Over Global Trust Privacy Policy

If you are a customer of Over Global Trust services or just visiting our website ("User" or "You"), this Data Privacy Policy ("Policy" or "Data Policy") applies to you.

The Over Global Trust is a global company, which aims to simplify the use of Cryptocurrencies, facilitating their use, mixing the marketplace of crypto strategies and the Exchange and Wallet functionalities, in a single solution, which can be accessed through the website .................................., as well as through applications (“Apps”) for iOS or Android phones from Over (“Platform”).

The User who accepts the “Terms and Conditions of Use” and this “Privacy Policy”, by registering on the Platform, automatically confirms that he has read and understood all the provisions contained in the respective documents, delivering his express acceptance. The following clauses govern the collection, treatment, rights and duties of the Parties in relation to the data that Over has access to.

1. Over Global Trust's Responsibilities

Over acts as a “Controller” of Users' personal data, according to the applicable Laws, if you are a customer or visitor to the Over Platform it means that Over determines how and for what purpose your data will be processed.

2. User Responsibilities.

Read this Privacy Policy and understand if the provisions here apply to you, depending on where you are located. More information about how we collect and process your data can be contained in the other documents signed between Over and you, so please read them carefully.

2.1 Additional information may be requested from you or others, for example, if Over needs to collect extra information for the purpose of complying with general laws and preventing money laundering and terrorist financing. In this case, the data collected will be used by Monnos only to fulfill the specific objectives that gave rise to its collection.

2.2 On the other hand, by sending us this information, you confirm that you have the right to share this information with us and authorize Over to process the data as set out in this Privacy Policy.

3. Age for using the Services

The Over Platform offers a service intended only for use by people aged 18+. We do not target children, and we do not knowingly collect any personal data from anyone under the age of 18.

4. Location of services offered

Over has operations and offers services globally, except in countries that do not allow operations with cryptocurrencies and/or in which Over does not have a specific license to operate. In addition, if the country in which you are located has specific data legislation incompatible with the treatment we give to your data set out in this policy and you are not in compliance with this policy, DO NOT USE OUR SERVICES. Stay tuned for the disclaimers in our Terms of Use, which can be accessed at this link. Read this document and the Terms of Use carefully.

4.1. To access this Policy in the English version, in case, for example, you are a customer or visitor located in the European Union, Click on this link.

4.2. If you are a customer or visitor located in Brazil, this policy applies, as well as specific sections of the General Data Protection Legislation (LGPD).

5. How and when Over collects your data

Over may collect your data directly, especially if you are a customer, in order to provide the services provided for in the Contract established between Over and you. We may also collect information automatically, in case you browse the Over website or when an email is sent to you.

5.1. For the services provided by Over, if you choose to register on our Platform, data are collected for the execution of the contract between us and for the creation of your registration, and also to comply with money laundering prevention legislation and others.

6. Data collected

Over collects User's contact information. The information collected depends on a series of criteria established by the Over Money Laundering Prevention and Terrorism Financing Policy (PLD/FT Policy) of Over, which is normally linked to the number of transactions carried out and the volume of these transactions. In any case, Over collects at least your name, date of birth, address, e-mail, telephone number, identity numbers, CPF (in the case of Brazil), declaration of being or not a Politically Exposed Person, if it is or not a FOREIGN citizen, and other information may be collected, as mentioned, due to internal PLD/FIT policies;

6.1. Financial information: Over asks for your bank account number. Over never stores your credit card details, which are verified by our partner. We may also request additional information in accordance with our PLD / FIT program.

6.1.1. We may also ask for more information, for security purposes, to prevent fraud and for credit protection purposes.

6.2. Other data collected by Over or received from the User: Login information, IP address, demographic information, geolocation information, time zone configuration, operating system and version, browser type and version, browser plug-in types, category of consumption affinity, types of devices used in navigation. Over also collects information about how you use our site, which pages you visit and the paths you take, what you do on each page, how long you stay on each page, services viewed and other actions.

7. Sensitive data

Over does not collect sensitive data from Users or visitors.

8. How Over uses your data and for what purpose

Data protection laws, especially the LGPD, state that Over may only use its data for a specific purpose and provided that there is a legal basis for it. Thus, the purposes of using your data when collected by Over are shown below:

8.1. Provision of services: Over processes your data to provide the services you agree to and at your request.

8.2. Registration (KYC - procedure for getting to know the customer): The collection and processing of your data is necessary for Over to comply with the internal compliance and KYC procedure. Your data may be shared with the competent authorities to comply with anti-money laundering laws and similar laws. This procedure is done through our partner ..........

8.3. Helping you (Customer Support): Over collects data to be able to resolve problems by email, phone or chat, interacting with you to notify you of any changes to our services or any bug fixes.

8.4. Marketing: Over collects your data to carry out the marketing activity, that is, to send emails and messages to you with content related to the services and also about new services, products or resources.

8.5. Improving our website and services: Over still uses its data to test resources, optimize traffic, manage pages on our website, heat map our website, analyze data and research, including profiling and using learning from machine and other techniques on your data and in some cases using third party services to do so.

9. Legal Basis

The law states that, in addition to the purpose, Over must have a legal basis to collect and process your data. Thus, the legal bases for collecting your data are presented below:

● Contract: When processing your data is necessary to fulfill the Contract you have with Over or because Over asks you for specific information to complete your registration on the Platform before agreeing to the Contract.

● Legal obligation: The processing of your data is necessary because a law or regulation requires Over to do so.

● Consent: when you give Over a clear and free consent. You can disable (remove your consent) in your account tools. In that case, we will stop processing the information that used consent as a legal basis (unless another legal basis permits or compels us to do so, such as complying with specific legislation, or a vital demand for the operationalization of the solution offered by Over ).

