# Preamble MYKOBO sp. z.o.o. is committed to protecting the privacy of it’s visitors. This privacy policy provides visitors with an overview of the measures taken to show the commitment of MYKOBO sp. z.o.o. to this policy. The policy describes how MYKOBO sp. z.o.o. collects, uses, stores, shares, and protects your information whenever you use the MYKOBO mobile application or the MYKOBO.CO website, or any of our affiliated sub-domains such as SUPPORT.MYKOBO.CO otherwise known as “MYKOBO”. We have prepared this privacy policy to explain to you, in accordance with the provisions of the Basic Data Protection Regulation (EU) 2016/679 and the Data Protection Act (DSG), which information we collect, how we use data and what decision-making options you have as a visitor using our services. # 1.0 GDPR Rights & Protections Rights According to the General Data Protection Regulation #### **1.1 Provisions of GDPR** According to the provisions of the GDPR you have the following rights in principle: * Right to correction * Right to cancellation (“Right to be forgotten”) * Right to restriction of processing * Right of notification – Obligation to notify in connection with the correction or deletion of personal data or limitation of processing * Right to data portability * Right to object * Right not to be subjected to a decision based solely on automated processing – including profiling #### **1.2 Who is responsible for the data processing and who can you contact?** MYKOBO is aware that both the protection and the careful handling of your personal data are very important. MYKOBO will solely use the personal data provided by you in compliance with the applicable data protection requirements, this Privacy Policy and your consent. MYKOBO is the controller and therefore responsible for the processing of personal data in connection with the services provided by our company. If you have any questions in connection with the processing of your personal data and the exercising of your rights under GDPR, you can contact our privacy team: . Please note that for certain requests, we require further identification data from you (e.g. Passport, ID card, etc), in order to ensure that your personal data is only shared with you. # 2.0 User Information When you use MYKOBO, we collect information sent to us through your computer, mobile phone, or other access device. This includes personal data that you volunteer on forms which you submit to us and in emails that you send to us. In addition we automatically gather details of browser types and IP addresses of the users who visit our site. We do not release this information to any outside party, except in suspected fraud cases. If you create an account or use MYKOBO, we may collect the following types of information: #### **2.1 Contact information** Your name, phone number, email address, date of birth and other similar information. #### **2.2 Financial information** Your full bank account and/or debit card details that you input when you use MYKOBO. #### **2.3 Transaction and usage information** When you use MYKOBO we collect information about your transactions and your other activities on MYKOBO, we may continuously collect information about your computer, mobile device, or other access device for fraud prevention purposes, to monitor for possible breaches to MYKOBO, and to identify any malicious software or other activity that may harm MYKOBO or its users. #### **2.4 Third party information** You may choose to provide us with access to certain personal information stored by third parties such as social media sites like Facebook, Twitter, LinkedIn, Discord and Instagram. The information we have access to varies by site and is controlled by your privacy settings on that site and your authorisation. By associating an account managed by a third party with your MYKOBO account and authorising MYKOBO to this information, you agree that MYKOBO may collect, store, and use this information in accordance with this privacy policy. #### **2.5 Customer support information** Finally, we may collect additional information you may disclose to our customer support team in order to be able to support you with any kinds of requests that may arise. #### **2.6. Storage of Information** We recommend that you never send confidential data by e-mail. The legal basis, in accordance with GDPR (lawfulness of processing), is that you give us consent to the processing of the data you have entered. You can revoke this consent at any time – an informal e-mail is sufficient, you will find our contact details in the imprint. # 3.0 Personal Information Throughout this policy, we use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person. This Privacy Policy does not apply to personal information that has been anonymised so that it does not and cannot be used to identify a specific user. MYKOBO takes reasonable precautions, as described herein, to protect your personal information from loss, misuse, unauthorised access, disclosure, alteration, and destruction. Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customised experience. We may use your personal information to: * Provide MYKOBO and customer support for MYKOBO as required; * Process transactions and send notices about your transactions; * Resolve disputes, collect fees, and troubleshoot problems; * Prevent and investigate potentially prohibited or illegal activities, and/or violations of our posted user terms; * Customise, measure, and improve MYKOBO; * Deliver targeted marketing, service update notices, and promotional offers based on your communication preferences; * Verify your identity by comparing your personal information against third-party databases. 