1. Introduction
   1. At Backed Assets (JE) Limited ("we", "our", and "us") we respect your privacy and we are committed to protecting your information. This privacy notice will inform you about the Personal Data that we collect about you when you visit our website ("Site") and/or use the features available thereon (together with the Site, the "Services"), the reasons why we use that data, how we use it, and tell you about your privacy rights. This Privacy Notice also explains how we process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information. If not otherwise defined herein, capitalized terms have the meaning given to them in the Terms of Service, available at https://www.backedassets.fi/terms-of-service ("Terms"). "You", "your", and "user(s)" means any visitor and/or user of the Site and/or Services.
   2. If you are an individual located in the European Union ("EU" and "EU Individual", respectively), some additional terms and rights may apply to you, as detailed herein. Our designated representative in the EU and the United Kingdom ("UK"), for privacy and data protections matters pursuant to applicable law, is the Prighter Group ("Prighter"). Prighter provides a way to exercise your privacy-related rights, as further detailed herein (e.g. requests to access or erase Personal Data). You may contact us via our representative, Prighter, or otherwise exercise your EU/UK data subject rights at https://prighter.com/q/14862971837. Alternatively, you may contact us directly as stated in paragraph ‎18 below.
2. About us and contact information

Backed Assets (JE) Limited is a data controller and your Personal Data will be transferred to and/or collected by us as a result of the Services we provide. We are responsible for the Personal Data we hold and if you have any queries about any aspect of this privacy notice, please contact us using the contact details below:Backed Assets (JE) Limited, c/o Cavendish Fiduciary (Jersey) Limited, First Floor, La Chasse Chambers, Ten La Chasse, St. Helier, JE2 4UE, Jersey

Email address: [email protected]

‍Tel: +44 1534 888860

www.backedassets.fi – please go to 'contact us'.

3. Privacy Notice Key Points

The key points listed below are presented in further detail throughout this Privacy Notice. You can click on the headers in this paragraph in order to find out more information about any topic. These key points do not substitute the full Privacy Notice.

4. Personal Data we collect
5. How we use and look after your Personal Data
6. Why we use Personal Data
7. Opting out
8. If you fail to provide Personal Data
9. Additional Uses
10. Cookies and Similar Technologies
11. Disclosures and transfers of your Personal Data
12. Security
13. How long we keep Personal Data
14. Your legal rights
15. Third-party links
16. Children
17. Changes to the privacy notice
18. Complaints

4. Personal Data we collect
   1. We may collect Personal Data relating to your identity and contact details such as names, addresses, email addresses, telephone numbers and date of birth and other Personal Data from you as a result of you using the Services we provide and/or through you using our Site.
   2. Certain other types of Personal Data may also be held by us. For example, if you use a device to access our Services, we may also employ cookies and similar technologies to collect or have access to technical data or usage data, including your IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, the operating system and platform. These technologies are utilized to enhance our Services, review usage patterns, and improve our Site's content and functionality. In addition, aggregated data or anonymised data may be held by us.
   3. If you communicate with us then, depending on the nature of your communication, we will collect Personal Data about you.
   4. We source your Personal Data from the information you provide to us either via our Site or otherwise in connection with the Services which we provide to you. For example, we may require you to provide Personal Data directly to third parties acting in connection with the Services we provide to you and such Personal Data may be transferred to us. Such Personal Data may be collected from you via direct interactions, or as a result of automated technologies or interactions.
   5. If you do not want us to collect any Personal Data from you, please do not ask us to provide any services to you or visit our website.
   6. If you choose not to provide certain Personal Data requested by us, we may not be able to fully register you for our Services or provide specific aspects of our offerings. However, your decision to withhold certain information will not impact your access to the core features of our Site.
   7. "Personal Data" means any information that refers to, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law. This Privacy Notice details which Personal Data is collected or processed by us in connection with provision of the Services.
5. How we use and look after your Personal Data
   1. We will only collect and use Personal Data where we have a legal basis for doing so. This includes:

1. where the use of your Personal Data is necessary to fulfil a contract with you, e.g. to provide you with the Site and Services by means of Necessary cookies and/or Functionality session cookies (each as defined in paragraph ‎10 below); or
2. to comply with our legal duties; or
3. any regulatory requirements which we are obliged to comply with; or
4. for the purposes of our legitimate interests (to operate successfully and to be responsive to your requests), e.g. to prevent fraud and/or to protect the security of our Site and Services; or
5. where you have consented to the collection and use of your Personal Data, e.g. for developing and improving our products and Services, review usage, and perform analytics.

