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INTRODUCTION

LUNAR ARK DMCC (“Lunar Ark” “We”, “Us”, “Our”, “company”) isa registered company incorporated in the Dubai Multi Commodities Centre, UnitedArab Emirates (UAE) bearing License Number [to be updated on receipt of license]. We comply with all applicable data privacy laws in Dubai including those prescribed under the Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data Protection (the PDPL) Law No 4 of 2022 Regulating VirtualAssets in the Emirate of Dubai, and any requirements of the Virtual AssetsRegulatory Authority (VARA) including the VARA Technology and InformationRulebook, along with applicable federal anti-money laundering (AML) and countering the financing of terrorism (CFT) laws, regulations and guidance.

This Privacy Policy (Privacy Policy) has been developed for Lunar Ark. This Privacy Policy is reviewed annually, unless there is a change in regulation that requires to implement an earlier update. The Chief Information Security Officer/ Data Protection Officer (CISO/DPO) is responsible for maintaining, developing, implementing, and updating this Privacy Policy and ensuring compliance with all applicable laws, regulations, and best practices.The Board of Directors of Lunar Ark (Board) is responsible for approving and monitoring the implementation of this Privacy Policy and the related procedures. Upon establishing that an update is required, the CISO/DPO proposes changes by presenting them to the Board. Once the Board approval is sought, the changes are incorporated in the Privacy Policy. 

This Privacy Policy is intended to assist those who use or access the Platform (you) you in making informed decisions when using our site and services and/or to understand why/how your personal information may be collected and processed by us. This Privacy Policy governs our data collection, processing, and usage practices. It also describes your choices regarding use, access, and correction of your Personal Data. Personal Data for the purpose of this Privacy Policy includes any data or information relating to you which may, by itself, or in combination with other data or information, be able to identify you (Personal Data). For purposes of this Privacy Policy, references to “personal information” shall be synonymous with “personal data”. 

By visiting, accessing, or using the Lunar Ark platform including the website at https://www.lunarark.ae (“Platform”), you confirm that you are at least eighteen (18) years old and agree to be bound by the terms and practices described in this Privacy Policy in its entirety. It is important that you read this Privacy Policy together with any other Personal Data processing notice we provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your Personal Data. This Privacy Policy supplements the other notices and is not intended to override them. 

Please Note: If you do not accept and agree with our privacy policy, then you must not access or use our platform. If you use the platform following a change to the terms of this Privacy Policy, you are providing your acceptance of our Privacy Policy as revised. 

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SCOPE

This Privacy Policy describes how Lunar Ark collects, uses, discloses, and protects the personal information of: 

   ·    Every person who visits our website

   ·    Every person who creates an account with us

   ·    Every person who uses our services 

   ·    Every person who applies to work at LunarArk 

   ·    Every person whose personal information we may process as a result of providing services to third parties 

   ·    Representatives of third-party service providers who interact with us to fulfill their contractual obligations with us. 

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Information Collection

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USE OF PERSONAL INFORMATION 

We may use the personal information we collect for the following purposes: 

  ·    To Provide Services: To operate, maintain, and provide you with our services, including facilitating transactions and account management. 

   ·    To Verify Your Identity: This may be done on an ongoing basis in compliance with regulatory requirements. 

   ·    To enable performance by Third Party: We may share your information with third party partners or third parties hired by us to perform functions and provide services to us subject to confidentiality obligations consistent with this Privacy Policy and on the condition that the third parties use your information only on our behalf and pursuant to our instructions. 

   ·    To Communicate: To communicate with you, respond to your inquiries, and provide customer support. 

   ·    To Improve Services: To analyze usage trends, conduct research, and improve our website and services, while creating abetter, more personalized experience for you. 

   ·    To Comply with Legal Obligations: This may include fulfilling KYC or AML requirements or any other regulations. 

   ·    Recruitment: To assess your suitability for any role which you may apply for at Lunar Ark, whether such application is received by us online, via email, hard copy or by in- person application. 

   ·    Aggregation: We may also create, process, collect, use, and share aggregated, anonymised, or de-identified data such as statistical or demographic data for any purpose as permitted under applicable laws. We may analyse such aggregated and anonymized information in a manner to further enhance the level of services that we offer on our Platform for business or research purposes, including improving and customizing the Platform for ease of use and the services offered by us. Such information also includes average number of users of the Platform, the average clicks of the services, the features used, the response rate, etc. and other such statistics regarding groups or individuals. In doing so, we shall not be making disclosures of anyPersonal Data as such information will then no longer identify you as an individual person and we ensure that ensures the data is put beyond further use, despite being derived from your Personal Data. We may archive this information to use it for future communications for providing updates and/or surveys.Furthermore, we may also use this information to comply with legal or regulatory obligations. 

