Last updated: November 1st, 2021

Far Horizon Capital Inc (the "Company", "we", "our" or "us") collects information about you ("you") from various sources to provide the Websites and Services to you, to protect our legitimate interests, to analyze and improve our Websites and Services, to communicate with you, and to comply with our legal and regulatory obligations. This Privacy Policy ("Privacy Policy") covers our treatment of the personally identifiable information that we gather when you access or use our Websites and the Services.

From time to time, we may revise or amend this Privacy Policy to reflect changes in law, our Personal Data collection and use practices, the features on the Websites and Services, or advances in technology. This Privacy Policy does not cover the practices of entities we do not own or control, or people we do not manage.

Our Privacy Policy applies to all Websites and Services we offer, but excludes any products, applications or services that have separate privacy policies which do not incorporate this Privacy Policy. For the purposes of data protection laws of the European Union ("EU"), and other relevant jurisdictions ("Data Protection Laws"), the Company is a data controller (i.e., the company who is responsible for, and controls the processing of, your Personal Data).

The access and/or use of our Website and Services implies acceptance of this Privacy Policy.

In this Privacy Policy, "Services" shall have the same meaning as in the Terms of Service Agreement; and "Websites" shall mean https://flagtheory.com, https://incorporations.io, https://residencies.io, https://passports.io, https://bankaccounts.io and any other online site operated by the Company.

What data we collect

To the fullest extent permitted under applicable Data Protection Laws, we collect the following data and information (collectively, "Personal Data"):

1. Full name, date of birth, gender, country of residence, username, passwords, tax numbers, and data included in government-issued identification documents;
2. Financial information, sources of wealth or funds or income, level of activity anticipated, distributed ledger network wallet addresses;
3. Personal Documents such as government-issued IDs, passport, bank statements, utility bills, internet bills, income, account balances, financial transaction history, credit history, tax information, and credit scores, and other forms of identification, address verification and source of funds and wealth verification;
4. Corporate information such as legal entity name, doing business as name, legal domicile, fiscal domicile, object;
5. Corporate documents such as certificate of registration, constitution, memorandum & articles of association, bylaws, statues, incumbency certificate, register of directors, register of shareholders, register of authorized signatories, registry excerpts, financial statements;
6. Information about how you access and use our Websites and Services, such as your actions on the Websites;
7. Communications between the Company and you including emails, social media messages, job applications, customer support inquiries; and
8. Current and historical information concerning your geographic location, GPS location, transaction location, and IP addresses that you use when you use and/or access our Websites and Services. We may use third-party services such as the Google Maps API to gather information about your location. Google uses various technologies to determine your location, including IP address, GPS, and other sensors that may, for example, provide Google with information on nearby devices, Wi-Fi access points, and cell towers (see Google’s Privacy Policy to learn more).

Our Websites and Services are not available to anyone under the age of eighteen (18) ("Minors"). The Company has implemented the appropriate controls to ensure that Minors do not use or have access to our Websites and Services. Therefore, the Company will never knowingly and intentionally collect Personal Data from Minors. If you are a parent or guardian of a Minor and you believe or are aware that a Minor has provided us with Personal Data, please contact us immediately. If we become aware that we have collected Personal Data from Minors with or without verification of parental consent, we will take measures to delete that information from our systems.

How we collect Personal Data

To the fullest extent permitted under applicable Data Protection Laws, we collect Personal Data about you and any other party whose details you provide to us when you:

1. Access or use our Websites and/or Services;
2. Complete online forms (including call back requests), take part in surveys, post on any forums, download information such as white papers or other publications or participate in any other interactive areas that appear within our Websites and Services;
3. Interact with us using social media;
4. Provide your contact details to us when registering to use or access any Websites or Services we make available or when you update those details; and
5. Contact us or otherwise connect with us, online or offline.

We will also collect Personal Data where you only partially complete and/or abandon any information inputted through our Websites and/or other online forms and may use this information to contact you to remind you to complete any outstanding information and/or for marketing purposes.

