PRIVACY POLICY

1. INTRODUCTION

Kiri Technologies Ltd, with registered office in 71-75 Shelton Streeet, Covent Garden, London, WC2H 9JQ ("Kiri"), which may be contacted at the email address info@kiritechnologies.com processes - in its capacity of data controller - personal data provided by the user (the "User") within the website www.kirimarket.com (the "Site"). In particular, Kiri informs the User about the Personal Data (as defined below) that are collected for entering in the promotion available in the Site (the "Promotion") and for providing any other requested services available on the Site related to the Promotion (the "Services").

2. WHAT AND WHO DOES THIS PRIVACY NOTICE COVER?

Kiri is the data controller of the Personal Data (as defined below) that is processed in compliance with the terms of this privacy notice (the "Privacy Notice") and the relevant provisions of law. Accordingly, this Privacy Notice applies to all Users

3. WHAT KIND OF PERSONAL DATA DOES KIRI COLLECT ABOUT THE USER?

Kiri collects the following categories of personal data:

· browsing data related to Services offered through the Site and collected through cookies, according to the Cookie Policy available at this link

· personal and contact information provided by the User for the creation of the account in the Site;

· data provided by the User for entering the Promotion;

· data provided in case of request of information or assistance in the context of the Services;

(jointly defined ("Personal Data").

4. HOW DOES KIRI USE PERSONAL DATA?

Kiri processes Personal Data for the following purposes:

a) the registration of a personal account in the Site;

b) the participation to the Promotion, carrying out the activities set out in the terms and conditions which govern the Promotion;

c) the provision of the Services offered through the Site, including the provision of responses to the User's requests of information or assistance;

d) the compliance with legal and regulatory obligations

(this purpose as per letters a) to d) shall be referred to as "Contractual Purposes")

e) the development and improvement of the Services offered through the Site;

f) the exercise or defence of legal claims in court proceedings or in an administrative or out-of-court procedures, including the handling any complaints relating to the Services provided in the Site; and

g) the completion a potential merger, sale of assets or transfer of all or a material part of its business, by disclosing and transferring the Personal Data to the third party or parties involved in the transaction as part of the transaction;

(the purpose as per letters e) to g) above are jointly referred to as "Legitimate Interest Purposes")

h) In accordance with applicable data protection laws, Kiri may process your e-mail address provided in the context of the Promotion, for commercial information purposes such as market surveys, newsletters, development of know-how and promotional material related to the Services offered through the Site;

i) with the User's consent, for the transfer of Personal Data collected through the Site to third party companies that may send commercial communication in relation to their own products and services;

(the purpose as per letters h) to i) above are jointly referred to as "Marketing Activities").

5. ON WHAT LEGAL BASIS DOES KIRI PROCESS THE PERSONAL DATA?

The processing of the Personal Data is necessary with regard to the Contractual Purposes as it is essential:

· for the participation of Users to the Promotion with regard to the cases as per Section 4 letters a) and b);

· for the provision of the requested Services with regard to the cases as per Section 4 letters c);

· in order to comply with provisions as provided by the applicable laws as per Section 4 letter d).

Should the User not provide its Personal Data with regard to the Contractual Purposes, Kiri will not be able to provide the User with the Services.

The processing of the Personal Data with regard to the Legitimate Interest Purposes as per Section 4 letters e) to g) is carried out for the pursuit of Kiri legitimate interest, which is adequately balanced with the User's interest since the data processing is performed within the limits strictly necessary to perform such economic activities. This data processing activity with regard to the Legitimate Interest Purposes is not mandatory and the User can object to the data processing at any time through the modalities as per Section 10 of this Privacy Policy. In such case no data processing will be carried out by Kiri, except in case where Kiri demonstrates the existence of legitimate prevailing arguments or the processing is necessary to exercise or defend Kiri' rights.

