PRIVACY POLICY - The Hashgraph Tower
ARTICLE 1: PREAMBLE
This privacy policy applies to the site: The Hashgraph Tower The purpose of this privacy policy is to inform users of the : How their personal data is collected and processed. All data that can identify a user must be considered as personal data. This includes the first and last name, age, postal address, email address, location of the user or his IP address; What are the users rights regarding this data; Who is responsible for the processing of personal data collected and processed; To whom these data are transmitted; Eventually, the site s policy on cookies files. This privacy policy supplements the legal notice and the General Terms of Use that users can consult at the address below: https://www.hashgraphtower.com/privacy-policy

ARTICLE 2: GENERAL PRINCIPLES OF DATA COLLECTION AND PROCESSING
In accordance with the provisions of the article of the European Regulation 2016/679, the collection and processing of data of the users of the site respect the following principles: Legality, fairness and transparency: data can only be collected and processed with the consent of the user who owns the data. Whenever personal data is collected, the user will be informed that his data is being collected, and for what purpose his data is being collected; Limited purposes: the collection and processing of data is carried out for one or more of the purposes set out in these terms and conditions; Minimization of data collection and processing: only the data necessary for the proper execution of the objectives pursued by the site are collected; Conservation of data reduced in time: the data is kept for a limited period of time, of which the user is informed. When this information cannot be communicated, the user is informed of the criteria used to determine the retention period; Integrity and confidentiality of collected and processed data: the data controller undertakes to guarantee the integrity and confidentiality of the data collected. In order to be lawful, and in accordance with the requirements of Article 6 of the European Regulation 2016/679, the collection and processing of personal data may only take place if they comply with at least one of the conditions listed below: The user has expressly consented to the processing; The processing responds to a legal obligation; The processing is necessary to safeguard the vital interests of the data subject or another natural person; The processing can be explained by a necessity linked to the execution of a mission of public interest or the exercise of public authority; The processing and collection of personal data is necessary for the purposes of the legitimate and private interests pursued by the controller or by a third party.

ARTICLE 3: PERSONAL DATA COLLECTED AND PROCESSED IN THE CONTEXT OF NAVIGATION ON THE SITEA. DATA COLLECTED AND PROCESSED AND METHOD OF COLLECTION
The personal data collected on the The Hashgraph Tower website are the following: First name Last name ; E-mail address; Phone number. This data is collected when the user performs any of the following operations on the site: When the User uses the contact form to send a request; When the User uses the contact form to obtain a free audit; The person in charge of the treatment will preserve in its data-processing systems of the site and under reasonable conditions of safety the whole of the collected data for a duration of : Marketing data: 3 years; Contractual and commercial documents: 3 years; Visit analysis cookie: 3 years. The collection and processing of data serves the following purposes: Response to requests sent through the contact form. The data processing carried out is based on the following legal grounds: Performance of the contract; User consent; Legal obligation.B. TRANSMISSION OF DATA TO THIRD PARTIESThe data may be transmitted to Netlify which is the host of the siteC. DATA HOSTINGThe The Hashgraph Tower website is hosted by : VERCELL, The data collected and processed by the site are transferred to the following country (ies): USA. This transfer of personal data outside the European Union is justified by the following reasons: The data is hosted in the USA because we have a contract with a host in the USA.

ARTICLE 4: DATA CONTROLLERA. THE DATA CONTROLLER
The person in charge of processing personal data is: The Hashgraph Tower. He can be contacted as follows: contact@makria-agency.com The data controller is responsible for determining the purposes and means of processing personal data.B. OBLIGATIONS OF THE DATA CONTROLLERThe data controller undertakes to protect the personal data collected, not to transmit them to third parties without the user s knowledge and to respect the purposes for which the data were collected. The site has an SSL certificate to ensure that information and data transfer through the site is secure. An SSL (Secure Socket Layer Certificate) is intended to secure the data exchanged between the user and the site. Furthermore, the data controller undertakes to notify the user in the event of rectification or deletion of the data, unless this would entail disproportionate formalities, costs and steps for the user. In the event that the integrity, confidentiality or security of the user s personal data is compromised, the data controller undertakes to inform the user by any means.

