# STEPN Terms of Use **STEPN** is a Web3 lifestyle app (**App**) launched by FindSatoshi Lab Limited (**Company**). Users of the App can accumulate tokens by walking, jogging, or running outdoors. Access to, and use of, the App and the services available through the App (**Services**) are subject to the following terms, conditions and notices (**Terms of Use**). By using the Services, you are agreeing to all of the Terms of Use, as may be updated by us from time to time. You should check this page regularly to take notice of any changes we may have made to the Terms of Use. ### 1. Amendments to Terms of Use The Company reserves the right to amend these Terms of Use from time to time. Amendments will be effective immediately upon notification on the App or through the Services. Your continued use of the App and the Services following such notification will represent an agreement by you to be bound by the Terms of Use as amended. ### 2. Who may use the App? You must be at least 18 years old, or the age of legal majority in your jurisdiction of residence, to access the App and the Services. As a user you should abide by all safety precautions, including resting, hydrating and modifying as needed. The App and the Services are offered only for your personal, non-commercial use. When interacting with the App or the Services, you should exercise caution and common sense to protect your personal safety and health. You agree that the Company is not responsible or liable for any loss, damage, injury, or other matters of any sort incurred as the result of interacting with the App or the Services. By using the App or the Services you represent and warrant that: 1. you are not a current resident of the United States of America, China (Mainland), Cuba, Crimea and Sevastopol, Iran, Afghanistan, Syria, North Korea, Antigua and Barbuda, Hong Kong, Thailand, Malaysia, India or Canada (Ontario); and 2. your access to and use of the App and Services is lawful in your country of residence in the manner in which you access and use them. ### 3. App Access to the App is permitted on a temporary basis, and we reserve the right to withdraw or amend the Services without notice. We will not be liable if for any reason the App is unavailable at any time or for any period. From time to time, we may restrict access to some parts or all of the App. We may from time to time change the rate at which users accumulate tokens using the App. We may reverse benefits allocated to you if we reasonably consider the circumstances justify a reversal, for example if they are allocated to you by mistake or if you accumulated them by misusing the App or the Services or in a way that is fraudulent, dishonest or otherwise unacceptable. You are responsible for ensuring your security of access to any digital wallet used by you in connection with the App or the Services. We make no representation and give no warranty that tokens accumulated through the App or the Services will have any particular value or any monetary value at all. You are liable for any loss or diminution value of tokens. ### 4. Linked sites The App may contain links to other apps or websites (**Linked Sites**), which are not operated by the Company. The Company has no control over the Linked Sites, makes no warranties or representations in relation to the Linked Sites and accepts no responsibility for them or for any loss or damage that may arise from your use of them. Your use of the Linked Sites will be subject to the terms of use and service contained within each respective Linked Site. ### 5. Privacy policy Our privacy policy, which sets out how we will use your personal information, can be found at . By using the App, you consent to our collection, storage, use and disclosure of your personal information as set out in the privacy policy and warrant that all data provided by you is accurate. ### 6. Safety warnings THE COMPANY OFFERS HEALTH AND FITNESS INFORMATION AND IS DESIGNED FOR EDUCATIONAL AND ENTERTAINMENT PURPOSES ONLY. YOU SHOULD CONSULT YOUR PHYSICIAN OR GENERAL PRACTITIONER BEFORE BEGINNING A NEW FITNESS PROGRAM USING THE APP OR THE SERVICES. YOU SHOULD NOT RELY ON THIS INFORMATION AS A SUBSTITUTE FOR, NOR DOES IT REPLACE, PROFESSIONAL MEDICAL ADVICE, DIAGNOSIS, OR TREATMENT. IF YOU HAVE ANY CONCERNS OR QUESTIONS ABOUT YOUR HEALTH, YOU SHOULD ALWAYS CONSULT WITH A PHYSICIAN, GENERAL PRACTITIONER OR OTHER HEALTHCARE PROFESSIONAL. DO NOT DISREGARD, AVOID OR DELAY OBTAINING MEDICAL OR HEALTH RELATED ADVICE FROM YOUR HEALTHCARE PROFESSIONAL BECAUSE OF YOUR QUEST TO ACCUMULATE TOKENS ON THE MOVE USING THE APP OR THE SERVICES. THE USE OF ANY INFORMATION PROVIDED THROUGH THE APP AND THE SERVICES IS SOLELY AT YOUR OWN RISK AND IS NOT MEDICAL OR HEALTHCARE ADVICE. ### 7. Purchase The Company may offer certain products and Services for purchase through the Apple App Store, Google Play or other external services as authorised by the Company (each an **External Service**, and any purchases made being an **External Service Purchase**). When making a purchase on the Service, you may have the option to pay through an External Service, such as your Apple ID or Google Play account (**External Service Account**) and your External Service Account will be charged for the purchase in accordance with the terms disclosed to you at the time of purchase and the general terms applicable to your External Service Account and as stated by the External Service. You may be charged a sales tax, depending on where you live, which may change from time to time. If your External