EFFECTIVE DATE: August 13, 2024

DATE OF LATEST UPDATE: November 16, 2024

MSS Mentra Services & Solutions Ltd, a limited liability company organized pursuant to the laws of the Republic of Cyprus, owns, manages and operates the website www.mentra.gg and any mentra.gg web and mobile applications (collectively referred to as the “Platform”).

The present Privacy Policy (the “Privacy Policy”) sets forth the terms and policy applicable to the collecting, handling, using, maintaining and storing of personal information and data obtained from or in connection with the Platform by MSS Mentra Services & Solutions Ltd.

The Platform operates as an e-commerce marketplace offering its users the ability to sell and purchase digital products. The Platform is intended to facilitate the sale, transfer and purchase of digital products, such as intellectual property, software and digital currencies.

Sellers may offer for sale and sell digital products on the Platform, provided the digital products offered for sale comply with the Platform’s Terms of Service, and are not prohibited. Buyers may purchase any such digital products offered for sale on the Platform by placing an order and paying the corresponding fee.

The following capitalized terms, when used in this Privacy Policy, shall have the meanings set forth below, unless the context requires otherwise:

“Affiliates” shall refer to the Company’s employees, consultants, contractors and affiliates.

“Buyers” shall refer to users of the Platform engaging in the purchase of any one (1) or more Products on the Platform.

“Company” shall refer to MSS Mentra Services & Solutions Ltd, a Cyprus company, whose registered address is located at Georgiou Karaiskaki 11-13, Carisa Salonica, Office 102, 7560 Pervolia, Larnaca, Republic of Cyprus. For reference purposes, the Company owns, manages and operates the Platform.

“GDPR” shall refer to the General Data Protection Regulation 2016/679.

“Order” shall refer to an order for one (1) or more Products placed by a Buyer via the Platform.

“Products” shall refer to all digital products listed as available for purchase and/or purchased on the Platform. Products may include, without limitation, intellectual property, digital currencies, digital items and software.

“Sellers” shall refer to users approved by the Company to sell Products on the Platform, and who hold a valid merchant account on the Platform.

“Terms of Service” shall refer to the latest version of the Platform’s Terms of Service, as may be amended or updated by the Company from time to time.

“Users” shall refer to all users of the Platform, including both Buyers and Sellers, without distinction and “User” shall refer to an individual user of the Platform.

The present Privacy Policy shall apply to the collection, handling, usage, storage and maintenance of personal information and data by the Company obtained from or as a result of using the Platform. Any provision or submission of personal information on the Platform shall be governed by the terms of this Privacy Policy.

The present Privacy Policy shall describe the rights granted to Users of the Platform in connection with their personal information and data.

Upon accessing or otherwise using the Platform, Users shall be deemed to have accepted and approved the present Privacy Policy, in full and without modification. Accordingly, any access or usage of the Platform by Users shall signify their acceptance of this Privacy Policy, as may be updated from time to time.

If a User does not agree with the provisions contained in the present Privacy Policy, the User’s sole recourse shall be to not access or use the Platform.

The present Privacy Policy has been drafted and prepared in accordance with terms of the GDPR as well privacy and data protection laws applicable in the United States.

For reference purposes, the GDPR was enacted in April 2016, and came into effect in May 2018. The GDPR applies to residents of the European Union (EU) and the European Economic Area (EEA). The GDPR governs the collection, usage and transfer of personal data, and was enacted to provide individuals with relevant information regarding the usage, collection and handling of their personal data, thereby allowing for control measures and data management.

The Company may modify, update or otherwise amend the present Privacy Policy at any time, at its sole discretion. For reference purposes, the latest version of the present Privacy Policy shall be published and made available for review on the Platform.

The latest version of the present Privacy Policy shall be applicable and binding as the date of its publication on the Platform, unless indicated otherwise. Unless stated otherwise, Users shall be required to comply with the updated Privacy Policy as of the date specified in the header.

For such purposes, the date of the latest update to this Privacy Policy shall be indicated in its header. Accordingly, the Company encourages Users to periodically review this Privacy Policy to ensure compliance with the latest version.

Users are not required to provide personal information and data to access the Platform. While Users are not under any obligation to provide personal information and data on the Platform, Users acknowledge that certain activities, such as the ability to place Orders and sell Products on the Platform, may be restricted or limited without a valid User account on the Platform.

