Effective as of 1st Day of July, Month, 2025

This Privacy Policy outlines how BitZup Exchange Limited or BitZup platform collects, uses, and processes your personal information through the BitZup websites, applications, and platforms that reference this Policy. The terms " we," "us," and "our" refer collectively to BitZup and its affiliates. BitZup encompasses a range of services delivered through its ecosystem, including but not limited to the website (e.g., www.Bitzup.com), mobile applications, desktop clients, applets, and any other platforms or tools developed to provide BitZup Services as defined in our Terms of Use.

The term "BitZup Operators" refers to all entities operating under the BitZup brand, including but not limited to legal entities, unincorporated organizations, and teams that deliver BitZup Services and bear responsibility for those services.

This Privacy Policy governs all activities involving the processing of personal information across all platforms, websites, applications, and departments managed by Bitzup and its Operators. When we request personal information from users, it is either to comply with legal obligations or to fulfil specific, legitimate operational purposes. Any personal information you voluntarily provide beyond mandatory requirements is given at your discretion.

If you are a customer or user of our services, this Privacy Policy applies in conjunction with our Terms of Use, Risk Disclosure Statement, and any other applicable contractual documents, agreements, or policies. If you do not agree with the terms set out in this Privacy Policy regarding how your personal information is handled, you must refrain from using BitZup services, products, software, APIs, or any associated features.

Given that personal information may be collected from various jurisdictions, you expressly consent to the transfer of your personal data to countries or regions outside of your own. If you do not consent to such transfers, your sole remedy is to discontinue use of BitZup services and terminate your account.

This Privacy Policy forms an integral part of BitZup’s Terms of Use, Risk Disclosure Statement, and all related agreements, policies, guidelines, and notices.

BITZUP RELATIONSHIP WITH YOU

• 1. For the purpose of this Privacy Policy, BitZup is the data controller for personal information collection in connection with the provision of BitZup Services.
• 2. In this Privacy Agreement, “Personal Information” means any information relating to an identified or identifiable nature person, including, but not limited to, a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, economic, cultural or social id‘BitZup’ of you are a natural person.

INFORMATION COLLECTED AND PROCESSED BY THE ‘BitZup’

BitZup collects, processes and stores Personal Information collected from you via your use of the ‘BitZup’ Services or where you have given your consent. The Personal Information may include:

• 1. Email address(es)
• 2. Name
• 3. Gender
• 4. Date of Birth
• 5. Address
• 6. Phone number
• 7. Nationality
• 8. Device ID
• 9. A video recording of you and a photographic image
• 10. Transactional information
• 11. The Internet protocol (IP) address used to connect your computer to the Internet
• 12. Time zone
• 13. Information about your activity on Bitzup we may process about you on your behavior and your activity for marketing and advertising purposes.

REASONS FOR STORING PERSONAL INFORMATION

BitZup collects, processes and stores your Personal Information in accordance with various regulations around the world to which we are subject. As these regulations are amended from time to time, we are similarly required to ensure that our practices are up to date by amending this Privacy Policy when necessary or required.

We collect Personal Information you provide during the BitZup onboarding process. We may also collect Personal Information:

• 1. When you communicate with us through our customer support portal or via email or other communication channels.
• 2. To communicate with you about orders and services.
• 3. To prevent and detect fraud and abuse to protect the security of ourusers.

RESTRICTION OF USE

BitZup does not allow anyone under the age of 18 to use BitZup Services and does not knowingly collect Personal Information from children under 18.

WHEN THE PERSONAL INFORMATION WOULD BE SHARED

BitZup We may share your Personal Information with third parties if we believe that sharing the same is in accordance with, or required by, any contractual relationship with you or us, applicable law, regulation or legal process.

1. We may also share your Personal Information with third parties:

• If it is necessary to enforce our Terms of Service.
• To comply with government agencies, including regulators, law enforcement and/or justice departments.
• If such third parties provide services to BitZup (for e.g., administrative or technical service providers)
• In connection with any sale of BitZup and/or BitZup Services and acquisitions of other businesses or services.
• To protect users or others, this includes but is not limited to exchanging information with other companies or organisations for fraud protection and credit risk reduction.

