Privacy Policy

At Six Clovers, Inc., a company registered in BVI, having its registered office at ABM Chambers, P.O.Box 2283, Road Town, Tortola, British Virgin Islands, company ID 2108802, d/b/a Versal ("Six Clovers", "we", "us") we consider the privacy of the users ("you," "User") of our website www.versal.money (the "Website") and our customers using our service (the "Service"), and the security of the Personal Information we collect about them to be very important. This Privacy Notice describes, in detail, the types of Personal Information we collect and record in and through the Website and the Service, and how we use and disclose Personal Information. As used in this Privacy Notice, "Personal Information" means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual or, where applicable, a household. This Privacy Notice applies only to Personal Information collected in and through the Website and/or the Service. This Privacy Notice does not apply to any information collected offline or via channels other than the Website and/or the Service. This Privacy Notice does not describe how we process Personal Information on our customers’ or any other person’s instructions (e.g., where we, for example, act as a Processor under the General Data Protection Regulation ("GDPR") or as a Service Provider under the California Consumer Privacy Act ("CCPA")).

I. COLLECTING PERSONAL INFORMATION

This section provides information about the Personal Information that we collect when you sign up and use the Service, that we collect when you communicate with us, and that we collect automatically.

a. Signing Up and Using the Service

When you sign up and use the Service, we collect the following information from you that may, alone or in combination with other information, constitute Personal Information:

• Legal first and last name
• Contact number
• Contact email address
• Photo identification cards
• Company name
• Company website
• Registered company address
• Country/State of incorporation
• Date of incorporation
• Entity type
• Ownership structure, including all natural persons who own over 10% of the company directly, or indirectly
• Source of funds
• Articles of incorporation
• Certificate of good standing

We do not collect payment card information in connection with any purchases. Payment card information is processed by a third-party vendor.

b. When You Communicate with Us

When you communicate with us in and through the Website or the Service, email us, or otherwise communicate with us, we collect the following identifiers that may, alone or in combination with other information, constitute Personal Information:

• first name;
• last name;
• email address or other contact information that you use to contact us; and
• the contents of the communications you sent to us.

You have no obligation to provide the Personal Information described above, but if you don’t provide such Personal Information, we may not be able to respond to your communications to us.

Please note that you have the right to opt out of receiving electronic direct marketing communications, such as newsletters, from us. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Should you decide to opt-out of receiving future mailings, we may share your e-mail address with third-parties to ensure that you do not receive further communications from third-parties. Despite your indicated e-mail preferences, we may send you notices of administrative nature of any updates to the Service or this Privacy Notice. If you have any additional questions about electronic direct marketing received from us, please contact us at privacy@versal.money.

c. Automatically Collected Information

Software used on the Website collects Internet or other electronic network activity information that may, alone or in combination with other information, constitute Personal Information:

• The domain from which you access the Website;
• The type of browser and operating system used in the device you use to access the Website;
• Internet Protocol (IP) address;
• The date and time you visited the Website (time stamp);
• The pages browsed on the Website;
• The website used to link to the Website from;
• Any search terms used to navigate the Website;
• Products purchased and viewed on the Website;
• A browsing session ID;
• Whether you are a first-time visitor to the Website; and
• Blockchain transaction information and wallet addresses.

For additional information about cookies used on the Website, please review Section VII below.

Google Analytics is an element of the Website. By using cookies, Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the Website, the IP address, and the type of operating system used in the devices used to access the Website. You can opt out of Google Analytics by using a browser plugin available at http://www.google.com/ads/preferences/plugin/.

II. PURPOSES OF COLLECTING PERSONAL INFORMATION

This section explains the several purposes we have for collecting your Personal Information:

For Website and Service operations. (i) To provide, operate, maintain, administer and improve the Website and/or the Service; (ii) to manage and communicate with you regarding your Service account, if you have one, including by sending you announcements relating to the Service, technical notices, updates, security alerts, and support and administrative messages; (iii) to process payments you may make through the Service; (iv) to better understand your needs and interests, and personalize your experience with the Website; (v) to send you information about the Website and/or the Service by email (vi) to respond to your Website and/or Service-related requests, questions and feedback.

To communicate with you. If you request information from us, or register to use the Website and/or the Service, we may send you Six Clovers-related marketing communications if permitted by law but will provide you with the ability to opt out.

Administration and analysis. We use automatically collected information to administer the Website and we analyze (and may engage third-parties to analyze) this information to improve and enhance the Website by, for example, expanding its features and functionality and tailoring it to our Users’ needs and preferences.

To comply with law. We use Personal Information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

With your consent. We may use or share Personal Information with your consent, such as when you instruct us to take a specific action with respect to Personal Information.

