BY ACCESSING OR USING OUR SERVICES, YOU CONSENT TO THE COLLECTION, TRANSFER, MANIPULATION, STORAGE, DISCLOSURE AND OTHER USES OF YOUR INFORMATION (COLLECTIVELY, "USE OF YOUR INFORMATION") AS DESCRIBED IN THIS PRIVACY POLICY AND OUR TERMS OF SERVICE. IF YOU DO NOT, OR NO LONGER, AGREE WITH OR CONSENT TO THIS PRIVACY POLICY AND OUR TERMS OF SERVICE YOU MAY NOT ACCESS OR USE OUR SERVICES. FURTHERMORE, FOR USERS OF OUR SERVICES, WE RELY UPON THE LEGAL GROUNDS FOUND IN THE SECTION ENTITLED "THE LEGAL BASIS AND REASONS FOR COLLECTION AND PROCESSING YOUR PERSONAL INFORMATION" FOUND HEREINAFTER IN THIS PRIVACY POLICY.

We at Vester, the owner and operator of the Vester platform (the "Website" or "Site"), hereafter referred to in this Privacy Policy as "Vester", "us", "our" or "we", respect the privacy of your personal information and, as such, make every effort to ensure your information is protected and remains private.

We have provided this Privacy Policy to explain how we collect, use, share and protect information about the users of our Website (hereafter referred to as “user”, “you” or "your"). We will not use or share your personal information with anyone except as described in this Privacy Policy. This Privacy Policy will inform you about the types of personal data we collect, the purposes for which we use the data, the ways in which the data is handled and your rights with regard to your personal data. Furthermore, this Privacy Policy is intended to satisfy the obligation of transparency under the EU General Data Protection Regulation ("GDPR") and the laws implementing the GDPR.

Vester collects information about you when you use our Website to access our services, and other online products and services (collectively, the “Services”) and through other interactions and communications you have with us. The term Services includes, collectively, various applications, websites, widgets, email notifications and other mediums, or portions of such mediums, through which you have accessed this Privacy Policy.

For purposes of this Privacy Policy, "Your Information" or "Personal Data" means information about you, which may be of a confidential or sensitive nature and may include personally identifiable information ("PII") and/or financial information. PII means individually identifiable information that would allow us to determine the actual identity of a specific living person, while sensitive data may include information, comments, content and other information that you voluntarily provide.

The Data Controller for Vester is Vester, Inc. and our contact details are set out in the Contact section at the end of this Privacy Policy. A Data Controller is the natural or legal person who (either alone or jointly with other persons) determines the purposes for which, and the manner in which, any personal information are, or will be, processed.

We may change this Privacy Policy from time to time. If we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Website. If the changes to the Privacy Policy are significant, we will send an email notice to you, and may request that you accept the revised Privacy Policy terms. Changes will go into effect on the "Last updated" date shown at the end of this Privacy Policy. By continuing to use the Website or our Services, you consent to the revised Privacy Policy. We encourage you to periodically review the Privacy Policy for the latest information on our privacy practices.

Information Provided Directly By You

We collect information you provide directly to us, such as when you request information, create or modify your personal account, request Services, complete a Vester form, survey, questionnaire or application, contact customer support, join or enroll for an event or otherwise communicate with us in any manner. This information may include, without limitation: your name, date of birth, e-mail address, physical address, business address, phone number or any other personal information you choose to provide.

Information Collected Through Your Use of Our Services

We collect information about your activity on, and use of, our services including, and without limitation, the date and time you logged in, features you’ve been using, searches, clicks and pages that have been shown to you, information related to financial investing and trading of securities, cryptocurrency markets, referring webpage address, advertising that you click on, and how you interact with other users and us. The following are situations in which you may provide Your Information to us:

• When you fill out forms or fields through our Services;

• When you register for an account with our Service;

• When you select cryptocurrencies and other digital assets for more information or analysis;

• When you order products or services from, or through our Service;

• When you provide responses to a survey or questionnaire;

• When you join or enroll in an event through our Services;

• When you sign up for any newsletters or other materials through our Services;

• When you provide information to us through a third-party application, service or website;

• When you communicate with us or request information about us, or our products or Services, whether via email or other means;

• When you participate in any of our marketing initiatives, including contests, events, or promotions; and

• When you participate in forums, reviews or provide or post user-generated content or other submissions.