Service Purchase includes an automatically renewing subscription, your External Service Account will continue to be periodically charged for the subscription on a monthly basis until you cancel your subscription. You will be automatically charged at the price and time period you agreed to when first making the purchase. If you do not want to renew your subscription, or if you want amend or cancel your subscription, you must log into your External Service Account and follow the instructions to manage or cancel your subscription. This applies even if you have deleted your account with us or if you have deleted the App from your device. If you initiate a chargeback or otherwise reverse a payment made with the Company or your External Service Account, the Company may terminate your subscription immediately in its sole discretion. All purchases are final and non-refundable, except if laws applicable in your jurisdiction provide for refunds. ### 8. Disclaimer of representations and warranties TO THE FULL EXTENT PERMITTED BY LAW, THE COMPANY MAKES NO REPRESENTATION OR WARRANTY OF ANY KIND, IMPLIED OR EXPRESS, AS TO THE APP’S OR SERVICES’ ACCURACY, COMPLETENESS OR APPROPRIATENESS FOR ANY PURPOSE. ### 9. User representations and warranties In becoming a user of the App and the Services, you represent and warrant that all of the following statements are true: 1. no physician or general practitioner has ever informed you that you have a heart condition or that you should only do physical activities recommended by a physician or general practitioner; 2. you have never felt chest pain when engaging in physical activity; 3. you have not experienced chest pain when not engaged in physical activity at any time within the past month; 4. you have never lost your balance because of dizziness and you have never lost consciousness; 5. you do not have a bone or joint problem that could be made worse by a change in your physical activity; 6. your physician or general practitioner is not currently prescribing medication for your blood pressure or heart condition; 7. you do not have a history of high blood pressure, and no one in your immediate family has a history of high blood pressure or heart problems; and 8. you do not know of any other reason you should not exercise. ### 10. Prohibitions You must not misuse this App or the Services. This means that you must not (among other things): 1. commit or encourage a criminal offence; 2. transmit or distribute a virus, trojan, worm, logic bomb or any other material which is malicious, technologically harmful, in breach of confidence or in any way offensive or obscene; 3. hack into any aspect of the App or the Services, corrupt data, or cause annoyance to other users; 4. infringe upon the rights of any other person's proprietary rights; 5. send any unsolicited advertising or promotional material, commonly referred to as “spam”; 6. attempt to affect the performance or functionality of any computer facilities of or accessed through this App or the Services; 7. use an emulator or similar third party software to cheat in accumulating benefits or gain an advantage; 8. make false, inaccurate, misleading or deceptive representations; 9. engage in fraudulent conduct or abuse, misuse or attempt to abuse or misuse the App or the Services; 10. submit any content that contravenes any laws; 11. infringe on the rights of any person who has a copyright, patent, trademark or any other form of intellectual property right, confidentiality or privacy; 12. contravene any applicable state, federal or international law or regulation; 13. engage in defamatory or libellous conduct towards any other person; 14. threaten or harass any other person; 15. publish or engage in obscene material that in the Company’s sole discretion, is in any way inappropriate or unsuitable for the platform; 16. publish or participate in publishing any malicious code, script or data that may causes harm, damage or interfere or modify the App or the Services without the express prior written consent from the Company; or 17. engage in conduct deemed contrary to the spirit of the App or the Services as determined by the Company in its sole discretion. You agree that, except as these Terms of Use expressly provide otherwise, we do not need to notify you in advance or give you any reasons for any action we may take in connection with your misuse of the App or the Services, including suspending or cancelling your access to the App and the Services. We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of this App or to your downloading of any material posted on it, or on any Linked Sites. We are not liable for any loss of tokens or assets incurred as a result of the suspension or cancellation of your access to the App and the Services. ### 11. Intellectual property, software and content The intellectual property rights in all software and content (including images) made available to you on or through the App or the Services remain the property of the Company or its licensors and are protected by copyright laws and treaties around the world. All such rights are reserved by the Company and its licensors. You may store, print and display the content supplied solely for your own personal use. You are not permitted to publish, manipulate, distribute or otherwise reproduce, in any format, any of the content or copies of the content supplied to you or which appears on the App or through the Services nor may you use any such content in connection with any business or commercial enterprise. You must not use