Date of Last Revision: 29 November 2023

Welcome to the APP DEV LLC’s (“App Dev” or “Lynx” “Us” or “We”) privacy notice.

Your privacy is important to us. This online privacy policy (“Privacy Policy”) explains how we collect,

share, use, and protect information when You use Our mobile application (“App”) and website

(“Website”, and collectively the App and Website are referred to “Lynx Platform”) or use of Our

online services (“Services”).

To the extent that you are a customer or user of our Services, this Privacy Policy should be read in

conjunction with our Terms of Use or User Agreement (“Terms”) and any other contractual

agreements we may have with you. All defined terms used in this Privacy Policy shall have the same

meaning ascribed to them in the Terms, unless expressly otherwise provided for. To the extent that

you are not a relevant stakeholder, customer, or user of our Services, but are using our website, this

This privacy notice is provided in a layered format so you can click through to the specific areas set

out below. Alternatively, you can download a pdf version of the policy from our website

http://lynxdigital.io/.

This version was last updated on 29 November 2023 and historic versions can be obtained by

contacting us. We reserve the right to revise this Privacy Policy at any time. If We change the Privacy

Policy, we’ll provide notice by posting the new Privacy Policy here and changing the date on the top.

YOUR DUTY TO INFORM US OF CHANGES

It is important that the personal data we hold about you is accurate and current. Please keep us

informed if your personal data changes during your relationship with us. If your data changes and

you do not inform us, we reserve the right to completely restrict you from using Lynx Application or

accessing our Services.

THIRD-PARTY LINKS

This website may include links to third-party websites, including External Service Provider website

link where You might be required to provide additional personal data. Clicking on those links,

accessing such External Service Provider’s service or enabling those connections may allow such third

parties (including External Service Provider) to collect or share data, including personal data, about

You. We do not control these third-party (including External Service Provider) websites and are not

responsible for their privacy statements. When you leave our website, we encourage you to read the

privacy notice of every website you visit.

TYPE OF PERSONAL DATA WE COLLECT

When You visit the Website or use Our Services, We may collect personal information from or about

You. In particular, We collect information You provide when you: (a) fill in any registration form to use

Lynx Platform, (b) register to use the App, (c) open an account or use any of Our Services, (d) KYC

completion or (e) contact Us for any other reason. We may collect Your personal information that

You have left with Us by visiting Our Website, or subscribing to Our Services or through any other

medium linked to Lynx Platform (“Personal Data”).

The Personal Data may include, but is not limited to, the following:

Category of

Data

Type of Personal Data

Purpose

Identification

information

● Full Name

● Contact Number

● Email Address

● Home Address

● Place of Birth

● Date of Birth

● Nationality

● Photograph or Selfie

Full Name, Contact Number, Email ID

● To Create and Maintain your

Lynx Accounts.

● To facilitate your access to

Lynx Platform

● To fulfil the contractual

obligations between You and

App Dev.

● To communicate with You on

Service related matters.

Gender, Home Address, Place of Birth,

Date of Birth, Nationality, Address

Proofs, Photograph or Selfie

● For completing KYC process.

● To maintain legal and

regulatory compliance.

Face ID

Face ID to verify your

identity (KYC Purpose),

with your consent or as

permitted by applicable

laws. Example, facial

scan data extracted

from your selfie or

government issued ID.

● For completing KYC process.

● To maintain legal and

regulatory compliance.

● If expressly consented by

you, for logging and account

access purposes.

Government

Identifiers

Any government issued identity

documents such as passport to

verify your identity, date of

birth or address.

● For completing KYC process.

● To maintain legal and

regulatory compliance.

Financial Data

● Bank account

information

● Payment card

information

● To provide you with Our

Services.

External

Digital Wallet

details

Digital Identifiers, Wallet

Address, or any other requisite

blockchain data to complete

any Services / transactions.

● To provide you with Our

Services.

Communicatio

● Complaints

● Survey Responses

● Any communications /

recordings with

customer service team

● To fulfil the contractual

obligations between You and

App Dev.

● To communicate with You on

Service related matters.

● To provide customer services.

Browsing

Information

Browsing information such as IP

address.

● To improve your experience

with the Lynx Platform.

● To provide enhanced

customer services.

● To promote safety and

integrity of Lynx Platform.