The processing of Personal Data for Marketing Purposes is:

· based on applicable data protection provision when it is performed as a consequence of the provisions of Services offered by Kiri through the Site;

· optional and subject to the prior consent of the User for the transfer of Personal Data to third parties. Any failure to provide consent determines the impossibility for Kiri, to transfer such data to third companies for sending communications or other information material that may be in line with their interests.

6. HOW DOES KIRI PROCESS THE PERSONAL DATA?

Personal Data will be processed both electronically and/or manually, in any case in such a way as to guarantee the security, protection and confidentiality of the data, thanks to appropriate administrative, technical, personnel and physical measures against loss, theft and unauthorized use, disclosure or modification.

7. WHO CAN HAVE ACCESS TO THE PERSONAL DATA?

Personal Data may be transferred to the following categories of recipients located both within the EU and, within the limits as per Section 8 below, outside of the EU:

a) third parties service providers entrusted with processing activities that provide services or assistance and advice to Kiri, with special - but not exclusive - reference to technology, accounting, administrative, legal, insurance, IT matters; and

b) persons and authorities whose right to access Personal Data is recognized by law, regulations or provisions issued by legally empowered authorities; and

c) potential purchaser of Kiri and the entities resulting from mergers or any other transformation involving Kiri.

8. IS THE PERSONAL DATA TRANSFERRED ABROAD?

The Personal Data may be transferred to countries outside the European Economic Area, in particular in the UK. If any transfers would apply, Kiri will put in place appropriate and suitable safeguards to protect the Personal Data as per applicable data protection rules.

The User shall have the right to obtain further information by making an express request to the Company at the address indicated in paragraph 10 of this Privacy Notice.

9. WHICH IS THE RETENTION PERIOD APPLYING TO THE PERSONAL DATA?

Personal data of the User will be stored for the period necessary to fulfil the purposes for which the data was collected as outlined in this Privacy Notice. In any case the following retention periods will apply to the processing of the Personal Data for Contractual Purposes and for Legitimate Interest Purposes is retained during the provision of the Services plus a period of 10 years after the termination of the Services, except when the storing of Personal Data is necessary to respond or to file a legal actions, upon request of the competent authorities or in compliance with the applicable laws.

10. WHAT ARE THE USER'S RIGHTS WITH REGARD TO PERSONAL DATA?

The User, at any given time, can exercise the following rights, by sending an email to the following address info@kiritechnologies.com:

a) to obtain from Kiri confirmation of the existence of Personal Data and to be informed of its content and source, verify its accuracy and request its integration, update or amendment;

b) request the deletion, anonymisation or restriction of the processing of Personal Data processed in breach of the applicable laws;

c) object in whole or in part, on legitimate grounds, to the processing of the data;

d) to withdraw the consent to the processing of the data (if and to the extent such a consent is necessary);

e) request Kiri to limit the processing of the Personal Data where

· the User contests the accuracy of the Personal Data until Kiri have taken sufficient steps to correct or verify its accuracy;

· the processing is unlawful but you do not want us to erase the Personal Data;

· Kiri no longer needs the Personal Data for the purposes of the processing, but the User requires them for the establishment, exercise or defence of legal claims; or

· The User has objected to processing justified on legitimate interests, pending verification as to whether Kiri has compelling legitimate grounds to continue processing.

f) object to the processing of the Personal Data;

g) request the deletion of the Personal Data without undue delay;

h) receive an electronic copy of the Personal Data, if the User would like to port its Personal Data to itself or a different provider, when Kiri is relying upon the User's consent or the fact that the processing is necessary for the provision of the Services and the Personal Data is processed by automatic means; and

i) lodge a complaint with the relevant data protection supervisory authority.

11. DATA OF USERS UNDER 18

The Site is not addressed to users under age of 18 and, in any case, Kiri does not collect and process wittingly Personal Data referred to users under age of 18. In case Kiri is aware of the collection and processing of such Personal Data, Kiri will delete it immediately.

12. UPDATES

This Privacy Notice might be subsequently updated or integrated, also as consequence of regulatory changes. Changes will be notified in advance and in any case, Users will be able to review the updated version of the privacy information notice on the website

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