Unicoin Group California Privacy Policy (“California Privacy Policy”) is effective as of March 23^rd, 2021. Please note that this California Privacy Policy will regularly be updated to reflect any changes in the way we handle your personal information or any changes in applicable laws.

1. SCOPE

This California Privacy Policy applies to California residents whose personal information is bien processed by TB Inc., Yandiki Inc., Sheworks Inc., and/or its affiliates, subsidiaries and newly acquired companies (indistinctively "Unicoin" or "we"). This California Privacy Policy, which is pursuant to the California Consumer Privacy Act (“CCPA”), tells you everything you need to know about how we protect the personal information we process and control relating to a California resident (“your personal information”; "your information") and which rights you have in relation to the processing of your personal information.

If you are not a California resident, this California Privacy Policy does not apply to you. In that case, please refer to the TransparentBusiness Group Privacy Policy.

2. GENERAL DESCRIPTION OF HOW Unicoin PROTECTS YOUR PERSONAL INFORMATION

It is of great importance to Unicoin, your right to privacy, and the protection of your personal data. We want you to trust that your personal data is secure when you deal with Unicoin, your personal data is in good hands.

Unicoin protects your personal data in accordance with applicable laws and our Privacy Policy. In addition, Unicoin maintains the best technical and organizational measures to protect your personal data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure, or access, or accidental or unlawful destruction of or damage thereto.

2.1. Which categories of personal information do we collect and how do we process such personal information?

The personal data collected comes from, but is not limited to, our employees, potential employees, clients, suppliers, business contacts, partners, ambassadors, shareholders, and website users (the “individuals). If the data we collect is not listed in this Privacy Policy, we will give individuals (when required by law) appropriate notice of which other data will be collected and how they will be used. However, all individuals shall be deemed to have accepted this Privacy Policy by using or entering any of the Unicoin websites.

The personal information we collect includes the categories of personal information referred to in this California Privacy Policy or in other statements you have received.

Below is also a chart describing the categories of personal information we collect in the context of the processing activities described in this California Privacy Policy.

General Categories
Category of personal information	Types of personal information captured by category
Personal details, contact details, and identifiers.	Name, pronoun, all types of identifiers and contact details (such as e-mail, phone numbers, physical address), gender, date of birth, age, place of birth.
Commercial information.	History and records of the services and softwares you have obtained from Unicoin.
Marketing and research information	Identifiers – the IP address, social media handle or other online identifiers of a person, e-mail address/mobile number if used for direct marketing, and name and address. Demographic information - (e.g., income, family status, age bracket, gender, interests, pets, home ownership, health, current service providers) Browser/web history information and preferences expressed through selection/viewing/purchase of goods, services, and content. Social media content – blogs, posts and anything posted by an individual online or which mentioned/references an individual. Analytics and profiles of the individuals based on the information collected on them
Sensitive information and biometric information.	Unicoin may also collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status and dietary requirements/allergies in the framework of the events we organize/sponsor) or biometric information, for example as when you elect to use fingerprint authentication.
Audiovisual materials.	Photograph, and images/footage captured/recorded on CCTV or other audio, video and related security monitoring systems or captured during marketing/public filming events/sessions (including recording of virtual or live workshops or similar events/sessions).
Position and professional or employment-related information.	Professional or employment-related information, such as description of current position, job title, employer, location, and Unicoin contact(s).
System and application access information and Internet and electronic network activity information.	Where you are provided with access to Unicoin’s systems, Unicoin may collect information required to access such Unicoin systems and applications such as System ID, LAN ID, e-mail account, instant messaging account, mainframe ID, system passwords, and internet or other electronic network activity information, including access logs, activity logs, and electronic content produced using Unicoin systems.
Cookies and geolocation information	As described below, we also may collect geolocation information in some circumstances. Please see our Cookies Policy for more details regarding our use of cookies.

In addition, for recruitment/employment and vendor selection purposes, Unicoin may process the personal information set out in the below table.

