COOKIE POLICY

Cookies are small pieces of information sent and stored on the user’s computer hard drive through their browser when they connect to a website. Cookies can be used to collect and store user data while they are connected to provide the requested services and are generally not retained (Session Cookies) or to retain user data for future services and may remain stored for an indefinite period (Persistent Cookies). Cookies may be first-party or third-party cookies.

There are various types of cookies:

Technical Cookies
These facilitate user navigation and the use of different options or services offered by the website, such as identifying the session, allowing access to certain areas, processing orders, purchases, filling out forms, registrations, ensuring security, or providing features (videos, social networks, etc.).
Personalization Cookies
These allow users to access services based on their preferences (language, browser, configuration, etc.).
Analytical Cookies
These enable the anonymous analysis of web user behavior, measuring user activity, and developing navigation profiles to improve websites.
Advertising Cookies
These manage the website’s advertising spaces.
Personalized Advertising Cookies
These manage the website’s advertising spaces based on user behavior and browsing habits, creating a profile to personalize the ads displayed on the user’s browser.

This Cookie Policy is an integral part of the Legal Notice and Privacy Policy of the website https://tokenify.io/ (hereinafter referred to as the “Website”). To ensure users have all the necessary information for proper navigation, we provide the following details about the types of cookies used on our Website and how they can be configured or disabled.

Tokenify uses first- and third-party technical, personalization, and analytical cookies that do not process personal data but track browsing habits for advertising purposes. For this reason, upon accessing our website, we have requested your consent for their use. Additionally, you can activate or deactivate these cookies by following your internet browser’s instructions, as detailed below:

Browser Instructions for Cookie Management:

Chrome: Go to Settings -> Show advanced options -> Privacy -> Content settings.
Firefox: Go to Tools -> Options -> Privacy -> History -> Custom settings.
Internet Explorer: Go to Tools -> Internet Options -> Privacy -> Settings.
Safari: Go to Preferences -> Security.

For more information, you can consult your browser’s Help section or the support pages:

Chrome: https://support.google.com
Firefox: https://support.mozilla.org
Internet Explorer: https://windows.microsoft.com
Safari: http://www.apple.com

Commercial Communications via Email

Since the primary communication method between Tokenify and users is the email address provided, we inform you that we will use this medium for all communications, including commercial information or notices related to the purpose of our portal. Consequently, acceptance of these terms of use implies your express authorization for us to send you commercial, advertising, and promotional messages.

If you do not wish to receive our commercial communications via email, you may opt out by contacting us at legal@tokenify.io.

We are not responsible for the privacy policies regarding personal data that may be provided to third parties through links available on our website.

Policy Modifications

Tokenify reserves the right to modify these privacy policies to adapt them to changes on our website, as well as legislative or jurisprudential updates regarding personal data. We recommend reviewing these policies each time you provide data through this website.

Retention Periods

Cookies used by Tokenify will remain on your device for the time necessary to fulfill their purpose and, at most, for two years unless you delete them through your browser settings as previously described.

International Transfers

Some personal data obtained through third-party cookies may be subject to international transfers. In such cases, we ensure that the necessary safeguards are implemented to protect their confidentiality, integrity, and availability in compliance with current regulations.

LEGAL NOTICE

Tokenify offers access to the website www.tokenify.io under the terms of use described below:

Access and Users

Access to the website www.tokenify.io grants the person who accesses it the status of User and implies full and unconditional acceptance by the User of each and every one of these TERMS OF USE. The provision of the website service is free of charge. However, Tokenify reserves the right to condition access to certain specific services upon prior registration of the shareholder or investor User by completing the appropriate User Registration Form, which will be made available, if applicable, to those wishing to register as a Registered User.

When it is necessary for the User to register as a Registered User or provide personal data to access specific services, the collection and processing of the User’s personal data will be governed by the provisions under the section on Security and Personal Data Protection.

The User agrees to use the website and its services and content in compliance with applicable laws, good faith, generally accepted customs, and public order.

Additionally, the use of the website for unlawful or harmful purposes against Tokenify, any of its Group companies, or third parties is prohibited. Such use may harm or impede the normal functioning of the website.

Links

The website www.tokenify.io provides links to other websites or content owned by third parties. The sole purpose of these links is to offer the User additional information through them. Tokenify assumes no responsibility for any consequences that may arise from the User’s access to these links.