Buyers may, however, be asked to submit personal information and data, such as their email address and payment information, for payment processing purposes and prior to placing Orders.

The Platform is intended for Users who are at least eighteen (18) years old. The Company does not knowingly target or advertise to minors. If a User is younger than eighteen (18) years old, the minor User shall require the authorization of the minor User’s parent or legal guardian to access or use the Platform, and all usage of the Platform by the minor User shall be supervised by the minor User’s parent or legal guardian.

The Company does not intend nor wish to receive any personal information and data from a minor User. If Users are aware of any personal information and data shared by a minor User on the Platform, Users should notify the Company to allow the Company to remedy the situation.

Minor Users are therefore urged to refrain from sharing or disclosing any personal information and data on the Platform.

The definition of the term personal data as per the GDPR is as follows: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”. The definition of personal data has been copied hereinabove and italicized for reference and information purposes only.

As stated in the GDPR, personal data consists of any information or data that allows for the identification of a specific individual, such as a name and identity. In the present Privacy Policy, the terms personal information and personal data shall be used interchangeably and shall refer to the same concept.

For reference purposes, indirect identifiers consist of personal information that does not allow for the identification of a specific individual. Indirect identifiers may consist of geographic location and browsing history. An indirect identifier may not be used in isolation to identify a particular individual. Indirect identifiers may, however, be used in combination with other information and data to identify a specific individual.

The Company understands the importance of protecting personal information and data provided on or obtained from the Platform. The Company adheres to strict guidelines and all applicable laws with respect to the collection of personal information and data. Accordingly, the Company shall only collect personal information and data that is voluntarily provided by Users on or through the Platform.

Considering Buyers may purchase Products and Sellers may sell such Products on the Platform, Users may be asked to input payment information, such as bank card details or other payment method. The relevant User’s payment method may be stored and maintained by a third party payment processing service for payment purposes, to allow for the payment of funds for Buyers or the receipt thereof for Sellers.

Prior to processing a payment or an Order, the Company shall collect the Buyer’s country of origin or residence, email address and name for fraud prevention and tracking purposes.

Further, the Company may collect information regarding a User’s purchase and selling history. The collection of such information shall allow the Company to provide suggestions and customized recommendations based upon past purchases and Products sold on the Platform.

The Company may obtain indirect identifiers such as IP addresses, locations, device details, browser information and similar data as a result of Users’ access to the Platform. Such indirect identifiers shall be anonymous, not allowing for the identification of a particular User. Indirect identifiers may be collected by the Company to gather data regarding the geographic location of Users.

When creating a User account on the Platform, Users may submit personal information and data. Such personal information and data may consist of the User’s selected username and email address. The provision of such personal information and data shall be voluntarily and optional, however, Users may not be able to purchase Products on the Platform without inputting such personal information and data.

Each User shall be responsible for ensuring the personal information provided on the Platform is true, accurate and complete. A User shall not be required to provide its credit card information or payment information on the Platform, except to purchase Products and process a transaction. Such financial information shall be provided by the User at its discretion and voluntarily.

The collection and handling of personal information and data by the Company shall comply with applicable laws and regulations pertaining to the collection, safeguard, handling and protection of personal information data. To ensure that personal information and data collected by the Company is safeguarded, the Company established appropriate measures and procedures to protect personal information and data provided on or via the Platform.

The Company undertakes not to share, disclose, communicate, transmit, or distribute personal information and data to its except to those who require such personal information and data to perform services in connection with the Platform. The Company shall only share personal information and data with its Affiliates if required in furtherance of the Platform’s purpose or to allow Users to sell and purchase Products on the Platform.

In any such cases, the disclosure of personal information and data to the Affiliates shall be limited to the information strictly required for purposes of the Platform. The Company implemented procedures to ensure the Affiliates granted access to personal information data are bound by confidentiality obligations as strict and enforceable as those set forth in the present Privacy Policy.

The Company’s handling of all personal information and data submitted on or via the Platform shall be transparent and in furtherance of the Platform as required under the GDPR.

The Company shall use personal information and data solely to fulfill the purposes set out in the present Privacy Policy. Any usage of personal information and data by the Company shall be limited to the extent required by the Company’s legitimate business interests, and based upon the requirements of the GDPR.