ARTICLE 5: USER S RIGHTS
In accordance with the regulations concerning the processing of personal data, the user has the following rights. In order for the data controller to comply with the user s request, the user is required to provide the data controller with his/her first and last name and e-mail address. The data controller is obliged to respond to the user within 30 (thirty) days.A. PRESENTATION OF THE USER S RIGHTS REGARDING DATA COLLECTION AND PROCESSINGa. Right of access, rectification and deletionThe user may view, update, modify or request the deletion of data concerning him/her, by following the procedure set out below: Mail to: contact@makria-agency.com Submission of sufficient proof of your identity (for these purposes, we generally accept a notarized photocopy of your passport plus an original copy of a utility bill showing your current address).b. Right: data portabilityThe user has the right to request the portability of his personal data, held by the site, to another site, by complying with the procedure below: Mail to: contact@makria-agency.com Submission of sufficient proof of your identity (for these purposes, we generally accept a notarized photocopy of your passport plus an original copy of a utility bill showing your current address).c. Right to limit and object to the processing of dataThe user has the right to request the limitation or to object to the processing of his/her data by the site, without the site being able to refuse, unless it can be demonstrated that there are legitimate and compelling reasons, which can prevail over the interests and rights and freedoms of the user. In order to request the limitation of the processing of his/her data or to formulate an objection to the processing of his/her data, the user must follow the following procedure: Mail to: contact@makria-agency.com Submission of sufficient proof of your identity (for these purposes, we generally accept a notarized photocopy of your passport plus an original copy of a utility bill showing your current address).d. Right not to be subject to a decision based exclusively on an automated processIn accordance with the provisions of Regulation 2016/679, the user has the right not to be subject to a decision based exclusively on an automated process if the decision produces legal effects concerning him/her, or significantly affects him/her in a similar way.e. Right to determine the fate of data after deathThe user is reminded that he/she can organize what should be the fate of his/her collected and processed data if he/she dies, according to the law n°2016-1321 of October 7, 2016.f. Right to refer to the competent supervisory authorityIn the event that the data controller decides not to respond to the user s request, and the user wishes to contest this decision, or if he/she believes that one of the rights listed above has been infringed, he/she is entitled to refer the matter to the CNIL (Commission Nationale de l Informatique et des Libertés, https://www.cnil.fr) or any competent judge.B. PERSONAL DATA OF MINORSIn accordance with the provisions of Article 8 of the European Regulation 2016/679 and the Data Protection Act, only minors aged 15 years or older may consent to the processing of their personal data. If the user is a minor under the age of 15, the consent of a legal representative will be required in order for personal data to be collected and processed. The editor of the site reserves the right to verify by any means that the user is over 15 years of age, or that he has obtained the agreement of a legal representative before browsing the site.

ARTICLE 6: USE OF COOKIES FILES
The site eventually uses cookies techniques. A cookie is a small file (less than 4 kb), stored by the site on the user s hard drive, containing information about the user s browsing habits. These files allow it to process statistics and information on traffic, to facilitate navigation and to improve the service for the user s comfort. For the use of cookies files involving the storage and analysis of personal data, the user s consent is necessarily requested. This consent of the user is considered valid for a maximum of 6 (six) months. At the end of this period, the site will again request the user s permission to save cookies files on their hard drive.a. User s objection to the use of cookies files by the siteCookies that are not essential to the operation of the site are only deposited on the user s terminal after having obtained his consent. The user can withdraw his consent at any time, as follows: With Internet Explorer (version 10), you can block cookies by using the replacement settings for cookie management available by clicking on Tools, Internet Options, Privacy then Advanced; with Firefox (version 24), you can block all cookies by clicking on Tools, Options, Privacy and then selecting Use custom settings for history from the drop-down menu and unchecking Accept cookies from sites; and With Chrome (version 29), you can block all cookies by going to the Personalize and control menu and clicking on Settings, Show advanced settings and Content settings and then selecting Prevent sites from setting data in the Cookies header. If you block cookies, you will not be able to use all the features of our website. You can delete the cookies already stored on your computer. More generally, it is brought to the user s attention that he/she can oppose the registration of these cookies files by configuring his/her browser software. For information, the user can find at the following addresses the steps to follow in order to configure his browser software to oppose the registration of cookies files: Chrome: https://support.google.com/accounts/answer/61416/ Firefox : https://support.mozilla.org/fr/kb/enable-and-disable-cookies-website-preferences Safari : http://www.apple.com/legal/privacy/ Internet Explorer : https://support.microsoft.com/help/17442/windows-internet-explorer-delete-manage-cookies Opera : http://www.opera.com/help/tutorials/security/cookies/ In the event that the user decides to deactivate the cookies files, they will be able to continue browsing the site. However, any malfunction of the site caused by this manipulation could not be considered as being due to the site editor.b. Description of cookies files used by the siteThe editor of the site draws the attention of the user to the fact that the following cookies are used during his navigation: We use Facebook, Google Analytics and Adwords on our website to: recognize a computer when a user visits the website/ track users as they navigate the website/ enable the use of a shopping cart on the website/ improve the use of a website/ analyze the use of the website/ administer the website/ prevent fraud and improve the security of the website/ customize the website for each user/ send targeted advertisements that may be of interest to certain users.

ARTICLE 7: CONDITIONS FOR CHANGING THE PRIVACY POLICY
This Privacy Policy can be viewed at any time at the address below: https://www.hashgraphtower.com/privacy-policy The site editor reserves the right to modify it in order to guarantee its conformity with the law in force. Therefore, the user is invited to consult this privacy policy regularly in order to be informed of the latest changes. The user is informed that this privacy policy was last updated on: 01/01/2022.

ARTICLE 8: USER ACCEPTANCE OF THE PRIVACY POLICY
By browsing the site, the user certifies that he/she has read and understood the present privacy policy and accepts its conditions, particularly with regard to the collection and processing of his/her personal data, as well as the use of cookies.

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