Information Collected Automatically

We may automatically collect information via the Website or through the use of various technologies, including, but not limited to Cookies, Pixel Tags, and Web Beacons (explained below). We may collect your IP address, browsing behavior, and device IDs. This information is used by us in order to enable us to better understand how our Services are being used by visitors and allows us to administer and customize the Services to improve your overall experience.

Information Collected From Other Sources

We may also receive information from other sources and combine that with information we collect through our Services. For example, if you choose to link, create, or log in to your Vester account with a social media service (e.g., LinkedIn, Facebook, or Twitter), or if you engage with a separate application or website that uses our API, or whose API we use, we may receive information about you or your connections from that website or application. This includes, without limitation, profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, your contact names, e-mail addresses, phone numbers, and other identifiers and any other information you permit the social network to share with third parties. The data we receive is solely dependent upon your privacy settings with the social network.

Cookies, Log Files and Anonymous Identifiers

When you visit our Services, we may send one or more Cookies—small data files—to your computer to uniquely identify your browser and let us help you log in faster and enhance your navigation through the Sites. “Cookies” are text-only pieces of information that a website transfers to an individual’s hard drive or other website browsing equipment for record-keeping purposes. A Cookie may convey anonymous information about how you browse the Services to us so we can provide you with a more personalized experience but does not collect personal information about you. Cookies allow the Sites to remember important information that will make your use of the site more convenient. A Cookie will typically contain the name of the domain from which the Cookie has come, the “lifetime” of the Cookie, and a randomly generated unique number or other value. Certain Cookies may be used on the Sites regardless of whether you are logged in to your account or not.

• Session Cookies are temporary Cookies that remain in the Cookie file of your browser until you leave the Site.

• Persistent Cookies remain in the Cookie file of your browser for much longer (though how long will depend on the lifetime of the specific Cookie).

When we use session Cookies to track the total number of visitors to our Website, this is done on an anonymous aggregate basis (as Cookies do not in themselves carry any personal data).

We may also employ Cookies so that we remember your computer or device when it is used to return to the Site to help customize your Vester experience. We may associate personal information with a Cookie file in those instances.

We use Cookies to help us know that you are logged on, provide you with features based on your preferences, understand when you are interacting with our Services, and compile other information regarding use of our Services.

Third parties with whom we partner to provide certain features on our Site or to display advertising based upon your Web browsing activity use Cookies to collect and store information.

Our Website may use remarketing services to serve ads on our behalf across the internet on third-party websites to previous visitors to our Sites. It could mean that we advertise to previous visitors who haven’t completed a task on our site. This could be in the form of an advertisement on the Google search results page or a site in the Google Display Network. Third-party vendors, including Google, use Cookies to serve ads based on your past visits to our Website. Any data collected will be used in accordance with our own privacy policy, as well as Google's privacy policies. To learn more, or to opt-out of receiving advertisements tailored to your interests by our third parties, visit the Network Advertising Initiative at www.networkadvertising.org/choices.

Vester may use third-party services such as Google Analytics to help understand use of the Services. These services typically collect the information sent by your browser as part of a web page request, including Cookies and your IP address. They receive this information, and their use of it is governed by their respective privacy policies. You may opt out of Google Analytics for Display Advertisers including AdWords and opt-out of customized Google Display Network ads by visiting the Google Ads Preferences Manager here https://adssettings.google.com/authenticated?hl=en. To provide website visitors more choice on how their data is collected by Google Analytics, Google has developed an Opt-out Browser add-on, which is available by visiting Google Analytics Opt-out Browser Add-on here https://tools.google.com/dlpage/gaoptout. For additional information on how Google uses data when you use Google partners’ sites or apps, go here: https://policies.google.com/technologies/partner-sites.