The Company shall use personal information and data in furtherance of the following general purposes:

In compliance with the data minimization obligation set forth in the GDPR, the Company shall limit the usage of personal information and data to that which is strictly necessary to fulfill the purpose of the usage. The Company undertakes to not use personal information and data in an unreasonable or excessive manner considering the reason for the collection or usage.

The Company shall use personal information and data provided and collected from the Platform to allow Users to sell and purchase Products, including place Orders. The personal information and data collected by the Company may be used to process payments made by Buyers, if applicable.

The Company may further use personal information and data to: (i) communicate with the relevant User, (ii) respond to the User’s inquiries, and (iii) provide support with respect to the Platform.

Users may subscribe to the Company’s mailing list. Upon doing so, Users may be asked to select preferences so as to receive emails that are adapted to their interests. Users acknowledge and agree that the Company may use personal information and data to send emails with respect to Products, news and other matters relating to the Platform. Such emails shall be sent by or on behalf of the Company on a regular basis.

Users may opt out of receiving emails regarding the Platform by selecting the unsubscribe button contained in the email sent by or on behalf of the Company.

Users may grant the Company the authorization to use their personal information and data for purposes beyond those explicitly mentioned in the present Privacy Policy.

Users shall have the option to consent to the usage of personal information and data by the Company for specific marketing purposes and to benefit from certain services. To be valid, the authorization provided by a User shall be specific and shall expressly set out the scope and duration of the authorization.

Provided the authorization granted by the User complies with the terms of the present Privacy Policy, the Company shall be empowered to use such personal information and data according to the extent specified in the consent provided by the User.

The Company may conduct surveys in connection with the Platform and Products sold or purchased thereon. Participation in any of such surveys shall be voluntary. Users may provide their names, email addresses and passwords to access any surveys. All data collected in connection with a completed survey shall remain strictly anonymous and shall not allow for the identification of the Users who completed the survey.

The Company may use indirect identifiers, including anonymized data, for analytical, tracking and statistical purposes, to analyze performance data, metrics and statistics relating to Users, the effectiveness of the Platform, the activities provided and other relevant data. Such data may be used to improve the Platform's features, understand User behavior, and enhance the experience and Products offered on the Platform.

The Company reserves the right to share Buyers’ country of origin or residence with relevant Sellers for tracking purposes, thereby enabling the Sellers to make informed decisions regarding Orders and subsequent transactions. The Company further reserves the right to share such information with third party providers for analytical and tracking purposes.

The Company may also use indirect identifiers to compare User behavior and usage of the Platform in comparison to the usage by other Users.

For fraud prevention purposes, the Company shall collect Buyers’ IP addresses, email addresses and names prior to processing their payments. The Company shall use the Buyers’ personal information and data to assess fraud scores and determine the safety of the contemplated transactions. The Company reserves the right to shares Buyers’ personal information and data with third party service providers to assess fraud scores and use such scores to prevent fraud on or in connection with the Platform.

The Company may also use Buyers’ fraud scores and personal information and data to establish a global blocklist for the Company. The global blocklist shall consist of a list of Buyers who engaged in risky transactions or initiated disputes with respect to transactions. The Company shall use the global blocklist for security purposes to prevent fraud on the Platform.

The Company may use Buyers’ personal information and data as well as indirect identifiers, such as browser information and device information, to ensure the security and safety of the Platform for Users. To this effect, the Company may share such information and data with third party providers to fulfill such purposes.

As data subjects, Users shall benefit from a series of rights granted by the GDPR. Users shall be permitted to exercise such rights in connection with the personal information and data provided on or via the Platform.

Users shall benefit from the right to be informed of the Company’s collection and usage of their personal information and data. While the present Privacy Policy describes how the Company collects and uses personal information and data provided on the Platform, Users shall be permitted to request additional information or specific information regarding the Company’s collection and usage of their personal information and data.

Upon written request provided to the Company by the requesting User, the Company shall secure copies of the personal information and data submitted by the User to the Company on the Platform. Users shall further benefit from the right to obtain information regarding the Company’s processing of personal information and data as well as the categories of Affiliates with whom personal information and data was shared.

To obtain additional information as to the Company’s usage of personal information and data, please submit a detailed written request to the Company’s attention. The request may be submitted by email to the Company.