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DISCLOSURE OF PERSONAL INFORMATION 

We may disclose your personal information to third parties in the following circumstances. Where your details are provided to any other party in accordance with an express purpose, we will require them to be kept safe and secure your Personal Data and only use it for the intended purpose.For this reason, you hereby agree that for every authorization which you grant to us in this Privacy Policy, you also grant to any third party that we may hire, contract, or otherwise retain the services for the purpose of providing service to you or for operating, maintaining, repairing, or otherwise improving or preserving our Platform or its underlying files or systems. As we do not control these third parties, you agree not to hold us liable for the actions of any of these third parties, even if we would normally be held vicariously liable for their actions, and that you must take legal action against them directly should they commit any tort or other actionable wrong against you. 

Employees and affiliates: Our employees, our affiliates, and their employees. For instance, Lunar Ark will share your information with otherLunar Ark affiliates for the purpose of the provision of our services or when such affiliates provide support services to Lunar Ark. 

Service Providers: Throughout the course of our provision of services to you, we may delegate our authority to collect, access, use, and disseminate your information. It is therefore necessary that you grant the third parties we may use in the course of our business the same rights that you afford us under this Privacy Policy. 

Auditors: auditors or contractors or other advisers auditing, assisting with or advising on any of our business purposes; 

Analytics: analytics and search engine providers that assist us in the improvement and optimisation of our Platform; 

Third-parties: any third-party where such disclosure is required in order to enforce or apply any terms and conditions pertaining to our services or other relevant agreements; 

Legal Compliance: We may disclose any information in response to a legal request such as a subpoena, court order, or government demand, to investigate or report illegal activity, or to enforce our rights or defend claims; and

Business Transfers: In connection with a merger, acquisition, or sale of all or a portion of our assets, your personal information may be transferred to the acquiring entity. 

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SECURITY OF PERSONAL INFORMATION 

We have established adequate information security policies, rules and technical measures, to protect the information we collect from unauthorized access, improper use, alteration, or unlawful destruction. We also use SSL certificates to secure our website. However, the internet is an open system, and we can make no warranties or guarantees as to the security or privacy of your information submitted to the Platform. For this reason, we recommend that you use anti-virus software, firewalls and other precautions to protect yourself from security and privacy threats.

Where you have been allocated a profile to interact with thePlatform, this area is protected by your username and password, which you should never divulge to anyone else. 

Please be aware that communications over the Internet, such as emails, are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered. This is the nature of the world wide web/internet. While we make our best efforts to secure personal data and facilitate access to your Personal Data, it is important to note that no transmission over the internet or any method of electronic storage can be guaranteed to be absolutely 100% secure. We cannot accept responsibility for any unauthorised access or loss of Personal Data that is beyond our control. 

Should we receive information that your Personal Data be breached, and your financial and personal security be at risk, we shall promptly and immediately communicate to you the nature of the breach which has taken place, the likely consequences of such a breach and shall describe thoroughly the measures we have implemented to address the breach and to mitigate any and all adverse effects to you and your rights. We will also notify the relevant data protection authority of the breach in accordance with applicable regulations. In the unlikely event of a breach occurring, please reach out to us at Compliance@Lunarark.ae for further information and for further advise on how to mitigate the potential adverse effects of such a breach. 

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COOKIES POLICY 

This clause of the Privacy Policy explains what cookies are, what information we collect using cookies and how we use cookies in respect of the Platform. 

What is a cookie?

A ‘cookie’ is a small piece of encrypted text saved on the browser or hard drive in your computer or mobile device when you visit a website. Cookies are selected pieces of information that websites or mobile applications send to your device or computer’s hard drive, while you are viewing or using our Platform. It allows us to recognise you and make your next visit easier and the experience of our services more useful to you. cookies can be stored for varying lengths of time on your browser or device. 

We use both session / transient cookies (which expire once you close your device web browser) and persistent cookies (which stay on your device until you delete them) to collect information to provide you with a more personalized and interactive experience in using our Platform and services.This type of data is collected to make our services more useful to you and to tailor your experience with us to meet your special interests and needs. 

How we use cookies?

When you use and access our Platform, we may place a number of cookie files on your device or web browser. We use cookies to enable certain functions of the Platform i.e., to provide analytics, to prevent fraudulent or illegal activity, to store your preferences, to enable advertisements delivery, including behavioural advertising. We also use cookies to enhance your browsing experience by: 

In addition to our own cookies, we may also use various third parties’ cookies to report usage statistics of our sites, deliver advertisements on and through our Platform, and so on. 

Types of cookies we use:

   ·    Essential cookies: These cookies are essential to let you move around the Platform and use its features. These cookies allow our Platform to provide services at your request. We use essential cookies to authenticate users and prevent fraudulent use of user accounts. 

   ·    Performance cookies: These cookies may be used to collect information about how you use the Platform e. g., which pages you visit most often, and if you experience any error messages. They also allow us to update our Platform to improve performance and tailor it to your preferences.These cookies do not collect any information that could identify you - all the information collected is anonymous. 

   ·    Functionality cookies: These cookies are used to remember the choices you make, e.g., your username, log in details and language preferences. They also remember any customizations you make to give you enhanced, more personal features of your digital experience. 

