Together Pool

PRIVACY POLICY

This Privacy Policy states the data handling practices of DATA CENTER TEC LTD (further as the " Togetherpool", " we" or " us") regarding our collection, use, and disclosure of information, including personal data, through our website available at www.togetherpool.com (the " Website") and the Togetherpool's dedicated platform accessible for registered users at www.togetherpool.com (the " Platform"), related software, applications, features and materials (collectively, the " Services").

The purpose of this Privacy Policy is primarily to inform users, visitors and interested parties about their rights in relation to the processing of their data by Togetherpool through Togetherpool's Services.

By accessing and using our Services, you accept the information handling practices described in this Privacy Policy.

1. GENERAL INFORMATION

1.1. A NOTE FOR EEA RESIDENTS

If you act as a resident of the European Economic Area (EEA), you are granted certain data protection rights under the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (" GDPR" ). You have the right to access, rectify, delete, restrict, object to the processing and transfer of your data. You may also submit a complaint to your local data protection authority in the European Economic Area (" EEA").

To receive further information on collection, processing and use of personal data, please read carefully our Privacy Policy with special attention to RIGHTS OF EEA'S RESIDENTS section.

1.2. DATA CONTROLLER

Regarding the aforementioned provision, the controller of your personal data is DATA CENTER TEC LTD, with its registered office in Saint Kitts and Nevis, at Hamilton Development, unit B, Charlestown, Nevis, box 642, company number C-51616.

Note that Togetherpool is the controller of your personal data, except where we process personal data on behalf of other third parties in connection with the provision of our Services, in which case Togetherpool acts as the processor of personal data, and those third parties are the controllers of your personal data.

Togetherpool shall not be held liable for usage by other users or customers or third parties of any data made publicly available by themselves through Togetherpool's Services.

In the event of any questions or concerns regarding data protection, please contact us directly at contact@togetherpool.com.

1.3. THIRD PARTY WEBSITES

This Privacy Policy does not apply to any website, offering, product or service of any third party, even if it links to our Website or Platform or incorporates any part of Services. Please refer to the applicable privacy policies before deciding to provide any data, including personal data, to any third parties.

Togetherpool shall not be held liable for the content provided by such websites, in consequence you are obliged to read the privacy policy or other regulations of visited websites or other services.

1.4. AGE POLICY

Services are not directed at persons under the age of 18. In general, and with certain exception, privacy laws, including the GDPR, require that the collection of personal data of persons under the age of 16 requires parental consent. Unless the member state of the European Union has provided a lower age limit (provided that such lower age is not under 13 years), the GDPR obliges parents or legal guardians to give a consent on behalf of their children. Togetherpool does not intentionally collect personal data of children aged below 16, without the consent of the parent or legal guardian. In the case of doubt, parents and legal guardians are asked to contact Togetherpool at contact@togetherpool.com.

If we become aware that we have been processing the personal data of a person under the age of 16, we will erasure or archive such data as soon as possible (provided that relevant law does not stipulate otherwise), although excluding the unjustified identification of such person for this purpose.

2. CATEGORIES OF DATA

2.1. PERSONAL DATA

Togetherpool may collect one or more information which is related to an identified or identifiable natural person through your use of our Services that can be used to contact or identify you (" personal data") including, but not limited to following data:

name and surname,
telephone number,
e-mail address.

2.2. OTHER DATA

Togetherpool may collect one or more data through our Services or other arrangements, including but not limited to:

company's name, address and relevant payment information,
electronical wallet address,
mining facilities' localization,
number and models of mining facilities up to maximum of 30 minutes,
mining facilities' operating history up to maximum of 7 days,
rewards' payment history.

2.3. USAGE DATA

Togetherpool may collect one or more information about how the Services are accessed and used including, but not limited to IP address, other technical information (e.g. regarding type of devices and other tools, type of the web browser), information necessary to provide technical assistance or support (e.g. parameters, logs, other technical descriptions), pages opened, duration of the visit, number of the various page views, number of visits, referral source, data of the ISP and subscriber's data. However, these data shall only be used for statistical purposes or to ensure the correct operation of the Services.

2.4. COOKIES

Togetherpool uses cookies files to gather information. Cookies are small files of information, which often include a unique identification number or value, which are stored on your computer's hard drive as a result of using Services. The purpose of cookies is to provide you with a more relevant and effective experience on our Website and on our Platform. Cookies are frequently used on many websites across the Internet and you are able to choose if and how cookies will be accepted by changing your preferences and options in your web browser.