As data subjects subject to the GDPR, Users shall benefit the right to obtain access to information regarding the transmission of personal information and data outside of the European Union (EU). To exercise this right, Users shall be required to send the Company a written request.

The Company undertakes to fulfill to the written request within a timely manner as of the Company’s receipt of a written request for information pertaining to the transmission of information outside of the European Union. Any transmission of personal information and data by the Company shall comply with the terms of the GDPR as well as those contained in the present Privacy Policy.

The Company shall employ reasonable measures to verify that personal information and data submitted by Users is correct and updated. If a User finds or believes that the personal information and data held by the Company is misleading, erroneous, unusable or otherwise false, the affected User may request the rectification or correction of its personal information and data.

If a User determines that its personal information and data is incomplete, the User may request that the Company provide additions or supplements to its personal information and data.

Any such requests shall be transmitted to the Company in writing by email. The Company shall make all necessary corrections and updates promptly as of the Company’s receipt of the relevant request.

Users may delete their personal information and data by following the instructions specified in their user accounts, namely by selecting User Setting in the Account Settings, under the Dashboard.

Users acknowledge that once a User account or store is deleted, all associated personal information and data shall be immediately deleted from the Company’s systems and servers, unless otherwise specified by the Company as per the Company’s Terms of Service.

Users shall benefit from the right to request the deletion of their personal information and data from the Company’s servers. Any such requests shall be provided to the Company in writing, and shall provide justification to support such request.

The Company shall delete personal information and data from its servers if the Company determines the personal information and data is prejudicial or unjustified. More specifically, the Company shall delete personal information and data, further to a User’s request, if any of the following conditions are met:

(1) the User’s personal information and data is no longer needed to fulfill the purposes for which it was collected, or

(2) the consent provided by the User with respect to its personal information and data has been withdrawn or is expired and the Company does not have any legitimate reason to maintain the personal information and data.

If the User’s request to be forgotten is justified, the Company shall delete or otherwise remove the targeted personal information and data from its servers. Upon request, the Company may provide a written confirmation of the deletion or removal of the personal information and data.

Users shall benefit from the right to request that the Company restrict the processing of their personal information and data. Any request to restrict processing shall be provided to the Company in writing, and shall specify the reasons justifying the request.

The Company deems the following to be valid reasons to restrict the processing of personal information and data:

If the User’s request to restrict the processing of its personal information and data is justified, the Company shall take the necessary action to prevent the processing of the User’s personal information and data.

Users may request a copy of their personal information and data submitted via the Platform in a structured, commonly used and machine-readable format. The receipt of its personal information and data in machine-readable format shall allow the User to transfer its data, or store it for the User’s own purposes.

The User may further request for the Company to transfer its personal information and data to a legitimate controller if feasible and lawful to do so. Any request to obtain personal information and data in machine-readable format shall be sent to the Company in writing via email.

Users shall have the right to object to the Company’s processing of their personal information and data for reasons of convenience or as a result of a particular circumstances. The Company shall evaluate the User’s request while considering the User’s interests and rights as well as any compelling grounds for processing the personal information and data. If the Company’s evaluation demonstrates that the User’s interests and rights outweigh the reasons for the Company’s processing of the personal information and data, the Company shall cease the processing of the User’s personal information and data.

Users may also object to the Company processing their personal information and data for specific purposes, such as marketing. In such cases, the Company shall cease processing the personal information and data for the purpose requested by the User. If the processing of the User’s personal information and data is required for reasons of public interest or by law, the Company may not be able to cease the processing of the personal information and data.

Users may provide the Company with an explicit permission to use their personal information and data for purposes beyond those provided in the present Privacy Policy. The authorization granted to the Company may relate to the collection, maintenance, storage, handling, usage and/or disclosure of the User’s personal information and data. To grant such a permission, the User must be at least eighteen (18) years of age, and legally capable of providing a valid consent.

A User may revoke the permission provided to the Company, at any time, by sending the Company a written notice in accordance with the terms of the present Privacy Policy.

California privacy laws allow California residents to request information regarding the disclosure of personal information and data to third parties for direct marketing purposes. If Users reside in the State of California and wish to submit such a request, such Users shall send an email to the Company in accordance with the terms of this Privacy Policy. In addition to the right to request information, California residents benefit from a number of rights, including the right to access personal information and data collected and the right to request the deletion thereof.

