1. Introduction

CAVERNA AUCTUS INC. a company duly organized and existing under laws of the Republic of Panama (“Company”, “us” or “we”) is committed to protecting your privacy through this privacy policy. This privacy policy describes the types of information we may collect from you or that you may provide to us when you visit our website https://www.neutrl.fi/ (the “Website” and together with our proprietary website application located therein, the “Services”), when you create an account with us to use the Services and our data collection and handling practices.

This privacy policy is part of the Terms of Use applicable to the use of our Services. Please review this policy together with the Terms of Use to understand all of your rights and obligations in respect of your use of the Services.

We are aware of our responsibilities to handle your personal data with care, to keep it secure, and comply with applicable privacy and data protection laws, including Law 81 of March 26, 2019, on the Protection of Personal Data and its Regulations, the Executive Decree 285 of May 28, 2021 (the "Data Protection Law"),

You UNDERSTAND, acknowledge AND AGREE that we use service providers to make our Services available to you, and that these SERVICE providers MAY intercept your communications or track your activities. By using our Services, you specifically consent to this interception, tracking and data collection by our third party service providers.

You have the right to withdraw your consent at any time by contacting our Data Protection Officer or through your account settings. Please note that withdrawal of consent for certain essential processing activities may impact our ability to provide you with access to all Platform features.

We maintain records of all consent provided by users in accordance with the Data Protection Law and make these records available to regulatory authorities upon legitimate request.

This privacy policy applies to information we collect:

• On and through the Services;
• In email, text and other messages between you and the Services, or otherwise transmitted on the Services;
• Through any mobile and desktop applications that you download from the Services;
• When you interact with our advertising and applications on third party websites and services, where such advertising or applications include links to this policy; and
• Through any other means associated with, or relating to, the Services.
• This policy does not apply to information collected by:
• Us offline or through any other means other than as set out above, including on any other website operated by the Company or any third party (including our affiliates and subsidiaries); or
• Any third party, including through any application or content (including advertising) that may link to the Services or is accessible from or on the Services.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with these policies and practices, your choice is not to use our Services. By accessing or using the Services, you agree to the terms of this privacy policy.

This privacy policy may change from time to time. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the privacy policy periodically for updates.

It is our policy to post any changes we make to this privacy policy on this page. If we make material changes as to how we treat our users' personal information, we will notify you by email to the email address specified in your account, if applicable. We may also post a notice on the Website’s home page. The date of last revision of this privacy policy is stated at the top of this page.

2. Information about underage persons

Our Services are not intended for persons under eighteen (18) years of age. No one under age eighteen (18) may provide any personal information to us or on or through the Services.

We do not knowingly collect personal information from persons under the age of eighteen (18). If you are under eighteen (18), do not use or provide any information on the Services or on or through any of its features or register on the Services, make any purchases on or through the Services, use any of the interactive features of the Services or provide any information about yourself to us, including your name, email address, telephone number or residential address or other contact details, or any screen name or username you may use.

If we learn we have collected or received personal information from a person under eighteen (18) years of age, we will delete that information. If you believe we might have any information from or about a person under the age of eighteen (18), please contact us at legal@neutrl.xyz

3. How We Use Your Information

We may use information that we collect about you or that you provide to us, including any personal information:

• To provide the Services and their contents to you;
• To provide you with information, products or services that you request from us;
• To fulfill any other purpose for which you have provided it or which we have disclosed to you through this privacy notice at the time you provide the information;
• To create and maintain your account, process your transactions, including verifying your identity, processing payments, and communicating with you about your account activities.
• To provide customer support, where such features are available;
• To provide features such as cross-posting or cross-service authentication, to the extent we collect information from accounts of other services that you connect to your account;
• To help others find your account, including through third party services and client applications;
• To enable you to engage in transactions;
• To provide you with notices about your account and the Services;
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including the Terms of Use;
• To notify you about changes to our Services;
• To allow you to participate in social and interactive features on our Services;
• To develop and improve the Services;
• For security and anti-fraud purposes;
• For behavioral tracking, profiling and advertising;
• For any other purpose as required for our business;
• For any other purpose with your consent;
• To contact you about our own and third parties' goods and services that we think may be of interest to you; and
• To enable us to display advertisements to our advertisers' target audiences.