the Company’s trade marks (including names and logos) in any circumstances (including by linking on websites or social media) without the Company’s prior written consent. You grant to the Company a non-exclusive, irrevocable, global licence (including the right to sublicense to third parties) to exercise the intellectual property rights in any content you submit through the App or the Services for any purpose. ### 12. Anti-Cheating In the end of each session after users long press the stop button, the Machine Learning Anti-Cheating System (**System**) will evaluate if users have exploited the STEPN move2earn mechanics. The System will add or deduct users’ Turing Score in the end of each session, user cannot start a new session before the System completes the analysis. A user starts with a 100/100 Turing Score (TS). When a user’s Turing Score is below 100, the user cannot interact with the NFT marketplace, or transfer between spending and wallet accounts. If a user is moving outdoor without cheating, the Turing Score will gradually return to 100/100. The following table outlines how the System works and you accept the Turing Score and token consequences that apply in these circumstances. The following table does not limit our rights to otherwise take action in connection with your misuse of the App or the Services.
Examples*System ResultConsequence**
Reverse engineeringCheatingNo earning, reduce TS
GPS spoofing/hackingCheatingNo earning, reduce TS
Motion simulation/hackingCheatingNo earning, reduce TS
Move with multiple mobiles with STEPN activated at the same timeCheatingNo earning, reduce TS
Make animals carry phones with STEPN activatedCheatingNo earning, reduce TS
Run with a group of friends all with STEPN activatedNo CheatingEarning, increase TS
Carry two mobiles but only one with STEPN activatedNo CheatingEarning, increase TS
\* Moonwalking is not part of the System’s scrutiny, as the feedback from Moonwalking is instant, whereas the System only displays the result after the end of each session. \*\* If the reset token earning is GST, a portion of the GST will go to the Schadenfreude Pool. If the reset token earning is GMT, it will be refunded back to the total GMT release of the day. ### 13. Disclaimer of liability 1. Subject to clause 13.4, any non-excludable consumer guarantees and other consumer protection provisions set out in the Australian Consumer Law or equivalent consumer protection law, the material displayed on the App or through the Services is provided without any guarantees, conditions or warranties as to its accuracy. 2. Subject to clause 13.4, to the fullest extent permitted by law the Company hereby expressly excludes all warranties and other terms which might otherwise be implied by statute, common law or the law of equity and is not liable for any damages whatsoever, including but without limitation to any direct, indirect, special, consequential, punitive or incidental damages, or damages for loss of use, profits, data or other intangibles, non-value or diminution in the value of tokens, damage to goodwill or reputation, or the cost of procurement of substitute goods and services, arising out of or related to the use, inability to use, performance or failures of the App, the Services or the Linked Sites and any materials posted on those apps or sites, irrespective of whether such damages were foreseeable or arise in contract, tort, equity, restitution, by statute, at common law or otherwise. 3. This does not affect the Company's liability for death or personal injury arising from its negligence, fraudulent misrepresentation, misrepresentation as to a fundamental matter or any other liability which cannot be excluded or limited under applicable law. 4. If the *Australian Consumer Law* or any other legislation provides that there is a guarantee in respect of goods or services supplied, and the Company’s liability for failure to comply with that guarantee may not be excluded but may be limited, clauses 13.1 and 13.2 do not apply to that liability and instead the Company’s liability for such failure is limited to: 1. in the case of a supply of goods, the Company replacing the goods or supplying equivalent goods or repairing the goods; or 2. in the case of a supply of services, the Company supplying the services again or paying the cost of having the services supplied again. ### 14. Linking to the STEPN website You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it, but you must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists. You must not establish a link from any website that is not owned by you. The STEPN website must not be framed on any other site, nor may you create a link to any part of the website other than the home page. We reserve the right to withdraw linking permission without notice. You must not create hyperlinks using any of the Company’s logos. ### 15. Disclaimer as to ownership of trade marks, images of personalities and third party copyright Except where expressly stated to the contrary all persons (including their names and images), third party trade marks and content, services and/or locations featured in the App are in no way associated, linked or affiliated with the Company and you should not rely on the existence of such a connection or affiliation. Any trade marks/names featured on the App are owned by the respective trade mark owners. Where a trade mark or brand name is referred to it is used solely to describe or identify the products and services and is in no way an assertion that such products or services are