To create de-identified data for analytics. We may de-identify Personal Information. We de-identify Personal Information by excluding information that makes the data personally identifiable to you, and use that de-identified data for our lawful business purposes.

For compliance, fraud prevention, and safety. We use Personal Information about you as we believe necessary or appropriate to (i) enforce the terms and conditions that govern the Website and/or the Service; (ii) protect our rights, privacy, safety or property, and/or that of you or others; and (iii) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

III. HOW WE SHARE PERSONAL INFORMATION ABOUT YOU

We do not share or sell the Personal Information that you provide us with other organizations without your express consent, except as described in this Privacy Notice. We disclose Personal Information to third-parties under the following circumstances:

Service Providers. We may employ third-party companies and individuals to administer and provide the Website and/or the Service on our behalf (such as credit card payment processing, customer support, revenue management, hosting, email delivery, database management services, and data storage services). These third-parties are permitted to use Personal Information about you only to perform these tasks only for lawful business purposes in accordance with the terms of the agreement(s) we have in place with such service providers and for no other purpose.

Professional Advisors. We may disclose Personal Information about you to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Business Transfers. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets. You acknowledge and agree that any successor to or acquirer of Six Clovers (or its assets) will continue to have the right to use Personal Information and other information in accordance with the terms of this Privacy Notice. Further, Six Clovers may also disclose aggregated Personal Information in order to describe the Website and/or the Services to prospective acquirers or business partners.

Compliance with Laws and Law Enforcement; Protection and Safety. We may disclose Personal Information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (i) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (ii) enforce the terms and conditions that govern the Website; (iii) protect our rights, privacy, safety or property, and/or that of you or others; and (iv) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

IV. YOUR DATA PROTECTION RIGHTS & CHOICES

You have the following rights:

If you wish to access Personal Information that Six Clovers collects about you, you can do so at any time by contacting us using the contact details provided under "How to Contact Us" heading below.

Six Clovers account holders may review, update, correct, or delete the Personal Information in their registration profile by logging into their account. Six Clovers account holders may also contact us to accomplish the foregoing or if you have additional requests or questions.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

V. RETENTION OF INFORMATION

We will retain Personal Information we process in connection with the Website and/or the Service as long as such Personal Information is needed for purposes described in this Privacy Notice. If you have an account in connection with the Website, you can remove Personal Information associated with your account by deleting the account in the Website. Please note that some Personal Information about you will be retained in backup systems following such deletion. If required by law, we will delete Personal Information by erasing it from our database.

VI. CHILDREN’S INFORMATION

The Website is not intended for use by anyone under the age of 16, nor does Six Clovers knowingly collect or solicit Personal Information from anyone under the age of 16. If you are under 16, you may not attempt to register for the Website or send any information about yourself to us. In the event that we confirm that we have collected Personal Information from someone under the age of 16 without verification of parental consent, we will delete that information promptly. If you are a parent or legal guardian of a child under 16 and believe that we might have any information from or about such child, please contact us.

VII. HOW DO WE USE COOKIES?

Some of the features on the Website require the use of "cookies." Cookies are small text files that are stored on your device's hard drive. We use cookies to measure which pages are being accessed, and which features are most frequently used. This enables us to continuously improve the Website to meet the needs of our visitors.

The following explains how we may use different types of cookies and your options for managing cookie settings:

VIII. SECURITY

We take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. Despite these efforts to store Personal Information collected on and through the Website and/or the Service and otherwise by us in a secure operating environment that is not available to the public, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee that our security measures will prevent third-parties such as so-called hackers from illegally obtaining access to Personal Information. We do not warrant or represent that Personal Information about you will be protected against, loss, misuse, or alteration by third-parties.

IX. FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA

This section provides information on additional rights under this Privacy Notice for residents of the European Economic Area.

a. Legal Basis for Processing Personal Information

The legal bases for our processing of Personal Information about you are as follows:

Contract. When you sign up for the Service, we collect Personal Information about you that is necessary for completing that transaction and providing the Service to you;

Consent. We obtain your consent to collect Personal Information for distinct purposes such as receiving marketing communications from us. You have the right to withdraw your consent at any time.

Legitimate Interest. We have a legitimate interest to collect Personal Information about you for certain purposes such as data analytics and the protection and administration of the Website so that we can (i) understand our customers’ preferences and improve the Website; (ii) protect the Website from information security threats and protect Six Clovers in connection with legal claims and proceedings; (iii) communicate administrative changes in connection with the use of the Website and/or the Service; and (iv) comply with laws that apply to us, the Website, and the Service.

b. Transfers of Personal Information

Six Clovers is based in the British Virgin Islands ("BVI"). If you are located in the European Economic Area ("EEA"), the United Kingdom, or Switzerland, this means that we may transfer Personal Information outside of the EEA, the United Kingdom, or Switzerland. Such transfers are made using adequate safeguards, such as the EU Standard Contractual Clauses.