We may also collect information from your devices (including mobile devices) and applications you or your users use to access and use our Websites or Services (for example, we may collect the device identification number and type, location information and connection information such as statistics on your page views, traffic to and from the Websites, referral URL, ad data, your Internet Protocol (IP) address, your browsing history and your web log information) and we will ask for your permission before we do so. We may do this using cookies or similar technologies (as described below).

If you intend to give us Personal Data about someone else, you are responsible for ensuring that you comply with any obligation and consent obligations under applicable Data Protections Laws. Insofar as required by applicable Data Protection Laws, you must ensure that beforehand you have their explicit consent to do so and that you explain to them how we collect, use, disclose and retain their Personal Data, or direct them to read our Privacy Policy.

How we use your Personal Data

To the fullest extent permitted under applicable under Data Protection Laws, we use your information to:

1. Provide any information or Services that you have requested or ordered;
2. Compare information for accuracy and to verify it with third parties;
3. Provide, maintain, protect and improve our Websites and Services;
4. Manage, monitor, and administer your use of the Websites and Services and provide an enhanced, personal, user experience;
5. Manage our relationship with you (for example, for the provision of Services);
6. Provide you with any information that we are required to send you to comply with our regulatory or legal obligations;
7. Comply with applicable Know Your Customer, Anti-Money Laundering, Counter-Terrorism Financing, and Anti-Corruption laws and regulations;
8. Detect, prevent, investigate or remediate, crime, illegal activities or to otherwise protect our legal rights (including liaison with regulators and law enforcement agencies for these purposes);
9. Contact you to see if you would like to take part in our customer research (for example, feedback on your use of our Websites or Services);
10. Monitor, carry out statistical analysis and benchmarking (provided that in such circumstances it is on an aggregated basis which will not be linked back to you or any living individual);
11. Deliver advertising, marketing (including but not limited to in-product messaging) or information which may be useful to you;
12. Deliver joint content and services with third parties with whom you have a separate relationship (for example, social media providers); and
13. In addition to the legal and commercial uses listed above, we may be required to provide any and all of your Personal Data to governmental authorities as necessary to comply with the law..

Our Websites may contain technology that enables us to:

1. Check specific information from your device or systems directly relevant to your use of the Websites, applications or websites against our records to make sure the Websites are being used in accordance with our end-user agreements and to troubleshoot any problems;
2. Obtain information relating to any technical errors or other issues with our Websites;
3. Collect information about how you use the features of our Websites; and
4. Gather statistical information about the operating system and environment from which you access our Websites.

If you become a follower in the Company’s social networks, the processing of Personal Data will be governed by the policies of the Social Network, as well as by their terms of use, privacy policies and regulations that belong to the social network that corresponds in each case and that you have previously accepted.

The Company will treat your Personal Data in order to correctly manage your presence in the social network, inform him of the Company activities, Services, as well as for any other purpose that the rules of the social networks allow.

In no case will the Company use the profiles of followers in social networks to send advertising individually.

Parties with whom we may share your Personal Data

We may share your Personal Data with:

1. Third-Party Internet and Marketing Services Vendors such as Active Campaign, Facebook, Twitter, Telegram, GoogleCloud, Google Analytics;
2. Government and State Authorities to respond to subpoenas, court orders, legal process, law-enforcement requests, legal claims, or government inquiries and to protect and defend the rights, interests, safety, and security of the Company, our affiliates, clients, website users, or the public;
3. The Company’s affiliates;
4. The Company’s subcontractors and/or agents as required for the provision of the Services, and as provided in the Terms of Service Agreement.
5. Third-Parties in connection to corporate transactions such as the sale of a website, a merger, consolidation, reorganization, financing, change or control or acquisition of all or a portion of our business by another company or third party, asset sale, initial public offering, or in the unlikely event of bankruptcy or similar proceeding.