You can control the use of Cookies at the individual browser level. Use the options in your web browser if you do not wish to receive a Cookie or if you wish to set your browser to notify you when you receive a Cookie. You can easily delete and manage any Cookies that have been installed in the Cookie folder of your browser by following the instructions provided by your particular browser manufacturer. Consult the documentation that your particular browser manufacturer provides. You may also consult your mobile device documentation for information on how to disable Cookies on your mobile device. If you reject Cookies, you may still use our Website, but your ability to use some features or areas of our Service may be limited.

Vester cannot control the use of Cookies by third parties (or the resulting information), and use of third-party Cookies is not covered by this policy.

We automatically collect information about how you interact with our Services, preferences expressed, and settings chosen and store it in Log Files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or website/application functionality, and to document your consent to receiving products, services, or communications from us or our partners. If we link such information with personally identifiable information in a manner that identifies a particular individual, then we will treat all such information as PII for purposes of this Privacy Policy.

When you use our Services, we may employ Web Beacons (also known as clear GIFs or tracking pixels) to anonymously track online usage patterns. No Personally Identifiable Information from your account is collected using these Web Beacons.

List of Cookies

Please note that the names of Cookies and other technologies may change over time.

• _hp2_id.3947090996

• _hp2_ses_props.3947090996

• _ga

• _ga_XH4TDRV89T

Information Third Parties Provide

We may collect information about you from sources other than you, such as from social media websites (i.e., LinkedIn, Facebook, Twitter, or others), blogs, analytics providers, business affiliates and partners, and other users. This includes, without limitation, identity data, contact data, marketing and communications data, behavioral data, technical data, and content data.

Device Information

When you use our Services through your computer, mobile phone, or other device, we may collect information regarding and related to your device, such as hardware models and IDs, device type, operating system version, the request type, the content of your request, and basic usage information about your use of our Services, such as date and time. In addition, we may collect information regarding application-level events and associate that with your account to provide customer service. We may also collect and store information locally on your device using mechanisms such as browser web storage and application data caches.

Location Information

When you use the Services, we may collect your precise location data. We may also derive your approximate location from your IP address.

Call and SMS Data

In connection with providing Service, we may receive call data, including the date and time of the call or SMS message, the parties’ phone numbers, and the content of the SMS message. You consent to the receipt, collection, and storage of this information.

Aggregated Data

We may collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data is de-identified or anonymized and does not constitute Personal Data as this data does not directly or indirectly reveal your identity. We may retain Aggregated Data that does not include your PII after you terminate your account with Vester for the continued functionality of our analytical tools. If we ever combine Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as PII which will only be used in accordance with this Privacy Policy.

Children’s Privacy

Our Services are intended for users who have attained the age of majority where they reside (18 years of age or older in most jurisdictions). Furthermore, we do not knowingly collect personally identifiable information (PII) from persons under the age of 13 in the United States ("U.S."), or under the age of 16 in the European Union ("EU"), the "Protected Age". If you are under the Protected Age, please do not provide us with information of any kind whatsoever. If you have reason to believe that we may have accidentally received information from a child under the Protected Age, please contact us immediately. If we become aware that we have inadvertently received Personal Information from a person under the Protected Age, we will delete such information from our records.

The Legal Basis and Reasons For Collection and Processing Your Personal Information

The legal basis upon which we rely for the collection and processing of your Personal Information under the GDPR are the following:

• When signing up to use our Services, you have given Vester consent to provide you with our Services and generally to process your information in accordance with this Privacy Policy, and to the transfer of your personal data to other jurisdictions including, without limitation, the United States;

• It is necessary for entering into, or performing, the obligations of a contract between you and Vester, including, without limitation, our Terms of Service agreement which may be accessed by you here;

• It is necessary registering you as a user, managing your account and profile, and authenticating you when you log in;

• It is necessary for our legitimate interests in the proper administration of our website and business; analyzing the use of the website and our Services; assuring the security of our website and Services; maintaining back-ups of our databases; and communicating with you;