   ·    Advertising and targeting cookies: These cookies are used to collect information about your visit to our sites, the content you viewed, browsing habits to deliver adverts which are more relevant to your interest, links you followed and information about your browser, device, and your IP address. They also measure the effectiveness of advertising campaigns. 

Cookies preferences 

Please note, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer on ourPlatform. You may not be able to store your preferences, and some of our pages might not display properly. Lunar Ark is not responsible and will not be held liable for any loss resulting from your decision or inability to use cookies. 

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RETENTION OF PERSONAL INFORMATION 

We will retain your personal information for as long as necessary to fulfil the purposes outlined in this Policy and for meeting any legal, accounting, reporting, government, regulatory or law enforcement requirements, unless a longer retention period is required or permitted by law.However, all Personal Data documents, records and files will be securely retained for a minimum of 5 years. Such retention period shall be calculated from the date of closing of your professional relationship with us. 

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YOUR RIGHTS 

Access and Correction: You have the right to access and correct your personal information held by us. You may update your account information or contact us to request access or correction. 

Withdrawal of Consent: You have the right to withdraw any consent you have provided to us for processing your personal information.However, withdrawing consent may affect your ability to use our services. And such request, would not affect prior use of your information made before the withdrawal request. 

Right to erasure: You have the right to request us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly. 

Right to lodge a complaint with the supervisory authority:If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the relevant regulatory authority. 

Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us. 

Object to processing your Personal Data and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing yourPersonal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which do not override your rights and freedoms. 

Request restriction of processing of your Personal Data.This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (i) if you want us to establish the data's accuracy;(ii) where our use of the data is unlawful but you do not want us to erase it;(iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, yourPersonal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the data or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations. 

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CHILDREN’S POLICY 

Lunar Ark does not offer any services to persons under the age of 18. We do not knowingly collect personal information from, or market to children. If we learn that we have inadvertently collected personal information from a child, we will deactivate the account and take reasonable measures to delete it as soon as possible. 

You undertake that all Personal Data provided to us by you is true, complete, and accurate and you must notify us of any changes to such Personal Data. 

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INTERNATIONAL DATA TRANSFER 

Your personal information may be transferred to and processed in countries other than the UAE where our service providers are located or where our servers are located. We will take appropriate measures to ensure that such transfers comply with applicable data protection laws, and do so only when the country or territory to which the Personal Data is to be transferred(i) has a bilateral or multilateral agreements related to Personal Data Protection with the UAE or (ii) has special legislation on personal data protection therein, including the most important provisions, measures, controls, requirements and rules for protecting the privacy and confidentiality of the your Personal Data and their ability to exercise their rights, and provisions related to imposing appropriate measures on the controller or processor through a supervisory or judicial authority. However, some countries to which your Personal Data may be transferred do not benefit from an appropriate data protection regulatory framework. For such countries, we shall transfer your Personal Data, only upon ensuring that a suitable degree of protection is afforded to it through the implementation of the necessary safeguards, such as an adequacy decision by the relevant authority, adequate binding corporate rules or through the inclusion of standard contractual clauses in our agreements with such organizations. 

We may also transfer your Personal Data to recipients outside the UAE based on (i) your express consent; or (ii) if such transfer is necessary for judicial processes; or (iii) if such transfer is necessary for entering into or performing a contract between us and you or between us and a third party for your interests, or (iv) if such transfer is necessary for an act relating to international judicial cooperation; or (v) if the transfer is necessary for protection of public interest. We shall notify you with regards to the specific safeguard we shall adopt in transferring your Personal Data to such recipients if you specifically seek such data in exercise of your rights as a data subject. You provide your consent, through the acceptance of this Privacy Policy for such transfer. 

If you wish to procure specific information about the third-party service providers with whom your Personal Data has been shared, please contact us at Compliance@Lunarark.ae. If you choose to proceed with a service that requires the involvement of a third-party service provider, then your Personal Data may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. For these providers, we recommend that you read their privacy policies, so you can understand the manner in which your Personal Data will be handled by these providers. 

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AMENDMENT 

We may update this Policy from time to time by posting a revised version on our website. The revised version will be effective as of the date we post it. We encourage you to review this Policy periodically for any changes. 

You must agree to the amendments as a condition of your continued use of our Platform. If you do not agree, you must immediately cease using our Platform and notify us of your refusal to agree by contacting us. 

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CONTACT US 

If you have any questions about this Privacy Policy or our privacy practices, please contact us by sending an email toCompliance@Lunarark.ae.

By using our services, you consent to the collection, use, and disclosure of your personal information as described in this PrivacyPolicy. 

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RECORD KEEPING 

Lunar Ark will retain all records relating to the details of the allegation and investigation into the wrongdoing, disciplinary actions taken, notification of disciplinary actions to the relevant person, including the updates to the relevant person's records, for a minimum period of eight (8)years.