endorsed by or connected to the Company. ### 16. Indemnity To the maximum extent permitted by law, you are liable for and must indemnify, defend and hold harmless the Company, its directors, officers, employees, consultants, agents, and affiliates, from any and all liability, loss, damages, costs or third party claims (including, but not limited to, legal fees on an indemnity basis), however caused, in connection with: 1. your use of the App or the Services; 2. any user content submitted by you or on your behalf; 3. any breach of these Terms of Use by you; 4. any alleged or actual infringement of a third party’s intellectual property rights or other right in connection with your use of the App or the Services; or 5. any unlawful or negligent act of you or anyone acting on your behalf. Each indemnity contained in these Terms of Use is a continuing obligation notwithstanding any settlement of account or the occurrence of any other thing, and it is not necessary for the Company to incur expense or make payment before enforcing or making a claim under an indemnity. ### 17. Variation The Company retains the right in its absolute discretion at any time and without notice to amend, remove or vary the Services or any part of the App. ### 18. Invalidity If any part of the Terms of Use are unenforceable (including any provision in which we exclude our liability to you) the enforceability of any other part of the Terms of Use will not be affected and all other clauses remain in full force and effect. So far as possible where any clause/sub-clause or part of a clause/sub-clause can be severed to render the remaining part valid, the clause must be interpreted accordingly. Alternatively, you agree that the clause must be rectified and interpreted in such a way that closely resembles the original meaning of the clause/sub-clause as is permitted by law. ### 19. Force majeure The Company will not be in breach of these Terms of Use as a result of, or liable for, any failure or delay in the performance of the Company’s obligations under these Terms of Use to the extent that such failure or delay is wholly or partially caused, directly or indirectly, by any event outside the Company’s reasonable control or any act or omission of you or any third party. ### 20. Assignment You must not assign, in whole or in part, or novate your rights and obligations under these Terms of Use without the prior written consent of the Company. The Company may assign its interest under these Terms of Use. ### 21. Waiver A right under these Terms of Use may only be waived in writing signed by the party granting the waiver, and is effective only to the extent specifically set out in the waiver. ### 22. Exclusion of third party rights Except under clause 15, no person other than the parties to these Terms of Use has any rights under them, nor are they enforceable by any person other than the parties to them. ### 23. Governing law and jurisdiction These Terms of Use are governed by the law of British Virgin Islands and you agree to submit to the exclusive jurisdiction of the courts of British Virgin Islands. ### 24. Complaints We operate a complaints handling procedure which we will use to try to resolve disputes when they first arise, please let us know if you have any complaints or comments. # Data Protection Notice ## **1 Glossary** “**Company**” means **Find Satoshi Lab Limited**, a company incorporated in the British Virgin Islands as a BVI Business Company pursuant to the BVI Business Companies Act, 2004, with its registered address at c/o CCS Trustees Limited, Mandar House, 3rd Floor, Johnson's Ghut, Tortola, British Virgin Islands. **“Data Controller**” means a person who either alone or jointly or in common with other persons processes any personal data, or has control over, or authorises the processing of any personal data, but does not include a data processor. “**Data Processor**” means a person who, processes data on behalf of a data controller, but does not include an employee of the data controller. “**Data Subject**” means a natural person, whether living or deceased. Natural persons who use or participate on the Company’s move2earn NFT Game-Fi Project “**STEPN**” and acquire game tokens or “**GSTs**” and/or acquire GMTs and participate in the Company’s profit pool will be Data Subjects. “**DPA**” means the British Virgin Islands Data Protection Act, 2021, as amended from time to time. “**Information Commissioner**” means the person appointed for an office established pursuant to DPA, responsible among others for monitoring compliance by public and private bodies with the requirements of DPA and receiving and investigating complaints about alleged violations of the data protection principles and in respect thereof, may make reports to complainants. “**Personal Data**” means any information in respect of commercial transactions, which (a) is being processed wholly or partly by means of equipment operating automatically in response to instructions given for that purpose; (b) is recorded with the intention that it should wholly or partly be processed by means of such equipment; or (c) is recorded as part of a relevant filing system or with the intention that it should form part of a relevant filing system, that relates directly or indirectly to a data subject, who is identified or identifiable from that information, or from that and other information in the possession of a data user, including any sensitive personal data and expression of opinion about the data subject; “**Processing**” means collecting, recording, holding or storing the personal data or carrying out any operation or set of operations on the personal data, including the (a) organisation, adaptation or alteration of personal data; (b) retrieval, consultation or use of personal data; (c) disclosure of personal data by transmission, transfer, dissemination or otherwise making available; or (d) alignment, combination, correction, erasure or destruction of personal data; ## **2 Legal Framework** In accordance with the provisions of the DPA concerning the protection of persons in relation to the processing of personal data, and any law, circular or regulation in the context of DPA, personal data may be processed by the Company and its Data Controller. ## **3 General Requirements** ### **3.1 Who is the Data Controller and who to contact?