1. Introduction
Pasa is a United States-based platform, where you can access the following Services regarding a variety of Digital Assets: save/earn, send, request payments, convert currency. You can use the Services of Pasa through our Website or through our App.

This is our Privacy Statement. In this document we explain what kind of personal data we collect via our Services. “Personal data” means all information by which a person can be directly or indirectly identified. We also explain what role we have in the processing of personal data, how long we retain personal data, and what rights you have as a data subject.

Please read this Privacy Statement carefully. Please note that this Privacy Statement uses certain terms that are defined in the General Terms and Conditions for Pasa.

2. Who is responsible for the processing of your personal data?
FINAX GLOBAL LLC (doing business as Pasa) is responsible for the processing of your personal data as described in this Privacy Statement and acts as the controller under applicable U.S. law and, where applicable, under the EU General Data Protection Regulation (“GDPR”) for processing of personal data of EU data subjects. Where personal data processing takes place in the context of Third Party Service Provider(s) (as further explained in the General Terms and Conditions), a given Third Party Service Provider may qualify as an independent controller for its processing activities.

If you have questions about the processing of your personal data, you can contact us through the contact details listed at the bottom of this Privacy Statement.

3. Which personal data could be processed and from which source?
Pasa may process your personal data if you:

• visit our Website;

• use our App; and/or

• use our Services.

3.1. Information we collect from you automatically
We receive and store certain types of information automatically when you interact with the Pasa Platform or use the Services. This information helps us address customer support issues, provide you with a streamlined and personalized experience, improve the performance of the Pasa Platform, and protect your account from fraud by detecting unauthorized access.

Information collected automatically includes:

• Online Identifiers: Information on how our Services are accessed and used, such as your IP address.

• Usage Data: When and for how long you visit the Pasa Platform, which pages you visit on the Pasa Platform, which links you click, and technical information (e.g., type of browser and operating system).

3.2. Information you provide to us
To open an Account and allow you access to our Services, we will ask you to provide certain information about yourself. This information is either required to verify your identity or necessary to provide the requested Services.

Below is an overview of the personal data we generally collect from our (potential) Users:

• Registration data: username, full name, email address, password.

• Account information: Recovery Key A.

If we add new features or Services and/or applicable laws and regulations change, you may be asked to provide additional information. In such case, we will inform you about the purposes and legal grounds for such additional processing separately and/or via an update of this Privacy Statement.

3.3. Profile picture data
To enhance the user experience and facilitate user identification, we may ask you to provide a profile picture when you use our App. This is entirely optional and is not required to use our Services.

When you upload a profile picture, we will collect and process this image data. Your profile picture may be visible to other users of our Services and will be associated with your account activity.

We use your profile picture solely to provide and enhance our Services. We do not use this data for other unrelated purposes, and we do not share it with third parties except with your explicit consent, or as required by law.

You may change or remove your profile picture at any time through the settings in our App. If you remove your profile picture, we will delete it from our servers and it will no longer be associated with your account.

Please do not upload images that contain sensitive personal data, and ensure you have the rights to any image you upload. By uploading a profile picture, you consent to the collection, use, and disclosure of the image data as described in this Privacy Statement.

3.4. Information we collect from other sources
We may enhance the data we collect from you by incorporating information gathered from third parties. The Pasa App may interoperate with third-party services and platforms (for example, Anchors or Yield Providing Anchors) that may provide supplemental information.

4. For what purpose are your personal data processed?
We may use your personal data for the following purposes:

• To provide the Services: We process personal data necessary to provide the Services to you. For example, to store Digital Assets in your Account we require certain information such as your username, email address, and (where applicable) phone number. We cannot provide Services without that information.

• To provide service communications: We send administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information. You may not opt-out of critical service communications necessary for legal or security purposes.

• To provide customer service: We process your personal data when you contact us to resolve questions or troubleshoot problems. Without processing your personal data for such purposes, we cannot respond to your requests or ensure uninterrupted use of the Services.

The following chart summarizes how we use the categories of personal data we collect from customers:

(1 = To provide the Services; 3 = To provide customer service.)

(continued)

We use the information we collect to administer your account and provide you the Services. We also use the information we collect to:

1. Provide, maintain, and improve our products and services.

2. Participate in the provision of account recovery services and verify your identity.

3. Send you technical notices, security alerts, and support and administrative messages.

4. Communicate with you about services, updates, and other information offered by Pasa and others that we think may interest you, unless you have opted out of marketing communications.

5. Target advertisements to you on third-party platforms and websites unless you have opted out.

6. Respond to your comments and questions and provide customer service.

7. Monitor and analyze trends, usage, and activities in connection with our Services.

8. Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity, and protect the rights and property of users.

9. Debug to identify and repair errors in our Services.

10. Comply with our legal and financial obligations.

11. Carry out any other purpose described to you at the time the information was collected.

5. Legal Bases for Processing your information
FINAX GLOBAL LLC processes personal data for specified purposes and, depending on the jurisdiction of the data subject, based on lawful grounds such as:

• performance of the contract between you and Pasa (to provide the Services and perform pre-contractual steps),

• compliance with legal obligations,

• our legitimate interests (for example, fraud prevention, network and information security, maintaining the Services), and

• where required, your consent for specific processing activities (for example, marketing preferences or optional profile pictures).

If you have given consent for any processing, you may withdraw that consent at any time by contacting us at info@getpasa.com. Withdrawal of consent will not affect the lawfulness of processing carried out prior to withdrawal.