4. Information We Collect About You and How We Collect It

We may collect information of various types from and about users of our Services (some of which is regarded as “personal information” under applicable law), including:

• Identifiers such as name, display name, username, date of birth, residential address, password, email address, telephone number or any other information that the Services collect and/or which applicable law may consider personally identifiable, personal information, personal data and other such designations;
• Information about the devices you use to access the Services;
• Information about your cryptocurrency wallet, transaction history, trading data and associated fees paid;
• Information about the transactions you make on or through the Services, such as the type of transaction, transaction amount, transaction signatures and timestamp;
• Your activity on the Services, including your posts and any information contained in them;
• Your interactions with other users’ content, and mentions or tags of you made by other users;
• How you interact with others on the platform, such as people you follow and people who follow you, including the contents of messages, recipients, and date and time of messages;
• We collect information on links you interact with across our services, including in our emails sent to you;
• Information about your social media accounts, including username and profile information;
• Third party single sign-in information (if used to access the Services);
• Your IP address, Identifier for Advertisers (“IDFA”), Android/Google Advertising ID, International Mobile Equipment Identity (“IMEI”) or other unique identifiers;
• Your device characteristics and functionality (including information about your operating system, hardware, mobile network, internet connection and provider, and browser);
• Referring and exit web pages and URLs;
• Your browsing history including the areas within our Services that you visit and your activities there, including remembering you and your preferences;
• Your device location and other data (including the time of day you visit our Services) or other geolocation information.

We collect this information:

• Directly from you when you provide it to us, such as when filling in forms on the Services (including when you register for an account or subscribe to a service) and when you correspond with us or our agents;
• Automatically as you navigate the Services, including through the use of cookies, web beacons, and other tracking technologies and analytics services;
• From third parties, such as our business partners and service providers, and the social media platforms for any social media accounts that you connect to the Services;
• When you engage in transactions on our Services
• When you interact with other users through the Services; and
• When you run searches on the Services.

5. Automatic Data Collection Technologies

As you navigate and interact with our Services, we may use automatic data collection technologies to collect certain information about you, including:

• Details of your visits to our Services, including traffic data, browsing patterns, location data, logs, other communication data and the resources that you access and use on the Services; and
• Information about your device, internet connection and service provider.

You acknowledge, understand and agree that our service providers will be collecting information about you, and may monitor and intercept your communications and actions on our Services as you browse, interact with or use functionality. These service providers may use the information they collect for their own benefit without restriction. You specifically agree to this arrangement, and consent to your communications and information being intercepted by our third party providers.

The information we collect automatically may be statistical data and may also include personal information, or we may maintain it or associate it with personal information we collect or which we receive from third parties. This information enables us to:

• Allow you to use and access the Services;
• Prevent fraudulent activity and improve security functionality;
• Assess and improve the performance of the Services;
• Offer enhanced functionality when accessing the Services, including identifying you when you sign in to our Services and keeping track of your specified preferences;
• Deliver content relevant to your interests on our Services and third party sites based on your interactions with our advertisements and/or content;
• Estimate our audience size and usage patterns and perform market research;
• Speed up your searches; and
• Analyze our services and products.

When you visit or leave our Services by clicking a hyperlink or when you view a third party site that includes our plugins or cookies (or similar technology), we may automatically receive the URL of the site from which you came or the one to which you are directed.

We may also receive location data passed to us from third party services or GPS-enabled devices that you have set up, which we may use for fraud prevention and security purposes. We may also use this information to provide customized services and content to you. You may disable the location features on your device. Please note that if you disable such features, your ability to access certain features, services, content, or products may be limited or disabled.

The technologies we use for automatic data collection include (or may include):

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Note that while you can set your browser to not allow cookies, we may not be able to honor that request, and may track your activity and collect information about you and your online activities even when the browser is set to “Do Not Track” (see below);
• Flash Cookies. Certain features of our Services may use local stored objects (also known as Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Services. Flash cookies are not managed by the same browser settings as are used for browser cookies and you may not be able to shut down our collection of and use of information through Flash cookies;
• Web Beacons, Pixels and Tags. Pages of our Services and our emails may contain small electronic files known as web beacons (also known as clear gifs, pixel tags or single-pixel gifs) that permit us to gather website-related statistics (e.g., to count users who have visited those pages or opened communications, verifying system integrity); Embedded Scripts. An embedded script is programming code that collects information about user interactions with the Services;
• ETag, or entity tag. An entity tag (also known as an Etag) is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. It is a mechanism that HTTP provides for web cache validation. These allow websites to be more efficient and not serve content again;
• Fingerprinting. Fingerprinting refers to the collection and analysis of information from your device for the purpose of identification, such as operating system, plug-ins and system fonts;
• Recognition Technologies. Recognition technologies are features used by websites which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user); and
• Log Files. Log files track actions occurring on the Services, and help us collect your IP address, browser type, internet service provider, the webpages from which you came or to which you go after visiting our Services, and the date and time of your visits.

6. Do Not Track

“Do Not Track” is a concept promoted by certain regulatory authorities and industry groups for development and implementation of a mechanism that would allow internet users to control the tracking of their online activities across websites. Various browsers offer a Do Not Track option that allows a user to set a preference in the browser to not have their online activities tracked. When a user’s browser is set to Do Not Track, some cookies and other tracking technologies may become inactive, depending on how the website visited responds to Do Not Track browser settings. If that occurs, the website visited will not recognize you upon return to that website or save your passwords or usernames, and some other features of that website may become unavailable or not function correctly.