The User, or any individual or legal entity intending to establish any technical linking device from their website to Tokenify’s website, must obtain prior written authorization from Tokenify. The establishment of the link does not imply any relationship between Tokenify and the owner of the website where the link is established, nor does it imply acceptance or approval by Tokenify of its content or services.

The establishment of any “hyperlink” to Tokenify’s website pages is subject to the following conditions:

Partial or complete reproduction of any of the services or content of Tokenify’s website is prohibited.
Deep-linking to Tokenify’s website or its services, or creating a browser or border environment over the content, is not allowed.
The website where the hyperlink is established must not contain any trademark, trade name, establishment label, denomination, logo, slogan, or other distinctive signs belonging to Tokenify or any of its Group companies.
Under no circumstances will Tokenify be responsible for the content or services made available to the public on the website from which the “hyperlink” is established, nor for the information and statements included therein.

Modifications

To improve the website’s features, Tokenify reserves the right to modify, expand, or temporarily suspend the presentation, configuration, technical specifications, content, and services of the website at any time unilaterally and without prior notice to the User.

Likewise, Tokenify reserves the right to modify these terms of use or any other specific conditions contained on the website www.tokenify.io at any time.

Intellectual and Industrial Property

The website, including but not limited to its programming, design, compilation, and other elements necessary for its operation, designs, logos, text, and/or graphics, and specifically the industrial property rights of the registered trademark “Tokenify,” are owned by KRUGERCORPORATION S.A.S. or, where applicable, have been licensed or expressly authorized by their owners.

All content on the website is duly protected by intellectual and industrial property regulations and is registered in the corresponding public records.

Regardless of its intended use, total or partial reproduction, usage, exploitation, distribution, and commercialization always require prior written authorization from the provider. Unauthorized use will be considered a serious breach of the author’s intellectual or industrial property rights.

Designs, logos, text, and/or graphics not owned by the provider that appear on the website belong to their respective owners, who are responsible for any dispute that may arise regarding them. In any case, the provider has prior and express authorization from them.

Tokenify recognizes the corresponding intellectual and industrial property rights of their owners. The mention or appearance of such rights on the website does not imply any rights or responsibility of Tokenify over them, nor does it imply endorsement, sponsorship, or recommendation.

Any observations regarding potential violations of intellectual or industrial property rights, or regarding any website content, can be sent to legal@tokenify.io.

Disclaimer of Warranties and Liability

Tokenify provides no guarantees and is not liable for any damages of any kind that may result from:

Lack of availability, maintenance, or proper functioning of the website and/or its services or content.
The unsuitability or failure of the website and/or its services or content to meet specific needs, activities, or expectations of Users.
The presence of viruses, malicious programs, or harmful content.
Users’ illegal, negligent, fraudulent, or contrary use of the website, its services, or content against these General Conditions, good faith, accepted practices, or public order.
The lack of legality, quality, reliability, usefulness, and availability of services provided by third parties made available on the website.
The failure of third parties to fulfill their obligations or commitments regarding the services provided to Users through the website.

Duration

The website’s services are provided indefinitely. However, Tokenify reserves the right to interrupt, suspend, or terminate the website’s services at any time.

Jurisdiction and Applicable Law

These Terms of Use are governed by Ecuadorian and Spanish legislation.

Tokenify and the User, expressly waiving any other jurisdiction that may apply, submit to the jurisdiction of the courts of Tokenify’s domicile for any disputes arising from the provision of the website’s services and its contents or the interpretation, application, compliance, or breach of these terms. If the User resides outside Spain or Ecuador, Tokenify and the User submit to the jurisdiction of the courts of Ecuador.

DATA PRIVACY POLICY
Effective as of January 1, 2023

About This Policy

This Policy describes how we process, collect, use, share, retain, and transfer your information (hereinafter, Personal Data) at Tokenify, received through contact forms, subscriptions, registrations, or other methods provided on the website, in accordance with the Constitution of the Republic of Ecuador; the Electronic Commerce, Electronic Signatures, and Data Messages Law; the National Data Registry System Law; the Comprehensive Organic Penal Code; the Organic Law for Personal Data Protection and its Regulations; and other applicable regulations.

