Privacy Notice

The Rezolve Group is committed to protecting and respecting your privacy. As an organisation enabling you to enter instant mobile-based transactions, it is important that we treat your personal data properly and with care.

Please read this privacy notice carefully to understand how we will respect and manage your personal data. By visiting our website, or by providing us with any information about yourself, you are accepting and agreeing to the practices described in this notice.

For the purposes of applicable data protection law (“Data Protection Law”), the data controller in relation to your data will depend on your location. Our data controller entities and locations are as follows:

Entity location	Entity name	Entity address
UK	Rezolve Limited	80 New Bond Street, London W1S 1SB, United Kingdom
India	Rezolve Technology (India) Private Limited	Office No. 10, Sr No. 167, Plot No. 16, Near Ragdari, Aundh Pune 411007, MH, India
USA	Rezolve Mobile Commerce Inc	BKC, CPAs, PC  39 State Route 12, Suite 2 Flemington NJ 08822 USA
China	Rezolve Information Technology (Shanghai) CO., LTD	Building 2 No. 268 Qinggong Road Fengxian District Shanghai
Spain	Rezolve Technology SL	C/ Negocios Puerta de Banus, Bloque E, Oficina 45, Marbella-Malaga-28660, Spain
Taiwan	Rezolve Taiwan Limited	4-2 Fl., No. 267, Lequn 2nd Rd., Zhongshan District, Taipei City, 10462, Taiwan
Mexico	Grupo Hanhei, SAPI de CV (RESELLER)	Sierra Mojada 447  Col. Lomas de Chapultepec. Miguel Hidalgo. C.P. 11000 CDMX
Germany	ANY Lifestyle Marketing GmbH	Nibelungenplatz 3 60318 Frankfurt am Main

In this notice, “Rezolve” and “we” refer to the relevant data controller in relation to your information. If you are in any doubt as to which entity is data controller in relation to your information, please contact us at DP*@re*****.com.

This notice sets out our commitment to be transparent about the data we collect about you, how it is used and with whom it is shared.

1. Information provided to Rezolve

1.1 Any information you provide Rezolve

This is any personal information that you provide to Rezolve, for example by:

a. registering or filling in forms on our website, apps or social media accounts (our “platforms”);

b. corresponding with us by phone, e-mail or otherwise;

c. making any purchase via our platforms;

d. subscribing to any service that we offer;

e. subscribing to any mailing list;

f. participating in any discussion boards or social media functions on our platforms;

g. entering competitions, promotions and surveys;

h.reporting a problem with our platforms, products or services; or

i. applying to work with us.

The information you give us may include your name, address, e-mail address, social media account details, images and phone number. If you are buying a product or service from us, it may include financial and credit card information. If you are applying to work with us, it may include professional qualifications, professional affiliations, education, details about your work and career and a personal description. If you are participating in one of our productions, it may include any information that you provide, or other aspect about you, in relation to your participation.

If you provide any information about other individuals such as friends, family or colleagues, you warrant us that you are entitled to provide that information and authorise us to process this data on the same basis as outlined in this privacy notice.

1.2 Information Rezolve collects about you

When you visit our platforms, we may automatically collect the following:

a. technical information, including the Internet Protocol (IP) address used to connect your device to the internet, your login information, browser type and version, time zone setting, browser plug-in types, plug-in versions, operating system and platform;

b. information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our platforms (including date and time), items you viewed, page response times, download errors, length of visits to pages, page interaction information (such as scrolling, clicks, mouse-overs) and methods used to browse away from the page.

We may also use location information provided by your device, but this is subject to your consent, which can always be withdrawn via your account settings.

1.3 Information we receive from other sources

We may receive information about you from sources other than directly from yourself, which may include social media such as LinkedIn, Facebook, Instagram and Twitter. We may also receive information from partners who we work with, such as merchants and our corporate customers.

2. Data Processing

2.1. Legal basis of Processing

Data Protection Law in some jurisdictions requires us to fulfil at least one “legal ground” for processing data that contains personally identifiable information. These are, for example, currently set out in Article 6 of the UK and EU General Data Protection Regulation (“GDPR”). The grounds applicable to the personal data to which this notice relates to are:

a. Where the processing is necessary for us to perform a contract that you are party to, or to take steps at your request prior to entering a contract; and/or

b. Where the processing is necessary for compliance with a legal obligation to which we are subject; and/or

c. Where processing is necessary for the purposes of our legitimate interests or the legitimate interests of a third party, provided that your fundamental rights and freedoms are not overridden. Our legitimate interests include the management, marketing and promotion of our business, products and services, the administration of your participation in the Rezolve community and its events, programmes and other activities, and the recruitment and management of staff; and/or

d. Where you have given consent to the processing.

If more than one of the above grounds apply to the processing of data in question, the applicable ground will be the first one listed.