Recruiment/Employment/Vendor Selection Categories
Category of personal information	Types of personal information captured by category
Additional personal details, contact details and identifiers.	In addition to the personal details listed above, Unicoin may collect additional personal details such as, but not limited to, national identification number, social security number, insurance information, marital/civil partnership status, domestic partners, dependents, emergency contact information, and military history.
Education information and professional or employment-related information.	Unicoin may collect information about your education and professional or employment-related information, such as your employment history.
Sensitive information for recruitment purposes.	Unicoin may collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status), trade union membership information, religion, race or ethnicity, minority flag, and information on criminal convictions and offences. Unicoin collects this information for specific purposes, such as health/medical information to accommodate a disability or illness (subject to legal limits on the timing of collection of such information and other applicable limitations) and to provide benefits; background checks and diversity-related personal information (such as race or ethnicity) in order to comply with legal obligations and internal policies relating to diversity and anti-discrimination.
Documentation required under immigration laws.	Unicoin may collect information on citizenship, passport information, and details of residency or work permit (a physical copy and/or an electronic copy).
Financial information for payroll/benefits purposes	Your banking, tax (when applicable), and other relevant financial details we need for payroll/benefits purposes.
Talent management information.	Information necessary to complete a background check, details on performance decisions and outcomes, performance feedback and warnings, e-learning/training programs, performance, and development reviews (including information you provide when asking for/providing feedback, creating priorities, updating your input in relevant tools), driver’s license and car ownership information, and information used to populate biographies.
Requested recruitment information	Information requested to provide during the recruitment process, to the extent allowed by applicable law.
Recruitment information you submit	Information that you submit in résumés/CVs, letters, writing samples, or other written materials (including photographs).
Information generated by us during recruitment	Information generated by interviewers and recruiters related to you, based on their interactions with you or basic Internet searches where allowed under applicable law.
Recruitment information received from third parties	Information related to you provided by third-party placement firms, recruiters, or job-search websites, where applicable.
Audiovisual information processed during recruitment	Photograph, and images/audio/footage captured on CCTV or other video systems when visiting our office or captured during recruitment events or video recruitment interviews.
Recommendations	Recommendations related information provided on your behalf by others.
Employment history and background checks	Information about your prior employment, education, and where applicable and allowed by applicable law, credit history, criminal records or other information revealed during background screenings.
Diversity related information	Information about race / ethnicity / religion / disability / gender and self-identified LGBT status, for purposes of government reporting where required by law, as well as to understand the diversity characteristics of the Unicoin workforce, subject to legal limits.
Assessment information	Information generated by your participation in psychological, technical, or behavioral assessments. You will receive more information about the nature of such assessments before your participation in any of them.

We also may derive inferences about you based on the information described above and collect other information about you as described in this California Privacy Policy.

If you provide us with personal information of another person (for instance, a potential employee/referral), you are responsible for ensuring that such person is made aware of the information contained in this California Privacy Policy and that the person has given you his/her consent for sharing the information with Unicoin.

The above-mentioned categories of personal information have been obtained either directly from you (for example, when you provide information to be contacted, register as a user or become a partner) or indirectly from certain third parties (for example, through our website’s technology). Such third parties include our affiliates, public authorities, public websites and social media, suppliers, and vendors. Except where certain information is required by law or by Unicoin policies (including management of an employment relationship with Unicoin), your decision to provide any personal information to us is voluntary. Please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this California Privacy Policy, and you may not be able to use certain tools and systems which require the use of such personal information.

2.2. For which purposes and on which legal basis do we use your personal information?

Unicoin uses your personal information only where required for specific purposes. Please view the table below for (i) a list of the purposes for which Unicoin uses your personal information and (ii) an overview of the legal basis for each such purpose.

