squarefi.app TERMS AND CONDITIONS
Updated on June 25, 2024
SquareFi Inc. (hereinafter referred to as the "Platform"), offers informational technology services for the users.
An individual who has agreed to the terms of this Agreement posted on the website at squarefi.app, registered on the website squarefi.app. (hereinafter referred to as the "User"), on the other hand, collectively referred to as the "Parties," have entered into an agreement on the terms of this Agreement.
Subject of the Agreement
1.1. This agreement is concluded by registering on the website squarefi.app. (Platform) between you (User) and the company (Platform) to provide access to the Services of the Seller (hereinafter referred to as the "Services").
1.2. You must comply with the conditions for accessing the account set by the Platform. By accessing this website, you signify your acknowledgment and acceptance of these terms and conditions. If you do not accept these terms, please stop using the Platform and refrain from purchasing the Services.
1.3. The Platform provides platform support for non-US citizens, as well as Users subject to the SEC regulator, and is not an investment vehicle. This means that the Platform is not itself an investment opportunity or a financial product that individuals can invest in. It serves as a technology platform or service provider that assists users in their investment activities.
Territory of Validity and Applicable Law
2.1. The Platform shall be governed by the applicable law of Wyoming, and disputes shall be settled in Wyoming. The use of a number of Services presented on the Platform requires the status of both a qualified investor and another specific type of investor. Please read the Seller's public offer inside the Offering Overview, which contains the essential terms of the transaction, the rights and obligations of the parties involved, information about the Target, and other parameters of the investment before making a transaction.
Functionality of the Platform
3.1. For Investors:
3.1.1. By utilizing the Platform, you gain access to Services provided on the Platform, which includes units associated with the Target that you can acquire based on the terms of issuance outlined in the Target description and legally significant conditions (Legal statement). However, it is important to note that the process of acquiring rights to the unit is determined by the supplier of the Issuer, as indicated in each Legal statement provided in the description.
3.1.2. The Platform facilitates the purchase of Services through transactions conducted within the Platform. It is important to note that the Platform itself is not a provider of virtual asset services, and the payment is made using external wallets owned by the User, the investor. The Unit Subscription Agreement is concluded by joining the user to the conditions of the Seller's Legal statement and making a transaction on the Platform. The Platform logs transactions and reflects the user's actions to purchase Services in the personal account.
3.1.3. A number of transactions on the Platform are carried out through payment gateways, each of which is an external independent system. The Platform is not responsible for the actions of the payment gateway related to the conversion, tariffs, terms, and procedure for crediting payments. The Platform in all cases provides the Parties, upon request sent by e-mail, with all known and accessible data of external systems and services and its representatives, and also provides free information support for obtaining data. The Platform does not arbitrate and is not responsible to the Parties for the fulfillment of obligations by external systems.
3.2. For Developers:
3.2.1. A developer shall purchase services on the Platform to list the objects of development. These services may include, but are not limited to, technical support, marketing assistance, or additional resources provided by the Platform. By utilizing the Platform, developers gain access to Services provided on the Platform, which includes the opportunity to offer their own developments for purchase. The terms and conditions for offering the developments are outlined in the Target description and legally significant conditions (Legal statement). The process of acquiring rights to the development is determined by the Seller as indicated in each Legal statement provided in the description.
3.2.2. The Platform facilitates the purchase of Services offered by developers through transactions conducted within the Platform. The terms and conditions for purchasing services as the Developer are outlined in the Listing Agreement, which specifies the scope, duration, and pricing of the services offered. By initiating a purchase transaction on the Platform, you agree to be bound by the terms and conditions of the Listing Agreement.
3.3. For Agencies:
3.3.1. Agencies shall procure services on the Platform with the primary intention of fulfilling the specific needs and objectives of their esteemed clientele.
3.3.2. The terms and conditions for purchasing services as an agency are outlined in the Agent Referral Agreement, which specifies the scope, duration, and pricing of the services offered. By initiating a purchase transaction on the Platform, you agree to be bound by the terms and conditions of the Referral Agreement.