2. We will ensure that our processing of your Personal Data complies with applicable data protection laws.

6. Why we use Personal Data
   1. We may use the Personal Data that we collect about you for the following purposes:

1. to provide you with the Site and Services;
2. to manage our relationship with you;
3. to administer and protect our business;
4. to use data analytics to improve our products/services, marketing, customer experience/relationship, the Services, and our Site;
5. to make suggestions and recommendations to you about products or services that may be of interest to you; or
6. to market our products and services to you. This may include sending direct marketing emails and other communications relating to our services or those of our partners, conducting statistical and marketing analysis, undertaking marketing research and sending to you advisories and invitations to seminars and other events.

2. We shall only send marketing communications to you to the extent that doing so is necessary for our legitimate interests (to operate successfully and to be responsive to your requests) or where you have consented to us doing so. As set out in paragraph ‎14 below, you may withdraw that consent at any time by contacting us using the contact details set out at paragraph ‎2 above. Each electronic marketing communication that you receive from us will also have an "unsubscribe" option, which will allow you to stop receiving similar communications in the future.
3. Please note that we may collect and use your Personal Data without your knowledge or consent, where this is required or permitted by law.

7. Opting out

You can ask us to stop sending marketing messages to you at any time by contacting us using the contact details set out at paragraph ‎2 above. Where you opt out of receiving these marketing messages, we may continue to collect and use other Personal Data about you.

8. If you fail to provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract. In this case, we may have to cancel a product or service you have with us, but we will notify you at the time if this is the case.

9. Additional Uses

We and/or our service providers use analytics tools, including "Google Analytics" to collect and analyze information about the use of the Site and/or Services, such as how often users visit the Site, what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the Site. By analyzing the information we receive, we may compile statistical information across a variety of platforms and users, which helps us improve our Site and Services, understand trends and customer needs and consider new products and services, and tailor existing products and services to customer desires. The information we collect is anonymous and aggregated and we will not link it to any Personal Data. We may share such anonymous information with our partners, without restriction, on commercial terms that we can determine at our sole discretion. You can find more information about how Google collects information and how you can control such use at https://policies.google.com/technologies/partner-sites.

10. Cookies and Similar Technologies
    1. We use cookies and similar technologies for a number of reasons, including to help personalize your experience. When visiting www.backedassets.fi, you shall be notified of the use of and placement of cookies and other similar technologies on your device as specified herein.
    2. What are Cookies? A cookie is a small piece of text that is sent to a user's browser or device. The browser provides this piece of text to the device of the originating user when this user returns.

1. A "session cookie" is temporary and will remain on your device until you leave the Site.
2. A "persistent" cookie may be used to help save your settings and customizations across visits. It will remain on your device until you delete it.
3. First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use both first- and third-party cookies.
4. We may use the terms "cookies" to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above, such as web beacons or "pixel tags".

3. How We Use Cookies. We use cookies and similar technologies for a number of reasons, as specified below. We will not place any cookies on your browser that are not strictly necessary unless you have first consented to the cookie pop up.
   
   The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories:
   
   Necessary
   ‍These cookies are necessary in order to allow the Site to work correctly. They enable you to access the Site, move around, and access different services, features, and tools. Examples include remembering previous actions (e.g. entered text) when navigating back to a page in the same session. These cookies cannot be disabled.
   
   Functionality
   ‍These cookies remember your settings and preferences and the choices you make (such as language or regional preferences) in order to help us personalize your experience and offer you enhanced functionality and content.
   
   Security
   ‍These cookies can help us identify and prevent security risks. They may be used to store your session information to prevent others from changing your password without your login information.
   
   Performance
   ‍These cookies can help us collect information to help us understand how you use our Site, for example whether you have viewed messages or specific pages and how long you spent on each page. This helps us improve the performance of our Site.
   
   Analytics
   ‍These cookies collect information regarding your activity on our Site to help us learn more about which features are popular with our users and how our Site can be improved.

4. Third Party Cookies. We use cookies from Google Analytics, TradingView, Finsweet and Webflow. Additionally, cookies may be placed in messages we send in order to track your interaction with such emails.
5. How to Adjust Your Preferences. Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Services may not function properly when cookies are disabled or removed. For example, if you delete cookies that store your account information or preferences, you will be required to input these each time you visit, and if you block cookies, certain legal notices may re-appear on each page of the Site that you visit.

11. Disclosures and transfers of your Personal Data
    1. We have business relationships with third parties. In some instances we may disclose your personal information to third parties where this is necessary to perform the Services for which you have engaged us or otherwise in furtherance of an outsourcing or other data processing arrangement. We may also share your Personal Data:
       1. with professional advisors such as auditors, law firms, or accounting firms;
       2. for legal and security reasons and to protect our Services and business;
       3. with our affiliates where this is necessary to provide you with our products and Services, and for the purpose of management of our business; or
       4. service providers and subcontractors; or
       5. in connection with an asset sale or purchase, a share sale, purchase or merger, bankruptcy, or other business transaction or re-organisation,

in each case in our legitimate interests (to operate successfully and to be responsive to your requests) or as required by law, as applicable. In such circumstances, any transfer of data to a third party will only be made in accordance with applicable data protection laws and on terms agreed with us. In relation to any other third parties, we will only disclose or transfer your information where you have given your consent, where it is in our legitimate interests to do so (to operate successfully and to be responsive to your requests), where it is necessary to perform our contract with you, or where we are required to do so by law or other regulatory code or practice, or where it is necessary for the purpose of, or in connection with legal proceedings or in order to exercise or defend legal rights.

