PRIVACY POLICY FOR TALENTRADE PLATFORM

1. INTRODUCTION AND PURPOSE

Freecords B.V. ("Freecords," "we," "us," or "our") operates the TalenTrade platform ("TalenTrade" or "the Platform") and is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our TalenTrade platform, which allows users to trade artist "talents" where artists license their intellectual property and receive fees from trading activity.

This Privacy Policy has been designed to comply with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the Dutch GDPR Implementation Act (Uitvoeringswet Algemene Verordening Gegevensbescherming, "UAVG"), and other applicable Dutch privacy laws.

We encourage you to read this Privacy Policy carefully to understand our practices regarding your personal data and how we will treat it.

2. DATA CONTROLLER INFORMATION

Freecords B.V. acts as the data controller for the personal data processed through the TalenTrade platform.

We have appointed a Data Protection Officer ("DPO") who is responsible for overseeing questions regarding this Privacy Policy. If you have any questions about this Privacy Policy or our data practices, please contact our DPO at [email protected].

3. TYPES OF PERSONAL DATA COLLECTED

We collect and process the following categories of personal data through the TalenTrade platform:

3.1 Information You Provide to Us

• Identity Information: Full legal name, date of birth, nationality, government-issued identification documents for KYC (Know Your Customer) verification
• Contact Information: Email address, telephone number, physical address
• Financial Information: Cryptocurrency wallet addresses, cryptocurrency transaction history, blockchain transaction identifiers
• Profile Information: Username, password, profile picture, artist bio (if applicable)
• Communication Data: Messages sent through the TalenTrade platform, customer support communications

3.2 Information We Automatically Collect

• Usage Data: Login information, pages visited, features used, time spent on platform, click-stream data
• Device Information: IP address, browser type, operating system, device identifiers
• Location Data: General location based on IP address

3.3 Special Categories of Personal Data

We do not intentionally collect any special categories of personal data (data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, or data concerning sexual orientation). If you choose to include such information in your profile, you do so voluntarily and provide your explicit consent for us to process this information.

4. LEGAL BASIS FOR PROCESSING

We only process your personal data when we have a valid legal basis to do so. Depending on the specific processing activity, we rely on one or more of the following legal bases:

4.1 Contractual Necessity

Processing is necessary for the performance of a contract to which you are a party (our TalenTrade Terms of Service) or to take steps at your request prior to entering into a contract.

This includes:

• Creating and managing your TalenTrade account
• Processing your cryptocurrency transactions on the platform
• Providing customer support for the TalenTrade platform

4.2 Legal Obligation

Processing is necessary for compliance with a legal obligation to which Freecords B.V. is subject under Dutch or EU law.

This includes:

• Complying with KYC (Know Your Customer) and AML (Anti-Money Laundering) requirements
• Responding to legal requests from authorities
• Maintaining records as required by tax or financial regulations

4.3 Legitimate Interests

Processing is necessary for the purposes of the legitimate interests pursued by Freecords B.V. or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms.

This includes:

• Improving and developing the TalenTrade platform
• Ensuring the security of the TalenTrade platform
• Detecting and preventing fraud or other illegal activities
• Analyzing platform usage to enhance user experience

4.4 Consent

You have given explicit consent to the processing of your personal data for one or more specific purposes.

This includes:

• Marketing communications about TalenTrade (when you have opted in)
• Processing of any special categories of personal data you voluntarily provide
• Use of certain cookies (as described in our Cookie Policy)

You may withdraw your consent at any time by contacting us at [email protected] or through your TalenTrade account settings.

5. PURPOSES OF DATA PROCESSING

We process your personal data for the following purposes related to the TalenTrade platform:

5.1 Platform Operation and Service Provision

• Creating and managing your TalenTrade user account
• Facilitating the licensing and trading of artist "talents"
• Processing cryptocurrency transactions and deposits
• Providing customer support and responding to inquiries

5.2 Legal and Regulatory Compliance

• Verifying your identity in accordance with KYC requirements
• Preventing fraud, money laundering, and other illegal activities
• Complying with tax reporting and other financial regulations
• Responding to legal requests from authorities when required by law

5.3 Platform Improvement and Security

• Analyzing user behavior to improve the TalenTrade platform
• Troubleshooting technical issues
• Ensuring the security and integrity of the platform
• Developing new features and services

5.4 Communication

• Sending administrative notices about your account or transactions
• Providing updates about the TalenTrade platform and services
• Sending marketing communications (when you have opted in)
• Responding to your requests and inquiries

6. DATA RETENTION PERIODS

We retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

6.1 Specific Retention Periods

• Account Information: We retain your TalenTrade account information for the duration of your relationship with us and for a period of up to 7 years following account closure, in line with Dutch business record requirements.
• Transaction Data: We retain cryptocurrency transaction data for a minimum of 7 years to comply with Dutch tax and financial regulations.
• KYC Documents: We retain KYC verification documents for the duration of your relationship with us and for 5 years after the termination of our relationship, as required by applicable anti-money laundering regulations.
• Communications: We retain customer service communications for 2 years from the date of the communication.
• Usage Data: We retain usage data for 2 years from the date of collection.

