Privacy Policy

1. Introduction

DE Asset Management ("DE Asset Management," "we," "us," or "our") is committed to protecting the privacy of individuals who interact with us through our website, services, and products related to DEMGTTOKEN. This Privacy Policy describes how we collect, use, disclose, retain, and protect your personal information, and your rights with respect to that information.

This Privacy Policy applies to:

• Visitors to our website at demgttoken.com and any related domains;
• Individuals who participate in the DEMGT pre-sale or otherwise purchase, hold, or transact in DEMGT;
• Individuals who contact us through forms, email, or community channels;
• Individuals who subscribe to our communications;
• Other persons whose personal information we collect or process in connection with our activities.

This Privacy Policy is incorporated by reference into our Terms of Use. By using our services, you acknowledge that you have read and understood this Privacy Policy.

2. Information We Collect

We collect personal information in several ways, depending on how you interact with us.

2.1 Information You Provide Directly

You may provide us with personal information when you:

• Create an account or participate in the pre-sale (full legal name, date of birth, nationality, residential address, phone number, email address, government-issued identification, photographs for identity verification, source of funds documentation);
• Complete KYC (Know Your Customer) and AML (Anti-Money Laundering) verification (additional identity documents, biometric data, occupation, source of wealth, politically exposed person status, sanctions screening results);
• Conduct transactions (wallet addresses, transaction amounts, transaction counterparties where known, payment information);
• Contact us through email, contact forms, or community channels (name, email address, the content of your communications);
• Subscribe to newsletters or updates (email address, preferences);
• Participate in surveys, contests, or promotional activities (information specific to the activity).

2.2 Information Collected Automatically

When you visit our website or use our services, we may automatically collect:

• Device information (IP address, browser type and version, operating system, device identifiers, screen resolution, language preference);
• Usage information (pages viewed, time spent on pages, links clicked, referring URLs, search terms, navigation paths);
• Location information (approximate geographic location derived from IP address);
• Cookie and tracking technology data (see Section 8 below);
• Log data (server logs, error logs, security logs).

2.3 Information from Third Parties

We may receive personal information about you from third parties, including:

• Identity verification and KYC service providers;
• Sanctions and watch-list screening providers;
• Blockchain analytics providers (which may provide information linking wallet addresses to identities);
• Marketing and analytics partners;
• Business partners, affiliates, and referral sources;
• Publicly available sources (social media, public registries, news sources);
• Law enforcement, regulators, and other authorities.

3. How We Use Your Information

We use personal information for the following purposes:

• Providing our services, processing transactions, and maintaining your account;
• Complying with legal and regulatory obligations, including KYC, AML, CTF, sanctions screening, tax reporting, and FINTRAC reporting;
• Verifying your identity, eligibility, and jurisdiction;
• Detecting, investigating, and preventing fraud, money laundering, terrorist financing, sanctions evasion, market manipulation, and other illegal or unauthorized activities;
• Communicating with you about your account, transactions, service updates, security issues, and other operational matters;
• Sending marketing communications about our products, services, and ecosystem developments (where you have consented or where permitted by law);
• Improving our website, services, and user experience;
• Conducting analytics, research, and business development;
• Enforcing our Terms of Use and other agreements;
• Protecting our rights, property, safety, and the rights of others;
• Any other purpose disclosed at the time of collection or with your consent.

4. Legal Bases for Processing

We rely on the following legal bases for processing your personal information:

• Consent: where you have consented to specific processing (e.g., marketing communications, optional analytics);
• Contractual necessity: where processing is necessary to provide the services you have requested;
• Legal obligation: where processing is required to comply with applicable law (e.g., AML/CTF compliance, tax reporting);
• Legitimate interests: where processing is necessary for our legitimate business interests (e.g., fraud prevention, security, business operations), provided your interests and rights do not override these;
• Vital interests or public interest: in limited circumstances where required.

You may withdraw consent at any time where processing is based on consent, although withdrawing consent will not affect the lawfulness of processing carried out before withdrawal. Withdrawal of consent may also affect our ability to provide certain services to you.

5. Disclosure of Personal Information

We may disclose your personal information to the following categories of recipients:

5.1 Service Providers

We share information with third-party service providers that perform functions on our behalf, including: identity verification, sanctions screening, blockchain analytics, cloud hosting, customer support, email and communications, payment processing, fraud prevention, security, analytics, marketing, and legal and professional services. Service providers are contractually obligated to protect your information and use it only for authorized purposes.