2. We use subcontractors and service providers and have affiliates who are located in countries other than your own, such as Switzerland, the United States and the State of Israel and send them information we receive (including Personal Data). We conduct such international transfers for the purposes described above. We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice, including appropriate remedies in the event of the violation of your data protection rights in such third country.
3. Your Personal Data may be transferred to, or accessed from, countries whose laws provide a level of protection for Personal Data not always equivalent to the level of protection that may be provided in your own country. In particular, if you are located inside Jersey, the UK or the European Economic Area ("EEA") your Personal Data may be transferred to a country outside of Jersey, the UK, or the EEA. We will ensure that cross border transfers comply with all relevant laws and regulations.
4. Unless:
   1. you have expressly consented to the transfer of your Personal Data;
   2. the transfer is necessary for the performance of the Services for which we have been engaged or the conclusion or performance of a contract concluded in your interests; or
   3. the transfer is otherwise permitted by applicable data protection laws,

we will only transfer your Personal Data to a country that is deemed to have an adequate level of protection under the applicable data protection law or otherwise where we have put in place adequate safeguards to protect the Personal Data. In particular, where we send your Personal Data outside of Jersey, the UK, or the EEA, we shall only do so where the recipient of the data is subject to:

1. binding corporate rules;
2. standard data protection clauses approved under applicable law;
3. an approved code of conduct; or
4. an approved certification mechanism.

5. Further details on the safeguards adopted by us may be obtained by contacting us using the contact details set out at paragraph ‎2 above.

12. Security

We have implemented and maintain appropriate technical and organization security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to Personal Data appropriate to the nature of such data. The measures we take include:

1. The physical, electronic, and procedural safeguards we employ to protect your Personal Data include secure servers and SSL encryption of data.
2. We dedicate efforts for a proper management of system entries and limit access only to authorized personnel, who have committed themselves to confidentiality, on a need to know basis of least privilege rules, review permissions periodically, and revoke access immediately after employee termination.
3. We maintain and regularly review and update our privacy related and information security policies.
4. We encrypt the data in transit using secure SSL encryption protocols.
5. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
6. As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.

13. How long we keep Personal Data
    1. We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may delete information from our systems without notice to you once we deem it is no longer necessary for these purposes. We require that our processors delete Personal Data when they no longer require it.
    2. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in relation to our relationship with you.
    3. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
    4. In some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
14. Your legal rights
    1. Under certain circumstances, you have the following rights under data protection laws in relation to your Personal Data. In each case, the exercise of these rights is subject to the provisions of the data protection legislation:

1. Request access to your Personal Data (commonly known as a "data subject access request"): This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
2. Request correction of the Personal Data that we hold about you: 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.
3. Request erasure of your Personal Data: This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Object to processing of your Personal Data: This enables you to object to processing your Personal Data where we are relying on a legitimate interest (or those of a third party). You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Request restriction of processing of your Personal Data: This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
   1. if you want us to establish the data's accuracy;
   2. where our use of the data is unlawful but you do not want us to erase it;
   3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
   4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer of your Personal Data to you or to a third party: 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.
7. Withdraw consent at any time where we are relying on consent to process your Personal Data: However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

2. If you wish to exercise any of the rights set out above, please contact us using the contact details set out at paragraph ‎2 above.

15. Third-party links

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our Site, we encourage you to read the privacy notice of every website that you visit.

16. Children

We do not knowingly collect Personal Data from children under the age of sixteen (16). In the event that you become aware that an individual under the age of sixteen (16) has used our Services without parental permission, please advise us immediately.

17. Changes to the privacy notice
    1. We keep our privacy notice under regular review. This privacy notice may be updated from time to time and was last updated on or around the date of this Securities Note. The current version of this privacy notice shall be displayed on our Site or may be requested using the contact details set out at paragraph ‎2 above.
    2. If you would like to access previous versions of this notice please contact us using the contact details set out at paragraph ‎2 above.
18. Complaints

You have the right to make a complaint at any time to the Jersey Data Protection Authority, the Jersey supervisory authority for data protection issues, which is contactable at the Jersey Office of Information Commissioner (JOIC – https://jerseyoic.org). We would, however, appreciate the chance to deal with your concerns before you approach the JOIC, so please contact us in the first instance.