It applies to your use of all Tokenify services and covers:

Identification, contact, and technical information, including but not limited to:
- Full name
- Email address
- Social media account
- Phone numbers
- Identification document
- Address, city, and country of residence
- Organization affiliation
- Position in the organization
- Sector affiliation (public, private, or civil)
- Anonymous data related to user behavior during visits to the website, such as cookies, pixels, or similar technologies, including visit duration and content viewed.
- Anonymous data about access tools and their interaction with the website, such as IP address, browser and device characteristics, language preferences, referrer URL, and other technical information.

Occasionally, we may develop new services or offer additional features. These will also be subject to this Policy unless otherwise indicated when introduced.

This Policy is distinct from Tokenify’s Terms of Use, which is a separate document.

How Do We Use This Information?

The data described above is used for:

Disseminating activities, projects, and events as well as maintaining and fulfilling contractual, legal, and transparency obligations.
Contacting users in response to requests made to Tokenify.
Maintaining relationships with stakeholders (e.g., suppliers, clients, or partners) to facilitate activities and obligations.
Determining content relevance and improving communication channels in terms of user experience and design.
Analyzing access tools to improve website performance, ensure proper functionality, and safeguard site and user data security.
Communication methods include, but are not limited to, emails, postal mail, phone calls, and digital announcements.

Will Your Information Be Shared?

Tokenify will not sell, distribute, or lease your information to third parties except as outlined in this Policy. Tokenify uses services and providers whose privacy policies prohibit sharing Tokenify’s data with third parties unless requested or required by applicable regulations.

Summaries or reports based on collected data, such as most visited pages or event registration counts, may be generated and shared. These summaries do not allow tracking of individual users.

Personal Data may be disclosed in response to legal processes, regulatory requirements, or to protect the safety, functionality, and rights of the website, Tokenify, or others. Tokenify may also share Personal Data with a third party if expressly requested by the user. If Tokenify cannot facilitate such sharing, users may request their data in a standard format for use and review.

How Do We Keep Your Information Secure?

To safeguard your Personal Data, Tokenify implements:

Encryption to maintain data privacy during transmission.
Secure Browsing Features to protect your account and information shared on our website.
Regular reviews of data collection, storage, and processing practices to prevent unauthorized access.
Restricted access to Personal Data to employees, contractors, and agents who require it for processing. These individuals are bound by confidentiality obligations and may face penalties for violations.

While we strive to protect your information, the internet’s open nature means absolute security against intrusion (e.g., hacking) cannot be guaranteed.

Users are solely responsible for damages resulting from submitting false, inaccurate, incomplete, outdated, or third-party information in Tokenify’s forms.

For additional questions, contact us at legal@tokenify.io.

Data Controller

To exercise your rights, send written communication to Tokenify’s registered address or email legal@tokenify.io, including a copy of your identification document (e.g., passport, ID, etc.).

Per the Organic Law for Personal Data Protection, users have the following rights:

Access and information rights: Request access to personal data stored by Tokenify.
Rectification and update rights: Request corrections to inaccurate personal data.
Deletion, portability, objection, and restriction rights: Request data deletion, transfer, or limitation of processing.
Structured data access: Request your data in a structured, commonly used, and machine-readable format.

You may also file complaints with the relevant data protection authorities. However, we encourage you to first contact us for any concerns regarding your data.

Rights to Access, Rectify, Cancel, and Object to Your Personal Data

At any time, users may exercise their rights to access, rectify, cancel, or object to their Personal Data by emailing legal@tokenify.io.

Personal Data will be retained until the user notifies Tokenify of their desire to discontinue services, after which their data will be deleted, except for information retained for advertising, informational, and marketing purposes. Users may request data deletion for all purposes by contacting legal@tokenify.io.

Social Media

Tokenify maintains profiles on major social networks (e.g., Facebook, Twitter, YouTube, Instagram, LinkedIn, TikTok). Once users access these platforms, Tokenify is no longer responsible for data management by these external platforms, which are governed by their own terms and privacy policies.

Policy Updates

We periodically update this Privacy Policy. Revisions will not limit your rights under this Policy. Please review it regularly, especially when accessing our website, to stay informed about how your data is managed.