Purpose	Legal basis
Managing our contractual and/or employment relationship with you.	Necessary for 1) the performance of a contract or similar arrangement to which you are a party or 2) managing your employment relationship with Unicoin.
Facilitating communication with you (including in case of emergencies, and to provide you with requested information).	Justified on the basis of our legitimate interests for ensuring proper communication and emergency handling within the organization.
Operating and managing our business operations.	Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.
Complying with legal requirements.	Necessary for the compliance with a legal obligation to which we are subject.
Monitoring your use of our systems (including monitoring the use of our website and any apps and tools you use).	Justified on the basis of our legitimate interests of avoiding non-compliance and protecting our reputation.
Research in general and market research.	Justified on our legitimate interest to gain market insights and insights in business and society in general or, where required, the consent of the relevant subjects.
Social listening (Identifying and assessing what is being said about Unicoin and our clients on social media (only publicly accessible content) to understand sentiment, intent, mood and market trends and our stakeholders’ needs and thereby improving our services. We do this through key-word searches and our goal is to gain insights in conversation trends over a specified period and not to identify an individual. To achieve this, we analyze and monitor conversation streams and monitor publicly available opinions, statements or other interactions on social media channels.)	Justified on the basis of our legitimate interest of protecting our assets and our brand on social media
Ethnographic videography – this is video recording of the activity of individuals in their natural environment, in order to experience, interpret and understand behavior. This may be part of a campaign or project.	Justified on the consent of the relevant subjects.
Improving the security and functioning of our website, networks and information.	Justified on the basis of our legitimate interests for ensuring that you receive an excellent user experience and our networks and information are secure.
Undertaking information analytics, i.e. applying analytics to business operations and information to describe, predict and improve business performance within Unicoin and/or to provide a better user experience.	Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.
Marketing our products and services to you	Justified on the basis of our legitimate interests for ensuring that we can conduct and increase our business.
Specific Recruitment/Employment/Vendor Selection Purposes	Legal basis
Assess your suitability for employment for the role for which you are applying, as well as future roles that may become available.	Justified on the basis of Unicoin’s legitimate interests of ensuring that it recruits the appropriate employees.
Manage your application.	Justified on the basis of Unicoin’s legitimate interests of ensuring that it recruits the appropriate employees.
Facilitate communication with you.	Justified on the basis of Unicoin’s legitimate interests of ensuring proper communication within the organization and with you.
Perform administrative functions (e.g. reimburse you for interview-related expenses).	Justified on the basis of Unicoin’s legitimate interests of ensuring that it recruits the appropriate employees.
Perform information analytics, including analysis of our applicant pool in order to better understand who is applying to positions at Unicoin and how to attract and keep top talent.	Justified on the basis of Unicoin’s legitimate interests of ensuring that it continually improves its recruitment processes.
In some cases, record your online interview for review by additional recruiters and hiring managers.	Justified on the basis of Unicoin’s legitimate interests of ensuring that it recruits the appropriate employees.
If you apply for a position in Unicoin, we may enter you into a information base to receive future mailings about Unicoin positions and events. You may also receive personalized job recommendations.	Justified on the basis of Unicoin’s legitimate interests of ensuring that it recruits the appropriate employees.
Transfer your contact information, education information, employment information, application information and the CV, all as supplied by you to our HR team in order to notify you about new positions that may be of interest to you.	Justified on the basis of Unicoin’s legitimate interests of ensuring that it recruits the appropriate employees.
Administration of employee benefits	Justified on the basis of Unicoin’s legitimate interests of ensuring that our employees receive the applicable benefits.
Perform any legally-required reporting and respond to legal process.	Compliance with a legal obligation.

Legitimate interest means that Unicoin has reasonable grounds to process your personal information. Where the above table states that we rely on our legitimate interests for a given purpose, we are of the opinion that our legitimate interests are not overridden by your interests, rights, or freedoms, given (i) the transparency we provide on the processing activity, (ii) our privacy by design approach, (iii) our regular internal privacy reviews and (iv) the rights you have in relation to the processing activity.