Types of cookies used by Togetherpool:

Session Cookies – temporary files, saved on your device until the you sign out, leave the website or close the browser.
Permanent Cookies – saved on your device for the period specified in cookies' parameters or until cookies' deletion.
Local storage - stored on your device for a definite or indefinite period or until its deletion.

Cookies are used for the following purposes, in particular:

to provide you with more precise and comfortable use of Services, tailoring the content as well as to optimize the use of Services,
to examine the activity on Website and Platform in order to create statistics, which help us to

understand in what way users use our Services, which contributes to the improvement of the structure and content of those as well as identification of the source, which user has used to enter Services,

to maintain the session of user (after logging-in),
analysis of the clicks, displays and visits to Services, maps of moving around Website, time spent on the Website and Platform,
marketing analysis and statistics.

In some circumstances, Togetherpool may work with third parties (e.g. Google, internet hosting provider) to provide range of different, necessary services for Website and Platform. For instance, third-party analytics providers may use their own cookies files to collect information about user's activities and/or marketing statistics. This information may be used for statistical purposes and analyzing of traffic recorded on the Services and also for optimizing the functionality of it (to be more accessible, intuitive). Be informed that Togetherpool does not control these Cookies. In order to disable or reject third-party Cookies, please refer to the relevant third party's website.

During your first visit to the Togetherpool's Website, information regarding cookies and Privacy Policy will be displayed. By activating a confirmation button, you agree to allow cookies on the device you currently use for Services. You can always change your settings for cookies or delete them from your browser.

Below, you can find links to popular browsers' guides describing how to disable the option of accepting specific types of cookies:

• Chrome

• Opera

• Safari

• Microsoft Edge

• Firefox

You may not be able to access some parts of Services or it may result in malfunctioning or other unforeseeable difficulties if you choose to disable cookie's acceptance in your browser, i.e. particularly the secure parts of Services. Please, bear in mind, t** he purpose of using cookies is not to collect any personal data about the user of any Togetherpool's Services, however it is not excluded that the information collected through cookies may be recognized as such data.**

2.5. SERVER LOGS

Togetherpool follows a standard procedure of using log files. These files log users when they visit websites. The information collected by log files includes, without limitation: internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, possibly the number of clicks on website, and information about errors that occurred during HTTP transaction. These are not linked to any information that is personally identifiable. The purpose of the information is generally for analyzing trends, administering purposes, tracking users' movement on the website, and gathering demographic and statistical information. Access to server's logs is available to authorized persons who administer Togetherpool's Services.

2.6. AUTOMATED PROCESSING DECISIONS

Your personal data are not subject to an automated processing decision as specified under GDPR regulation.

3. PURPOSE AND LEGAL BASIS

3.1. PURPOSE OF DATA COLLECTION

Togetherpool's primary purpose in collecting personal data is to provide you with a secure and efficient customised experience of our Services. We use your data to improve services, content and advertising, and for loss prevention and anti-fraud purposes. Examples of purposes for which your data is used, may include in particular:

performing a contract or taking an action at your request prior to the conclusion of the contract and for the purpose of pursuing claims under the contract,
providing and improving our blockchain and mining services,
providing you with Togetherpool's Services and customer support that you request,
answering your questions through the contact form or e-mail address,
verifying your identity if you act as registered user to Platform (e.g human identification, data for registration),
processing transactions on the Platform,
sending administrative or account related messages,
better understanding the customers, users and visitors interact with our Services,
delivering targeted marketing, service update notices, and promotional offers based on your communication preferences (if this lines withing the applicable law),
communicating with you about our events or our partner events,
customising, measuring, and improving Services, content and layout of our Website and Platform,
providing personalised experience and implementing preferences that you requested,
enhancing security, preventing fraud, monitoring and verifying identity or Platform access, combating spam or other malware or security risks,
preventing and investigating potentially prohibited or illegal activities, and violations of Privacy Policy or terms of the Platform or both,
resolving disputes, collecting fees or charges, answering complaints,
complying with legal obligations under binding and relevant laws (e.g. tax and accounting legislation),
enforcing our agreements with third parties, affiliates and partners,
for quality control and personnel training,
collecting additional information from customers who wish to work with us as a partner.

Togetherpool reserves that some of the purposes may not apply to residents of EEA, therefore if you are EEA's resident, please refer specifically to the legal basis under GDPR in section 3.2 herein.

Your submission of personal data is voluntary, however it is required in accordance to be able to use the Services provided through www.togetherpool.com .