** The Company shall be the Data Controller. The Data Controller collects, stores and process by electronic or other means the data supplied by the Data Subjects, for the purpose of fulfilling the offered services and complying with their legal obligations and specifically in compliance with the provisions of DPA. Data Subjects who wish to contact the Data Controllers can do it at: **** Data Subjects should note that the processors may also act as Data Controllers for their own purposes. In this case Data Subjects may consult the data privacy notices of the relevant processor acting as independent data controller, when available. ### **3.2 What kind of personal data do we process?** Personal data includes, but it is not limited to, the name, address, passport or identification card details, bank account details of each Data Subject. In particular the data we may process about you (the “**Personal Data**”) includes: • identification data (e.g. name, e-mail, postal address, telephone number, country of residence, passport, identity card, driving licence, tax identification number, bank account details); • electronic identification data (e.g. IP addressed, cookies, traffic data); • personal characteristics (e.g. date of birth, marital status); • banking and financial data (e.g. financial identification, financial situation); • employment and occupation (e.g. employer, function, title, place of work, specialization); • tax-related data; • communications (e.g. exchange of letters with you); • images and sound (e.g. copies of identifications documents); • advertisement and sales data (e.g. potential interesting products for you). ### **3.3 How do we receive your personal data and Recipients and Categories of information?** Certain personal data shall be collected, recorded, stored, adapted, transferred or otherwise processed. We process data we receive through our business relationship with you. We receive the data directly from you. The Company may sub-contract to another entity the processing of personal data. Data Subjects must be aware that the personal data may be disclosed (i) other parties who assist the Company with undertaking its duties to the Company (e.g. external processing centers, dispatch or payment agents), including companies based in countries where data protection laws might not exist or be of a lower standard than in the British Virgin Islands or (ii) when required by law or regulation (British Virgin Islands or otherwise). When the Company uses processors, it shall ensure that such processors provide sufficient guarantees to implement appropriate technical and organizational measures and that such processing on behalf of the Company meets the requirements of the DPA and ensures the protection of the rights of the Data Subjects. ### **3.4 For which purposes do we process your Personal Data?** We may process personal data about a Data Subject if the processing is necessary for the performance of a contract to which the Data Subject is a party, for the taking of steps at the request of the Data Subject with a view to entering into a contract, for compliance with any legal obligation to which the Data Controller is the subject, other than an obligation imposed by a contract, in order to protect the vital interests of the Data Subject, for the administration of justice, or for the exercise of any functions conferred on a person by or under any law. #### **3.4.1 For the performance of a contractual obligation** We process your personal data for you to use our services. In this regard Personal Data may be processed for the following purposes: (i) maintaining the register of registered users, (ii) processing subscriptions and payments , (iii) complying with applicable anti-money laundering laws and regulations, and any regulatory requirements applicable to the Company, any of the service providers of the Company or any of its affiliates and professional advisers of those entities in connection with the operations of the Company, its subsidiaries and investments, and to the legal advisors, investment consultants and custodian banks of each of the Company and the financial intermediaries of such Investors, and (iv) more generally providing other services by the Company. The information required by the Company is necessary to sign up and use services offered by the Company. Failure to provide such information will imply rejection to use our services. #### **3.4.2 For compliance with laws and regulations** The Company, any of the service providers of the Company and any of their affiliates are subject to various legal obligations in terms of statutory (e.g. laws regulating the financial services sector, anti-money laundering and combatting the financing of terrorism laws, tax