We will process your personal information for the purposes mentioned above based on your prior consent, to the extent such consent is mandatory under applicable laws. To the extent you are asked to click on/check “I accept”, “I agree” or similar buttons/checkboxes/functionalities in relation to one of our privacy policies, doing so will be considered as providing your consent to process your personal information, only in the countries where such consent is required by mandatory law. In all other countries, such action will be considered as a mere acknowledgement and the legal basis of the processing of your personal information will not be your consent but any other applicable legal basis.

We will not use your personal information for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so.

2.3. Will we share your personal information with third parties?

We may transfer personal information to our service providers and professional advisors, public and governmental authorities, Unicoin companies/affiliates or third parties in connection with Unicoin’s operation of its business, including any (potential) corporate or commercial transaction. Such third parties may be located in other countries. Before we do so, we shall take the necessary steps to ensure that your personal information will be given adequate protection as required by relevant information privacy laws and Unicoin’s internal policies. Unicoin may also transfer your personal information to any of its global affiliates/partners in furtherance of any visits to our Unicoin locations.

For example, we may disclose personal information to third parties for other business purposes as follows:

• We share your information with third-party service providers that provide services to us, including billing, payment processing, customer service, email deployment, advertising and marketing, security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, information hosting, auditing, and information processing;
• To protect and defend the legal rights, safety, and security of Unicoin, our affiliates, users, or the public, including to protect against fraud and malicious activity;
• For other business purposes described in this California Privacy Policy or for any other purpose disclosed to you at the time we collect the information or pursuant to your consent; and
• In connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of a bankruptcy.

Unless you are otherwise notified, any transfers of your personal information from within the European Economic Area (EEA) to third parties outside the EEA will be based on an adequacy decision or are governed by the standard contractual clauses. Any other non-EEA related transfers of your personal information will take place in accordance with the appropriate international information transfer mechanisms and standards.

2.4. What about sensitive information?

We do not generally seek to collect sensitive information (as defined in the second below) (also known as special categories within the EEA). In the limited cases where we do seek to collect such information, we will do this in accordance with information privacy law requirements and/or ask for your consent.

The term "sensitive information" refers to the various categories of personal information identified by information privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic information, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).

2.5. What about information security?

We maintain organizational, physical, and technical security arrangements for all the personal information we hold. We have protocols, controls and relevant policies, procedures, and guidance to maintain these arrangements considering the risks associated with the categories of personal information and the processing we undertake.

2.6. Where will your personal information be processed?

As a global organization with offices and operations throughout the world, personal information we collect may be transferred or be accessible internationally throughout Unicoin's global business and between its entities and affiliates.

Any such transfers throughout Unicoin’s global business take place in accordance with the applicable information privacy laws.

2.7. What are the sources we get your personal information from?

If we do not obtain your personal information directly from you, we may obtain it from the following sources: publicly available sources (registers or the internet), Unicoin’s actual and potential employees, contractors, partners, investors, members of board of directors, shareholders, Unicoin’s affiliates, subsidiaries and newly acquired businesses, employers of our contractors, public authorities, public websites and social media, previous employers, educational institutions, suppliers and vendors (including third party information providers).

2.8. How long will your personal information be retained by us?

We will retain your personal information only for as long as is necessary. We maintain specific records management and retention policies and procedures, so that personal information are deleted after a reasonable time according to the following retention criteria:

• We retain your information if we have an ongoing relationship with you. This includes, for example, Unicoin’s actual and potential employees, contractors, partners, investors, members of board of directors, shareholders, Unicoin’s affiliates, subsidiaries and newly acquired businesses, employers of our contractors.
• If you have a user account with us, we will only keep the information while your account is active or for as long as needed to provide services to you.
• We retain your information for as long as needed to comply with applicable law, with our global legal, and contractual obligations.

