your personal data?

At Iceblock, regardless of the service provided, we keep your personal data for no longer than is necessary for the purposes for which they are processed. Thus, personal data is kept for the duration of the business relationship.

Nevertheless, personal data may be kept for longer periods insofar as they will be processed exclusively for archival purposes in the public interest, for scientific or historical research purposes or for statistical purposes in accordance with Article 89(1) of the GDPR. Iceblock keeps the personal data of its customers for a period of 5 years from the end of the business relationship for the above-mentioned purposes. It is then archived and anonymised on a secure external server.

7. What are your rights and how can you exercise them?

In accordance with the applicable regulations, you have various rights, namely

• Right of access: you can obtain information about the processing of your personal data and a copy of the personal data.
• Right of rectification: if you believe that your personal data is inaccurate or incomplete, you may request that this personal data be amended accordingly.
• Right to erasure: You may request the erasure of your personal data to the extent permitted by law.
• Right to restrict processing: you may request the restriction of the processing of your personal data.
• Right to object: you may object to the processing of your personal data on grounds relating to your particular situation. You have the absolute right to object to the processing of your personal data for the purpose of commercial prospecting, including profiling in connection with such prospecting.
• Right to data portability, where applicable, you have the right to have the personal data you have provided to us returned to you or, where technically possible, transferred to a third party;
• The right to set up instructions on the retention, deletion or disclosure of your personal data, applicable after your death.
• Right to withdraw your consent: if you have given your consent to the processing of your personal data, you have the right to withdraw your consent at any time.

You can exercise the rights listed above by writing to Iceblock - 19 rue de la Sablière - 75014 Paris or on our website.

In accordance with the applicable regulations, you are entitled to lodge a complaint with the competent supervisory authority such as the CNIL (Commission nationale de l'informatique et des libertés) in France.

8. How can you find out about changes to this information document on personal data?

In a world of constant technological change, we regularly update this information document.

Please check our website for the latest version of this document and we will inform you of any substantial changes through our website.

9. How to contact us?

If you have any questions about the use of your personal data referred to in this document, you can contact Iceblock - 19 rue de la Sablière - 75014 Paris.

10. Miscellaneous

Information about our cookie policy and computer security is available on our website.

‍