Disclaimer
4.1. Information about the Services posted on the Platform is for reference only and cannot be considered by the client as a guarantee of profitability. In cases where the Legal statement contains examples of investment results and statistical data for a specific period of time, they also cannot be considered by the client as a guarantee of profitability. The User independently makes decisions on the purchase of Services and is fully responsible for the result of the decisions made.
Intellectual Property
5.1. The content of the Platform, including but not limited to text, graphics, images, links, and sounds, is the property of the Platform and is protected by copyright. The Platform retains all copyrights, trademarks, patents, intellectual property rights, and other proprietary rights in the information contained on this website. Any unauthorized use or reproduction of the information, materials, and proprietary rights contained on the Platform website is strictly prohibited. The information and materials on this website, as well as the terms and descriptions that appear, are subject to change without any further notice.
5.2. Any information, data, or materials posted on the Platform are considered the property of the Platform. Except as agreed in the terms of the Platform's customer relationship or otherwise specifically agreed or required by law, the Platform may use it for any purpose it deems appropriate, including but not limited to copying, transmitting, distributing, and publishing.
License Fees
6.1. Investors, developers, and agencies shall bear the responsibility of remunerating the Seller for the usage of the service. The precise terms and conditions governing the fee charging process shall be subject to mutual agreement during the stage of concluding the agreement.
AML Verification, KYC, and Limitation of Liability
7.1. You acknowledge and agree that the Platform has the right to verify and examine carefully the information you provide. If the Platform finds that the information is defective, incorrect, or inaccurate, at any time the Platform, in its sole discretion, has the right to take any action it deems appropriate.
7.2. You acknowledge and agree that you use the services offered through this website at your own risk and that the Platform shall not be liable for any claims, demands, liabilities, costs, losses, judgments, expenses, and damages of any kind (including reasonable attorneys' fees and expenses) ("Damages") arising from the use of the services offered on this website. We make no warranties or representations regarding the accuracy, adequacy, or completeness of the information. The information on the Platform is for general information purposes only and should not be used as a basis for making decisions.
7.3. The Platform is not and will not be liable for any loss or damage arising directly or indirectly (including special, incidental, or consequential loss or damage) as a result of the use of this website, regardless of how they arise and including any damages, damages, or expenses arising from, but not limited to, any defect, error, imperfection, malfunction, error, or inaccuracy in this website, its content or related services, or due to any unavailability of the website or any part of it or any content or related services.
SLA Terms of Use of the Platform
8.1. The Platform has the right to temporarily suspend the operation of the Service and the Referral Link for technical, technological reasons while eliminating such reasons, as well as to carry out any actions (control measures) to verify the content and quality of the Referral Links posted by the Provider and their compliance with the requirements of the Agreement. The data obtained as a result of the implementation of control measures are sufficient, but not the only basis for making a decision. At the same time, the Platform independently determines the methods, frequency, and grounds for conducting control measures.
8.2. Based on the results of the control measures, the Platform independently decides on the imposition of a ban (restrictions) or deletion of the User's account. The Platform decides to impose restrictions or delete the account, including due to complaints received related to the activities of the Supplier, inconsistency of information about the product with the Supplier's product, and/or violation of intellectual property rights of any kind.
8.3. The Platform is under no obligation to provide the service on the website or any part of it at any time or at any specific hours and may withdraw, suspend or limit the service at its sole discretion, providing sufficient time for the Users to provide the data of the product supplier to resolve issues themselves.
8.4. The Platform shall not be liable for any Losses paid, incurred, or charged to you. In the event of wrongdoing on your part, you will indemnify the Platform and hold harmless the Platform from any Losses paid, incurred, or sustained by it, arising directly or indirectly from or in connection with (I) your performance or failure to perform your obligations in accordance with all applicable agreements; (ii) any defective, erroneous, incorrect, or inaccurate information provided on this website; (iii) acting on any information provided by you or on your behalf; or (iv) exercising the rights or fulfilling the obligations of the Platform in accordance with the provisions governing all applicable agreements governing the services.
8.5. Technical support is provided by replying to messages sent to the https://t.me/SquareFi telegram channel within 48 hours.
8.6. This Agreement may be changed without any special notice to the User, the new version of the Agreement comes into force from the moment it is posted on the website at squarefi.app.