Given the lack of a standard in the industry or any clear regulatory guidance, we do not comply with Do Not Track signals from your browser at this time.

7. Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Services may be served by third parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you access or use the Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and services. They may use this information to provide you with behavioral advertising or other targeted content.

We do not control the technology of these third parties or how they may be used. If you have any queries or concerns about an advertisement or other targeted content, you should contact the responsible provider directly.

8. Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To other users and the general public;
• To our affiliates;
• To contractors, service providers and other third parties we use to support our business and assist us in providing the Services;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Company's assets or shares, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Services users is among the assets transferred;
• To third parties to market their products and services to you;
• To fulfill the purposes for which you have provided it or any other purposes disclosed by us to you through this privacy policy; and
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law or legal process, including responding to any government or regulatory request;
• To enforce or apply the Terms of Use, including this privacy policy, and any other agreements between us; and
• If we believe disclosure is necessary or appropriate to protect the rights, property or safety of the Company, our customers or other persons. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

9. International Data Transfers

We and our affiliates, licensors and third party providers may process your personal information outside of your country of residence. Data privacy laws in countries to which your personal information is transferred may not be equivalent to, or as protective as, data privacy laws in your country of residence. By using the Servies, you acknowledge and consent that your personal information may be transferred to and processed in countries that may have different data protection rules than your country of residence.

For transfers of personal data to countries outside the European Economic Area (EEA), we implement appropriate safeguards and mechanisms to ensure adequate protection of your personal information. These safeguards include entering into Standard Contractual Clauses approved by the European Commission with our service providers and partners.

We maintain appropriate technical and organizational measures to protect your personal information during international transfers, including encryption of data in transit and storage. Where we engage third-party service providers who may access your personal information from other countries, we require them to provide at least the same level of privacy protection as required under applicable data protection laws.

If you are located in the European Union, you have the right to obtain information about the safeguards we use for transferring your personal information outside the EEA. You may contact our Data Protection Officer using the contact information provided in Section 10 to request such information.

10. Data Deletion Requests

You may request the deletion of your personal information by contacting us at legal@neutrl.xyz We will consider each request and may comply with such requests at our discretion.

Please note that we reserve the right to retain personal information as permitted or required by law.

11. Data Security

We have implemented measures intended to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure while you use our Services (but please note that all of your trading information and digital asset creation will also be available on the Neutrl platform, and if you connected your social media accounts to the Services, all your activities will also be seen on that social media page, and we have no control over such features or other technologies or services).

The safety and security of your information also depends on you. Where you have chosen, or we have given you, a password for access to certain parts of our Services, you are responsible for keeping your password confidential and secure. We ask you not to share your password with anyone and to change your password from time to time, using appropriate password security (e.g., not using the same password for multiple sites, using passwords which are not easily guessed).

Access to personal information is strictly limited to authorized employees, agents, and service providers who require such access to perform their assigned duties. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

We conduct regular security assessments and audits of our infrastructure and security practices to ensure compliance with industry standards and applicable data protection laws.

Unfortunately, the transmission of information via the internet is not completely secure. Although we try to protect your personal information, we cannot guarantee the security of your personal information transmitted or collected through the Services. Any transmission of your personal information is at your own risk.

In the event of a security breach that affects your personal information, we will notify you and the relevant authorities within 72 hours of becoming aware of the breach, as required by applicable law. We maintain incident response plans that specify the actions we will take to investigate and remediate security incidents.

We are not responsible for circumvention of any security measures or privacy settings contained on the Services.

12. How to Complain

You may exercise their rights of access, rectification, cancellation, or opposition concerning their personal data, as well as request the revocation of their consent, by sending a request to us via email at legal@neutrl.xyz providing your full name and address or any other data or document that allows their identification, including a legal document proving ownership, as well as the purpose of their request and/or procedure to be carried out. If the person submitting the request is the parent, mother, or guardian of the personal data owner, they must be accompanied by the minor's birth certificate and/or a legal document proving guardianship. The official identifications accepted by us are; valid Passport, Personal Identity Card, Driver's License, valid immigration document issued by the competent authority.

We will endeavor to respond to your inquiries within ten (10) days of receipt.

Nothing in this Privacy Policy shall limit your rights under the Data Protection Law, including your right to file complaints with the National Authority for Transparency and Access to Information (ANTAI) for matters related to personal data protection. However, disputes arising from other contractual matters shall be resolved through arbitration.

13. Contact Information

To raise any questions or comments about this privacy policy, please contact us at:

Email: legal@neutrl.xyz