Privacy Policy

YUZU FINTECH LLC

Brand "Yuzu Money"

Privacy Policy – Protecting Your Data

Our Principles

• The protection of your privacy is very important to us.

• We treat your data responsibly and only for specified purposes.

• We are aware of the sensitivity of the data you have entrusted to us.

• We do not process any personal data without a legal basis.

• We will never pass on your data to third parties without your explicit consent.

• We use several well-established measures (such as encryption) to prevent any misuse of your data.

• We follow the principle of data minimization.

General

YUZU FINTECH LLC (hereinafter: 'YUZU') is a legal entity incorporated pursuant to the Company Law of Georgia by the National Agency of Public Registry of Georgia.

YUZU is aware that the personal data you have entrusted to us is sensitive. We ensure that the personal data that customers and prospective customers provide when using our services is always treated confidentially.

Personal data is any information that personally identifies you (or can be directly linked to you) such as your name, telephone number, address, and other information required for the provision of our services. This does not include information which cannot be directly linked to your person.

We protect the personal data of customers and prospective customers through the use of high security standards as well as standard operating procedures, which have been created specifically to prevent any misuse of this information.

Customer Information about data processing in accordance with the Law of Georgia on Personal Data Protection and the EU General Data Protection Regulation (GDPR).

The protection of personal data is important to us at YUZU and we aim to comply with the data protection regulations in order to achieve sufficient protection and security of the customer data. With this document we wish to inform you about the processing of your personal data by YUZU and the rights regarding data protection, to which you are entitled.

YUZU FINTECH LLC processes personal data in accordance with the Law of Georgia on Personal Data Protection. Where applicable, YUZU also observes the standards and principles of the EU General Data Protection Regulation (GDPR). In case of conflict, the Law of Georgia shall prevail.

1. Who is responsible for data processing and who can you contact?

Responsible for the data processing is:

YUZU FINTECH LLC – YUZU MONEY

Address: Avtomshenebeli St. N88, Kutaisi, Plot N01/298, Georgia (Free Industrial Zone) Email address: [e-mail]

Our corporate data protection officer can be reached at:

Data protection officer: Tsotne Shengelia

Address: Avtomshenebeli St. N88, Kutaisi, Plot N01/298 Georgia (Free Industrial Zone) Email address: [e-mail]

2. Which data is processed by us and what are the sources for this data?

a) We process personal data that we receive from you in the context of the customer relationship. The customer relationship begins with the use of our services and includes the permanent termination of such use. We also process data that we obtained permissibly from publicly available sources (e.g. commercial register).

b) Personal data from you that we process includes for example:

first and last name, address, date and place of birth, nationality, occupational information, phone numbers, email address, bank account information, information on personal income, information on personal wealth, marital status, tax number, data from identification documents, login data, customer number, etc.

c) YUZU’s services are not intended for individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that a minor’s data has been collected without parental consent, we will delete such data promptly.

d) Security measures include encryption in transit (TLS 1.2+), hashed password storage, restricted access control, and continuous monitoring of infrastructure for vulnerabilities.

e) Certain blockchain transactions are public by design and stored permanently on decentralized networks. While YUZU does not control such public ledgers, we treat associated identifiers (wallet addresses, transaction hashes) as pseudonymous data and protect them accordingly.

3. For what purposes and on what legal basis do we process the data?

a) To fulfill contractual obligations: We process personal data in order to provide our services under the platform contract and other relevant required activities. Pre-contractual information that you provide as part of the registration process is also included.

b) To meet legal obligations: We may process personal data for the purpose of fulfilling various legal obligations, e.g. due to taxation law etc.

c) Within the framework of your consent: In case you give us consent for the processing of your personal data for specific purposes, we process data in accordance with the purposes and to the extent defined in the declaration of consent. You have the possibility to revoke your consent at any time with effect for the future.

d) To protect legitimate interests: It is possible as result of a balancing of interests that in favor of YUZU or third parties or a third party process data beyond the actual fulfilment of the contract to protect legitimate interests of YUZU or third parties. Such processing is: i) Testing and optimization of requirements analysis and direct customer approach; ii) Measures to manage the business, to improve services and to recover customers; iii) Advertising or market and opinion research, unless you have not objected to this kind of usage of your personal data according to applicable law.

4. Who receives my personal data?

a) Within YUZU those departments and employees process your personal data, which need the data to fulfill the contractual obligations, legal obligations or legitimate interests.

b) In addition, data processors (e.g. external IT service providers) and distribution partners contracted by us process your personal data if they need the data to perform their respective services. All data processors and distribution partners have a contractual obligation to treat your data as confidential and to process the data only within the framework of the provision of their services to us. A list or overview of current data processors and sub-processors, such as cloud storage providers, payment processors, marketing analytics, and IT maintenance services, engaged by YUZU is available upon request by contacting the Data Protection Officer.

c) Based on the fulfillment of legal obligations YUZU may be obliged under certain circumstances to forward data to public bodies and institutions.

d) Other persons may receive your data if you have given your consent for the transmission of data to such persons.

5. Does YUZU transmit my data to a third country or an international organization?

a) In principle, your personal data will not be transmitted to a third country or international organization. In any case such transmission only occurs as part of a data processing agreement, an express consent by you or based on a legal obligation and taking into account legal restrictions.

b) Where personal data is transferred to a country that does not ensure an adequate level of protection, YUZU will implement appropriate safeguards such as Standard Contractual Clauses or equivalent measures.