Data Retention

We will retain your Personal Data for as long as it is necessary for the purposes of performing a contract, comply with our legal and regulatory obligations, and protecting our legitimate interests. Specifically, we reserve the right to retain your Personal Data for the purposes of complying with applicable Know Your Customer, Anti-Money Laundering, Counter-Terrorism Financing, and Anti-Corruption laws and regulations for a period of at least seven (7) years from the termination of the Services, and for the purposes of legal proceedings, complaints and disputes for as long as this is necessary to protect our legitimate interests.

Persons who may access your Personal Data

The Company’s authorized personnel, including but not limited to our Compliance Officers, shall have access to your Personal Data on a need-to-know basis. Our Compliance Officers and other authorized personnel are bound to confidentiality and non-disclosure agreements, and subject to strict company policies related to the access and use of the data.

We may engage from time to time to third-party service providers to assist the Company with the implementation of the KYC/AML & CTF Policy as well as the compliance with applicable Know Your Customer, Anti-Money Laundering, Counter-Terrorism Financing, and Anti-Corruption laws and regulations. Where applicable, we will enter into a data processing agreement with these third-parties to ensure data security and protection of your Personal Data against Data Beaches. Such Data Processors will only process your Personal Data to the extent required for the provision of services for which they are engaged.

We may provide your Personal Data to competent authorities upon their request to the extent legally required or to the extent necessary to defend our rights in legal proceedings or investigations.

Data Security

To protect your Personal Data, the Company takes all reasonable precautions and follows the best practices of the industry to prevent the loss, misuse, improper access, disclosure, alteration or destruction of the same.

In addition to the purposes described in this section, we may also use information we gather to deliver targeted and interest-based advertising, marketing (including in-product messaging) or information to you which may be useful, based on your use of the Websites and/or the Services or any other information we have about you.

Legal basis for processing in the EU

In the EU, we collect your Personal Data for the following purposes:

1. Based on your consent, for marketing purposes, which can be revoked at any time;
2. Where necessary to perform any contract we enter into, or have entered into, with you to provide Services or provide access to our Websites and/or Services;
3. Where necessary for our legitimate business interests (or those of a third party) when your interests and fundamental rights do not override those interests; and
4. Where we need to comply with a legal or regulatory obligation either in the EU or elsewhere.

You have the following rights:

1. The right to access your own Personal Data;
2. The right to have your Personal Data rectified if it is inaccurate or incomplete;
3. The right to request deletion or removal of your Personal Data where there is no good reason for processing to continue;
4. The right to restrict processing of your Personal Data where there is no good reason for processing to continue;
5. The right to data portability to enable moving, copying or transferring of Personal Data from one platform to another;
6. The right to object to the processing of your Personal Data in certain circumstances; and
7. Rights relating to profiling and automated decision making resulting from the processing of your Personal Data.

The exercise of these rights is personal and therefore must be exercised directly by the interested party, requesting it directly to the Company, which means that any client, user, subscriber or collaborator who has provided their data at any time can contact the Company and request information about the data that it has stored and how it has been obtained, request the rectification of the same, request the portability of your Personal Data, oppose the processing, limit its use or request the cancellation of that data in the Company’s files.

To exercise the rights of access, rectification, cancellation, portability and opposition, you must send an email to the Data Protection Officer of the Company cristiana@flagtheory.com together with a valid proof of identity such as a Government-issued ID document.

Third-Party Content

The Websites may include embedded content (for example, videos, images, articles, etc.). The embedded content of other internet websites behaves in exactly the same way as if you had visited other internet websites.

These internet websites may collect data about you, use cookies, embed an additional third-party tracking code, and monitor your interaction using this code.

Cookies policy

Our Websites use cookies. By accessing our Websites we will inform you, through a pop-up banner, of our use of cookies.

1. About cookies

Cookies are files, often with unique identifiers, that web servers send to Internet browsers and can then be sent back to the server each time the browser requests a page from the server.

