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PRIVACY POLICY

Last Updated: 26.06.2026

This Privacy Policy ("Policy") describes how Sole Technologies Ltd. ("Sole Technologies", "Company", "we", "us", or "our") collects, uses, stores, shares, and protects personal data when individuals access our website, products, services, applications, platforms, and related offerings (collectively, the "Services").

Sole Technologies is committed to protecting your privacy and processing your personal data in accordance with applicable data protection legislation, including Regulation (EU) 2016/679 ("GDPR"), the Bulgarian Personal Data Protection Act, and other applicable laws.

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1. DATA CONTROLLER

Sole Technologies Ltd.

UIC: 208080819

Registered Office: 25 Angel Kanchev Street, Ground Floor, Sofia 1000, Bulgaria

Email: [email protected]

Website: https://www.sole-pay.com

2. APPLICABILITY

This Policy applies to:

Visitors of our website;

Prospective and existing customers;

Business partners and merchants;

Beneficial owners, directors and representatives of legal entities;

Users of our digital asset and payment services;

Applicants for employment opportunities;

Individuals contacting us.

3. PERSONAL DATA WE COLLECT

3.1 Information You Provide Directly

We may collect:

Full name;

Date of birth;

Nationality;

Residential address;

Email address;

Telephone number;

Government-issued identification documents;

Selfies and biometric verification data;

Tax identification numbers;

Bank account details;

Wallet addresses;

Source of funds and source of wealth information;

Company information;

Employment information;

Communications with us.

3.2 Information Collected Automatically

When you access our website or Services, we may automatically collect:

IP address;

Browser type and version;

Device identifiers;

Operating system;

Geographic location data;

Log files;

Cookies and similar technologies;

Usage information;

Access timestamps.

3.3 Information Obtained From Third Parties

We may receive information from:

Identity verification providers;

KYC and AML service providers;

Sanctions screening providers;

Blockchain analytics providers;

Financial institutions;

Payment service providers;

Public registries;

Credit reference agencies;

Government authorities.

4. PURPOSES OF PROCESSING

We process personal data for the following purposes:

a) Service Provision

Opening and maintaining accounts;

Executing transactions;

Providing customer support;

Facilitating payments and settlements.

b) Legal and Regulatory Compliance

AML/CTF compliance;

Sanctions screening;

Customer due diligence;

Fraud prevention;

Regulatory reporting.

c) Security and Risk Management

Monitoring transactions;

Detecting suspicious activity;

Protecting systems and infrastructure.

d) Business Operations

Internal administration;

Accounting;

Auditing;

Record keeping.

e) Marketing

Where permitted by law, we may send marketing communications regarding our products and services.

You may opt out at any time.

5. LEGAL BASES FOR PROCESSING

We process personal data based on one or more of the following legal grounds:

Contract Performance

Processing necessary to provide requested services.

Legal Obligations

Compliance with:

AML legislation;

MiCA requirements;

Tax obligations;

Financial regulations.

Legitimate Interests

Including:

Fraud prevention;

IT security;

Business management;

Product improvement.

Consent

Where legally required.

You may withdraw consent at any time.

6. AML, KYC AND COMPLIANCE

As a regulated digital asset service provider, Sole Technologies is required to conduct identity verification, sanctions screening, transaction monitoring, and enhanced due diligence procedures.

Failure to provide requested information may result in refusal or termination of services.

7. DISCLOSURE OF PERSONAL DATA

We may disclose personal data to:

Regulators and supervisory authorities;

Law enforcement agencies;

Courts and governmental authorities;

Banking partners;

Payment processors;

KYC/AML providers;

Blockchain analytics providers;

IT infrastructure providers;

Professional advisers;

Auditors and accountants.

Personal data shall only be disclosed where legally permitted or required.

8. INTERNATIONAL DATA TRANSFERS

Personal data may be transferred outside the European Economic Area.

Where transfers occur, we implement appropriate safeguards including:

European Commission adequacy decisions;

Standard Contractual Clauses;

Other lawful transfer mechanisms.

9. DATA RETENTION

Personal data shall be retained only for as long as necessary.

Regulatory records may be retained for a minimum period required under applicable AML and financial services legislation, generally no less than five (5) years following termination of the business relationship.

Longer retention periods may apply where required by law.

10. SECURITY

We maintain administrative, technical, and organizational safeguards designed to protect personal data, including:

Encryption;

Access controls;

Multi-factor authentication;

Monitoring systems;

Secure storage;

Incident management procedures.

However, no transmission or storage method can guarantee absolute security.

11. YOUR RIGHTS

Subject to applicable law, you may exercise the following rights:

Right of access;

Right to rectification;

Right to erasure;

Right to restriction of processing;

Right to data portability;

Right to object;

Right to withdraw consent;

Right not to be subject solely to automated decision-making.

Requests may be submitted to:

[email protected]

12. COMPLAINTS

You have the right to lodge a complaint with the Bulgarian Commission for Personal Data Protection or another competent supervisory authority.

13. THIRD-PARTY WEBSITES

Our website may contain links to external websites.

We are not responsible for the privacy practices of third-party websites.

14. CHANGES TO THIS POLICY

We may amend this Privacy Policy from time to time.

Updated versions will be published on our website together with the revised effective date.

Continued use of our Services constitutes acceptance of the revised Policy.

15. CONTACT

For any privacy-related questions, please contact:

Sole Technologies Ltd.

Email: [email protected]

Website: https://www.sole-pay.com

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