California residents are granted a right to access and be informed of the Company’s collection and usage of their personal information and data. California residents further benefit from the right to obtain copies of the personal information and data that the Company collected and stored.

Residents of the State of Nevada have the right to disallow the sale or licensing of their personal information and data by third parties. To exercise this right to opt out, Nevada residents must send an email to the Company.

The Company shall be authorized to communicate and disclose personal information and data if required by a valid court order or pursuant to a legal obligation.

The Company shall disclose all necessary personal information and data to ensure compliance with applicable laws and regulations. In such cases, the Company may disclose a User’s personal information and data without informing the User prior to or pursuant to the disclosure. The Company’s disclosure of personal information and data shall be limited to the personal information and data absolutely required pursuant to the legal obligation.

If required by a valid court order, the Company may disclose personal information and data in compliance with the requirements of the court order. If possible, the Company shall notify the affected User following the Company’s receipt of the court order or notice of court order. This notification, while not obligatory, shall allow the affected User to seek a protective order or other legal remedy to maintain the confidentiality of the personal information and data and avoid the disclosure thereof.

Unless otherwise indicated, all maintenance of the Platform shall be handled by the Company. Accordingly, the storage and maintenance of personal information and data collected from the Platform shall be handled exclusively by the Company, unless otherwise stated.

The present Data Retention Policy (the “Data Retention Policy”) outlines the Company’s standards and procedures for the retention of personal information and data collected from the Platform (collectively, the “Personal Data”). This Data Retention Policy further establishes the legal framework applicable to the retention of Personal Data, and provides the rights granted to Users with regard to the destruction or deletion of their Personal Data.

This Data Retention Policy has been drafted and prepared in compliance with the General Data Protection Regulation 2016/679 (the “GDPR”), a regulation on information privacy applicable in the European Union and the European Economic Area, and the Data Protection Law of 2018 (Law No. 125(I)/2018) (the “Data Protection Law”), a legislative framework in Cyprus that encompasses the GDPR at the national level.

This Data Retention Policy shall apply to all Personal Data collected and obtained by the Company from the Platform. This Data Retention Policy shall apply to all Company directors, officers, employees, contractors and service providers who collect or otherwise obtain access to Personal Data from the Platform (collectively, the “Company Representatives”). All Company Representatives shall be responsible for reviewing this Data Retention Policy, and complying with its terms.

All Personal Data collected and obtained from the Platform shall be handled according to this Data Retention Policy. Personal Data shall include, without limitation, Users’ names, email addresses, payment information, past purchases and sales, and any information shared in the User’s account on the Platform. Personal Data may also be obtained from emails sent by Users and data generated and logged on the Platform.

As per the terms of the GDPR and the Data Protection Law, Personal Data shall be retained by the Company for the duration needed to fulfill the purpose of its collection. The Company shall retain Personal Data for the purposes set out in the Privacy Policy.

The Company shall keep and retain Personal Data to allow Users to sell subsequent Products, and/or purchase subsequent Purchases as well as to track selling and/or buying history. While a User has an active account on the Platform, the Company shall retain the User’s Personal Data. Once a User’s account on the Platform is closed or terminated, the Company shall retain the User’s Personal Data for a reasonable period, but no longer than absolutely needed, to fulfill pending transactions, handle payment disputes, if applicable, and comply with legal obligations, including regulatory requirements or audits.

Unless otherwise specified in this Data Retention Policy, the Company shall retain Personal Data for at most three (3) years following the date at which the User’s account was closed or terminated.

The Company undertakes to retain and store the Personal Data in secure servers. The Company acknowledges there is a potential risk of unauthorized access and leaks of Personal Data. Accordingly, the Company shall take all reasonable and appropriate measures to protect the Personal Data while retained by the Company. When electronic storage media are used by the Company, the Company shall establish proper protocols and procedures to ensure the Personal Data remains accessible for the duration of the retention. Such protocols and procedures shall provide for a back-up system, allowing for the accessibility of Personal Data in case of future technological advancements.

Whilst the Company undertakes to not retain Personal Data for longer than three (3) years, except where the User holds an active account on the Platform, certain Personal Data may require longer retention periods. As such, the Company reserves the right to retain Personal Data for a longer duration if required by applicable laws, court orders or to protect its legitimate interests, including but not limited to the exercise or defense of legal claims. Further, the Company reserves the right to maintain Personal Data for longer than the set term to fulfill its professional standard obligations, such as for tax and accounting purposes. Additionally, if any investigation or claim is in place, the Company shall extend the data retention period for the relevant and applicable Personal Data relating to the investigation or claim.