Last Updated: January 1, 2023

Data Protection
General Information

Tokenify, located in Quito, Arízaga Luque N34-206 and Federico Páez, Ecuador, processes personal data from different categories of individuals for various activities. In all data processing, we fully comply with the applicable laws: the Organic Law on Personal Data Protection of Ecuador, Regulation (EU) 2016/679 of the European Parliament and Council of April 27, 2016 (General Data Protection Regulation or GDPR), national and sector-specific legislation depending on the activities that, as a listed company, we need to carry out, as well as development regulations.

Specific Information by Categories of Data Subjects

Tokenify needs to process personal data from various categories of individuals for different purposes. The main groups whose personal data we process include:

Shareholders and investors.
Employees and collaborators.
Legal representatives.
Suppliers (since exceptionally they may be natural persons).
Visitors to our offices and facilities.
Legal representatives and contacts from other entities or individuals.
Beneficiaries of our employees’ insurance.
Whistleblowers (users of our Whistleblowing Channel).
Job candidates.

The same or different personal data from each of these groups may be used in various ways and shared with different individuals, whether natural or legal persons, depending on the specific purposes for which they are needed. Therefore, we provide each of these categories of individuals with information regarding the data processing we carry out. This information is made available through both internal/private channels and, depending on the case, through this website in the “Your Personal Data” section, where we explain among other things:

Why we need to process your data.
How long we retain it.
What types of data we may hold.
Who we share it with.
What your rights are regarding your data and how to exercise them.

Under no circumstances do we make solely automated decisions or profiling that could significantly affect you, nor do we use your personal data for purposes other than those mentioned in the aforementioned section.

Security Applied to Data Processing

In accordance with the applicable regulations, Tokenify has implemented appropriate technical and organizational security measures to ensure the integrity, availability, and confidentiality of personal data, taking into account the nature, scope, context, and purposes of each of the data processing activities we carry out. This also includes evaluating the likelihood and impact of any risks involved for individuals whose personal data we handle.

Generally, but not exclusively, we have adopted the following security measures:

Assigning user permissions based on their roles.
Various physical and/or logical access controls.
Backup copies and data recovery.
Appointment of a Data Protection Officer.
Management and control of devices containing personal data.
Appointment of a Security Officer.
Creation of data protection policies and protocols.
Encryption of sensitive information and biannual audits for high-risk data processing.

Additionally, we periodically carry out verification processes to assess the effectiveness of the security measures implemented for each data processing activity (not just those with the highest risks) and continuously improve to ensure the security of data processing in line with technological advancements.

Your Collaboration is Important

At Tokenify, we aim to control, to the best of our ability, the proper use of personal data by third parties to whom we have provided them. For this reason, we ask you to notify us immediately if you become aware or suspect that any entities with whom we share your data or any of our suppliers are misusing your personal information, so that we can take the necessary actions.

Furthermore, to ensure that the data we hold about you is correct and up to date, we ask that if there are any changes to your details (such as a change of address or phone number), or if you detect any incorrect data in our records, you inform us as soon as possible so that we can rectify it accordingly.

In any case, if you have any concerns or suggestions regarding the processing of your personal data, please contact us at legal@tokenify.io.

Your Rights

You generally have the following rights regarding the processing of your personal data:

Right to Information: You have the right to request confirmation from Tokenify about whether or not we are processing your personal data and, if so, to obtain the information provided in this document.
Rights to Access, Rectification, and Erasure of Your Data: You have the right to access your personal data, as well as to request the rectification of any inaccurate data or, in certain cases, to request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
Right to Restriction of Processing: Under certain circumstances, you may request the restriction of the processing of your data, in which case we will only retain it for the establishment or defense of legal claims.
Right to Object: Under certain circumstances, and for reasons related to your specific situation, you may object to the processing of your data. In that case, we will stop processing it, unless there are compelling legitimate grounds or it is necessary for the establishment or defense of legal claims.
Right to Data Portability: Under certain circumstances, you have the right to receive the personal data we process under your consent or a contract, and transmit it to another entity you designate, in a structured, commonly used, and machine-readable format (interoperable format).
Revocation of Consent: Regarding data processing based on your consent, you have the right to withdraw that consent at any time. Once consent is revoked, unless there is another legal basis for continuing the processing, it will cease. However, the revocation will not affect any processing carried out prior to the revocation.