# Privacy Policy

**Last Update: September 2023**

This Privacy and Cookie Policy (“Policy”) govern the access to and use of all parts of the platform and services branded as Journey Bridge (“JB”, “we”, “our”, “us”) and refers to the domain [www.journeybridge.io](http://www.journeybridge.io) (hereinafter referred as the “Platform”) and all documents, data, materials or other information made available on the Platform.

This Policy applies to all visitors and/or users (“User”, “you”, “your”). Please read this Policy along with our Terms and Conditions carefully, and note that by using JB, you are consenting to the collection, storage, processing, and transfer of your personal information in accordance with this Policy.

1. **DEFINITION**

&#x20;1.1. “Account” means the account created on Our JB Platform.

&#x20;1.2. “Third Party Website” refers to the website with whom we collaborate, where you can utilize your JB Account credentials to access their services.

&#x20;1.3. “Personal data” refers to any information that relates directly or indirectly to a natural person whether living or deceased, who is identified or identifiable from that information, or from that and other information in the possession of a data User, including any sensitive Personal data and expression of opinion about the User;

2. **PURPOSE OF THIS POLICY**

&#x20;2.1. We at JB know and understand how important it is for you to understand how we collect, store, process, share, and use your Personal data. We respect and protect the privacy of our users’ Personal data in our Platform.

&#x20;2.2. The purpose of this Policy is to describe how JB collects, processes, and manages users’ Personal data through the Platform, which is developed to offer JB services.

3. ACCEPTANCE

&#x20;3.1. By accessing and using our Platform, you are consenting and accepting the terms of this Policy. If you do not agree or consent to the details we require with any aspect of this Policy, you shall at any time withdraw your consent and discontinue access or use of our services.

4. **USER LOGIN CREDENTIAL  INFORMATION**

&#x20;4.1. Third PartyWebsites' Privacy Policy: Users understand and acknowledge that when they choose to access specific services provided by Third Parties Websites through the Platform, they shall be subject to the individual privacy policy of each respective Third Party Website. The privacy practices, data collection, processing, and usage of information by the Third PartyWebsites are governed solely by their own privacy policies. JB shall not have any discretion or control over the privacy practices of the Third Party Websites.

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&#x20;4.2. User Information Usage: Users grant JB permission to use their personal information as required to create and maintain an account on the Platform. This information may include but is not limited to name, email address, contact details, and other relevant information required for account registration and management. For more information please refer to clause 5.

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&#x20;4.3. Login Credentials for Access: Users acknowledge that JB will use the provided personal information to generate login credentials (such as username and password) for accessing the Platform. These login credentials will enable Users to access the various services provided by Third PartyWebsites through the Platform.

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5. **PERSONAL INFORMATION THAT WE COLLECT FROM USERS**

&#x20;5.1. Your Personal data is collected and stored with us in order to provide, develop, and enhance our products and services including technical infrastructure, security, compliance, fraud prevention, and customer support. We are committed to exercising due diligence when dealing with every User and in the course of conducting business, we ensure that it is able to comply with all the applicable Laws and regulations.

&#x20;5.2.     The Personal data we collect from our Users are:

&#x20;     5.2.1.         Users - Individual

&#x20;                                5.2.1.1.   Full name

&#x20;                                5.2.1.2.   Date of Birth

&#x20;                                5.2.1.3.   Email Address

&#x20;                                5.2.1.4.   Gender

&#x20;                                5.2.1.5.   Residence Address

&#x20;                                5.2.1.6.   Nationality

&#x20;                                5.2.1.7.   Zip Code

&#x20;                                5.2.1.8.   Telephone number

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&#x20;     5.2.2.         Users - Legal Entity

&#x20;                                5.2.2.1.   Company name

&#x20;                                5.2.2.2.   Company Registration Number

&#x20;                                5.2.2.3.   Country of Incorporation

&#x20;                                5.2.2.4.   Country of Operation

&#x20;                                5.2.2.5.   Registered Address

&#x20;                                5.2.2.6.   Details of the Authorized Person of the Entity

&#x20;                                5.2.2.7.   UBO Details and Proof of address