laws) and regulatory requirements (e.g. requirements of the British Virgin Islands Financial Services Commission (FSC)). This covers our processing of your Personal Data for compliance with applicable laws such as the applicable legislation on know-your-Customer (KYC) and anti-money laundering and combatting the financing of terrorism (AML/CFT), compliance with requests from or requirements of local or foreign regulatory enforcement authorities, tax identification and reporting (where appropriate) notably under the OECD’s standard for automatic exchange of financial account information commonly referred to as the Common Reporting Standard or CRS), for Foreign Account Tax and Compliance Act (FATCA) purposes, for the Automatic Exchange of Information (AEOI) and any other exchange of information regime to which we may be subject to from time to time. Your Personal Data may be shared with tax authorities (or to service providers for the purpose of effecting the reporting on our behalf) and may be forwarded by the latter to foreign tax authorities (failure to provide correct information to us or to respond may result in incorrect or double reporting). In addition, the Company, any of its advisers and any other party may, subject to all applicable laws, disclose to any governmental, regulatory, taxation or court authority such information relating to Data Subjects as the Company reasonably determines. For the avoidance of doubt, this includes, without limitation, information which in the reasonable determination of the discloser, may be required to be disclosed to such authority or may be necessary to be disclosed pursuant to the Common Reporting Standard approved by the OECD Council on 15 July 2015, as subsequently amended and implemented, and FATCA. Should any such authority require any further information, the Company may require each Data Subject to provide such information to the Company (to the extent such potential Data Subject is in possession of or entitled to receive such information or such information can be acquired without unreasonable effort or expense) and the Company and any of its advisers and any other party may, subject to all applicable laws, disclose such information to any such authority. Such information shall not be passed on to any unauthorized third persons. ### **3.5 For how long do we keep your Personal Data?** As far as necessary, we will keep your personal data for the duration of your relationship with us and for the length of time required by applicable law. The personal data processed for any purpose will not be kept longer than is necessary for the fulfilment of our services. The British Virgin Islands laws and regulations relating to anti-money laundering requires that documents be retained for a period of at least five (5) years after the relationship has come to an end. The Data Controller will take all reasonable steps to ensure that all personal data is destroyed or permanently deleted if it is no longer required for the purpose for which it was to be processed. ### **3.6 Automated Decision Making** Data Subjects should note that the data will not be used for direct marketing or profiling. If any of the data processors uses the data for direct marketing or profiling they will be doing so in their capacity as independent data controller. In that case Data Subjects may consult the data privacy notice of the processors acting as independent data controller, when available. ### **3.7 Rights of the Data Subject** Each Data Subject has: a) a right to request the Data Controllers access to his/her personal information being processed. b) a right to have the Company rectify his/personal data if they are incorrect or incomplete. c) a right to request the erasure of his/her personal data in accordance with the DPA including in the following situations (i) where the personal data is no longer necessary, (ii) the Data Subject objects to the processing of its data and there are no overriding legitimate grounds for the processing, and (iii) the data has been unlawfully processed. d) a right to request a restriction of the processing in accordance with the provisions of the DPA. e) a right to lodge a complaint with the Information Commissioner. f) a right to receive the personal data concerning him or her or to request that it be transmitted to another data controller, when feasible, in accordance with the DPA. To make any of the above requests you need to put the request in writing addressing it to the Data Controller at the following email address: **.** ## **4 Transfer of Data outside the British Virgin Islands** Data may be transferred (i) to other companies or entities within the Administrator’s group, where such transfer is necessary for the maintenance of records, administration or provision of services to the Company. In such cases, personal data which are transferred to countries outside of the British Virgin Islands will be protected by appropriate safeguards such as, in this case, standard contractual clauses, or, upon obtaining consent from the Data Subject. You may obtain a copy of such safeguards by contacting the Data Controller at the following email address: **** ## **5 Additional Information** The Data Controller may request the Data Subject to provide additional or updated identification documents from time to time pursuant to on-going due diligence requirements under relevant laws and regulations, and shall comply with such requests. Data Subjects may in accordance with the DPA lodge a complaint with the Information Commissioner.