2.9. Which rights do you have with respect to the processing of your personal information?

You are entitled (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:

• Request access to the personal information we process about you: this right entitles you to know whether we hold personal information about you and, if we do, to obtain information on and a copy of that personal information.
• Request a rectification of your personal information: this right entitles you to have your personal information be corrected if it is inaccurate or incomplete.
• Object to the processing of your personal information: this right entitles you to request that Unicoin no longer processes your personal information.
• Request the erasure of your personal information: this right entitles you to request the erasure of your personal information, including where such personal information would no longer be necessary to achieve the purposes.
• Request the restriction of the processing of your personal information: this right entitles you to request that Unicoin only processes your personal information in limited circumstances, including with your consent.
• Request portability of your personal information: this right entitles you to receive a copy (in a structured, commonly used and machine-readable format) of personal information that you have provided to Unicoin, or request Unicoin to transmit such personal information to another information controller.
• To the extent that the processing of your personal information is based on your consent, request the withdrawal of such consent at any time. Please note that this will not affect Unicoin’s right to process personal information obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent.

In addition, you every California resident is entitled to the following rights:

• California law provides California residents with the right to receive a privacy notice with information about what we have collected, disclosed for business purposes, and sold during the preceding 12 months. This California Privacy Policy provides information about the categories of information that we have collected, the sources of that information, the purposes for which we have used the information, and the categories of third parties to whom we have disclosed the information for business purposes.
• California law also affords California residents a right to opt out of the “sale” of your personal information. This right is applicable to the extent that Unicoin is engaging in a “sale” of your personal information as that term is defined under applicable law. While Unicoin generally is not in the business of selling information, there are limited circumstances where we share personal information with our clients, third-party partners, or others that we treat as a sale for which California residents have the right to opt out. We do not sell the personal information of minors under 16 years of age without affirmative authorization.
• If you choose to exercise your rights, we will not charge you different prices or provide different quality of services unless those differences are related to your personal information or otherwise permitted by law. Contact us to opt out of the “sale” of your personal information. If at any time you would like to opt back in and allow Unicoin to sell your personal information, please contact us.
• To exercise any other rights available to you under California law, please contact us. Unicoin has 45 days to respond to your request. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. Where necessary, this may include asking you for a copy of your passport or driver’s license. If you would like to use an authorized agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. We reserve the right to deny requests from authorized agents in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.
• Unicoin may offer certain financial incentives for the collection, sale, or deletion of personal information. Where we would do so, we will provide California residents additional information where required by California law.

If, despite our commitment and efforts to protect your personal information, you believe that your information privacy rights have been violated, we encourage and welcome individuals to come to Unicoin first to seek resolution of any complaint. You always have the right to register a complaint directly with the relevant supervisory authority or to make a claim against Unicoin with a competent court (either in the country where you live, the country where you work or the country where you deem that information privacy law has been infringed).

3. HOW DO WE USE PERSONAL INFORMATION WHEN YOU VISIT UNICOIN’S WEBSITES?

In addition to the information set out above, this section describes how we use personal information when you visit Unicoin’s website:

3.1. Which personal information do we gather?

Unicoin collects personal information at its websites in two ways: (1) directly (for example, when you provide personal information to sign up as a user, register as an investor or as an ambassador or provide contact information); and (2) indirectly (for example, through our website's technology).

We may collect and process the following personal information:

• Personal information that you provide by filling in forms on our website. This includes registering to use the website, subscribing to services, registering as an investor, registering as an ambassador, newsletters, and alerts, or requesting further information. It is completely up to you whether you want to provide it.
• If you contact us, we may keep a record of that correspondence.
• We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
• Any postings, comments, or other content that you upload or post to a Unicoin website.
• Our website collects personal information about your computer, including (where available) your IP address, operating system, and browser type, for system administration, to filter traffic, to look up user domains and to report on statistics.
• Details of your visits to our website, the pages you view and resources you access or download, including but not limited to, traffic information, location information, weblogs and other communication information. Please see the Cookies Policy for more information.