&#x20;                                5.2.2.8.   A copy of the Certificate of Incorporation

&#x20;                                5.2.2.9.   Shareholder Registry

&#x20;                              5.2.2.10.   Director Registry

&#x20;                              5.2.2.11.   VAT Identification

&#x20;                              5.2.2.12.   General information about the nature of business

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&#x20;     5.2.3.         Browser Information

&#x20;                                5.2.3.1.   IP Address

&#x20;                                5.2.3.2.   Login information

&#x20;                                5.2.3.3.    Browser type and version

&#x20;                                5.2.3.4.    Time zone setting

&#x20;                                5.2.3.5.   Platform

&#x20;                                5.2.3.6.   Operating System

&#x20;                                5.2.3.7.   Transaction history

&#x20;                                5.2.3.8.   Pages accessed and links clicked

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6. **HOW USERS Personal data IS USED**

&#x20;6.1.     To communicate with the User

&#x20;6.2.     To comply with legal and regulatory compliance

&#x20;6.3.     To detect and prevent fraud and credit risks

&#x20;6.4.     To provide, troubleshoot, and improve JBD Services

&#x20;6.5.     To enforce our terms in our Term of Use

&#x20;6.6.     To provide customer services

&#x20;6.7.     To ensure quality control

&#x20;6.8.     To ensure network and information security

&#x20;6.9.     To enhance and personalize User experience

6.10.     To facilitate corporate acquisitions, mergers, or transactions

6.11.     To engage in marketing activities

6.12.     For Transaction services

6.13.     Purposes for which we seek User’s consent

7. **DATA TRANSFER**

&#x20;7.1. We may share your Personal data with selected third parties, including partners, business suppliers, distributors, and subcontractors, when it is necessary for the delivery of our services, or when there is a legal basis to do so. The aforementioned third parties only collect, use, and disclose your information in the ways indicated by us in order to provide adequate services.

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&#x20;7.2. We further ensure that we comply with the applicable data protection legal norms and we shall only share information in the following circumstances:

&#x20;     7.2.1.With applicable regulatory bodies of the British Virgin Islands.

&#x20;     7.2.2. With third-party KYC/AML service providers of JB to identity verification services in the User onboarding process.

&#x20;     7.2.3. With service providers under contracts to operate the business. For instance;

&#x20;                                7.2.3.1.   Cloud storage

&#x20;                                7.2.3.2.   Network Infrastructure

&#x20;                                7.2.3.3.   Security

&#x20;                                7.2.3.4.   Customer Support

&#x20;                                7.2.3.5.   Marketing

&#x20;                                7.2.3.6.         Data Analytics

&#x20;     7.2.4. We transfer only the minimum amount of data necessary for a particular outsourced service provider(s) (if applicable) and we only cooperate with the outsourced service providers who can provide and ensure adequate level of Personal data protection.

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&#x20;     7.3. JB ensures that the service providers and affiliates/ business partners who process personal information acknowledge the confidentiality of this information and protect the User’s right to privacy by complying with all applicable privacy and data protection laws.

&#x20;      7.4. Each Third Party Website may have its own data transfer clauses, terms of use, and privacy policies governing how your information is handled, processed, and shared. By using our Platform to access the services of Third Party Websites, you acknowledge and agree to adhere to the data transfer clauses and privacy policies of those Third Party Websites.

8. **PROTECTION AND STORAGE OF PERSONAL DATA**

&#x20;8.1. JB maintains physical, technical, administrative, and procedural safeguards in connection with the collection, storage, and disclosure of the User’s Personal data. We use firewall barriers, encryption techniques, and authentication procedures to maintain the security of User’s online sessions.

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&#x20;8.2.  Furthermore, JB does not ensure the security or privacy of data transmitted via email, phone, or SMS, till such data reaches the domain of our network since we have no access to protect such data until it reaches our network domain.

9. **DATA RETENTION**

&#x20;9.1. JB is obligated to retain either the original or an accurate copy of all data and information received from its Users in an easily accessible format for a period of five (5) years subsequent to the termination of your association with our Services, initiated at your request. It's important to be aware that the Personal data furnished by you will be maintained by us until such time as you make a request for the termination of our association.