NON- PERSONAL DATA

Aggregated

Data and

Usage

Information

Data such as statistical or

demographic data for any

purpose. Aggregated Data may

be derived from your personal

data but is not considered

personal data in law as this data

does not directly or indirectly

reveal your identity. For

example, we may aggregate

your Usage Data to calculate

the percentage of users

accessing a specific website

feature. However, if we

combine or connect Aggregated

Data with your personal data so

that it can directly or indirectly

identify you, we treat the

combined data as personal data

which will be used in

accordance with this Privacy

Policy.

● To improve your experience

with the Lynx Platform.

● To provide enhanced

customer services.

● To promote safety and

integrity of Lynx Platform.

Marketing

Information

Certain marketing and research

information such as browser

data, preferences etc. This will

be anonymized for processing

purposes.

● To provide enhanced

customer service.

● To provide you with

promotional and marketing

information.

● For market research purposes.

Unregistered users: If you are a passive user of Lynx Platform and do not register for any Services,

you may still be subject to certain passive data collection (“Passive Data Collection”). Such Passive

Data Collection may include through cookies, as described below, IP address information, location

information, and certain browser data such as history and/or session information, usage data,

marketings and communications.

DATA COLLECTED FOR KYC COMPLETION

You acknowledge and agrees that in order to access certain Services provided by App Dev under Lynx

Platform, You may be required to complete some KYC verification with an External Service Provider

selected by Us from time to time.

Personal Data provided for KYC includes, but is not limited to (a) Full Name (b) Mobile Number (c)

Government Identifiers (d) Address and Place of Birth (e) Selfie Picture or/ and any Face ID and / or

any additional information our External Service Provider for KYC (“KYC Provider”) from time-to-time

request to complete the KYC process. (collectively “KYC Data”). We do not share your KYC Data,

including your Face ID with any third party or External Service Provider, except KYC Provider.

For KYC Data, KYC Provider shall be the processor and processing of KYC Data shall be done by KYC

Provider. Our current KYC Provider is “Sumsub” and their privacy notice can be accessed using the

following link http://sumsub.com/privacy-notice-service/ . Any changes to KYC Provider shall be

reflected here from time to time and Users are advised to keep themselves updated by periodically

reviewing this Privacy Policy. For any further information, contact us at policy@lynxdigital.io.

This KYC Data provided for KYC purposes by the User shall be retained by App Dev only until KYC is

completed and approved by KYC Provider, unless You consent to otherwise for Lynx Account access

purposes. Once KYC is obtained, App Dev will no longer hold such KYC Information, except for your

full name and mobile number (and with your consent Face ID for access control) to control access to

Lynx Platform. All other personal identifiers including Face ID (unless specific consent to retain it is

provided by You) shall be discarded in the most appropriate and secured manner. If you consent to

use Face ID for Lynx Account access purpose, this data will be stored until you maintain your Lynx

Account.

For further information as to how long your KYC Data will be retained by KYC Provider, please visit

the above link to review their privacy notice or alternatively reach out to us at policy@lynxdigital.io.

The User expressly acknowledges that App Dev have limited control over the data processing and

privacy policies of KYC Provider, and the User should read and understand their privacy notice(s)

through the link provided above. Completion of KYC with the KYC Provider is a condition precedent to

accessing the Services, and failure to complete KYC verification may result in the User being

unable to access the Services. By accessing the Services, the User acknowledges and accepts the

terms of this clause and agrees to indemnify and hold harmless Us, our affiliates, officers, directors,

agents, and employees from any and all claims, damages, and expenses arising from the KYC process.

OTHER WEBSITES

We are not responsible for the practices employed by any websites or services linked to or from Our

Services, including the information or content contained within them. Please remember that when

You use a link to go from Our Services to another website or service, Our Privacy Policy does not apply

to those third-party websites or services. Your browsing and interaction on any third-party website or

service, including those that have a link on Our website, are subject to that third party's own rules

and policies. In addition, You agree that We are not responsible and do not have control over any

third-parties that You authorize to access Your account. If You are using a third-party website or

service and You allow them to access Your Lynx Account, You do so at Your own risk.

WHY DO WE COLLECT YOUR INFORMATION?