You have the following rights with respect to the Personal Information we hold about you. The right to:

• know what Personal Information we hold about you;
• have incomplete, incorrect, outdated, or unnecessary Personal Information corrected, deleted, or updated;
• request that we restrict the processing of Personal Information we hold about you in certain circumstances;
• object to the processing of Personal Information we hold about you; and/or
• receive any Personal Information we hold about you in a structured and commonly used machine-readable format or have such Personal Information transmitted to another company.

In connection with exercising your rights described above, we may request additional Personal Information for purposes of verifying your identity and for no other purpose.

Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Information about you. We encourage you to first reach out to us at privacy@versal.money so we have an opportunity to address your concerns directly before you do so.

To exercise any of the rights described above, please contact privacy@versal.money. We seek to promptly respond to your inquiry.

X. FOR CALIFORNIA RESIDENTS

Under California’s Shine the Light law, Cal. Civ. Code § 1798.83, California residents have the right to request in writing from businesses with whom they have an established business relationship, (i) a list of the categories of personal information, such as name, email and mailing address including billing ZIP code and the type of services provided to the customer, that a business has disclosed to third-parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties' direct marketing purposes; and (ii) the names and addresses of all such third-parties. To request the above information, please contact us at privacy@versal.money. We will respond to such requests for information access within 30 days following receipt at the email or mailing address stated below. Please note that we are only required to respond to an individual once per calendar year.

Additionally, California law requires that we indicate whether we honor "Do Not Track" settings in your browser concerning targeted advertising. We do not currently alter our practices when a Do Not Track signal is received. To learn about Do Not Track and for information about how to opt out of receiving targeted advertising, please click www.aboutads.info/choices.

Furthermore, subject to certain exemptions, California residents have the following rights with respect to Personal Information we may have collected about them:

a. Requests to Know

You have the right to request that we disclose:

• The categories of Personal Information we have collected about you;
• The categories of Personal Information about you we have sold or disclosed for a business purpose;
• The categories of sources from which we have collected Personal Information about you;
• The business or commercial purposes for selling or collecting Personal Information about you;
• The categories of Personal Information sold or shared, if any, about you, as well as the categories of third-parties to whom the Personal Information was sold, by category of Personal Information for each party to whom Personal Information was sold; and
• The specific pieces of Personal Information collected.

You may submit a request by emailing us at privacy@versal.money. The delivery of our response may take place electronically or by mail. We are not required to respond to requests to know more than twice in a 12-month period.

We do not sell, and have not in the prior 12 months sold, Personal Information about California residents. Therefore, we have not included a "Do Not Sell My Personal Info" link on the Website. If our practices change, we will update this Privacy Notice and take any other necessary action to comply with applicable law.

b. Requests to Delete

In certain circumstances, you have the right to request that we delete any Personal Information about you that we have collected. Upon receiving a verified request to delete Personal Information, we will do so unless otherwise required or authorized by law. You may submit a request by emailing us at privacy@versal.money.

c. Authorized Agents

You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney pursuant to Probate Code sections 4000-4465 may submit a request on your behalf.

d. Methods for Submitting Consumer Requests and Our Response to Requests

You may submit a request for access and requests to delete Personal Information about you via email at privacy@versal.money.

Upon receipt of a request, we may ask you for additional information to verify your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose.

We will acknowledge the receipt of your request within ten (10) business days of receipt. Subject to our ability to verify your identity, we will respond to your request within 45 calendar days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. In order to protect your privacy and the security of Personal Information about you, we verify your request via email.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

e. The Right to Non-Discrimination

You have the right not to be discriminated against for the exercise of your California privacy rights described above. Unless permitted by the CCPA, we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services; or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

XI. CHANGES TO OUR PRIVACY NOTICE

Changes to this Privacy Notice will be made when required in response to changing legal, technical, or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.

You can see when this Privacy Notice was last updated by checking the "Last Updated" date displayed at the bottom of this Privacy Notice. The new Privacy Notice will apply to all current and past users of the website and will replace any prior notices that are inconsistent with it.

XII. SECURITY

If you require any more information or have any questions about this Privacy Notice or our practices relating to Personal Information, please feel free to contact us by email at privacy@versal.money with the subject line "Questions about Privacy Notice."