Information Bulletin AFORTI Group November 2017

1. GENRAL PROVISIONS
1. The present Privacy Policy informs on the procedures used to protect personal data of the users of the platform available at the website: https://www.afortiexchange.ro hereinafter referred to as the “Platform”.
2. Aforti Exchange Romania S.A. with its registered office in Bucharest, Gara Herestrău street,no. 4B, 2nd sector,post code 020334 entered in the register of entrepreneurs of the National court Register under CUI number 37812805 is the administrator of the Platform Users’ personal data.
3. The contents of the Platform websites constitutes the property of the data Administrator and is legally protected.
4. In order to use the Platform the user should have a computer or other device with software which enables viewing websites and access to the Internet Network. The Platform may be accessed with the use of the most popular web browsers.
5. The Administrator represents that the Platform websites are free of contents infringing the rights of third persons or the applicable provisions of law, and in particular, of contents including information which poses or constitutes a threat to privacy or security of any person, information promoting unlawful actions or conduct which are abusive, threatening, obscene, defamatory or libellous, promoting racism, persecution on ethnic, cultural or religious grounds, promoting or conducive to criminal activities, or infringing the rights of third persons, including the intellectual property rights, or otherwise infringing rights protected under law.
2. THE PURPOSE OF DATA COLLECTION

Data Administrator processes the users’ personal data for the purpose of and to the extent necessary for their use of the Platform in accordance with the Act of 18^th July 2002 on rendering services by electronic means (Journal of Laws of 2016 item 615 as amended) and also for additional purposes which include direct marketing within the meaning of the provision stipulated in Article 172 Section 1 of Telecommunication Law of 16^th July 2004 (Journal of Laws of 2016, item 1489 as amended) yet solely provided that an additional consent has been granted by a given Platform User.

3. RIGHT OF ACCESS
1. Users have the right to amend, update, or correct their personal data, to temporarily or permanently suspend the processing of the questioned data, or to have them deleted from the filing system, if the personal data are incomplete outdated, untrue or collected in violation of the provisions of law or are no longer required for the purpose for which they have been collected.
2. Data Administrator reserves the right to refuse to remove a user’s data if keeping the data is necessary for the pursuit of claims or if the data are required by the applicable provisions of law.
3. THIRD PARTIES’ ACCESS TO THE DATA
4. Only authorized employees or associates of the Administrator and authorized persons responsible for the operation of the Platform to whom the appropriate authorizations have been granted, have direct access to the personal data collected by the data Administrator.
5. Users’ personal data may be shared with entities authorized to receive the data under applicable provisions of law, in particular, with competent judicial authorities.
4. SECURITY MEASURES AND THE PROTECTION OF PERSONAL DATA

Data Administrator represents that users’ data are processed in accordance with the provisions of the Act of 29^th August 1997 on Personal Data Protection (Journal of Laws of 2016, item 922 as amended) and that appropriate technical and organisational measures are implemented to provide security adequate to the possible risks and categories of the protected data, and in particular, that users’ personal data are protected against access of unauthorised persons, loss or damage.

5. COOKIES MECHANISM

The Platform uses two types of “cookies” files – "session cookies" and "persistent cookies". Session cookies are temporary cookies that remain on the User’s device until the user logs out of the website or closes the software (internet browser). A persistent cookie remains on the User’s device for a period stipulated in the „cookie” files parameters or until the user manually deletes it. The User who does not agree to the use of cookies (wishes to block cookies) should change appropriate settings in the web browser they use. The process of accepting the use of cookies differs depending on the User’s browser.

In accordance with applicable provisions of the Telecommunication Law of 16^th July 2004 (Journal of Laws 2016, item 1489 as amended) users have the right to decide on the scope of access of cookie files to their computer by selecting such in their browser.

How to manage cookie files – instructions of browsers producers:

• Mozilla Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
• Internet Explorer: https://support.microsoft.com/en-gb/help/278835/how-to-delete-cookie-files-in-internet-explorer
• Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
• Safari: http://safari.helpmax.net/en/saving-time/blocking-content/
• Opera: http://help.opera.com/Linux/9.22/en/cookies.html

Data Administrator reserves the right to use the services rendered by third entities for creating statistics related to the use of the Application. We guarantee that in such an event, such entities will not be provided with any data allowing User identification.

The advertisements displayed at the Application website may use cookies of third entities to enable the analysis of the advertising campaign efficiency.

The present Privacy Policy does not regulate the rules of cookie mechanism use by third entities.

6. VII. IP ADDRESS

Data Administrator reserves the right to collect Users’ IP address, which may result helpful in diagnosing technical problems with the server, creating statistical analysis (for instance, on the region form which the most connections are made). Moreover, the IP address may be useful for administrating and improving the Application.

7. VII. DISCLAIMER
1. The present Privacy Policy does not include any information on services or products belonging to other entities than the data Administrator posted on the Platform websites commercially, hospitably, on a reciprocal basis or not intended to reach a commercial effect.
2. Data Administrator is not responsible for the acts or omissions of Users which lead to the Administrator’s processing of the personal data submitted by them as described in this Privacy Policy.
3. Data Administrator reserves the right to introduce changes to, withdraw or modify functions or properties of the Platform websites, as well as to terminate its operation, assign the rights to the platform or to undertake any legal actions permitted by the applicable provisions of law. No actions undertaken by the administrator shall infringe users’ rights.
8. CONTACT WITH DATA ADMINISTRATOR

Any additional questions related to the Privacy Policy should be sent to the data Administrator’s address indicated in Point I or to the e-mail address: biuro@afortiexchange.pl.

9. AMENDMENTS TO THE PRIVACY POLICY
1. Data Administrator reserves the right to amend the Privacy Policy when it is required by the provisions of law or by changes introduced to the Platform. Administrator shall inform the users on the changes and the date on which they become effective, in particular, by publishing a notification on the Platform website.
2. The date indicated below is the effective date for the Privacy Policy in its most recent version.

Date: 2018.01.09