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, we may request your permission to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties, or from 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 authorisation. If you choose to so limit the use of your personal information, certain features or MYKOBO may not be available to you. We collect personal data that you volunteer on forms which you submit to us and in emails that you send to us. In addition we automatically gather details of browser types and IP addresses of the users who visit our site. We do not release this information to any outside party, except in suspected fraud cases. We store and process your personal and transactional information, including certain payment information, where MYKOBO facilities or our service providers are located, and we protect it by maintaining physical, electronic, and procedural safeguards in compliance with applicable laws. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorise access to personal information only for those employees who require it to fulfill their job responsibilities. Full bank account information is securely transferred and hosted off-site by a payment vendor in compliance with Payment Card Industry Data Security Standards (PCI DSS). This information is not accessible to MYKOBO employees. We store our customers' personal information securely throughout the life of the customer's MYKOBO account. MYKOBO will retain your personal information for a minimum of five years or as necessary to comply with our legal obligations or to resolve disputes. You may request that we amend any personal data that we are holding about you\ which is factually inaccurate. You can contact customer support stating your wishes. MYKOBO may contain links to other sites. MYKOBO is not responsible for the privacy practices of such other sites. This privacy statement applies solely to information collected by MYKOBO. # 4.0 Recipients of Personal Information Who could receives your personal data? The protection and confidentiality of your personal data is important to MYKOBO. Therefore, we transfer your personal data only to the extent described below or within the scope of an instruction at the time the data is collected from you. In addition, personal data that we collect concerning you will neither be sold by us nor otherwise disclosed to third parties. #### **4.1 Data transfer to processors** To a limited extent, we also transmit personal information to processors who perform services for us such as Know Your Customer (KYC) authentication services (e.g. Sum and Substance Ltd), IT services (Amazon Web Services Inc.), Client support (Zoho Corporation Pvt. Ltd.), sending out newsletters (e.g. UAB MailerLite). Processors may only use or disclose this data to the extent necessary to perform services for us or to comply with legal rules. We contractually oblige these processors to ensure the confidentiality and security of your personal data that they process on our behalf. #### **4.2 Data transfer to public bodies and institutions** We might also transfer your personal data (i) if we are required to do so by law or in the context of legal proceedings, (ii) if we believe that disclosure is necessary to prevent damages or financial loss, or (iii) in connection with an investigation into suspected or actual fraudulent or illegal activities. # 5.0 Cookie Policy MYKOBO uses cookies, that are downloaded to your computer, to improve your experience. This section describes what information they gather, how we use it and why we sometimes need to store these cookies. MYKOBO uses cookies for a variety of reasons detailed below: Recognise you as a MYKOBO user. If you create an account with us then we may use cookies for the management of the signup process and general administration. These cookies will usually be deleted when you log out, however in some cases, they may remain afterwards to remember your site preferences when logged out. We may use both session and persistent cookies when you access our websites or content. Session cookies expire and no longer have any effect when you log out of your account or close your browser. Persistent cookies remain on your browser until you erase them or they expire. We may use cookies when you are logged in so that we can remember this fact. This prevents you from having to log in every single time you visit a new page. These cookies are typically removed or cleared when you log out to ensure that you can only access restricted features and areas when logged in. When you submit data to through a form, cookies may be set to remember your user details for future correspondence. In order to provide you with a great experience on this site, we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences we may need to set cookies so that this information can be called whenever you interact with a page is affected by your preferences. We may also use Local Shared Objects, commonly referred to as "Flash cookies," to help ensure that your account security is