The Company shall conduct regular reviews of all Personal Data held and retained in the Company’s possession to determine if the retention is necessary. Once Personal Data is no longer deemed necessary, the Company shall take reasonable steps to either delete or anonymize such Personal Data, in compliance with the terms of this Data Retention Policy.

Once the Personal Data of a User who holds or held an account on the Platform is deleted by the Company, the Company shall undertake to notify the User by sending an email.

In compliance with the GDPR and the Data Protection Law, the Company’s handling and retention of Personal Data shall be transparent. Users may communicate with the Company at any time to request a copy of all Personal Data the Company has retained. Users may submit such a request to the Company by way of email. The Company shall respond to such requests within a timely manner.

Further, Users may request that the Company cease retaining and delete their Personal Data. The Company asks that all deletion requests be submitted by email. The Company shall assess all deletion requests to determine if the Company can fulfill the request. Ultimately, if there are no contraindications to deleting the Personal Data, the Company shall proceed with the deletion of the requesting User’s Personal Data, and shall inform the User of the deletion thereof by email.

The Company shall proceed with the deletion or destruction of Personal Data once: (i) the Company has determined there is no longer any need for the Personal Data, (ii) the User terminated its user account on the Platform and a three (3) year term has lapsed, or (iii) the User has requested the deletion thereof. The Company shall then delete the Personal Data from its servers, ensuring all personal and private information is deleted and rendered inaccessible to the Company Representatives. The deletion shall be performed using any lawful method allowing for secure electronic deletion. Alternatively, if any Personal Data is contained in a physical document or file, the Company shall destroy such document or file through shredding or other disposal technique.

If permissible and on an as needed basis, the Company may anonymize Personal Data to allow for the use of aggregated data for analytical purposes without undermining individual privacy.

Certain data collected or obtained from the Platform shall be subject to ongoing routine disposal, and shall not be subject to the retention obligations set forth in this Data Retention Policy.

Any data that does not contain Personal Data may be immediately disposed of by the Company. Such data shall include, without limitation, notices of daily meetings, ordinary publicly available information, and transmission messages such as emails that accompany a document but do not add any value.

The Company shall store personal information and data in its secure servers for a reasonable duration as determined by the Company on a case-by-case basis. Typically, the Company retains and stores personal information and data in its servers for no more than a ninety (90) day term.

If the storage of personal information and data for an extended duration is required for reasons of public interest, the Company may exercise its right to maintain personal information and data for such extended term.

The Company employs strict and reliable processes to protect the security, confidentiality and integrity of personal information and data. The Company shall not disclose personal information and data to any third party, except as provided in the present Privacy Policy. The Company shall take all necessary precautions to protect and safeguard personal information and data from unauthorized disclosure, breaches, leaks and other illegal usage.

Nonetheless, the transmission of personal information and data on the Internet is never completely secure. The Company cannot guarantee the security of personal information and data transmitted via the Platform. Users acknowledge that the submission of personal information and data on the Platform shall be at their sole risk. Users further agree that the Company shall not be responsible for any unauthorized usage, distribution or disclosure of personal information and data, except to the extent required pursuant to the GDPR.

The Company shall not transfer any personal information and data collected from or through the Platform outside of the European Union, except if the transfer complies with the conditions set forth in the GDPR. The GDPR allows for data transfers outside the European Union if the data is transferred to countries that comply with strict data protection legislation. The United States and Canada are considered compliant with such data protection requirements. In consideration thereof, personal information and data may be transferred to such countries in compliance with the GDPR.

The present Privacy Policy applies exclusively to the Platform, and does not apply to any third party websites or applications. The Platform may provide links or reference to such third party websites or applications. The links are provided for reference and information purposes only, and shall not bind or otherwise implicate the Company.

Further, any personal information and data provided on a third party website or application shall be governed by such third party’s privacy policy. The Company shall not be responsible for the usage and collection of personal information and data by third party websites or applications.

The Company welcomes questions and comments regarding the present Privacy Policy. Any questions and comments may be sent to the Company by email ([email protected]).