2.2 How Rezolve processes the information you provide

We will use this information to:

a. carry out our obligations arising from any contracts entered into between you and us;

b. deliver information, products and services that you request from us;

c. share information about other products and services we or our partners offer that are similar to those that you have already obtained from us or enquired about;

d.permit selected third parties to provide you with information about products or services we feel may interest you, so long as, where required by law, you have given the relevant consent;

e. notify you about changes to our services, events or other items;

f. ensure that content from our platforms is presented in the most effective manner for you and for your device;

g. manage our own legal or risk issues;

h. process job applications submitted to Rezolve, in order to evaluate and manage those applications.

When you enter into a contract with, or make a request to, Rezolve, you are required to provide the necessary information. If you do not provide the necessary information, we may not be able to fulfil the contract or request.

2.3 How Rezolve processes the information we collect about you

We will use this information to:

a. administer our platforms;

b. deliver information, products and services that you request from us;

c. manage internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

d.improve our platforms to ensure that content is presented in the most effective manner for you and for your device;

e. allow you to participate in interactive features of our platforms, if you choose to do so;

f. support our efforts to keep our platforms safe and secure;

g. measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

h. make suggestions and recommendations to you and other users of our platforms about goods or services that may interest you or them.

2.4 How Rezolve processes the information we receive from other sources

We may aggregate multiple sources of data we collect about you from other sources and use this data only for the purposes outlined in sections 2.2 and 2.3 above.

3. Cookies and Pixels

Our platforms use cookies to distinguish you from other users of our platforms. This helps us to provide you with an optimal experience when you browse our platforms. For detailed information on the cookies we use and the purposes for which we use them, please read our Cookie policy.

Pixels or beacons may be included in our emails. These are similar to cookies, and may be used to track users’ activity in relation to our emails. If you sign up to receive emails, newsletters etc, each email can collect limited information, for example about whether and when you opened our mail. If you do not want this information to be collectable, you should disable and not open images in your email application.

See Cookie Notice, below.

4. Information Disclosure

4.1. Within our group

We may share your personal information with any group undertakings as defined in s1161(5) of the UK Companies Act 2006, for administrative purposes. This includes any undertaking which is under 50% or more ultimate common ownership with us, provided that they are either:

a. in the same jurisdiction as us;

b. in a country that our jurisdiction has decided has adequate data protection laws in place; or

c. have provided appropriate data protection safeguards of the sort approved by the our jurisdiction’s data protection authorities and provide effective rights and remedies for you.

Any use of one group member’s personal data (beyond administration) by other members of the group will be subject to all the requirements of Data Protection Law

4.2. Parties we may disclose your information to

Rezolve will not generally disclose your personal data to any other person unless and to the extent that:

a. You have expressly consented to it; or

b. such disclosure is necessary for the performance of any contract we enter into with you. That may include the disclosure of order and contact details of our customers which will need to be disclosed to the relevant merchant to enable delivery.

If we disclose your personal data to a third party in these circumstances, please note that its treatment by that third party will be subject to their own privacy or data protection policies.

We may however disclose your personal information to third parties in the following limited instances:

a. If we outsource any aspect of our business or systems, then we may disclose your personal data to our service provider(s); or

b. If we sell or buy any business or assets, then we may disclose your personal data to the prospective seller or buyer of such business or assets;

c. If we or a substantial part of our assets are acquired by a third party, in which case personal data held by us about our customers may be one of the transferred assets; or

d. In the event of a legal obligation to an authorised body or to protect the rights, property, or safety of Rezolve, our customers, or others. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

If you provide us with any special categories of personal data, you expressly consent (and you hereby do) to us processing that data for the purposes set out in clause 2.1. By special categories of personal data, we mean information referred to as such in the GDPR, i.e. information as to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sex life or sexual orientation or genetic or biometric data personal data. We also include in this category information relating to criminal convictions and offences. If you do not want us to process any such categories, please do not provide it to us.

6. Data storage

6.2. Where we store your personal data

The data that we collect from you will be stored on our servers or those of our service providers. If that information is stored in the UK or the European Economic Area (“EEA”) or the country of operations, it will not be transferred to, and stored at, a destination outside the UK or EEA or the country of operations as the case may be unless:

a. to one of our group undertakings to which section 4.1 applies;

b. to a processor acting on our behalf which is either (i) within the UK or EEA or the country of operations as the case may be, or (ii) in a country that the UK or European Union or the country of operations as the case may be has decided has adequate data protection laws in place, or (iii) has provided appropriate data protection safeguards of the sort approved by the UK or European Union or the country of operations as the case may be and provide effective rights and remedies for you; or

c. you have given consent to us transferring data about you to third parties outside the UK or EEA or the country of operations as the case may be.

All payment transactions will be processed by secure third party payment processors. Any handling of cardholder data by us will be done in compliance with the applicable PCI-DSS standards.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our platforms you are responsible for keeping this password confidential, and for all use made of your account with such password. We ask you not to share your password with anyone.]

Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via the internet; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

6.3. Length of data storage

Our policy is to ensure that personal data is only stored for as long as is necessary for the purposes set out at section 2 above. This may vary according to the type of information and the specific applicable purpose(s). In determining how long we retain your information for, the criteria that we will take into consideration include our legal obligations, good industry practice, the guidance of relevant UK authorities or similar authorities in your country such as the Information Commissioner’s Office and HMRC, and also tax, accounting, health and safety and employment rules. We can provide you with further details applicable to your data on request – please see section 7 below as to how to request this information.

7. Your rights

You have various rights under Data Protection Law. These include:

a. the right to ask us not to process your personal data for direct marketing purposes, even if you have given consent;

b. the right to withdraw any consent you may have given for our processing of your data – if you exercise this right, we will be required to stop such processing if consent is the sole lawful ground on which we are processing that data;

c. the right to ask us for access to the data we hold about you (see section 8 below for further details);

d.the right to ask us to rectify any data that we hold about you that is inaccurate or incomplete;

e. the right to ask us to delete your data in certain circumstances;

f. the right to ask us to restrict our processing of your data in certain circumstances;

g. the right to object to our processing of your data in certain circumstances;

h. the right to require us to give you the data we hold about you in a structured, commonly used and machine-readable format so that you can provide the data to another data controller.

You can exercise any of the rights set out above, free of charge, by contacting us at DP*@re*****.com. If we require any more information from you in order to process the request, we will ask this from you following your request.

If you submit unfounded or excessive requests to exercise any of these rights, we reserve the right to decline your request or make a reasonable charge for fulfilling your request.

You also have the right to lodge a complaint with the Information Commissioner’s Office (www.ico.org.uk) for UK and similar authority in your country if you are concerned that we are not respecting your rights under Data Protection Law. The Information Commissioner’s Office is the authority in the UK which is responsible for overseeing the application of, and enforcing, Data Protection Law.

8. Accessing your data

You have the right to obtain from Rezolve a confirmation as to whether we are processing (including holding) personal data about you.

If we are processing personal data about you, you are entitled to be provided with:

a. information as to the purposes for which we process the data;

b. information as to the categories of the data that we are processing;

c. information as to the recipients or categories of recipients to whom the data has or will be disclosed;

d. information as to the envisaged period for which we will store the data, or if that has not been determined, the basis on which that period will be determined;

e. a copy of the data (should you request further copies, we may make a reasonable charge which will inform you of at the time). Please note that this right is subject to the rights of others in relation to their own or someone else’s personal data.

See section 7 above for details of how to exercise these rights.

9. Other websites

Our platforms may, from time to time, contain links to and from the platforms of third parties. If you follow a link to any of these platforms, please note that they should have their own privacy policies and that we do not accept any responsibility or liability for those policies. Please check those policies before you submit any personal data to those platforms.

10. Changes to this privacy notice

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, we will notify you by e-mail. Please ensure you review this privacy notice frequently to see any updates or changes.

11. Contact

If you have any questions, comments and requests regarding this privacy notice, please email them to DP*@re*****.com.

Cookie Notice

Cookies are tiny files stored on your computer or other device when you visit certain web pages.
If you disable these cookies, you may be able to still browse the site, however you may not be able to take advantage of all features available on the site.

We may use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We may use this information to make our website and the advertising displayed on it, or communications that we send to you, more relevant to your interests. [We may also share this information with third parties for this purpose.]

You can usually (depending on the browser you are using) block cookies by consulting the “Help” tab of your browser via the menu bar. Please note that if you use your browser settings to block all cookies (including strictly necessary cookies), this may prevent our website from functioning properly or at all. You are taken to have agreed to any cookies that you have not blocked.

To change your cookie settings, if you want to be notified each time a cookie is about to be used or if you want to reject cookies that you have previously agreed to, you can amend the settings as described above. Except for essential cookies, all cookies will expire (which means they will either be removed or cease operating) after a maximum of two years.

Please also note that we may use pixels in emails that you will receive as a result of signing up with us. Pixels are similar to cookies, and can enable us to, for example, track email opens, if you have images enabled in your email client/mailbox. This is a standard approach for measuring open and click rates, and is used by most email platforms in the market.

All links in emails are proxied through a link redirection service that records data for each link clicked. This leads to the ability to record a set of events which may include:

• Event type (delivery, bounce, open, click, spam complaint, unsubscribe)
• Email address of the recipient (which you will have provided)
• IP address of the recipient (in the case of open and click)
• GEO location based on IP address (city level) (in the case of open and click)
• Device type (e.g. mobile/computer/tablet) and browser (e.g. firefox/chrome/safari).
  If you do not want this information to be collectable, you should disable and not open images in your email application.