not compromised, to spot irregularities in behaviour to help prevent fraud, and to support our sites and services. We may use cookies to collect information about your computer or other access device to mitigate risk, help prevent fraud, and promote trust and safety. We shall encode our cookies so that only we can interpret the information stored in them. You are free to decline our cookies if your browser or browser add-on permits, but doing so may interfere with your use of MYKOBO. Disabling cookies will usually result in also disabling certain functionality and features of the this site. The help section of most browsers or browser add-ons provides instructions on blocking, deleting, or disabling cookies. In some special cases we also use cookies provided by trusted third parties. This section details which third party cookies you might encounter through this site. We use Google Analytics, which is one of the most widespread and trusted analytics solution on the web, to help us understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content. For more information on Google Analytics cookies, see the official Google Analytics page. As we may eventually sell products it's important for us to understand statistics about how many of the visitors to our sites actually make a purchase and as such this is the kind of data that certain cookies will track. This is important to you as it means that we can accurately make business predictions that allow us to monitor our advertising and product costs to ensure the best possible price. We intend to use several partners to advertise on our behalf and affiliate tracking cookies will simply allow us to see if our customers have come to the site through one of our partner sites so that we can credit them appropriately and where applicable allow our affiliate partners to provide any bonus that they may provide you for making a purchase. If there is something you aren't sure you need or not, it's usually safer to leave cookies enabled in case it does interact with one of the features you use on our site. However, if you still need more information, please contact us. If you want to know which cookies have been saved in your browser, change cookie settings or delete cookies, you can find this in your browser settings: * [Safari: Manage cookies and site data with Safari](https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac) * [Firefox: delete cookies to remove data that websites have stored on your computer](https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored) * [Chrome: delete, activate, and manage cookies in Chrome](https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop\&hl=en) * [Internet Explorer: delete and manage cookies](https://support.microsoft.com/sw-ke/help/17442/windows-internet-explorer-delete-manage-cookies) If you do not wish the storage of data in cookies, you can set up your browser to inform you about the setting of cookies and to allow this only in individual cases. You can always delete cookies that are already on your computer or disable cookies. The procedure for doing this is different according to browser, it is best you search the instructions in Google with the words “delete cookies Chrome” or “disable cookies Chrome” in the case of a Chrome browser or exchange the word “Chrome” against the name of your browser for example, Edge, Firefox, Safari. # 6.0 Online Payment Methods MYKOBO is not associated with any of the trademarks which might appear visible in the Online Payment method lists or payment gateways. MYKOBO does not itself support these payment methods, or claim to be in partnership with them. Also, services provided by MYKOBO are not authorised, approved, endorsed or sponsored by any of the payment methods we use or their respective trademark owners. Payment method listings are visible on MYKOBO for informative purposes only. Trademarks which might appear visible on MYKOBO, belong to the respective trademark owners alone. Data retention policy We retain your personal information as long as it is necessary and relevant for our operations. In addition, we may retain personal information from closed accounts to comply with national laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Service and take other actions permitted or required by applicable national laws. If you have any questions about this Privacy statement, the practices, or your dealing with this web site, please contact us here and your inquiry will be dealt with as soon as possible. # 7.0 Google Analytics Privacy Policy We use Google Analytics from Google LLC (1600 Amphitheater Parkway Mountain View, CA 94043, USA) to statistically analyse visitor data. Google Analytics uses targeted cookies. #### **7.1 Cookies from Google Analytics** * \_ga * Expiration time: 2 years * Usage: Differentiation of website visitors * Example value: GA1.2.1326744211.152211077756 * \_gid * Expiry time: 24 hours * Usage: Differentiation of website visitors * Example value: GA1.2.1687193234.152211077756 * \_gat\_gtag\_UA\_ * Expiry time: 1 minute * Usage: Used to throttle the request rate. If Google Analytics is provided through Google Tag Manager, this cookie will be named \_dc\_gtm\_ . * Example value: 1 For more information about Terms of Use and Privacy, please visit or . #### **7.2** **Pseudonymisation** Our concern in the sense of the DSGVO is