5.2 Regulators and Law Enforcement

We disclose information to regulators, law enforcement agencies, tax authorities, and other government bodies as required by law, including pursuant to FINTRAC reporting obligations, court orders, subpoenas, sanctions enforcement, and other legal processes. We may also disclose information to defend ourselves in legal proceedings or to investigate suspected illegal activity.

5.3 Business Transactions

In connection with a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or other business transaction, personal information may be transferred to or accessed by parties involved in the transaction, subject to appropriate confidentiality protections.

5.4 Affiliates and Partners

We may share information with our affiliates and certain business partners for purposes consistent with this Privacy Policy.

5.5 With Your Consent

We may share information with other parties where you have provided consent.

5.6 Blockchain Transparency

By design, blockchain networks (including the Ethereum network on which DEMGT operates) are public and transparent. Transaction details, including wallet addresses and amounts, are visible to anyone with access to the blockchain. While wallet addresses alone do not directly identify you, sophisticated analysis may link addresses to identities. We cannot delete or modify blockchain records.

6. International Data Transfers

We are based in Canada. Personal information we collect may be processed, stored, or accessed in Canada and in other countries where we, our affiliates, or our service providers operate, including the United States and other jurisdictions that may have different data protection laws than your country of residence.

Where we transfer personal information internationally, we take reasonable steps to ensure adequate protection through contractual safeguards, recognized transfer mechanisms, or other measures consistent with applicable law.

7. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements. Retention periods vary based on the type of information and the purpose for which it is collected.

In particular, FINTRAC regulations require that we retain KYC and transaction records for a minimum of five years from specified trigger events. Other records may be retained for longer or shorter periods as required by applicable law or our legitimate business needs. When personal information is no longer needed, we will securely delete or anonymize it.

8. Cookies and Tracking Technologies

We use cookies, web beacons, pixels, local storage, and similar technologies to operate the website, remember your preferences, analyze usage, and (where applicable) deliver targeted advertising.

Categories of cookies we may use:

• Strictly necessary cookies: required for the website to function (e.g., authentication, security);
• Performance and analytics cookies: help us understand how visitors use the website;
• Functional cookies: remember your preferences;
• Marketing and advertising cookies: enable targeted advertising and measurement (only with consent where required).

You can manage cookies through your browser settings or, where available, through our cookie consent banner. Disabling certain cookies may affect website functionality.

9. Your Rights and Choices

Subject to applicable law, you may have the following rights with respect to your personal information:

• Access: request a copy of the personal information we hold about you;
• Correction: request correction of inaccurate or incomplete information;
• Deletion: request deletion of personal information (subject to legal retention obligations and other exceptions);
• Restriction: request restriction of certain processing activities;
• Portability: request transfer of certain information to another organization;
• Withdrawal of consent: withdraw consent where processing is based on consent;
• Objection: object to certain processing activities (including marketing);
• Complaint: lodge a complaint with a privacy regulator (in Canada, the Office of the Privacy Commissioner of Canada or your provincial privacy regulator).

To exercise these rights, contact us using the information in Section 14. We will respond within the time limits required by applicable law. We may require verification of your identity before processing requests.

Important limitations: certain rights may be limited by our legal obligations, including AML/CTF record-keeping requirements. We may be unable to delete information that we are legally required to retain.

10. Security

We implement reasonable physical, technical, and organizational safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, or destruction. Safeguards may include encryption in transit and at rest, access controls, employee training, vendor due diligence, and incident response procedures.

However, no security system is impenetrable, and we cannot guarantee the security of your information. You are responsible for safeguarding your account credentials, private keys, and access devices, and for notifying us promptly of any suspected unauthorized access.

11. Children's Privacy

Our services are not directed to individuals under the age of 18 (or the age of majority in your jurisdiction, if higher). We do not knowingly collect personal information from children. If we become aware that we have collected information from a child, we will take steps to delete it. If you believe we may have collected information from a child, please contact us.

12. Marketing Communications

With your consent (or where permitted by law), we may send you marketing communications about our products, services, and ecosystem developments. You may opt out at any time by following the unsubscribe instructions in our emails or by contacting us directly. Even if you opt out of marketing communications, we may continue to send you operational and transactional communications.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated Privacy Policy on our website and updating the "Last Updated" date. For significant changes, we may provide additional notice (such as email). Your continued use of our services after changes take effect constitutes acceptance of the updated Privacy Policy.

14. Contact and Privacy Officer

For questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact:

If you are not satisfied with our response to a privacy concern, you may contact the Office of the Privacy Commissioner of Canada atwww.priv.gc.ca, or your provincial privacy regulator.