Last updated: November 1, 2023

We at XNB Pty Ltd respect your privacy and is committed to protecting your personal data.

This privacy policy ("Policy") applies to the processing of personal data by XNB Pty Ltd, (collectively, "XNB", "we", "us",

"our") regarding the use of our services or products and the access of our website at www.xnb.com or our mobile

application (collectively, our "Services"). We will inform you as users of our Services in this Policy as to how we look

after your personal data and tell you about your privacy rights and how the law protects you.

We may update this Policy from time to time by posting amended versions including the effective date of the amended

version.

Our Services are not intended for minors below the age of 18 years ("Minors") and we do not knowingly collect data

relating to any Minors.

CONTENTS OF THIS POLICY

1. PURPOSE OF THIS PRIVACY POLICY

2. PERSONAL DATA WE COLLECT

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. CROSS BORDER DATA TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS AND CHOICES

10. HOW TO CONTACT US

1 PURPOSE OF THIS PRIVACY POLICY

1.1 This Policy aims to give you information on how XNB collects and processes your personal data through

your use of our Services, including any data you may provide through our website or our mobile

application or other services when you sign up, register or continue using our Services.

1.2 It is important that you read this Policy together with any other privacy policy we may provide on specific

occasions when we are collecting or processing personal data about you so that you are fully aware of

how and why we are using your data. This Policy supplements other notices and privacy policies and is

not intended to override them.

1.3 This Policy is in accordance with Australian Privacy Principal on the Protection of Personal Data (the

'Data Protection Legislation').

Controller

1.4 We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation

to this Policy. If you have any questions about this privacy policy, including any requests to exercise your

legal rights, please contact the DPO using the details set out below.

1.5 If you have any questions about this Policy or our privacy practices, please contact our DPO at

info@xnb.com.

Changes to the privacy policy and your duty to inform us of changes

1.6 We keep our Policy under regular review. This version was last updated on November 1, 2023. Historic

versions can be obtained by contacting us via the contacts details set out in in 1.5.

1.7 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.

Third-party links

1.8 This website 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 statements. When you leave our

website, we encourage you to read the privacy policy of every website you visit.

2 PERSONAL DATA WE COLLECT

2.1 Personal data means any data or information about an individual from which that person can be identified.

It does not include data or information where the identity has been removed, which is referred to as

anonymous data.

2.2 We may collect, use, store and transfer different kinds of personal data about you while you use our

Services, which we have grouped together as follows:

a) Identity Data includes full legal name (including first name, maiden name and last name), username

or similar identifier, title, date of birth, place of birth, nationality, government issued identification

document (such as passport, identification card), your live facial image for verification.

b) Contact Data includes residential address, proof of residential address such as utility bills, country of

residence, email address and telephone numbers.

c) Background Data includes your employment status, business type, political background, close

connections, geographical location/exposure, relationships with politically exposed persons, risk

assessment information, compliance assessment information, information provided by personal

referrals.

d) Financial Data includes description of source of funds, source of wealth and related documents, bank

account, payment card details, virtual currency accounts, stored value accounts.

e) Transaction Data includes details about payments to and from you and other details of products and

services you have subscribed from us.

f) Technical Data includes internet protocol (IP) address, your login data, browser type and version, time

zone setting and location, browser plug-in types and versions, operating system and platform, device

data, MAC address, and other technology on the devices you use to access this website.

g) Profile Data includes your username and password, requests and transaction history of our Services

made by you, your interests, preferences, feedback and any other responses you provide in your

communication with us including our customer support.

h) Usage Data includes information about how you use our Services.

i) Marketing and Communications Data includes your preferences in receiving marketing from us and

our third parties and your communication preferences.

2.3 We will collect your live facial image through us or our third party service providers for the purpose of

checking and verifying your identity for client on-boarding purposes. The foregoing may constitute

Sensitive Personal Data, which is defined as any data that directly or indirectly reveals an individual's

family, racial origin, political or philosophical opinions, religious beliefs, criminal records, biometric data,

or any data related to the health of the individual (including physical, psychological, mental, genetic or

sexual condition, health care services and health status).