the improvement of our offer and our web appearance. Since the privacy of our users is important to us, the user data is pseudonymised. The data processing takes place on the basis of the legal regulations of the § 96 Abs 3 TKG as well as the kind 6 EU-DSGVO Abs 1 a) (consent) and / or f (legitimate interest) of the DSGVO. #### **7.3 Deactivation of Data Collection by Google Analytics** The browser add-on to disable Google Analytics JavaScript (ga.js, analytics.js, dc.js) allows site visitors to prevent Google Analytics from using their data. You may prevent the collection by Google of the data generated by the cookie and related to your use of the website as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: #### **7.4 Google Analytics Addendum to Data Processing** We have entered into a direct customer agreement with Google for the use of Google Analytics by accepting the “Data Processing Supplement” in Google Analytics. To read more about the Google Analytics Add-on, please visit #### **7.5 Google Analytics Demographics and Interest Reports** We’ve turned on the advertising reporting features in Google Analytics. The demographics and interest reports include age, gender, and interests. This allows us – without being able to assign this data to individuals – to get a better picture of our users. Learn more about the advertising features at . You can stop using your Google Account’s activities and information under “Advertising settings” at via checkbox. #### **7.6 Google Analytics Deactivation Link** By clicking on the following deactivation link, you can prevent Google from recording further visits to this website. Attention: The deletion of cookies, the use of the incognito / private mode of your browser, or the use of another browser results in the collection of data again. [Deactivate Google Analytics](https://developers.google.com/analytics/devguides/collection/analyticsjs/user-opt-out) # 8.0 Social Media Presence Is data processed on social media platforms and if so, who is responsible? #### **8.1 General declarations** MYKOBO maintains a social media presence on a number of different platforms (see below) in order to communicate with our customers, prospective customers and interested social media users of MYKOBO's services, products and other news. When you access such social media platforms, the general terms and conditions, as well as the privacy policies of these operators, additionally apply. We would like to point out that user data may also be processed outside the European Union. This can result in risks for users due to different legal frameworks (e.g. it could make it more difficult to enforce data subject rights). As part of the technical process of different social media platforms (e.g. Google, Facebook, Twitter, LinkedIn etc.), these platforms will know when you click on content or a website you are visiting, if you are logged in to your social media account at the same time. Such information is collected by social media platforms and assigned to your social media accounts, regardless of whether you click on content of this platform or not. By logging out from your accounts, you can prevent such companies from associating the information collected with your accounts. The activities of those companies are not controlled by MYKOBO and therefore, we do not assume any liability for damages that you may incur through the use of your data by these companies. For more information regarding tracking, cookies and similar technologies as well as opt-out possibilities, have a look at our section [5.0 Cookie Policy](/cookie-policy). #### 8.2 Controlling the data MYKOBO can only process personal data of social media users if they communicate directly with MYKOBO via such platforms (e.g. number of visitors, posted articles, likes, direct messages, customer inquiries, support requests, comments, etc.). In such cases, MYKOBO is also responsible for the processing of personal data gathered there. In addition to the data processing by us, other providers, in particular operators of social networks and platforms, also process personal user data. We have no influence on this data processing and are not responsible for it - the data processing takes place exclusively in the area of responsibility of the other providers. For a detailed explanation of the respective processing and the possibilities of objection (opt-out) by providers of social media networks, we refer to the respective privacy policies of the providers (see below). In the case of requests for information and the assertion of data subject rights regarding data processing by other providers, we point out that these can be asserted with the below-mentioned providers. Only the providers have access to the data of the users and can directly take appropriate measures and give information. **8.3 Our social media pages and channels and links to their privacy policies:** | Social Media Channel | Privacy Policy | Active/Inactive | | --------------------------------------------------- | ------------------------------------------------------------------------- | ------------------------------- | | [Twitter](https://twitter.com/myk0b0) | [Link](https://twitter.com/en/privacy) | Active | | [Medium](https://medium.com/@myk0b0) | [Link](https://policy.medium.com/medium-privacy-policy-f03bf92035c9) | Active | | [LinkedIn](https://www.linkedin.com/company/myk0b0) | [Link](https://www.linkedin.com/legal/privacy-policy) | Active | | [Discord](https://discord.gg/6ByPsKGFWR) | [Link](https://discord.com/privacy) | Active | | [Instagram](https://www.instagram.com/myk0b0) | [Link](https://help.instagram.com/519522125107875) | Active, not regularly monitored | | [Reddit](https://www.reddit.com/r/myk0b0) | [Link](https://www.redditinc.com/policies/privacy-policy#section_cookies) | Active, not regularly monitored | # 9.0 Email Communication Newsletters, Emails and General Communication What’s the legal basis for electronic notifications and how to unsubscribe? At MYKOBO we have three processing routes to which you can receive email communication from us. These are as follows: #### 9.1 Transactional emails These are emails which are of a transactional nature, meant to only inform you of critically important details surrounding your activity in our MYKOBO app, but as well via our API anchor service if you are possibly interacting with it via one of our business partners It is not possible to opt out of these specific kind of emails given they are part of the regular service that comes with our product offerings (MYKOBO App, MYKOBO Anchor API). he only way to opt out is to terminate your account with us or with any of our partners who are plugged into our API service. Overall, these kinds of emails usually involve summaries of your most recent transaction of buying/selling EURC, sending, receiving or swapping transactions, password resets, and any other message that is related to the everyday functioning of our service to you. Such messages will only be delivered upon you as the customer taking an action that warrants one of these transactional emails. For this messaging service we use Mailgun Technologies, Inc. (112 E Pecan St #1135, San Antonio, TX 78205) in order to provide a reliable service. #### 9.2 App critical messaging emails These are emails which are different to the nature of a transactional email and the newsletter/general marketing update emails. When you sign up to our app service, you as the customer will be added to this specific email group. The nature of these emails are only for very important updates regarding the app or our services that you need to be aware of in order to continue using our service. It could also involve any kinds of technical issues that become important for you to be notified of. We desire to give you the best possible service so for us these kinds of emails are also not possible to opt out of given the mission critical/app critical nature. We trust that in order for us to provide you with the best possible service, when you sign up to our app, you agree to be added to this email notification service. For this service we use UAB MailerLite (J. Basanavičiaus 15, LT-03108 Vilnius, Lithuania) as our service provider. #### 9.3 Newsletters and general marketing update emails. In our email newsletter and our general marketing update emails, we inform you about MYKOBO’s services and products. If you would like to receive our newsletter, you have to subscribe with your email address. We send newsletters and other general marketing update emails only with your express consent if you’ve subscribed for it (double opt-in). We have two routes to which you can be signed up to our newsletter and general marketing emails. 1. Via our website and the sign up form. With this procedure we have a double opt-in active to check whether you are the holder of the email address given or if its holder agrees with receiving electronic notifications. This procedure serves as proof in case a third party misuses an email address through registering to receive the newsletter without the knowledge of the entitled party. 2. The second route is by signing up to use our service and our app, you thereby agree to be signed up to the newsletter. As we have an email check to also verify you are the holder of the email address upon signing up, this acts as well as a double opt-in to confirm you are the holder of the email address. Of course, it is possible at any time upon receiving our first email newsletter to opt out and remove yourself from the list by following the unsubscribe link in the email. Our Newsletter and general marketing updates are created using third party software company called UAB MailerLite (J. Basanavičiaus 15, LT-03108 Vilnius, Lithuania) and in the newsletter so-called web beacons (also called ClearGIFs or tracking pixels) might be used. Such web beacons provide us with a better understanding of our customers interactions with our newsletters and general marketing communication. They fulfil a similar function as cookies, but they are not visible to users. Information can be obtained via web beacons, in particular about whether an email was opened and whether the user’s system is capable of receiving HTML emails. You may unsubscribe from our newsletter, e.g. by withdrawing your consent, at any time via the unsubscribe link on each message and newsletter. Please note that we will continue to process your personal data until you withdraw your consent to the storage of the data, so that we can prove consent previously given to receive newsletters. The processing of this data is limited to the purpose of a possible defence against claims and you shall have the right to request the deletion of your personal data.