We collect your information in order to:

(a) provide you with information and Services that you request from Us;

(b) allow You to register for Lynx Services;

details provided on Your account registration form to create and administer Your account;

(d) provide You with access to the Lynx Platform in a manner convenient and optimal for You and

with personalized content relevant to You, including enabling you to create a profile;

(e) connect Your Lynx Account with third party financial services providers or Your External Digital

Wallet/s at Your request;

(f) allow You to participate in interactive features of Our App when You choose to do so;

(g) provide You with email marketing information about other services or products We offer that

are similar to those that You have already requested or purchased, or about the services or

products You have consented to receiving email marketing about;

(h) manage Our relationship with You, including notifying You about changes to Our Services

and/or products;

(i) provide customer support;

(j) gather information and insights on how users are using Our Service in order to deliver

improvements and new features;

(k) administer Lynx Platform and for internal operations, including troubleshooting, data analysis,

testing, research, statistical and survey purposes;

(l) deliver (whether directly or indirectly via third parties) effective and personalized marketing

material and content of App Dev and where you have consented and to assist us in the

improvement and optimization of advertising, marketing material and content, our services

and the sites; and

(m) comply with Our legal obligations, policies, and procedures.

USE OF PERSONAL DATA.

We use the information discussed above in a number of ways, such as: (a) processing transactions,

(b) verifying Your identity (such as when You access Your account information), (c) preventing fraud

and enhancing the security of Your account or Our Services, (d) responding to Your requests and

communicating with you, (e) managing Your preferences, (f) performing analytics concerning Your

use of Our Services, including Your responses to Our emails and the pages and advertisements You

view, (g) providing You tailored content and marketing messages, (h) operating, evaluating and

improving Our business (including developing new products and services; improving existing

products and services; performing data analytics; and performing accounting, auditing and other

internal functions), (i) to send You information about Our Services, or promotional marketing

communication, (j) to administer Your account, or to service Your account, or to contact You when

necessary, (k) complying with and enforcing applicable legal requirements, relevant industry

standards, contractual obligations and Our policies and (l) for any other purposes that We may

specifically disclose at the time You provide or We collect Your information.

We may also use data that We collect on an aggregate or anonymous basis (such that it does not

identify any individual customers) for various business purposes, where permissible under applicable

laws and regulations.

If You no longer wish to receive any communications from Us, you can opt out by following the

instructions contained in the e-mails You receive or by contacting Us at policy@lynxdigital.io.

SHARING OF YOUR INFORMATION.

We will not rent or sell Your information to third parties outside App Dev without Your consent,

except as noted in this Privacy Policy.

Parties with whom We may share Your information:

(a) With Our corporate entities including any holding company, group company and subsidiary

(Group Company): We may share information with entities within App Dev family

companies.

(b) With third parties: We may share Your information with the following third parties: (i) with

External Service Provider/s and partners. We may share information about You with service

providers, including KYC Provider who perform services on Our behalf and business partners

that provide services and functionality; (ii) with third parties for legal reasons. We may share

information about You if We reasonably believe that disclosing the information is needed

to: (1) comply with any valid legal process, governmental request, or applicable law, rule, or

regulation; (2) investigate, remedy, or enforce potential violations of the terms and

conditions; (3) protect the rights, property, and safety of us, Our users, or others; (4) detect

and resolve any fraud or security concerns.

asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of Our

business to another company, We may share Your information with that company before

and after the transaction closes.

(d) other users in your jurisdiction when You post a comment on our app.

(e) Our professional advisors (including without limitation tax, legal or other corporate advisors

who provide professional services to us).

(f) third parties that You approve (including without limitation, any External Digital Wallet of

your choice, social media sites, and third-party payment providers).

(h) Our regulators, law enforcement or fraud prevention agencies, as well as Our legal advisers,

courts, the police, and any other authorized bodies, for the purposes of investigating any

actual or suspected criminal activity or other regulatory or legal matters including but not

limited to: Government authorities.

(i) tax bodies or agencies to comply with Our legal and regulatory obligations.

Consent for Data Transfer and Use by Third Parties: By using AppDev’s services, you acknowledge

and consent to the transfer of your personal and usage data to third parties, including but not limited

to AppDev’s business partners, service providers, external consultants, banks, financial institutions

(including but not limited to entities like CardList) ("Third Parties"). You understand and agree that

these Third Parties may further use, process, or transfer your data in furtherance of any

arrangements between AppDev and such Third Parties for legitimate business purposes. These

purposes may include, but are not limited to, providing services to you, data analysis, marketing and

promotions, payment processing, compliance with legal obligations, and other related activities. You

also acknowledge that such data transfers may involve the transmission of your data to other

jurisdictions, where data protection laws and regulations may differ from those in your jurisdiction.