6. How long will my data be stored?

a) YUZU stores your personal data no longer than absolutely necessary. In order to fulfill the contract, we store the data for the duration of the entire customer relationship. Based on legal retention and documentation requirements, YUZU can store data beyond the customer relationship. Unless a longer retention period is required by law, YUZU will retain customer identification and transactional data for at least 6 years after the end of the business relationship, in accordance with anti-money laundering and tax laws.

7. Which privacy rights do I have?

a) Right of information: Your right of information includes that you can request from YUZU a confirmation whether we process personal data of you. Is this the case, you have the right to get information about this data and further information about how we process the data.

b) Right to rectification: If your information is not correct (anymore), you have the right to claim for rectification of incorrect personal data by us.

c) Right to erasure: You have the right to call for an immediate erasure of your data by us if any of the following applies: i. The keeping of the personal data is no longer necessary for the purposes for which it was collected or otherwise processed. ii. You have revoked your consent and there is no other legal basis for processing. iii. Your personal data has been processed without good reason. iv. Your personal data must be deleted to meet legal requirements.

d) Right to restrict processing: The right to restrict processing includes that you can require limited data processing if any of the following applies: i. The accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data. ii. The processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead. iii. YUZU no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims; iv. You have objected to the processing and the verification whether the legitimate grounds of the controller override those of the data subject is still pending.

e) Right to object: If data processing takes place on the basis of a legitimate interest or of the public interest, you have the right to object to this data processing. Detailed information on your right of objection can be found at the end of this section.

f) Right to data portability: You have the right to receive your personal data provided to us in a portable format and ask us to transmit such data to another controller without hindrance from YUZU.

g) Right to complain: In case you believe that we process your data against national or European data protection law, we kindly ask you to contact us, to find a solution together. In addition, there is a right to complain at the respective data protection supervisory authority. You may also file a complaint with the State Inspector’s Service of Georgia (Personal Data Protection Service), the competent supervisory authority for data protection matters in Georgia.

h) Revocation of consent for data processing: A consent to the processing of personal data can be revoked at any time without any form requirements. This also applies with regard to the withdrawal of declarations of consent issued to us prior to the application of applicable law. We would like to point out that any revocation only applies for the future.

8. How are Cookies used in your website?

a) YUZU may use “cookies” and other technologies or methods of web analysis to gather, store, and track certain information related with your access to and activities through the Platform, including when you are simply visiting YUZU. The term "cookie", as used herein, shall be deemed to be a small piece of information that YUZU assigns to your device while you are viewing or otherwise accessing YUZU. Cookies are beneficial and may be used for various purposes, including allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering preferences and making the interaction between you and the Platform quicker, easier and smoother.

b) YUZU may use the following types of cookies: i. Strictly Necessary Cookies: These cookies are essential to enable you to log in, navigate in and use YUZU, its features or to provide a service requested by you. YUZU shall not need to obtain your consent in order to use these cookies. ii. Functionality Cookies: These cookies allow YUZU to remember choices you make (such as on username, language, or applicable region customisations) and provide enhanced, more personal features. The information these cookies collect remains anonymous, and they cannot track your browsing activity on other websites. iii. Performance cookies: These cookies collect information about how you use YUZU, for example, which pages you go to most often, record difficulties that you may experience while using YUZU such as error messages. All information collected by these cookies is aggregated and therefore anonymous. It is only used to improve the efficiency of YUZU. iv. Targeting Cookies or Advertising Cookies: These cookies are used to deliver advertisements tailored to you and your interests specifically. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. These cookies remember that you may have visited a third-party linked website, and this information may be shared with other organizations such as advertisers. It may be the case that targeting or advertising cookies shall be linked to the sites functionality provided by the other organizations. While YUZU strives to do not use or limit the use of this type of cookie, it does not fully guarantee complete exclusion of their use.

You may remove these cookies by following the instructions of your own device preferences. However, if you choose to disable cookies, some features of YUZU may not operate properly, and your online experience may be limited.

9. Am I required to provide personal data?

a) In the context of the customer relationship, you must provide the personal data necessary for the initiation and fulfillment of the costumer relationship. Also you must provide us with personal data necessary for the fulfillment of legal obligations.

b) Should you disagree with the provision of these required personal data, we are not in a position to conclude or execute a contract with you.

10. Does YUZU use automated decision making (including profiling)?

a) YUZU does not use automated decision making in the sense of applicable law as part of the business relationship. YUZU processes your data partially automated to evaluate certain personal aspects (profiling) and to be able to provide the best possible service to you. In order to inform you about products in a targeted manner, we use evaluation tools that enable us to communicate and advertise on demand.

11. Information about our website

a) Links to external webpages are provided on our website for informational purposes only. If it is not obviously recognizable, we will explicitly point out when such links are to external websites. YUZU is not responsible for the contents and the design of third-party websites and cannot attest to their correctness, factuality or legality. Our privacy policy does not apply for those websites.

b) Except for strictly necessary cookies, YUZU will not place any analytics or marketing cookies without your explicit consent through the website cookie banner. You may modify or withdraw your consent at any time.

Effective Date: 18-Oct-2025 We may amend this Privacy Policy from time to time. Any updated version will be published on our website and marked with a revised “Effective Date.” Material changes will be communicated in advance, where required by law.