Procuchain

Terms & Conditions

SC Links Group SRL, a Romanian legal entity, with its headquarters in Bucharest, sector 2, Colentina Road, No. 24,
registered with the Trade Register under no. J40/8534/2005, unique registration number RO 17571923, a personal data
operator registered under no. 14754/04.12.2009, hereinafter referred to as the “Personal Data Operator,” in the capacity
of a personal data operator, hereby transmits the following:

Informative Note to Detail How We Process and Protect Your Personal Data Our Policy on the Use and Processing of Personal Data

This information note is transmitted through our website and, upon request, by mail or email, using the correspondence
request address: email: office@procuchain.com, in writing, at the address: Colentina Road, No. 24, Bucharest, Sector 2.

Our company expresses joy for your visit to our website and your interest in our products. Thank you for your trust!

In this regard, we take data protection seriously, and we want you to feel safe when visiting our website. The security
of your personal data, whatever it may be (name, address, phone number, or email address), is important to us.

Therefore, we consider the security of your personal data in all our business processes.

Online activities are carried out in accordance with data protection and security laws. Below, you will find what
information we collect and how we process it.

Note! Our website may contain links to websites on the Internet that may or may not be covered by data protection
statements, and this is the responsibility of the owners of those websites. Please check the privacy and data protection
policies of the respective website owner when accessing an external site, as it is the responsibility of the site owner.

The processing policy applies to the personal data of visitors and users of our website that can be accessed on our
website.

For any situation that does not correspond to this data processing and protection policy and if you do not fall into any
of the categories listed above, please contact office@procuchain.com, and we will provide you with information
established in accordance with the provisions of the situation you are in.

Personal Data – Responsible Party

The collection and processing of personal data are carried out in accordance with
legal provisions, namely Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the
protection of individuals with regard to the processing of personal data and on the free movement of such data, as well
as the applicable Romanian legislation.

Compliance with the above provisions on data protection is monitored by the following internal or external persons and
organizations, who can be contacted by any user of our website:

Internal Data Protection Officer of SC LINKS Group SRL: Mr. Marius Lazarescu, phone: 0316 302 622, email:
office@procuchain.com Romanian Supervisory Authority: The National Authority for the Supervision of Personal Data
Processing, to be contacted at 28-30 Gd. Bd. Gheorghe Magheru, Sector 1, postal code 010336, Bucharest, or
www.dataprotection.ro.

What Information We Collect About You

We collect and process your personal data when you interact with us (e.g.,
information you provide by filling out forms on our websites or contacting us by phone, email, or any other means).

There is information that you provide when you register to use the site, when you subscribe to our services, when you
participate in discussion forums or other social communication activities on our site, by filling out a form on the
site, or when you register for contests, promotions, or studies organized by us, and when you shop on our site or report
a site-related issue.

The information you provide may include your name, address, email address, and phone number, personal description and
photograph, age, date of birth, and gender, as well as other information, as applicable. Calls made through the website
may also be recorded.

We will not collect or process sensitive personal data related to you (e.g., information about racial or ethnic origin,
political opinions, religious beliefs or philosophical convictions, health, sexual life, or sexual orientation) unless
required by law and/or if you have given us explicit consent, separately.

If you voluntarily provide us with personal data (including sensitive personal data) by interacting with our website or
contacting us by phone, email, or in any other way, we will delete such personal data from our systems unless we
consider that such processing is necessary for a legitimate purpose, except where you have made such data public (e.g.,
in a public forum message), in which case we will delete such data from our website at your written request or only if
required by law or if we do not want to keep it.

Warning! We do not collect personal data through our website without notifying you. You are the one who decides whether
or not to disclose this information when registering on the site, placing an order, or participating in a survey.

You can withdraw your consent to use it for any personal reason and for any reason by sending a notice to
office@procuchain.com or by sending a letter to the person responsible for personal data protection at Links Group SRL
at: Colentina Road, No. 24, Sector 2, Bucharest.

Note: Withdrawing your consent will not affect the legality of any processing that occurred before its withdrawal.

Use of Your Personal Data

Whenever you visit our website, we automatically collect the following data:

  • Technical data: This may include the Internet Protocol (IP) address used to connect your device to the Internet,
    login
    information, browser type and version, and its extensions, device type and brand of mobile device, this data may be
    collected and processed on our behalf through third-party cookies, and you can find more information about it at
    https://procuchain.com/cookies-policy/
  • Information about your visit: it may include uniform resource locators
    (URLs), click-through sequences to, from, and through our site (including date and time) (including publicly
    published
    materials, categories of uploaded materials, page response times, download errors, duration of visits to certain
    pages), time spent in an application, and the number of views in such applications, the average number of materials
    viewed on
    our site, information about your interaction with pages (such as scrolling, mouse clicks, and passes), methods used
    to
    navigate the page, data about your behavior, and any phone number you use to call us or any email address used to
    contact us.

If we obtain your personal data from a third party, we will provide you with all relevant information
about the processing of your personal data upon request, and this will be automatically included in this Privacy Policy.

We may process your personal data if we need to perform a contract we have entered into with you; if we need to comply
with a legal obligation; when it is necessary for our legitimate interests and/or for your interests (e.g., to detect
and prevent fraud or ensure network security), unless your fundamental rights prevail over these interests.

We process your personal data for various technical, administrative, and operational reasons, such as ensuring that
content is presented in the most efficient way for you and your computer; improving our website, including its
functionality; administering it; internal operations, including data analysis, testing, research, statistics;
advertising and marketing, so we can provide personalized content that may be of greater interest to you.

If we request personal data in order to comply with legal or contractual obligations, the provision of such personal
data by you is mandatory. This means that if such personal data is not provided, we will not be able to manage
contractual relationships or comply with our obligations towards you.

