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Privacy Policy

Effective Date: 2026-07-27

This Privacy Policy (the "Policy") explains how Unicode Digital Ltd. ("Unicode", the "Company", "we", "us" or "our") collects, uses, discloses and protects personal information obtained through our website (the "Website"). We are committed to protecting your privacy and complying with applicable data protection laws.

This Policy should be read together with our Important Notice, Terms of Use, Legal Disclaimer, Investment Risk Disclosure and Cookie Policy.

1. Overview

This Policy applies to personal information collected from or relating to you through the Website. Please note that the Website may contain links to third-party websites. This Policy does not apply to such external websites, and we recommend that you review the privacy policies of any linked websites you visit.

We may update this Policy from time to time. If we make any material changes, we will publish the updated Policy on the Website. The "Effective Date" at the top of this Policy indicates the date on which it was last revised.

2. Information We Collect

We may collect the following categories of information:

  • Personal information you voluntarily provide: When you contact us, request information, subscribe to updates or otherwise interact with the Website, you may provide personal information including your name, email address, postal address, telephone number and, where applicable, information regarding your investor status, such as whether you are an accredited investor or qualified institutional buyer.
  • Technical and usage information: The Website may automatically collect certain information about your visit, including the pages you view, links you click, the date and time of your visit, the website from which you arrived, and technical information about your computer or device, such as browser type, operating system, IP address and device identifiers.
  • Cookies and similar technologies: We use cookies and other tracking technologies to improve the content, usability and functionality of the Website. Cookies help us tailor the Website according to user preferences, understand the frequency of new and repeat visits, identify popular features or pages, and analyse browsing patterns. For further information regarding these technologies, their specific purposes and your choices, please refer to our Cookie Policy.

3. How We Use Your Information

We may use the information we collect for the following purposes:

  • to respond to your enquiries, provide information regarding our services and communicate with you;
  • to operate, maintain and improve the Website, including analysing usage trends and user preferences and improving Website content and user experience;
  • to record your cookie and privacy choices;
  • to maintain the security of the Website, our systems and communications;
  • to verify your eligibility to access certain parts of the Website, including for compliance with applicable laws, regulations and regulatory requirements;
  • to send you administrative information, such as updates to this Policy or other legal notices;
  • to protect the security and integrity of the Website, detect and prevent fraud, misuse or unauthorised activity, and comply with applicable laws, regulations or legal processes; and
  • for any other purpose with your consent or as otherwise permitted by law.

4. Cookies and Your Choices

The Website may use necessary cookies to support Website security, language selection, session management and the recording of cookie preferences.

You may configure your web browser to notify you before accepting cookies, automatically accept cookies or reject all cookies. Please note that rejecting cookies may restrict your ability to access certain parts of the Website or use all of its features and services.

Other than strictly necessary cookies, we will determine whether to set or enable additional cookies in accordance with applicable law and your choices. For detailed information regarding cookie categories, providers, purposes, duration and management options, please refer to our Cookie Policy.

5. Legal Bases for Processing Personal Information

Depending on the circumstances and applicable law, we may process personal information on one or more of the following bases:

  • you have provided consent to a particular processing activity;
  • processing is necessary to respond to your request, take steps before establishing a business relationship or perform a relevant arrangement;
  • processing is necessary for compliance with legal or regulatory obligations applicable to the Company;
  • processing is necessary to protect the legitimate interests of the Company, users or other persons, including operating the Website, responding to enquiries, maintaining security, preventing fraud and managing legal risk, provided that such interests do not improperly prejudice your rights; or
  • another lawful basis permitted under applicable law.

Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of any processing carried out before the withdrawal.

6. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients to the extent necessary to fulfil the purposes described in this Policy:

  • the Company's affiliates and related business entities;
  • website hosting, cloud storage, email, form management, IT support, cybersecurity, analytics and other technology service providers;
  • legal advisers, auditors, accountants, compliance consultants and other professional advisers;
  • banks, custodians, fund administrators or other service providers, but only where you proceed to a further business engagement or verification process;
  • law enforcement, judicial, regulatory, tax and other governmental or competent authorities;
  • parties involved in a potential or actual business, asset or corporate transaction, and their advisers; and
  • other persons authorised by you or permitted under applicable law.

The Company does not sell your personal information.

Where applicable, we will require service providers processing personal information on our behalf to implement appropriate confidentiality, data protection and security measures and to process such information only for the agreed purposes.

7. Data Security

We implement reasonable administrative, technical and physical safeguards designed to protect the personal information we collect against loss, misuse, unauthorised access, use, disclosure, alteration or destruction.

However, no method of transmission over the internet or method of electronic storage is completely secure. The Company cannot guarantee that any transmission, Website, system or storage environment will be entirely free from security risks.

8. Retention of Personal Information

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected and to satisfy applicable legal, regulatory, accounting, security, dispute-resolution or reporting requirements.

When we no longer have a lawful or business need to retain personal information, we will delete, anonymise or otherwise appropriately dispose of it.

9. Your Rights

Depending on the jurisdiction in which you are located, you may have certain rights regarding your personal information, including:

  • the right to access, correct or update your personal information;
  • the right to request deletion of your personal information, subject to legal restrictions;
  • the right to object to or restrict certain processing activities; and
  • the right to withdraw consent where processing is based on consent.

These rights are not absolute and may be subject to identity verification, legal exceptions, regulatory requirements, third-party rights and record-retention obligations.

To exercise any of these rights, please contact us using the details provided in the "Contact Us" section below. We will respond to your request in accordance with applicable law.

10. Children's Privacy

The Website is not intended for persons under the age of 18. We do not knowingly collect personal information from persons under the age of 18.

If we become aware that we have inadvertently received personal information from a person under the age of 18, we will delete such information.

11. International Transfers

If you access the Website from outside the British Virgin Islands, please be aware that your information may be transferred to, stored in and processed in the British Virgin Islands or other jurisdictions in which we or our service providers operate.

When transferring personal information internationally, we will take appropriate measures in accordance with applicable law, which may include assessing the level of data protection in the receiving jurisdiction, implementing contractual or other appropriate safeguards or, where applicable, relying on contractual necessity, legal obligations, your valid consent or other exceptions permitted by law.

By using the Website, you consent to such transfer, storage and processing.

12. Changes to This Privacy Policy

We reserve the right to amend this Policy at any time.

Any changes will take effect immediately upon publication of the revised Policy on the Website. Your continued use of the Website following publication of any changes constitutes your acceptance of those changes.

We recommend that you review this Policy periodically.

13. Contact Us

If you have any questions or concerns regarding this Privacy Policy or our data practices, please contact us at:

Email: info@unicodedigital.com

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