● Legitimate interest: The processing of User and Visitor data is necessary for Over, representing Over's legitimate interest or the legitimate interest of third parties, but only if balanced with the rights and interests of the User and Visitor. Legitimate interest is the legal basis for us to collect the necessary data for the activities listed above Providing Services, Marketing and Improving our website.

10. User Options

Some features developed to improve the User experience on the Platform can be disabled at any time.

10.1. Disabling cookies. You can block cookies by changing your browser settings. You can also delete cookies through your browser settings.

10.1.1. If you disable cookies, you can continue to use the website and browse the Over Platform, but some services may not work properly. For more information on how we use cookies, please go to the cookies section below.

10.2. Marketing deactivation. You can opt out of receiving marketing communications by e-mail by simply formalizing the order by sending e-mail to .......................... ............... Or by clicking on a specific link in every email sent by Over.

10.3. Use of the Over Platform without registration. If you browse the Over Platform, but do not register and, consequently, do not send your personal data, it is still possible to access our Platform and browse some of our pages, but we cannot process transactions or enroll you in our services without personal data.

11. User Rights

You have the right to confirm that Over has yours data, to access and be informed about what information (if any), Monnos has about you, or you can also ask Over for more information about:

● The purposes of processing your data;

● The categories of data processed;

● Third parties with whom data can be shared or transferred;

● How long your data will be stored (or the basis we use to determine how long we will store it);

● The other rights you may have, including those listed in this section.

11.1. Update or correct information. You can access your registration page on the Over Platform to change, update or correct general information as long as it is not vital to the operation or is not required for regulatory reasons. If you are unable to do so, contact us by email [email protected]

11.2. Opposition to the use of data. You can object to the collection and processing of your data at any time, upon express request by e-mail [email protected]. In this case, the services will be stopped and your User account will be automatically deleted.

11.2.1. You have the right to object to the use of your data for direct marketing, choosing to remove this function from our Platform.

11.2.2. We may use your data to check what information is relevant to you (emails, for example), based on the services you choose and their use.

11.3. Portability. We will provide you with a copy of your data so that you can provide it to another service provider.

11.4. Right to be forgotten. You can ask for your data to be deleted, asking to delete any personal data that Monnos has about you. Your information may be erased if it is not necessary to keep it for the purposes of the services you have with us (for example, it may be necessary to keep your data in order to comply with specific legislation). Please contact Over at e-mail [email protected].

11.5. Registration of complaints. You can contact us if you have any problems with our Platform and / or services. If Over is unable to resolve your concern, you can file a complaint with the National Data Protection Authority (ANPD).

11.6. You can exercise any of your rights listed in this session by sending Over an email to [email protected] or accessing your registration on our App, as described below.

11.6.1. Over will provide you with your order information as soon as possible, respecting the 30-day deadline for people located in the European Union, observing the GDPR precepts. If Over cannot respond to your request, we will inform you of the reasons for this.

11.6.2. Over may inform you that additional time is required if the request is complex. It may also take longer to respond fully to you if it can significantly affect the rights and freedoms of others.

12. Processing and storage of data

As described above, Over offers services in several countries. For this reason, the personal data collected is processed at our office in Brazil.

12.1. If your data is transferred or stored outside Brazil or outside the European Union, Over performs the transfer using the same security levels used in the European Union, as described in this Privacy Policy. This means that Over takes all measures to ensure that your information remains protected and that your privacy rights are respected.

12.2. By registering on the Over Platform and sending your personal data, you agree to the processing, transfer or storage performed by us, as described in this Privacy Policy.

13. Data storage time

Over deletes your personal data from the files after 5 years from the last time you used our services or as agreed with you in the Service Agreement. Over also deletes your data if you request it, as described above and unless there is no other reason to keep it.

14. Data security

We have physical and electronic procedures to protect and keep the information we collect secure, and that includes internal policies.

14.1. You are also responsible for keeping your login, password and other information necessary to access the Over Platform secure.

14.2. If you have reason to believe that your data has been exposed, please contact us by email, at [email protected]

15. Third parties we work with

Like any other digital service provider, Over uses other companies to assist it with specific tasks, such as hosting the website, marketing, storing information, sending e-mails, etc.

15.1. When using them, Over may share some of your data for the purpose of performing specific tasks, for the purposes described above in item 8. This means that Over only shares the information necessary for them to do their job and for the tasks we ask them to do, following Over's policies.

15.2. In the case of third parties located outside Brazil (or the European Union, as applicable), Over uses the same level of security, as explained above in item 12.

15.3. If the company we share is located in the United States of America (USA), Over makes reasonable efforts to ensure that the organization in question is certified in compliance with the Privacy Shield standards, which are the EU-US Privacy Protection rules and Switzerland-USA administered by the US Department of Administration for International Trade (ITA).

16. Cookies

About the policy

Cookies are used to collect information about how you use and interact with a website. There are two types of cookies. Session cookies, which last as long as the session lasts and self-delete when you leave the browser page. Permanent cookies, which are not automatically deleted, but help a website to recognize you when you return, to improve your experience.

16.1. As a rule, Over Global Trust uses cookies when you interact on the Platform, and this sometimes includes the cookies of the third parties above (please check their privacy policies). Over Global Trust is not responsible for these cookies, as it has no control over their use.

16.2. You have the option of accepting or not accepting cookies while using our website. When disabling cookies, some pages or parts of the Platform may not work correctly. Thank you for reading our Privacy Policy. Please contact the Over Global Trust if you need more information and access it again if you need to confirm any information.