In all other cases, the provision of personal data is optional, and you have no obligation to provide them.

How and to whom we disclose your personal data:

We do NOT sell your personal data to third parties.

Within the company, only a limited number of staff members, such as those in the administration, sales, or IT
departments, have access to your personal data. These staff members are subject to confidentiality obligations regarding
personal data.

Appropriate technical and organizational measures are taken to protect personal data.

Company staff members have the right to process personal data only in connection with their job responsibilities, and
any processing of personal data for transportation is documented in a record of such processing.

Personal data may be disclosed to government authorities and/or law enforcement agencies if required by applicable law
or if necessary for the exercise of our rights, including the terms of use, or for the protection of our legitimate
interests (including the legitimate interests of third parties) only in accordance with applicable laws.

Your personal data may also be disclosed to third parties, including:

Service providers who provide administrative, professional, and technical support to the company for IT support,
security, and business resources; namely, the accounting firm, courier service, or other firms that assist us
technically or logistically.
Business partners, suppliers, and subcontractors for the execution of all contracts we enter into with you.
Advertising agencies and advertising networks that request your information to select and deliver relevant ads to you.
We do not disclose advertisers’ identifying information, but we will provide aggregated information about our users. We
may also use aggregated information to help advertisers reach their targeted audience. We may use the personal
information we have collected from you to comply with advertisers’ preferences by displaying their advertising messages
only to the target audience.
Search engines and search engines that help us improve and optimize our website.

Storage of your personal data and international transfers

Your personal data that we collect is stored in the European Union (“EU”) and the European Economic Area (“EEA”).
However, information collected by third parties through cookies (e.g., through Google) will generally serve traffic from
a data center outside the EU/EEA. This means that such information, including advertising traffic, may be processed by
servers located in the EEA and may be transferred outside the EEA. For more information, please refer to
https://procuchain.com/cookies-policy/

In addition, your personal data may be transferred and stored in a location outside the EU and EEA by these third
parties. When your personal data is transferred from your own country to another country, the laws and rules that
protect your personal data in the country to which your information is transferred may differ (or may provide less
protection) from those in the country where you are located.

As a general rule, we intend not to transfer your personal data outside the EEA unless adequate safeguards exist.

To learn more about transfers and the adequate protection measures we have established before these transfers, you can
contact us using the contact information above.

YOUR RIGHTS

You can ask us to:

– confirm whether your personal data is or is not processed by us,
– provide a copy of your personal information and/or correct it.
– use your right to request the deletion of personal information.
– stop the processing of your personal data (e.g., the use of direct marketing processing or certain automated
processing
decisions, including profiling).
– withdraw your consent for the processing of personal data.
– restrict the processing of your personal data in certain circumstances you desire or request the transfer of this data
under the conditions you desire.
We will not charge fees to respond to your request.
If you wish to exercise these rights, please contact us using the contact details mentioned above.

Retention of your personal data

We retain your personal data only for as long as necessary, in accordance with the Data Processing Policy, for a period
not exceeding the time required to fulfill the purposes outlined in this Notice and/or as required by applicable law, in
accordance with the minimum legal retention periods applicable and/or as long as it is necessary to exercise our
legitimate rights (and the legitimate rights of other third parties).

If we process your personal data with your consent, such personal data will be processed only for the duration of your
consent, unless you withdraw or limit it before the expiration of that period. In such cases, we will cease processing
that personal data for the relevant purposes, subject to any legal obligation to process such personal data and/or our
need to process such personal data for the purposes of our legitimate rights (including the legitimate rights of other
third parties).

Data Security

We store your data on our servers and on third-party hosted servers (including cloud-based services).

We employ appropriate technical and organizational measures to protect your personal data and prevent unauthorized
access.

All payment transactions will be encrypted, but you are responsible for maintaining the confidentiality of all
authentication means (e.g., passwords) used by you to access parts of our website.

Data transmission over the Internet is not entirely secure. While we will do our best to protect your data, we cannot
guarantee the security of your data transmitted to our site; any transmission is at your own risk. Only after we receive
your data will we use strict procedures and security features to try to prevent unauthorized access.

Children’s Privacy

We do not knowingly collect personally identifiable information on our website from individuals under the age of 18.
If a parent or guardian becomes aware that minors under their direct supervision or otherwise have provided their
personal data to us, they must inform us immediately.

If we discover that a person under the age of 18 has provided personal data, we will promptly delete this information
from our servers unless the parent or guardian explicitly consents to us processing the minor’s personal data.

Cookies and Social Media Widgets

Our website uses cookies to distinguish us from other users of our site. For detailed information about the cookies we
use, how long we use them, and the purposes for which we use them, please visit
https://procuchain.com/cookies-policy/.

Links to Other Websites

Our website may provide links to websites that we do not control. Once you click on a third-party link, you will be
directed to that site. For each visit, you should review their privacy policies.

We are not responsible for the policies and practices of other companies.

We do not control and do not assume any responsibility for the content, privacy policies, and notifications or practices
of third-party websites or services.

Contact

If you have any questions or concerns regarding the processing of your personal data or if you wish to exercise your
rights, you can contact the Data Protection Officer at office@procuchain.com or send a letter to the Data Protection
Officer at Links Group SRL, 24 Colentina Road, Bucharest, Sector 2.

Please do not disclose sensitive personal data (such as information about racial or ethnic origin, political opinions,
religious beliefs or other beliefs, health, or membership in a union), personal identification number, social security
numbers, or criminal record information when contacting us through our website.

Last updated: February 5, 2023.

We will update this policy when new data emerges or legislation requires it. We will notify you of any changes either by
posting the new version on our website or, if you have provided your contact information and agreed to be contacted, we
will inform you using the provided contact information.

Please check this information notice periodically for any changes that may occur.