We will only collect Sensitive Personal Data from you with your explicit consent and will only use such data for

the specified purpose in the table under 4.2 below.

2.4 If you fail to provide personal data

a. 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 we have or

are trying to enter into with you (for example, to provide you with our Services). In this case, we may have to

cancel our Services you have with us but we will notify you if this is the case at the time.

3 HOW IS YOUR PERSONAL DATA COLLECTED?

3.1 We use different methods to collect data from and about you including through:

● Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by

corresponding with us by email, phone, instant messaging through customer service, or post or otherwise.

● Automated technologies or interactions. As you interact with our website or mobile application, we will

automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this

personal data by using cookies, server logs and other similar technologies. We may also receive Technical

Data about you if you visit other websites employing our cookies.

● Third parties or publicly available sources. We may receive personal data about you from various third

parties and public sources such as background check agencies, fraud and crime prevention agencies, third

party individuals, information on the internet available to the public.

4 HOW WE USE YOUR PERSONAL DATA

o Lawfulness of Processing

4.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal

data in the following circumstances:

b) Where it is necessary to perform the contract we are about to enter into or have entered into with you as a

party (such as providing the Services to you).

c) Where we have obtained your consent (in a clear, simple and unambiguous manner, obtained electronically

or in writing)

d) Where we need to comply with a legal obligation.

Purposes for which we will use your personal data

4.2 We have set out in the table below, a description of the purposes and lawfulness of processing your

personal data.

Purpose/ Activity

Type of Personal data

Lawfulness of Processing

Client on-boarding process:

Carrying out customer risk

assessment, client due diligence,

Anti-

Money Laundering ("AML")

checks and Know Your

Customers ("KYC") checks

1) Identity Data

2) Contact Data

3) Financial Data

4) Background Data

To assess the level of client due

diligence required and to carry out our

legal and regulatory obligations, such as

to assess and mitigate AML and financial

crime risks, as well as suitability and

appropriateness of certain products for

you.

To register you as our user/ new

customer

1) Identity Data

2) Contact Data

3) Financial Data

To enable us to register and sign you up

as our user and perform our contractual

obligations with you.

To process and perform our

Services for you

1) Identity Data,

2) Contact Data

3) Financial Data

4) Transaction Data

5) Technical Data

6) Profile Data

To provide you with your prescribed

Services and to perform our contractual

obligations with you.

To manage, process, collect,

transfer payments, fees, charges

for our Services

1) Identity Data

2) Contact Data

3) Financial Data

4) Transaction Data

5) Profile Data

As part of providing you our Services to

perform and complete the contractual

obligations.

To manage and prevent AML and

financial crime risks, to conduct

sanctions screening, fraud and

other background checks and to

prevent re-onboarding risks in the

future by compiling an internal

blacklist of rejected customers

1) Identity Data

2) Contact Data

3) Background Data

4) Financial Data

To prevent AML and financial crime risks

and to abide by legal obligations.

5) Technical Data

6) Transaction Data

To manage our relationship with

you which will include:

Notifying you about

changes to our terms

or Policy;

Asking you to leave a review or

take a survey

1) Identity Data

2) Contact Data

3) Profile Data

Marketing and

Communications Data

To provide you with updated information

on the Policy and to review the quality of

our services for review and

improvement. To perform our contractual

obligations and legal obligations

regarding data protection.

To deliver relevant website

content and advertisements to you

and measure or understand the

effectiveness of the advertising we

serve to you

1) Identity Data,

2) Contact Data

3) Profile Data

4) Usage Data

Marketing and

Communications Data

To understand and study how our users

use our Services, to allow us to develop

the appropriate products and services

and grow our business and to inform

users of our marketing strategy with

consent, if required.

To use data analytics to improve

our

website, products/services,

marketing, customer relationships

and experiences

1) Technical Data

2) Usage Data

3) Profile Data

To analyse user information for providing

improved services and user experience

with consent, if required. .