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&#x20;9.2. We shall take reasonable measures to ensure that all Personal data is destroyed or permanently deleted if it is no longer required for the purpose of providing our services for which it was processed and in certain circumstances, if required by law, the JB may not destroy any relevant records or Personal data even though the prescribed period for retention shall have elapsed.

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&#x20;9.3. Furthermore, information or data collected via technical means such as cookies, web page counters, and other analytics tools is kept for a period of up to one year from the expiry of the Cookie policy.

10. **DATA PROTECTION LAW AND EUROPEAN DATA PROTECTION RIGHTS**

10.1. This Policy is governed by and shall be construed in accordance with the data protection laws of the British Virgin Islands. Additionally, the highest standard of data protection, as set forth in the General Data Protection Regulation ("GDPR"), shall also apply to the processing of personal data covered by this Policy.

10.2. According to the GDPR, JB provides privacy notices,

&#x20;  10.2.1.         in a concise, transparent, intelligible, and easily accessible form,

&#x20;  10.2.2.         written in clear and plain language,

&#x20;  10.2.3.         delivered in a timely manner; and

&#x20;  10.2.4.         provided free of charge

#### 10.4.     If the Users are located in the European Economic Area (EEA), you will have the rights as described below. <a href="#a49ldmqk8s63" id="a49ldmqk8s63"></a>

&#x20;  10.4.1. You may request access to and receive information about the Personal data we maintain about you, update and correct inaccuracies in your Personal data, restrict or object to the processing of your Personal data, have the information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal data to another company.

&#x20;  10.4.2. You may withdraw any consent you previously provided to us regarding the processing of your Personal data, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdraw your consent.

&#x20;  10.4.3. If you are located in the EEA, we will comply with applicable GDPR law when transferring your Personal data outside of the EEA.

11. **YOUR RIGHTS PROTECTED UNDER THE GDPR**

#### 11.1.     Under certain circumstances, you have rights under data protection laws in relation to your Personal data which are set out in more detail below <a href="#id-28ey5wj0h57j" id="id-28ey5wj0h57j"></a>

&#x20;  11.1.1. Request access - This enables you to receive copies of your Personal data. We hold about you and to check that we are lawfully processing it. This is also commonly known as a "data subject access request". This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

&#x20;  11.1.2. Request erasure - This enables you to request us to delete or remove Personal data where there is no good reason for us to continue to process it. Please note that there may be circumstances where we may be legally entitled to retain your Personal data.

&#x20;  11.1.3.  Request to Restrict Processing- This enables you to object to the processing of your Personal data, which is processed based on our legitimate interests. In the event of such an objection, we will no longer process your Personal data, unless we demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defense of legal claims.

&#x20;  11.1.4. Request to Object Processing - You have the right to object to the processing of your Personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal data for direct marketing purposes.

&#x20;  11.1.5. Request to transfer - If you request us, we will provide you or a third party you have chosen, your Personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.

12. **COOKIE POLICY**

#### 12.1.  Cookies are small text files that are placed on your device like a computer, mobile, or any other device by a Platform, containing details of your browsing history.  Whenever you visit our Platform, the Platform sends a cookie to the device you are using to access our Platform, and your device automatically stores the Cookie in a file located within your Platform browser allowing us to recognize your device upon future access. <a href="#g14mfvsrazo7" id="g14mfvsrazo7"></a>

#### 12.2.     We use the following Cookies to operate our Platform, such as; <a href="#id-1qmcvcr2h65d" id="id-1qmcvcr2h65d"></a>

&#x20;  12.2.1. Session Cookies are temporary and expire once you close your browser. It stores information for the time, or session when you are on our Platform;

&#x20;  12.2.2. Persistent Cookies encompass all Cookies that remain on your hard drive until you erase them or your browser does it. It depends on the Cookie’s expiration date. All persistent cookies have an expiration date written into their code, but their duration can vary;

&#x20;  12.2.3. First-party-cookies are put on your device directly by the Platform you are visiting;