Web servers use cookies to identify and track users while browsing the different pages of the Websites, as well as to identify users returning to the Websites.

Cookies can be "persistent" cookies or "session cookies". A persistent cookie consists of a text file sent by a web server to an Internet browser, which is stored by the browser and remains valid until the defined expiration date (unless the user deletes it before the expiration date). On the other hand, a session cookie expires at the end of the user’s session, when the Internet browser is closed.

Cookies from the Websites

On our Websites, we use session and persistent cookies.

We will send you the following cookies:

1. Session Cookies
2. Google Analytics: This cookie allows us to identify unique users, unique sessions, regulate the rate of requests and store information about user sessions and campaigns.

Cookie 1 is a session cookie, while Cookie 2 is a persistent cookie.

How we use cookies

Cookies do not contain personally identifiable information, but we have the possibility of linking the Personal Data we store about you with the information obtained and stored from cookies.

We use the information we obtain from the use of our cookies for the following purposes:

1. Recognize your computer when you access and/or use our Websites.
2. Improve the usability of the Websites.
3. Analyze the use of our Websites.
4. Manage the Websites.
5. Third party cookies

When you use the Websites, you may also be sent third-party cookies.

Our service providers can send you cookies. They use the information they obtain through their cookies for the following purposes:

1. Track your browser on different Websites.
2. Create a profile of your Internet browsing.
3. Select specific ads that may be of interest.

Deletion and blocking of cookies

You can, at any time, restrict, block or delete cookies from the Websites. To do this, you must modify the configuration of your browser regarding the use of cookies through the "Preferences", "Options" or "Tools" menu (the name of the menus or the procedure to access the cookie options vary depending on the browser used).  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

• https://support.google.com/chrome/answer/95647 (Chrome);
• https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-Services-preferences (Firefox);
• https://help.opera.com/en/latest/security-and-privacy/ (Opera);
• https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
• https://support.apple.com/en-gb/guide/safari/manage-cookies-and-Services-data-sfri11471/mac (Safari); and
• https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

Navigation

When accessing and/or using the Websites, non-identifying data may be collected, which may include the IP address, geolocation, a record of how Services and Websites are used, browsing habits and other data that cannot be used to identify the User.

The Websites use the following third-party analysis services: Google Analytics

The Company uses the information obtained to obtain statistical data, analyze trends, administer the Websites, study navigation patterns and to gather demographic information.

Accuracy and veracity of Personal Data

You agree that the information provided to the Company is correct, complete, accurate and current. You are solely responsible for the veracity and correctness of the data you submit when access and/or using the Websites and/or the Services, exonerating the Company from any responsibility in this regard.

Acceptance and consent

You declare to have been informed of the conditions on protection of Personal Data. You accept and consent to the treatment of the same by the Company in the manner and for the purposes indicated in this Privacy Policy.

Revocability

To exercise the rights of access, rectification, cancellation, portability and opposition, you must send an email to cristiana@flagtheory.com along with your valid proof of ID such as a Government-issued identification document. The exercise of your rights does not include any Personal Data that The Company is obliged to keep for administrative, performance of contracts, legal or security purposes.

Change of Operatorship

In case of incorporation, acquisition, merger or any other causes that cause the change of Operatorship of the Websites and Services, you expressly consent that your registration data and information are transferred by the Company to the new Operator. When and if this occurs, the Company will comply, in any case, with the duty of information to you.

Changes to the Privacy Policy

The Company reserves the right to modify this Privacy Policy to adapt it to legislative developments, as well as to industry practices. The Company may notify you of changes to this Privacy Policy by email or through the Websites and Services.

Websites and Services Operator

The Websites and Services are operated by Far Horizon Capital Inc with address at 100 Peck Seah Street #08-14 PS100 S079333 Singapore.

Contact

In case you have any questions or complaints about the Privacy Policy, you can contact our data protection officer via email to cristiana@flagtheory.com