Consent to the Processing of Personal Data
9.1. Privacy Policy
9.1.1. SquareFi Inc. is committed to providing the highest level of privacy and security regarding the collection and use of our customers’ personal information. This policy describes how we may collect, use, and disclose your personal information.
9.1.2. Personal information comprises all the details we hold or collect directly or indirectly (including via cookies or other similar tools) about you, your transactions, financial information, interactions, or dealings with us, including information received from third parties and information collected through the use of our websites and mobile solutions.
9.1.3. If you have any questions regarding this privacy policy or the security of your personal information, please contact us on squarefi.app.
9.1.4. For more information about our use of cookies please refer to our Cookie Policy. Please take the time to read this Privacy Policy carefully. By opening an account with us you consent to our use of your personal data in accordance with the Terms and Conditions and the Privacy Policy.
9.1.5. By implementing and operating this Privacy Policy, we will make your online experience a more secure and enjoyable one.
9.1.6. Use of squarefi.app (“our website”) is subject to our Terms of Use and any Services and services supplied are subject to our Terms and Conditions. By visiting our website you are accepting and consenting to the practices described in this Privacy Policy.
9.2. Why Have a Privacy Policy?
9.2.1. There are a number of laws that set out important standards regarding information that identifies a living individual. This is known as “personal data.” All organizations processing personal data must do so fairly and lawfully.
9.2.2. We treat our obligations seriously and take all steps necessary to comply when we store and process your personal data.
9.2.3. It is essential for us to collect, store, and process only the minimum required amount of personal data so that we can offer and perform our services. Typical information we might ask for includes your name, your address, other contact details, and Anti-Money Laundering / Know Your Customer (AML/KYC) related information. In addition, our servers automatically receive and record information on all visitors to our website. Please see our Cookie Notice for more information on the cookies on our website.
9.2.4. We will record your personal data (aside from the automatic information detailed above) once you have fully registered with us.
9.3. How Do We Collect Your Personal Data?
9.3.1. We collect your personal data in a number of different ways, including the following:
- If you provide it when communicating with us (for example when registering for our services);
- If you invest in any of our Services or services;
- If you enter a competition or promotion;
- If you make payments or modify your account details;
- When you visit our website (for example by cookies, technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other browser-generated information such as information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); Services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number).
9.4. How Do We Use Your Personal Data?
9.4.1. We retain and use your personal data for the following main purposes:
- Assessing customer suitability for Services and services;
- Anti-money laundering (AML), Know Your Customers (KYC) assessments, and setting investor risk profiles;
- Conducting market research and surveys with the aim of improving our Services and services;
- For the prevention, detection, investigation, and prosecution of crime (including without limitation, money laundering, terrorism, fraud, and other financial crime) in any jurisdiction, identity verification, government sanctions screening, and due diligence checks;
- To comply with local or foreign law, regulations, voluntary codes, directives, judgments or court orders, regulator or enforcement agency policies, reporting requirements under financial transaction legislation, and demands or requests of any authority, regulator, enforcement agency, or exchange body;
- To seek professional advice, including in connection with any legal proceedings (including any prospective legal proceedings), for obtaining legal advice or establishing, exercising, or defending legal rights;
- If we are required to do so by law, or if it is necessary for the proper operation of our systems, our protection or the protection of our users and customers, or for the enforcement of our Terms and Conditions;
- Processing applications made by you, running your accounts, providing our services, contacting you;
- Servicing our relationship with you, for example, administration and accounting, billing and auditing, and other legal purposes;
- Security, payment verification, preventing and detecting money laundering, fraud, and other crime, recovering debt;
- Generating statistics on our users, such as the popularity of certain of our services, and about the “traffic” on our website. When we do this, data is anonymized and you are not personally identifiable;
- To provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you;
- To notify you about changes to our service;
- To ensure that content from our website is presented in the most effective manner for you and for your computer;
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To allow you to participate in interactive features of our service, when you choose to do so;
- To assist us with keeping our website safe and secure;
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- To make suggestions and recommendations to you and other users of our website about goods or services that may interest you or them;
- Except where you have opted out, we may also use your personal data to keep you informed about relevant Services and services.
