CCFOUND

PRIVACY POLICY

This Privacy Policy sets out the rules for the processing of Users' personal data in relation to activities performed on the Platform, in accordance with the provisions of the Terms and Conditions. This Privacy Policy is an attachment to the Terms and Conditions available on the Platform beta.ccfound.com/

All terms included in this Privacy Policy should be interpreted in accordance with the provisions of the Terms and Conditions, unless their different meaning has been clearly indicated in this document.

I. DATA PROCESSING

By submitting data from the User to the Service Provider, with regard to the use of the Site, the User agrees to the following to place his/her personal data in the Service Provider's database and to process them for the purpose of providing the Services under these Regulations.

The Administrator of Personal Data is acting jointly:

1)

CC FOUND Education & Training Computer Software (License no.: 952117) with registered office at. Marina Plaza 1302, Marsa Avenue, P.O. Box 283 691 Dubai, United Arab Emirates;

2)

CCFOUND EDUCATION AND TRAINING COMPUTER SOFTWARE LIMITED (License No.: CL5622) with. Headquartered at Dubai International Financial Centre, Unit GD-PB-04-06-OF-13 Level 6 Building Name Gate Precinct Building 04, Dubai, United Arab Emirates;

collectively referred to as "Administrator" or "Service Provider". Contact with the Administrator is available at:support@ccfound.com

Personal data are processed in accordance with the Regulation of the European Parliament and of the Council (EU) 2016/679 of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation - hereinafter "RODO"), the Law on Personal Data Protection of May 10, 2018. (Journal of Laws of 2018, item 1000), and the Act on Providing Electronic Services of July 18, 2002 (Journal of Laws of 2017, item 1219, as amended).

The Administrator processes personal data in accordance with the requirements of applicable law, including in particular the Privacy Protection Laws in the United Arab Emirates regarding the security of personal data. The User is responsible for providing false personal data. By accepting the Privacy Policy, the User agrees to the terms of collecting, processing and securing personal data related to the use of the Website.

II. RESPECT FOR PRIVACY

The Service Provider makes every effort to ensure that personal data is processed with the greatest respect for the privacy of the data provider and with the utmost care for the security of personal data processed, and in particular ensures that all legal measures are taken to protect the collected personal data.

III. MEASURES APPLIED

The Service Provider declares that he uses technical and organizational measures to ensure protection of the processed personal data appropriate to the threats and categories of data protected, and in particular protects the data against unauthorized disclosure, processing in violation of the law and its loss, damage or destruction.

IV. SCOPE AND PURPOSE OF PROCESSING

The Service Provider processes the User's personal data for the purpose of:

1.

Establishing, changing, performing or terminating the contractual relationship between the Service Provider and the User

2.

fulfillment of the Administrator's legal obligations

3.

marketing and advertising of the Services, as well as sending commercial information

4.

the use of ICT end devices and automatic triggering systems for marketing purposes

V. DATA PROFILING

The processing of personal data includes profiling of Users in terms of their behavior, interests, payment credibility and shopping preferences. On the basis of profiling, Users are provided with specific content that may potentially be of interest to them.

VI. DATA SHARING

In order to perform the Agreement, the Administrator may share the collected personal data with entities, including: employees, associates, a courier company, Internet payment system operators, entities providing operational, legal, accounting and IT services to the Service Provider, as well as entities personally or financially related to the Service Provider. In such cases, the amount of information disclosed is limited to the necessary minimum.

VII. TRAFFIC ANALYSIS IN THE SERVICE

The Service Provider declares that he may use tools for analyzing traffic on the Website, such as Google Analytics and other similar ones. In particular, the Service Provider has the right to collect information about the User's activity and behavior, such as visiting the Website and using the Services. The Service Provider uses this data to research the market and traffic on the Website, as well as to create statistics, in particular to assess the interest in the posted content, as well as to improve the Website and fulfill obligations in the field of anti-money laundering and counter-terrorist financing. The collected data will be processed anonymously and used only for statistical purposes or to ensure proper use of the Website.

VIII. TERMINATION OF THE USE OF THE SERVICE

After the termination of the Agreement by the User, the Service Provider does not process the User's personal data, except for:

1.

statements made by the User on the basis of this Policy and the Terms and Conditions

2.

advertising, market and behavior research to improve the quality of services provided

3.

explanation of circumstances inconsistent with this Policy and Terms and Conditions or the right to use the Website or Services provided on the Website

4.

authorization to process the data on the basis of an agreement or separate legal provisions.

IX. USER RIGHTS

The Service Provider ensures that the applied conditions for the processing of personal data are consistent with the Users' rights resulting from applicable law, in particular the right to access, correct, update, delete, limit processing, transfer own data, raise objections, withdraw consent, and submit a complaint to the supervisory authority. Inquiries regarding the Privacy Policy and personal data are considered in accordance with the complaint procedure specified in the Terms and Conditions.

X. SCOPE OF DATA

The Service Provider processes or may process the User's personal data, respectively in the scope of data provided by the User, including in particular identification and contact details.

XI. BROWSING THE WEBSITE

Browsing the Website does not require providing personal data by the User, unless access to specific content or services depends on its provision.

XII. RULES OF DATA PROCESSING

The Service Provider adheres to the following rules for the processing of personal data

1.

saving the collected personal data only on such storage media that are protected against access by third parties

2.

reporting personal data files or designating persons performing the required duties for this purpose

3.

supervision over the security of personal data throughout the period of its possession in order to ensure, in particular, protection against unauthorized access, damage, destruction or loss

4.

sharing personal data with competent authorities on the basis of applicable law

5.

maintaining the confidentiality of personal data.

Personal data processed by the Service Provider is not made available in a form that allows any identification of the User, unless the User has consented to it or the obligation to disclose such information results from applicable law.

XIII. COOKIES

Types of Cookies

The Service Provider may use the following types of cookies on the Website and in the App:

1.

temporary, which are deleted after leaving the Website or turning off the web browser

2.

permanent, which are stored on the User's end device for an indefinite period or until they are manually deleted by the User

3.

statistical data that tracks traffic on the Website

4.

functional, enabling personalization of the website in relation to the User

5.

advertisements that enable the delivery of content to the User tailored to their personal preferences

6.

mandatory and security, which relate to the principles of security on the Website and the principles of authentication.

Purposes of use

The Service Provider uses cookies for the following purposes:

1.

optimizing and increasing the efficiency and quality of the Services

2.

correct configuration of the functions available on the Website and in the App

3.

personalization of the displayed content and matching of advertisements to people visiting the Website and the App

4.

after logging in to maintain the User's session on the Website and in the App, thanks to which the User does not have to re-enter the login and password on each subpage

5.

maintaining the security and reliability of the Website and the App

6.

collecting and using general and publicly available statistical data using analytical tools.

Analysis

To ensure the highest quality, cookies are analyzed to determine which subpages are visited most often, which browsers are used by visitors and whether the structure of the Website is error-free

Cooperation with entities

Cookies stored on the User's end device may be used by other entities that affect the quality of the Services provided. The User may at any time change their own cookie settings, specifying the conditions for storing and granting access to cookies on the User's device. The User has the option to change the settings referred to above using the web browser settings or by configuring the Services. These settings can be changed in such a way as to block the automatic activity of cookies in the web browser or inform the User about the placement of a cookie file on the User's device.

User rights

Users may at any time delete cookies using the settings available in the web browser they use. Limiting or blocking cookies by the web browser used will not prevent Users from using the Website, however, it may cause difficulties or malfunctions in the operation of the Website, for which the Service Provider is not responsible. It is recommended to use software that enables cookies.

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