AppDev shall take reasonable measures to ensure that any data transferred to these Third Parties is

handled in accordance with applicable data protection laws and regulations. However, you

understand and acknowledge that the data protection standards in these other jurisdictions may not

provide equivalent levels of protection as those in your jurisdiction. Should you have any concerns or

questions about the potential transfer and use of your data by Third Parties, including CardList, we

strongly recommend reviewing AppDev’s Privacy Policy or contacting AppDev’s support team for

more information. Your consent to the data transfer and potential use described in this section is

inherent in your continued use of AppDev’s services. You retain the right to withdraw your consent

for data transfer to Third Parties by contacting AppDev’s support team. However, please be aware

that withdrawing your consent may impact your ability to access certain features or services

provided by AppDev.

RESPONDING TO LEGAL REQUESTS AND PREVENTING HARM

We may access, preserve and share Your information in response to a legal request if We have a good

faith belief that the law requires Us to do so. This may include responding to legal requests from

jurisdictions outside of Saint Vincent and the Grenadines where We have a good faith belief that the

response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent

with internationally recognized standards. We may also access, preserve and share information when

We have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal

activity; to protect ourselves, You and others, including as part of investigations; and to prevent

death or imminent bodily harm. Information We receive about You may be accessed, processed and

retained for an extended period of time when it is the subject of a legal request or obligation,

governmental investigation, or investigations concerning possible violations of Our terms or policies,

or otherwise to prevent harm.

STORAGE AND PROCESSING.

Your information collected through the Services may be stored and processed in any country in which

App Dev maintain facilities.

We will retain Your information in accordance with Our internal records retention and management

policies and procedures, including as necessary to provide You with the Services or administer Your

Lynx Account, or as long as necessary to comply with Our legal obligations, resolve disputes, reserve

Our legal rights, and enforce Our agreements.

We aim to collect only what We need, keep it up-to-date and remove it when We no longer need it.

We will only retain your Personal Data for so long as we reasonably need to offer You Our Services

unless a longer retention period is required by law.

We take reasonable steps to ensure that the personal information We process is limited to what We

require in connection with the purposes set out in this Privacy Policy; it is accurate and, where

necessary, kept up to date; and it is erased or rectified without delay if it is inaccurate. From time to

time, We may ask You to confirm the accuracy of Your personal information.

App Dev, any of its group company (from time to time), or service providers may transfer information

that We collect about you, including personal information across borders and from Your country or

jurisdiction to other countries or jurisdictions around the world. We endeavor to ensure that people

to whom we provide Personal Data hold it subject to appropriate safeguards and controls.

We use commercially reasonable safeguards to help keep the information collected through the

Services secure and take reasonable steps (such as requesting a One Time Password (OTP) connected

to Your registered mobile number to verify Your identity before granting You access to Your account)

however, App Dev cannot ensure the security of any information You transmit to App Dev or

guarantee that information on the Services may not be accessed, disclosed, altered, or destroyed.

We will retain copies in a form that permits identification for as long as We deem necessary in

connection with the purposes set out in this Privacy Policy, unless applicable law requires a longer

retention period. In particular, We will retain personal information for as long as it is needed to

establish, exercise or defend any legal rights.

Please do Your part to help us. You are responsible for maintaining the secrecy of Your account

information, and for controlling access to emails between You and App Dev, at all times.

YOUR RIGHTS RELATED TO YOUR PERSONAL DATA.

You have the right to:

- Request access to your Personal Data. This enables you to receive a copy, upon your request, of

the Personal Data we hold about you and to check that we are lawfully processing it.

- Request correction of the Personal Data that we hold about you. Upon your request, this

enables you to have any incomplete or inaccurate information we hold about you corrected.

- Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal

Data where there is no legal requirement for us continuing to process it. You also have the right

to ask us to delete or remove your Personal Data where you have exercised your right to object

to processing.

- Object to processing of your Personal Data. This right exists where we are relying on a

legitimate interest as the legal basis for our processing and there is something about your

particular situation, which makes you want to object to processing on this ground.

- Request the restriction of processing of your Personal Data. This enables you to ask us to

suspend the processing of Personal Data about you, for example if you want us to establish its

accuracy or the reason for processing it.

- Request the transfer of your Personal Data. We will provide to 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 which you initially provided consent for us

to use or where we used the information to perform a contract with you.

- Consent Withdrawal. This right only exists where we are relying on consent to process your

Personal Data. If you withdraw your consent, we may not be able to provide you with access to

the certain specific functionalities of Lynx Platform or Services. We will advise you if this is the

case at the time you withdraw your consent.

HOW TO EXERCISE YOUR RIGHTS

If you want to exercise any of the rights described above, please contact us at policy@lynxdigital.io.

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other

rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your

request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request

in these circumstances. We may need to request specific information from you to help us confirm

your identity and ensure your right to access your Personal Data (or to exercise any of your other

rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has

no right to receive it. We may also contact you to ask you for further information in relation to your

request to speed up our response. We try to respond to all legitimate requests within one month.