3.2. LEGAL BASIS AS REGARDS TO RESIDENTS OF EEA UNDER GDPR

Regarding users and customers who are from the European Economic Area (EEA), Togetherpool's legal basis for collecting and using personal data provided with this Privacy Policy depends on the category of the personal data we collect, specific context in which we collect data, our legitimate interest and given consents.

Togetherpool's grounds for collecting and processing personal data is based on the following legal basis granted to residents of EEA under GDPR:

performing a contract or taking an action at your request prior to the conclusion of a contract, and for the purpose of pursuing claims under the contract - Article 6(1)(b) or (f) GDPR;
answering the questions you asked through the contact form or e-mail address, which is in the exercise of our legitimate interest - Article 6(1)(f) GDPR;
direct marketing activities through the information channel of your choice as well as improving our websites, offers and advertising to your interests, which are based on your voluntary and explicit consent - Article 6(1)(a) GDPR;
providing you marketing information about our products and services as well as relevant third-party products and services by other means, such as advertising on websites which is based on our legitimate interest - Article 6(1)(f) GDPR;
fulfilling our legal obligations arising from applicable law, including tax and accounting legislation - Article 6(1)(c) GDPR.

4. RIGHTS OF EEA'S RESIDENTS

Togetherpool declares to ensure a high standard of protection of the personal data belonging to the users, visitors and customers to www.togetherpool.com.

Regarding users, visitors and customers who are residents of the European Economic Area (EEA), certain rights under GDPR legislation are vested in them, in particular, the right to:

access your personal data that we collected,
data portability (the right to be provided with a copy of personal data we collected in a structured, machine-readable and commonly used form),
request to rectify, correct or delete your personal data,
object (forbid) to the processing of your personal data,
request a restriction of your personal data processing,
request a transfer of your personal data to another entity,
withdraw your consent to the processing of personal data at any time, however the withdrawal does not affect the lawfulness of processing based on the consent before its withdrawal.

Users, visitors and customers with the EEA resident's status, notwithstanding the aforementioned are granted the right to request the erasure of their personal data (the right to be forgotten) without undue delay, unless:

personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed,
consent given earlier has been effectively revoked, unless it is not overridden by another legal ground or binding laws,
you object to the processing of your personal data for marketing purposes,
deletion of your personal data will be necessary to comply with legal obligation,
processing of your personal data is not in accordance with the applicable law,
you object to the processing (also by profiling) of your personal data, based on the legally legitimate interest pursued by Togetherpool or by third party, unless there are valid, legally justified grounds for processing of your personal data that override your interests, rights and freedoms or there are other grounds for establishing, exercising or defending legal claims.

You may also submit a complaint to your local data protection authority in the European Economic Area (EEA). For more information, please contact your local data protection authority. You may exercise this right when you certainly believe that we are processing your data without justification or in a manner inconsistent with the applicable law.

In the case of any questions or doubts about your personal data protection, please contact us at contact@togetherpool.com.

5. DATA RETENTION PERIOD

Safeguarding the privacy of your data is important to us, whether you interact with us using various communication channels. We hold data in a combination of secure computer storage facilities, paper-based files and other records. We take reasonable steps to protect data we hold from misuse, loss, unauthorized access, modification or disclosure. When we consider data is no longer needed, we will remove any details that will identify you or we will securely destroy or archive any records. Although, we may need to maintain records for a significant period of time which may arise under certain legal obligation applicable to us (e.g. tax and accounting legislation, anti-money laundering law, the time necessary to defend our justified rights, resolve disputes, process potential claims, enforce our agreements, other binding arrangements and policies). If we hold any personal data in the form of a recorded communication, such information will be held in line with local regulatory requirements which may be up to 10 years after our business relationship with you has ended. Where you have opted out of receiving any marketing communications where your consent was needed we may move your details to archive data base so that we know you do not want to receive these communications.

Togetherpool stores your data solely within period necessary for obtaining purposes specified in this Privacy Policy for which data have been collected. In certain extraordinary situations, longer retention periods may be required under the applicable law as explained above. However, in each case data retention is based on the appropriate legal basis – e.g. consent or binding provision of law.

Togetherpool operates in line with GDPR regulation regarding EEA's residents, in this extend, personal data of such residents will be process over the time defined as:

fulfilling the legal obligations arising from the provisions of the GDPR in connection with the exercise of EEA's residents rights and archiving the requests made to us or informing about privacy risks, as well as fulfilling the obligations arising from tax law and other applicable legal regulations - until the expiry of the limitation periods and until the time necessary to defend our justified rights and process claims,
necessary in the context of contact through a form or e-mail or other application and necessary for the preparation and presentation of a response or offer of cooperation - until the objection is raised or consent to such contact is revoked,
to conduct marketing activities regarding the news, any services and products we offer - until such processing is objected or until withdrawn of the consent to receive information with such content,
if the processing of personal data is based on the consent – until it is withdrawn.