9.5. How Do We Safeguard Your Personal Data?
9.5.1. The security of your personal information is important to us and we have invested significant resources to protect the safekeeping and confidentiality of your personal information. When using external service providers, we require that they adhere to the same standards as us. Personal information may be transferred or stored at a location outside of your country of residence. Regardless of where personal information is transferred or stored, we take all steps reasonably necessary to ensure that personal information is kept secure.
9.5.2. The Internet is not a secure form of communication and sending and receiving information over the Internet carries risks including the risk of access and interference by unauthorized third parties. Information passing over the Internet may be transmitted internationally (even when the sender and recipient are located in the same country) via countries with weaker privacy and data protection laws than your country of residence. We do not accept responsibility or liability for the confidentiality, security, or integrity of your personal information in connection with its transmission over the Internet.
9.5.3. However, we take all reasonable care in the collection, storage, processing, and disclosure of your personal data and have implemented internal security procedures to minimize the risk that unauthorized parties will be able to access the information. It is because of these security procedures that we may ask for proof of identity before we disclose any personal information about you. To help protect your personal data and minimize the risk of it being intercepted by unauthorized third parties, our secure servers use industry-standard Secure Socket Layer (SSL) and Transport Layer Security (TLS) technology when you submit information to us through our website. This security is documented by the usage of the secure “https” protocol and the padlock on the URL bar.
9.5.4. You can also help to protect your personal data by following the guidelines below:
- Choose a password that you will be able to remember but that would be hard for someone to guess. Ideally, it should include special characters (such as “?” or “#” for example) and numbers. We recommend that you change it regularly and if you need to write it down, always keep it in a safe place;
- Make sure that no-one can see the details you are entering when you log in;
- Remember to close your browser each time you log off and end your session and, if possible, clear any history of the websites you have visited and that your browser may have saved or “cached”;
- Never disclose your account details to anyone;
- Ensure that the software you use has installed the latest security upgrades and that your software protection is up-to-date.
9.5.5. To get the best from our services, please keep your personal data (including your email address) accurate and up to date. You can do this by logging into our secure website. We will store your personal data (aside from the automatic information detailed above) once we have received your registration.
9.6. How Long Do We Retain Your Personal Data?
9.6.1. Information relating to your financial transactions with us will be kept for the period required by applicable tax and revenue legislation.
9.6.2. Your personal profile and membership data will be retained while you continue to be an active free or paid member, and for up to 7 years following cessation of membership activity. In all other cases, we will erase or anonymize your data once it is no longer necessary for the purpose we obtained it for.
9.7. Who Do We Disclose Your Personal Data To?
9.7.1. We allow third-party service providers to process personal data where this is needed in connection with a service they provide to us. These arrangements may involve your personal information being located in various countries around the world.
9.7.2. You should be aware that different privacy laws may apply in these countries from any laws that may apply in the country where you are located. We will always strive to adopt the highest standards of privacy protection wherever your personal information is located. Our Privacy Policy does not apply to third-party websites where our online advertisements are displayed or to linked third-party websites that we do not operate or control.
9.7.3. We may share your information with selected third parties including:
- Business partners, suppliers, and sub-contractors for the performance of any contract we enter into with them or you;
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
- Analytics and search engine providers that assist us in the improvement and optimization of our website;
- Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you;
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- If we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any agreements between us and you, or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
9.8. How Do You Withdraw Your Consent Including Marketing Opt-Out?
9.8.1. You may withdraw your consent for data processing at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
9.8.2. You may also instruct us not to process your personal information for marketing purposes. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt-in to the use of your personal information for marketing purposes. You can unsubscribe from our emails at any time by clicking on “unsubscribe” at the bottom of the email.
9.8.3. You can also contact us at info@squarefi.co should you wish to withdraw your consent or opt out of marketing communications at any time.
9.9. Do We Carry Out Profiling and Automated Decision-Making?
9.9.1. We use Google Analytics to collect details of how you use our website, as well as anonymous data that you enter into our forms. We do this to help us analyze how visitors use our site (including behavior patterns and the tracking of visits across multiple devices), administer our site, and manage your account. Please see our Cookie Notice for more details about Google Analytics.