7. DATA SHARING WITH THIRD PARTIES

We may share your personal data with the following categories of recipients:

7.1 Service Providers

We share your personal data with third-party service providers who perform services on behalf of the TalenTrade platform, such as:

• Cryptocurrency payment processors
• Cloud storage providers
• KYC verification services
• IT and system security providers
• Customer support services

7.2 Legal and Regulatory Authorities

We may disclose your personal data to legal and regulatory authorities when required by law, regulation, or legal process.

We do not sell your personal data to third parties.

8. INTERNATIONAL DATA TRANSFERS

Freecords B.V. is based in the Netherlands, but we may transfer your personal data to recipients in countries outside the European Economic Area ("EEA") for the operation of the TalenTrade platform.

When we transfer personal data outside the EEA, we ensure that appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission.

9. USER RIGHTS UNDER GDPR

Under the GDPR and Dutch privacy law, you have the following rights regarding your personal data:

9.1 Right to Access

You have the right to request access to your personal data that we process and obtain information about how we process it.

9.2 Right to Rectification

You have the right to request that we correct any inaccurate personal data or complete any incomplete personal data we hold about you.

9.3 Right to Erasure ('Right to be Forgotten')

You have the right to request that we delete your personal data in certain circumstances, such as when the data is no longer necessary, when you withdraw consent, or when you object to processing based on legitimate interests and there are no overriding legitimate grounds.

9.4 Right to Restriction of Processing

You have the right to request that we restrict the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data or when the processing is unlawful but you oppose erasure.

9.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller without hindrance from us.

9.6 Right to Object

You have the right to object to the processing of your personal data in certain circumstances, including when we process your data based on our legitimate interests or for direct marketing purposes.

9.7 Right to Withdraw Consent

Where we process your personal data based on your consent, you have the right to withdraw that consent at any time.

9.8 Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work, or place of the alleged infringement.

9.9 How to Exercise Your Rights

To exercise any of these rights, please contact our DPO at [email protected] or write to us at Herengracht 420, 1017 BZ Amsterdam, the Netherlands. We will respond to your request within one month. This period may be extended by two additional months where necessary, taking into account the complexity and number of requests.

10. DATA SECURITY MEASURES

We have implemented appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including:

10.1 Technical Measures

• Encryption of personal data in transit and at rest
• Secure Socket Layer (SSL) technology for all data transfers
• Multi-factor authentication for account access
• Firewalls, intrusion detection, and prevention systems
• Regular security assessments and penetration testing
• Pseudonymization and data minimization where possible

10.2 Organizational Measures

• Strict access controls and authentication procedures
• Regular staff training on data protection and security
• Documented data protection policies and procedures
• Data Protection Impact Assessments for high-risk processing activities
• Incident response and data breach notification procedures
• Regular audits of security measures and practices

11. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies to enhance your experience on the TalenTrade platform, gather information about users and their devices, and track platform usage.

11.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the platform to function properly and cannot be disabled.
• Functional Cookies: Enable enhanced functionality and personalization.
• Analytical/Performance Cookies: Provide information about how users interact with our platform.
• Targeting/Advertising Cookies: Used to deliver relevant advertisements and track marketing campaign effectiveness.

11.2 Cookie Management

You can manage your cookie preferences through our cookie consent banner when you first visit the TalenTrade platform. You can also adjust your browser settings to refuse cookies or alert you when cookies are being sent.

12. CHANGES TO THE PRIVACY POLICY

We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make.

We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws. We encourage you to periodically review this page for the latest information on our privacy practices.

The date at the top of this Privacy Policy indicates when it was last updated.

13. CONTACT INFORMATION

If you have any questions or concerns about this Privacy Policy or our data practices related to the TalenTrade platform, please contact our Data Protection Officer:

This Privacy Policy has been drafted to ensure compliance with Dutch and EU data protection law, including the GDPR and the Dutch GDPR Implementation Act.