6. DATA TRANSFER; DATA RECIPIENTS

Togetherpool may be obliged to provide data to the following category of data recipients, in particular:

any affiliates, business partners and related entities – if necessary, in connection with our business activity, notably for the purpose of performing contracts or other arrangements with such third parties, providing services and ensuring the appropriate standards of performance and compliance with the provisions of the law and safety requirements, communicating with users customers and with third parties, meeting financial obligations and responding to your requests, complaints and other legal demands;
third parties providing daily services for Togetherpool (i.e. tax and legal advisors, IT service providers, hosting internet providers, auditors, accounting companies, outsourced workforce providers, customer and support service, software providers, e-mail operators, server hosting providers, cloud computing server providers, mining facilities providers, maintenance and support, and other contractors);
public entities entitled under applicable law (i.e. administrative bodies, supervisory bodies, regulators, law enforcement bodies);
other third parties as notified to you at the time of data collection.

Should Togetherpool transfers your personal data outside the European Economic Area (EEA), e.g. Google LLC, it applies to the residents of the EEA. To the extent we may transfer your personal data outside the EEA, we will ensure that the transfer is lawful and that there are appropriate security arrangements. In order to transfer personal data to third parties in territories that do not have a finding of adequacy by the applicable authority and regulations, we enter (or will enter) into agreements ensuring appropriate and suitable safeguards based on standard contractual terms adopted by the European Commission. We may require that the third party agrees to at least the same level of privacy safeguards as required under applicable data protection laws.

Residents of EEA should be informed that due to the loss of legal force of the Privacy Shield, USA does not ensure an adequate level of protection of personal data. Additionally, due to the lack of a decision by the European Commission regarding the determination of an adequate level of Personal Data protection, we may not provide appropriate and sufficient safeguards as determined in Article 46 of GDPR regulation. Therefore, subject to such personal data transfer, we would like to inform you that there is a risk of insufficient protection of your personal data. In this case, the basis for the transfer of personal data is your voluntary consent in accordance with the Article 6(1)(a) GDPR.

Togetherpool may enter into written data processing agreements with another entity (the " Processor" ) when it comes to EEA's residents personal data. The right to enter into such agreements arises from the provisions of the GDPR regulation. Data processing based on the agreement may be process solely in the scope necessary for realization of aim agreed with the Processor and only to the extent necessary for the purposes of such aim. Togetherpool declares to apply all required, legal and technical reasonable measures for data protection in order to ensure the highest quality of the Services.

7. SECURITY MEASURES

Togetherpool takes appropriate and reasonable safety measures to ensure technical and organizational safeguards (e.g. SSL certificate for the Website) to protect any data collected through Website or Platform, having regard to the fact of the potential risks and categories of data covered by protection. Data are protected technically and organizationally against, including but not limited to, unauthorized access, disclosure, modification, processing in violation and change, loss, damage or destruction.

We apply the principle of data minimization in accordance with the GDPR regulation, processing only personal data that are solely necessary to provide our Services and maintain satisfactory quality for you.

We would like to emphasize that the use of the Internet and related services may cause the risk of cyber attacking, including unauthorized access by third parties to your data. To avoid or minimize potential threats and frauds while connected to the Internet, we encourage you to apply appropriate technical security measures, e.g. strong password, firewall, antivirus programs (and keep it all updated), secure internet connection and any other measures protecting you from identification by the third parties.

8. AMENDMENTS TO PRIVACY POLICY

Any information that we collect is subject to this Privacy Policy in effect at the time such information is collected. We may, however, revise and amend Privacy Policy at our discretion. The current version will be posted to our Privacy Policy page at www.togetherpool.com.

We recommend that you read through the contents of this Privacy Policy, other regulations and information available to you on our Website and Platform regularly.

Actual version of Privacy Policy is effective from 8th February 2021.

9. COPYRIGHTS' NOTE

All content, including text, images, graphical animation, videos, music, sounds and other material whether posted or submitted or made available through any of Togetherpool's Services are protected under binding copyright laws. It is strictly forbidden to copy, modify, download, or interfere in any other way into such material for commercial use in a manner that exceeds reasonable fair use.

If you are willing to use or share our content, please contact us in the first instance.

10. CONTACT

Any questions and matters referring your data should be addressed to Togetherpool at contact@togetherpool.com.