9.9.2. We do not carry out any other profiling or automated decision-making in respect of the information we automatically collect about you when you visit our site.
9.10. Monitoring
9.10.1. To the extent permitted by law, we may record and monitor your communications with us to ensure compliance with our legal and regulatory obligations and our internal policies. This may include the recording of telephone conversations.
9.11. What Rights Do You Have?
9.11.1. In order to protect your data, you have a number of rights in respect of your information, which include the right to:
- Access your information;
- Withdraw your consent to the processing of your information at any time;
- Ask us to make changes to the information we hold about you to make sure that it is accurate and up to date;
- Delete or erase your information (sometimes called the right to be forgotten);
- Stop or restrict our processing of your information;
- Object to our processing your information;
- Not be subject to automated decision-making; and
- Request the transfer of some of the information we hold about you (known as data portability).
9.11.2. If you would like to exercise any of your rights, please contact us at info@squarefi.co. Please note that an archive copy of any information provided to us may be retained by us for our records and for audit purposes.
9.11.3. You have the right to request a copy of the information we hold about you by sending your request in writing to us at info@squarefi.co.
9.12. Third-Party Websites
9.12.1. The website contains links to other websites. We are not responsible for the privacy policies or practices of third-party websites.
9.13. Social Media
9.13.1. We operate channels, pages, and accounts on some social media sites to inform, assist, and engage with customers. We monitor and record comments and posts made on these channels about us so that we can improve our services.
9.13.2. We are not responsible for any information posted on those sites other than information we have posted ourselves. We do not endorse the social media sites themselves or any information posted on them by third parties.
9.14. International Data Transfers
9.14.1. Information that we collect may be stored and processed in and transferred between any of the countries in which we operate to enable us to use the information in accordance with this Privacy Policy.
9.14.2. Information that you provide may be transferred to countries, including the United States, which may not have data protection laws equivalent to those in force in the European Economic Area. However, any transfers of personal data will be done in compliance with applicable data protection laws.
9.14.3. In addition, personal information that you submit for publication on the website will be published on the internet and may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
9.14.4. You expressly agree to such transfers of personal information.
9.15. Changes to This Privacy Policy
9.15.1. We may, in our absolute discretion, update this Privacy Policy from time to time. It is therefore recommended that you review it regularly.
9.16. Contact
9.16.1. If you have any questions, concerns, or complaints about the way we process your personal information, please contact squarefi.app.
9.16.2. If you are not happy with the way we have handled your complaint or are still concerned about our handling of your personal information, you can lodge a complaint with the relevant privacy supervisory authority.
9.17. The processing of personal data is carried out by the Rightholder and the Seller, acting as the Platform / Platforms in a mixed way, i.e., occurs both with the use of automation tools and without them.
9.18. The following actions are carried out with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer, provision, access, depersonalization, blocking, deletion, and destruction of personal data.
9.19. During processing, the accuracy, sufficiency, and relevance of personal data in relation to the purposes of their processing are ensured. If inaccurate or incomplete personal data is found, they are updated.
9.19. The receipt and processing of personal data in cases provided for by law are carried out by the Platform with the written consent of the subject of personal data. Consent in the form of an electronic document signed by authorization on the Platform is recognized as equivalent to a written consent on paper containing a handwritten signature of the subject of personal data.
9.20. Consent to the processing of personal data may be given by the subject of personal data or his representative in any way allowing confirming the fact of its receipt.
9.21. Processing of special categories of personal data is not carried out.
9.22. Information that characterizes the physiological characteristics of a person and on the basis of which it is possible to establish his identity (biometric personal data) can only be processed with the written consent of the subject of personal data.
9.23. Processing and storage of personal data are carried out no longer than required by the purposes of processing personal data if there are no legal grounds for further processing.
9.9. The processing of personal data on the basis of contracts and other agreements of the Platform, instructions to the Platform, and instructions of the Platform for the processing of personal data is carried out in accordance with the terms of these contracts, agreements, and instructions. The above documents may determine, in particular: the purposes, conditions, and terms of personal data processing; obligations of the parties, including measures to ensure the security of personal data; the rights, obligations, and responsibilities of the parties regarding the processing of personal data.