To make suggestions and

recommendations to you about

our Services that may be of

interest to you

2) Identity Data

3) Contact Data

4) Technical Data

5) Usage Data

6) Profile Data

Marketing and

Communications Data

To provide suggestions to users that

suits their interests. For development

and growth of our business. All with

consent, if required.

o Promotional offers from us

4.3 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 products, services

and offers may be relevant for you ("Marketing Communications"). You will receive Marketing

Communications from us if you have provided explicit consent.

o Third-party marketing

4.4 We will get your explicit opt-in consent before we share your personal data with any third party for

marketing purposes.

o Opting out

4.5 You can ask us or third parties to stop sending you marketing messages at any time by clicking the opt-

out links on any marketing message sent to you or by contacting us at info@xnb.com any time.

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

to us in connection with the use of our Services.

o Cookies

4.7 You can set your browser to refuse all or some browser cookies, or to alert you when websites set or

access cookies. If you disable or refuse cookies, please note that some parts of this website may become

inaccessible or not function properly.

o Change of purpose

4.8 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 contact us. Otherwise, we will write to you to obtain your consent for processing

your personal data for the new purpose.

5 DISCLOSURES OF YOUR PERSONAL DATA

5.1 We may share your personal data with the parties set out below for the purposes set out in the table

under 4.2 above:

a) Third parties service providers, agents, subcontractors, associated companies, affiliates in order to

provide you with our Services;

b) Third party enforcement authorities, other judicial or governmental bodies as required by the law or

legal process or when it is necessary for such disclosure to protect the public interest (for example to

facilitate the investigation of suspected or actual illegal activities);

c) Other third parties with your consent; and

d) Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our

business, then the new owners may use your personal data in the same way as set out in this Policy.

5.2 Please be assured that we require all third parties to respect the security of your personal data and to

treat it in accordance with the law. We do not allow our third-party service providers to use your personal

data for their own purposes and only permit them to process your personal data for specified purposes

and in accordance with our instructions.

6 DATA SECURITY

6.1 We have put in place appropriate security measures to prevent your personal data from being accidentally

lost, used or accessed in an unauthorised way, altered or disclosed. 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.

6.2 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.

7 DATA RETENTION

7.1 We will only retain your personal data for as long as reasonably necessary or appropriate to fulfil the

purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting

or reporting requirements. 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 respect to our relationship with you.

7.2 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.

7.3 Details of retention periods for different aspects of your personal data, please contact us at info@xnb.com.

7.4 In some circumstances, you can ask us to delete your data: see section 8 below for further information.

7.5 Under certain 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 the anonymous data will no longer be deemed

as personal data and we may use this information indefinitely without further notice to you.

8 YOUR LEGAL RIGHTS

8.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data

as follows:-

(a) Request to obtain information regarding

(b) Request access to your personal data and information relating to the processing of it. This enables you

to receive a copy of the personal data we hold about you and to check that we are lawfully processing

it.

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.

(d) 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. Please note 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.

(e) Object to processing of your personal data where we are processing your personal data for direct

marketing purposes or for purposes of conducting surveys unless it is necessary for public interest. In

some cases, we may demonstrate that we have compelling legal basis to process your information.

(f) 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:

(i) If you want us to establish the data's accuracy.

(ii) If you are of the view that the processing of your personal data has exceeded the scope of the

agreed purposes.

(iii) Where our use of the data is unlawful.

(iv) 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.

(v) You have objected to our use of your data but we need to verify whether we have overriding

legitimate grounds to use it.

(g) 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, 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.

(h) 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.

How do you exercise your legal rights

8.2 You will not have to pay a fee to access your personal data (or to exercise any of the other rights).

However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

Alternatively, we could refuse to comply with your request in these circumstances.

8.3 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.

Time limit to respond

8.4 We try to respond to all legitimate requests within one month. Occasionally it could 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.

9 HOW TO CONTACT US

9.1 If you have any questions or comments about this Policy or if you would like to exercise your rights

pursuant to section 8 of this Policy, you may contact us via the details set out below:-

Contact details:

Full name of legal entity: XNB Pty Ltd

Email address: info@xnb.com