Occasionally it may take us longer than a month if your request is particularly complex or you have

made a number of requests. In this case, we will notify you and keep you updated.

CHILDREN’S PRIVACY.

App Dev does not knowingly collect or solicit any information from anyone under the age of 18 or

knowingly allow such persons to register for the Services. The Services and its content are not

directed at children under the age of 18.

CONFIDENTIALITY AND SECURITY OF PERSONAL DATA.

Except as otherwise provided in this Privacy Policy We will keep Your Personal Data private and will

not share it with third parties, unless such disclosure is necessary to:

 Comply with a court order or other legal process; or

 Protect Our rights or property.

App Dev offers You different security layers such as two factor authentications and one-time

passwords and maintain a secure server infrastructure that protects Your Personal Data.

We, at App Dev, are guided by top security standards to improve the security of Our Platform. In

addition, we limit access to your Personal Data to those employees, agents, contractors and other

third parties who have a business need to know. They will only process your personal data on our

instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal

with any suspected personal data breach and will notify you and any applicable regulator of a breach

where we are legally required to do so.

Should You wish to retrieve Your Personal Data, please get in touch by emailing Us on

policy@lynxdigital.io.

LIMITATION TO OUR PRIVACY POLICY.

Our Website might contain links to other websites. We are not responsible for the privacy practices

or the content of such websites. Please understand that any information that is disclosed in these

areas becomes subject to the privacy policies and practices of those sites. We have no control over

its use and You should exercise caution when deciding to disclose Your Personal Data.

CHANGE OF PURPOSE

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably

consider that we need to use it for another reason and that reason is compatible with the original

purpose. If you wish to get an explanation as to how the processing for the new purpose is

compatible with the original purpose, please email us at policy@lynxdigital.io.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain

the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in

compliance with the above rules, where this is required or permitted by law.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around

marketing and advertising.

We may use your identity, contact, technical, usage and profile data to form a view on what we think

you may want or need, or what may be of interest to you. This is how we decide which our Services

and offers may be relevant for you.

You will receive marketing communications from Us if you have requested information from Us or

availed Services from Us or if you provided Us with your details when you entered a competition or

registered for a promotion and, in each case, you have not opted out of receiving that marketing.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by contacting us

email at policy@lynxdigital.io any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data

provided to us as a result of a product/service purchase, warranty registration, product/service

experience or other transactions.

HOW TO CONTACT US.

If You have any questions about this Privacy Policy or the Services, You may contact Us through the

following email address policy@lynxdigital.io.

COOKIES AND SIMILAR TECHNOLOGIES.

Like most online services and websites, We may use Cookies and other technologies, such as web

beacons, web storage, and unique advertising identifiers, to collect information about Your activity,

browser, and device.

A browser cookie is a small piece of data that is stored on Your device to help websites remember

things about you. Other technologies, including web storage and identifiers associated with Your

device, may be used for similar purposes. In this Privacy Policy, We use Cookies (Cookies) to refer to

all of these technologies.

We may also use these Cookies to collect information when You interact with the Lynx Platform or

any Services We offer through Lynx Platform or any External Service Provider or any other third party

service provider, such as for advertising and commerce features. Most web browsers are set to

accept Cookies by default. You can choose to remove or reject browser Cookies through the settings

on Your browser or device. Keep in mind, though, that removing or rejecting Cookies could affect the

availability and functionality of Our Services.

Like most providers of online services, App Dev uses Cookies for a number of reasons, such as

protecting Your data, helping Us see which features are most popular, counting visitors to a page,

improving Our users’ experience, keeping Our Services secure, and generally providing You with a

better, more intuitive, and satisfying experience. The Cookies We use generally fall into one of the

following categories: (i) preferences: We use these Cookies to remember Your settings and

preferences (For example: language); (ii) security: We use these Cookies to help identify and prevent

security risks (For example: to store Your session information to prevent others from changing Your

password without Your username and password); (iii) performance: We use these Cookies to collect

information about how You interact with Our Services and to help Us improve them (For example: to

determine if You have interacted with a certain page); (iv) analytics: We use these Cookies to help Us

improve Our Services (For example: to learn more about which features are the most popular with

Our users and which ones might need some tweaks); and, (v) advertising: We use these Cookies to

deliver advertisements, to make them more relevant and meaningful to consumers, and to track the

efficiency of Our advertising campaigns, both on Our Services and on other websites.

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