&#x20;  12.2.4. Third-party-cookies are placed on your device, not by our Platform, but by a third party like an advertiser or an analytic system. Generally, Third-Party Cookies consist of tracking Cookies used to identify online behavior, understand interests, and then customize advertising for the User on other Platforms. Any information obtained from Third-Party Cookies is processed by the respective Collaborative Partners;

&#x20;  12.2.5. Google Analytics Cookies to measure our User’s interactions with the content on our Platform. These Cookies collect information about your interactions with our Platform, such as unique visits, repeat visits, session duration, and Platform activity;

&#x20;  12.2.6.Facebook Pixel processes information about a User’s activity on our Platform, such as the Platform visited, Facebook identity, browser data, and more. The information processed from Facebook pixel is used to serve ads based on your interests through Facebook, as well as to measure cross-device conversions and User interactions on our Platform;

&#x20;  12.2.7. Essential Cookies are known as strictly necessary Cookies for you to browse our Platform and use its features, such as accessing secure areas of our Platfrom. These Cookies are generally First-Party Session Cookies. These Cookies do not require consent from you. Essential Cookies helps to make our Platform easy to use by providing basic functions such as page navigation, language selections, authorization, and filling in forms. Our Platform will not function without these Cookies and they cannot be disabled. These Cookies do not reveal the User’s identity or collect information. They are stored on the User’s device until the browser is closed;

&#x20;  12.2.8. Functionality Cookies allow our Platform to remember choices you have made in the past like what language you prefer, what region you would like, or what username and password are so you can automatically log in. We use Cookies for navigation and to facilitate your access to and use of this site. These Cookies are necessary for the transmission of communications on the network or to supply services whatever requested by you. Further, they help us to know which pages are the most and least popular and see how visitors move around the Platform;

&#x20;  12.2.9. Performance Cookies collect information about how you use our Platform, like which page you visited and which link you clicked on. None of this type of information can be used to identify you. The sole purpose of performance cookies is to improve our Platform functions. Analytics may collect information through log data, such as; (i) IP address, (ii) Type of browser and device, (iii) Operating system, (iv) Name of the Internet Service Provider, (v) Country information, (vi) Date and time of visit, (vii) Web page origin and exit; and/or

&#x20;12.2.10. Marketing Cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an advertisement. These Cookies can share information with other organizations or advertisers. These cookies may be set through the Platform by our advertising partners. If you do not allow these cookies, you will experience less targeted advertising. These cookies are set on your device for up to two (2) years or deleted if you erase your browser cookie data.

#### 12.3. You reserve the right to decide whether to accept or reject Cookies from our Platform. You can exercise your Cookie rights by setting your preferences in the Cookie Consent Manager. However, you will not be able to reject the Essential Cookies and still access the Platform, as they are strictly necessary to provide you with our Services. In the event you choose to reject certain Cookies, you may still use our Platform though your access to some functionality and areas of our Platform may be restricted. You may also set or amend your web browser controls to accept or refuse Cookies. <a href="#kffj05e2a9pm" id="kffj05e2a9pm"></a>

13. **MODIFICATIONS**

#### &#x20;13.1.  We reserve the right, at our sole discretion, to modify, amend, supplement, or replace this Policy at any time and such update details shall be indicated at the top of this page. <a href="#eng1s96kvau" id="eng1s96kvau"></a>

#### &#x20;13.2.  Our Platform Policies and Terms may be revised or updated periodically to meet the necessary requirements and standards. We encourage You to regularly visit our Platform to stay informed about any changes to these Policies and the Terms. <a href="#bspu58vvqhv2" id="bspu58vvqhv2"></a>

#### &#x20;13.3.  Your continued access to the Platform means that you agree to the updated content and to abide by the updated Policy. <a href="#id-3zrazpbriz03" id="id-3zrazpbriz03"></a>

14. **CONTACT INFORMATION**

#### &#x20;14.1.  In the event of any comments, questions, inquiries, or complaints regarding this Policy, the User has the right to submit questions and/or concerns at <info@journeybridge.io> or contact <https://support.journeybridge.io/> <a href="#tm7lbey1m3ui" id="tm7lbey1m3ui"></a>