3.2. Do we include (links to) websites and programs of third parties?

Our websites may include:

• Links to and from the sites of our partner networks, advertisers, and affiliates.
• Certain programs (widgets and apps) of third parties. Where this is the case, note that such third parties may process your personal information collected through such programs for their own purposes. We do not accept any responsibility or liability for such third parties’ sites or programs. Please check such third parties’ terms of use and privacy statements before using and providing any information to such third parties’ sites and programs.

3.3. How do we use personal information that we collect from our websites?

We use personal information for the purposes described in section 2.2 above, as well as to provide you with information you request, process user accounts, create investor and partners profiles.

We also analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it, make it more effective and, eventually, to determine how we can tailor our website to make it a more positive and relevant user experience.

By using our website, you agree that we can place cookies and other similar technologies on your device as explained in our Cookies policy.

4. HOW DO WE USE PERSONAL INFORMATION FOR MARKETING PURPOSES?

In addition to the information set out above, this section describes how we use personal information for marketing purposes:

4.1. Do we send targeted e-mails?

We send commercial e-mail to individuals at our client or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws. Our targeted e-mail messages typically include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in a marketing e-mail you receive from Unicoin, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site.

Targeted e-mails from Unicoin may include additional information privacy information, as required by applicable laws.

4.2. Do we maintain Customer Relationship Management (CRM) information bases?

Like most companies, Unicoin uses customer relationship management (CRM) information base technology to manage and track our marketing efforts. Our CRM information base include personal information belonging to individuals at our client and other companies with whom we already have a business relationship or want to develop one. The personal information used for these purposes includes relevant business information, such as: contact information, publicly available information (e.g. board membership, published articles, press releases, your public posts on social media sites if relevant for business purpose), your responses to targeted e-mail (including web activity following links from our e-mails), website activity of registered users of our website, and other business information included by Unicoin professionals based on their personal interactions with you.

4.3. Do we combine and analyze personal information?

We may combine information from publicly available sources, and from our different e-mail, website, and personal interactions with you (this includes information collected across our different websites and information collected when you sign-up or log on to our sites or connect to our sites using your social media credentials (such as LinkedIn). We combine this information to better assess your experience with Unicoin and to perform the other activities described throughout our California Privacy Policy.

4.4. Do we share personal information with third parties?

In addition to the third parties mentioned in section 2.3. above, we may share your personal information with marketing agencies and service providers.

4.5. What are your rights regarding marketing communications?

You can exercise your right to prevent marketing communications to you by not checking certain boxes on the forms we use to collect your personal information, or by utilizing opt-out mechanisms in e-mails we send to you.

You can exercise the right to discontinue marketing communications to you, or to have your personal information removed from our customer relationship management (CRM) information bases at any time by communicating to the link indicated in section “5. CONTACT” below. In such cases, we will retain minimum personal information to note that you opted out to avoid contacting you again.

5. HOW DO WE USE PERSONAL INFORMATION FOR PRODUCTION ACTIVITIES?

In addition to the information set out above, this section describes how we use personal information in connection with content creation/production purposes.

Some Unicoin entities are in the business of content production. We may process your personal information for these TV, film, marketing, advertising or other related content creation, production, and distribution activities.

The personal information that we process for production purposes include images and footage of you and may include your location at the time of filming.

If you are a member of public, we will diligently attempt to make you aware of our location and filming activities in advance and will give you an opportunity not to enter the location where filming is taking place and participate in them.

If you are a focus of our filming activities (i.e. a contributor or talent such as an interviewee, extra or actor, as opposed to a member of public) we will also collect and process your name, contact information and any other information provided in any pre-filming questionnaires and/or release forms, such as next of kin details.

We may also collect and process special categories of information a such as health or disability information to the extent that this is necessary to enable us to make any necessary adjustments to our filming arrangements to assist or support you.

6. CONTACT US

Please send an email to dataprivacy@unicoin.com  if:

• You have a general question about how Unicoin protects your personal information.
• You wish to exercise your rights in relation to your personal information rights.
• You wish to make a complaint about Unicoin’s use of your information.

LAST UPDATED: December 25, 2022