9.24. In cases not expressly provided for by applicable law or the contract, processing is carried out after obtaining the consent of the subject of personal data. Consent can be expressed in the form of performing actions, accepting the terms of the offer agreement, putting down the appropriate marks, filling in the fields in forms, forms, or in writing in accordance with the law.
9.25. The Platform takes the necessary legal, organizational, and technical measures to ensure the security of personal data, their protection against unauthorized (including accidental) access, destruction, modification, blocking access, and other unauthorized actions. Such measures, in particular, include: appointment of employees responsible for organizing the processing and ensuring the security of personal data; verification of the presence in contracts and inclusion, if necessary, in contracts of clauses on ensuring the confidentiality of personal data; issuing local acts on the processing of personal data, familiarizing employees with them, training users; ensuring the physical security of premises and processing facilities, access control, security, video surveillance; restriction and differentiation of access of employees and other persons to personal data and means of processing, monitoring of actions with personal data; identification of threats to the security of personal data during their processing, the formation of threat models on their basis; the use of security tools (anti-virus tools, firewalls, means of protection against unauthorized access, means of cryptographic information protection), including those that have passed the conformity assessment procedure in the prescribed manner; accounting and storage of information carriers, excluding their theft, substitution, unauthorized copying, and destruction; backing up information for recovery; implementation of internal control over compliance with the established procedure, verification of the effectiveness of the measures taken, response to incidents.
9.26. Rights of Personal Data Subjects
9.26.1. The subject of personal data has the right to withdraw consent to the processing of personal data by sending a corresponding request to the Platform by mail or by contacting in person.
9.26.2. The subject of personal data has the right to receive information regarding the processing of his personal data, including the following:
- Confirmation of the fact of processing personal data by the Platform;
- Legal grounds and purposes of personal data processing;
- The purposes and methods used by the Platform for processing personal data;
- The name and location of the Platform, information about persons (excluding employees/employees of the Platform) who have access to personal data or to whom personal data may be disclosed on the basis of an agreement with the Platform or on the basis of federal law;
- Processed personal data relating to the relevant subject of personal data, the source of their receipt, unless a different procedure for the submission of such data is provided by federal law;
- Terms of processing personal data, including the terms of their storage;
- The procedure for the exercise by the subject of personal data of the rights provided for by the Wyoming Consumer Protection Act;
- Information about the performed or proposed cross-border data transfer;
- The name or surname, name, patronymic, and address of the person who processes personal data on behalf of the Platform, if the processing is or will be entrusted to such a person;
- Other information provided for by the Wyoming Consumer Protection Act or other federal laws.
9.26.3. The subject of personal data has the right to demand from the Platform the clarification of his personal data, their blocking, or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights.
9.26.4. If the subject of personal data believes that the Platform is processing his personal data in violation of the requirements of the Wyoming Consumer Protection Act or otherwise violates his rights and freedoms, the subject of personal data has the right to appeal against the actions or inaction of the Platform to the authorized body for the protection of the rights of subjects of personal data. The subject of personal data has the right to protect his rights and legitimate interests, including compensation for losses and (or) compensation for moral damage in court.
9.27. Rights and Obligations of the Platform
9.27.1. The rights and obligations of the Platform are determined by the current legislation and agreements of the Platform.
9.27.2. Control over the fulfillment of the requirements of this Policy is carried out by the person responsible for organizing the processing of personal data.
9.27.3. The liability of persons involved in the processing of personal data on the basis of the instructions of the Platform for the unlawful use of personal data is established in accordance with the terms of the civil law contract concluded between the Platform and the counterparty or the Information Confidentiality Agreement.
9.27.4. Persons guilty of violating the rules governing the processing and protection of personal data bear material, disciplinary, administrative, civil, or criminal liability in the manner prescribed by federal laws, local acts, and agreements of the Platform.
9.27.5. The personal data processing policy is developed by the person responsible for organizing the processing of personal data and put into effect after approval by the head of the Platform. Suggestions and comments for changes to the Policy should be sent to info@squarefi.co. The policy is reviewed annually to keep it up to date and updated as necessary.