6. Who may receive your personal data?
Pasa limits access to your personal data to Pasa staff members who need that access to perform their job duties. We require such staff to keep personal data confidential.

Pasa may share personal data with Third Party Service Providers who perform services on our behalf (such as hosting, analytics, customer support, account recovery services, or payment and anchor providers). In some cases, those third parties may act as separate controllers (for example, when you interact directly with an Anchor); in other cases they act as processors under contract with Pasa. Where a third party is a controller for its own processing, Pasa is not responsible for that third party’s handling of your data; you should consult that third party’s privacy policy.

In addition, Pasa may disclose personal data:

• to comply with legal obligations, court orders, or lawful requests by public authorities (including to meet national security or law enforcement requirements),

• to enforce our agreements, terms, and policies, and to protect the rights, property, or safety of Pasa, our users, or third parties, and

• in connection with corporate transactions (e.g., mergers, acquisitions, sale of assets), where personal data may be transferred as part of that transaction.

6.1 Advertising and analytics
We may permit third parties to provide analytics services and to serve advertisements on our behalf across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your usage of our Services and other websites and applications, including IP address, browser type, pages visited, time spent, links clicked, and transaction information. This information may be used by Pasa and others to analyze and track data, determine content popularity, deliver advertising and content tailored to your interests, and better understand your online activity.

6.2 For example, we use Google Analytics to improve the performance of the Services and for analytics purposes. For more information about how Google Analytics collects and uses information, visit https://www.google.com/policies/privacy/partners/. To opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.

6.3 For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices or, if you are in Europe, http://www.youronlinechoices.eu/. Your device may also include a feature that allows you to opt out of certain information collection used for behavioral advertising in mobile apps.

6.4 We also work with third parties to serve ads to you as part of customized campaigns on third-party platforms (such as Facebook and Instagram).

7. Does Pasa transfer personal data to recipients outside the United States?
Pasa may transfer personal data to recipients located in jurisdictions outside the United States, including to service providers in other countries, for the purposes described in this Privacy Statement. When we do so, we will take appropriate steps to ensure your data receives an adequate level of protection (for example, by relying on standard contractual clauses, other safeguards, or where required, explicit consent). If you are located in the European Economic Area (EEA) or the United Kingdom, transfers from the EEA/UK to the United States or other jurisdictions will be handled in accordance with applicable cross-border transfer requirements (including, where relevant, the GDPR).

8. Your rights
Where applicable law grants you rights with respect to your personal data, Pasa respects and facilitates those rights. Depending on your jurisdiction, such rights may include:

• the right of access to personal data we hold about you;

• the right to request rectification of inaccurate personal data;

• the right to request deletion of your personal data;

• the right to restrict or object to certain processing activities;

• the right to data portability; and

• the right to withdraw consent to processing where applicable.

If you are a California resident, you may also have rights under the California Consumer Privacy Act (CCPA) and related California privacy laws, including the right to request disclosure of categories of personal information collected, categories of sources, purposes for collection, and categories of recipients; the right to request deletion of personal information; and the right to opt out of the sale of personal information (to the extent applicable). To exercise rights under the CCPA, please contact info@getpasa.com.

To exercise any privacy right set forth above, please contact us at info@getpasa.com. We may request additional information to verify your identity before fulfilling your request. We will generally respond to verifiable requests within applicable statutory timeframes (for example, the GDPR allows up to one month to respond, with the possibility of an extension where appropriate). If we need more time, we will inform you of the reason and the expected date of completion.

Some rights are not absolute; we may be required to retain or refuse requests to the extent permitted by applicable law (for example, to comply with legal obligations or to preserve public safety).

9. Complaints
If you believe Pasa has processed your personal data unlawfully or you are not satisfied with our response to a request, you may submit a complaint to us at info@getpasa.com. We will respond as soon as reasonably practicable.

If you are in the European Union or the United Kingdom and you believe your GDPR rights have been infringed, you may also lodge a complaint with your local data protection supervisory authority. If you are in the United States and are not satisfied with our response, you may have other options to pursue remedies under applicable state laws (for example, California’s privacy regulator or attorney general’s office) depending on your jurisdiction.

10. How will Pasa protect your personal data?
Pasa will retain your personal data no longer than necessary for the purposes described in this Privacy Statement, unless a longer retention period is required or permitted by law. Where retention periods are mandated by law, we will retain data for the statutory period.

Personal data processed to perform the User Agreement will be retained for the term of that agreement and thereafter as required by applicable law (for example, for financial recordkeeping and anti-money-laundering obligations). Where processing is based on your explicit consent, we will retain your personal data until you withdraw that consent, unless otherwise required by law.

We employ administrative, technical, and organizational measures intended to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. However, no security measure is perfect or impenetrable; we cannot guarantee absolute security of your data.

11. Updating the Privacy Statement
Pasa may update this Privacy Statement. Any update will apply after announcing the update on our Website, our App, or through other official communications. If a change to the Privacy Statement involves a material change to the nature of the processing (for example, a new category of sensitive data or a new purpose that materially affects you), or otherwise may be relevant and impact you, Pasa will inform you explicitly and in advance of the change taking effect.

12. Contact and questions about this Privacy Statement
If you want to know more about Pasa’s Privacy Statement or have any questions or requests, please contact us at:

FINAX GLOBAL LLC (Pasa)
12550 Biscayne Blvd., Suite 218
North Miami, FL 33181
United States

Email: info@getpasa.com

We will respond to your request as quickly as reasonably practicable.