2. Notwithstanding the foregoing, BitZup may disclose your Personal Information to a third party or parties where there is sufficient grounds to believe, based on BitZup’s sole discretion, that you have violated applicable laws or regulations giving rise to a justification of such disclosure, or wherefore the disclosure of Personal Information would facilitate the conclusion of, inter alia, a dispute settlement process, a judicial or administrative investigation or a trade carried out on BitZup.

MEASURES TO ENSURE THE SECURITY OF YOUR INFORMATION

1. We design our systems with your security and privacy in mind. We have appropriate security measures in place to prevent your information from being accidentally lost, used or accessed in an authorized way, altered or disclosed. We work to protect the security of your personal information during transmission and while stored by using encryption protocols and software. We maintain physical, electronic and procedural safeguards in connection with the collection, storage, and disclosure of your personal information. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties on a need-to-know basis.

2. Our security procedures mean that we may ask you to verify your id BitZup to protect you against unauthorized access to your account password. We recommend that you use a unique password for your BitZup account that is not utilized for other online accounts and to sign off when you finish using a shared computer.

ADVERTISING AND MARKETING

In order for us to provide you with the best user experience, we may share your personal information with our marketing partners for the purposes of targeting, modelling and/or analytics as well as marketing and advertising.

You have the right to object to our use of Personal Information for advertising and marketing purposes. Please write to [email protected]’ to process your objection

ACCESS, CORRECTION, AND DELETION OF YOUR PERSONAL INFORMATION

1. You have the right to obtain a copy of your Personal Information upon request and ascertain whether the information we hold about you is accurate and up-to-date. In addition, when you consent to our processing of your Personal Information for a specified purpose, you may withdraw your consent at any time.

2. If you wish to exercise any of your rights to either access, correct or delete Personal Information, please contact us at [email protected]. You agree that these rights may be limited in some situations, for example, where we can demonstrate we have legitimate interest to process your Personal Information.

3. In response to any request to access, correct or delete Personal Information, you agree, for your own protection as well as ours, that we shall only be able to respond to such requests provided we receive proper and verified authorization from the Personal Information owner. In this connection, you agree that before we respond to any request to access, correct or delete Personal Information, we will take all steps necessary in our sole discretion to carry out verification of the requester’s id Bitzup to ensure the legitimacy of the request. These steps may include, but are not limited to:

• Telephone call-back
• Email response from requester’s email address on record
• Any other procedure as we may in our discretion require.

4. You agree that, given the sensitive nature of such requests, coupled with potential cross-border time differences, BitZup shall not commit to a timeline within which such requests can be fulfilled, save to the extent under applicable or in a reasonable timeframe, determined at the sole discretion of BitZup. You therefore agree that BitZup will not be liable for any loss or damage however arising as a result of an untimely response to your request.

5. BitZup reserves the right to charge a reasonable fee for Personal Information requests which prove to be onerous, repetitive or require additional resources to be complied with.

RETENTION OF PERSONAL INFORMATION:

‘BitZup’ stores your information securely throughout the life of your BitZup Account. ‘BitZup’ will retain your personal information for a minimum of six (6) years, or as necessary to comply with ENTITY’s legal and regulatory obligations, or as needed in order to resolve any disputes.

Personal Information is kept to enable your continued use of BitZup Services and/or for as long as it is required in order to fulfil the relevant purposes described in this Privacy Policy, and/or as may be required by law either for tax and accounting purposes and/or compliance with Anti-Money Laundering laws.

ACCOUNT DELETION

• 1. You may request for your BitZup account to be deleted at any time, subject to applicable laws.
• 2. Take Notice: The deleted BitZup account cannot be recovered once it is deleted. To protect your rights and interest against fraud or other malicious acts, we have in place strict procedures to ensure that the application to delete your account is bona fide and remind you of the risks of deleting your account before and during the account deletion process.
• 3. The deletion of a BitZup account does not mean that all account operations, responsibilities and/or liabilities are avoided. All records and information associated with your account will be deleted. However we may retain certain Personal Information pertaining to your account according to the provisions of this Privacy Policy and/or required by applicable laws and regulations.

CONTACT INFORMATION

• 1. Our data protection officer can be contacted at [email protected], and will work to address any questions or issues that you have with respect to the collection and processing of your Personal Information.
• 2. If you have any requests and comments, you can send an email to [email protected] with the subject “INQUIRY OF PERSONAL INFORMATION”, which is the only valid and official email through which we will communicate with you