• To resolve technical issues you encounter, to respond to your requests for assistance, comments, and questions, to analyze crash information, to repair and improve the Services and provide other customer support;

• To send communications via email and within the Services, including, for example, responding to your comments, questions, and requests, providing customer support, and sending you technical notices, product updates, security alerts, and account management related messages;

• To send promotional communications that you have consented to receive or have expressed a legitimate interest in receiving;

• It is necessary for our legitimate interests in the protection and assertion of our legal rights, and the legal rights of others, including you; and

• It is necessary for our compliance with certain legal provisions which may require us to process your personal data. By way of example, and without limitation, we may be required by law to disclose your personal data to law enforcement or a government regulatory agency.

Protective Measures We Use

We protect your information using commercially reasonable technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. Although we take measures to secure your information, we do not promise, and you should not expect, that your personal information, or searches, or other information will always remain secure. We cannot guarantee the security of our information storage, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet including, without limitation, email and text transmissions. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

How We Use Information We Collect

Our primary purpose in collecting, storing, using, and disclosing your Information is for our legitimate business purposes and to provide you with a safe, smooth, efficient, and customized experience. We will not rent, sell, lease, or barter your information to anyone unless you grant us explicit permission for this information to be shared in that manner. We will use this information in order to:

• Operate and provide our Services;

• Improve our internal operations, systems, products, and Services;

• Provide users with customer support including, sending you related information, including confirmations, technical notices, updates, security alerts, and administrative messages;

• Understand you and your preferences to enhance your experience and enjoyment using our Services;

• Analyze, improve, and manage our Services and operations;

• Resolve problems and disputes, and engage in other legal and security matters;

• Protect, investigate, and deter against fraudulent, unauthorized use, or illegal activity;

• Enforce our Terms of Service and any terms and conditions of any agreements for our Services;

• Send you communications we think will be of interest to you, including information about our products, services, promotions,news, and events related to Vester;

• Verify your identity and prevent impersonation, spam, or other unauthorized or illegal activity, including, without limitation, infringement of intellectual property rights of third parties;

• Comply with legal obligations and enforce our agreements with third parties.

How We Share and Disclose Information We Collect

We share the information we collect about you as described in this Privacy Policy, or as described at the time of collection or sharing, as follows:

• With third-party service providers to enable them to provide the services you request;

• With affiliates and partners to provide functionality and improve user experience;

• In response to legal obligations to comply with applicable laws, regulations, court orders, or government requests;

• To protect Vester and its users by investigating or deterring illegal activities, unauthorized use, or policy violations;

• During business transactions, such as mergers, acquisitions, or asset sales;

• With your consent, in scenarios where you agree to specific data-sharing arrangements;

• In aggregated or anonymized forms that do not directly identify you.

User Content and Public Sharing

If you share User Content (as defined in our Terms of Service) or post publicly on our platform, third parties may view, share, or interact with your content. You should exercise caution when posting personal or sensitive information. Public content is not subject to this Privacy Policy.

Data Retention

We retain your information as long as necessary to provide services or comply with legal obligations. Once your account is deactivated, we may retain certain data for backup, legal, or business purposes. Aggregated or anonymized data may be retained indefinitely.

Protective Measures We Use

We use commercially reasonable technical and administrative measures to safeguard your information. These include encryption, access controls, and secure storage practices. However, no system can guarantee 100% security. In the event of a data breach, we will notify affected users and relevant authorities as required by applicable laws.

Your Rights and Choices

Depending on your location, you may have rights under data protection laws, including:

• Access and correction: Request access to or correction of your personal data.

• Deletion: Request the removal of your personal information, subject to legal and business constraints.

• Data portability: Receive a copy of your data in a machine-readable format.

• Withdraw consent: Revoke previously granted permissions for data processing.

• Opt-out of communications: Unsubscribe from marketing emails or other non-essential notifications.

To exercise these rights, contact us at contact@vesterai.com

Changes to This Privacy Policy

We may update this Privacy Policy periodically. Significant changes will be communicated via email or notifications on our platform. Your continued use of Vester services signifies your acceptance of any updates.

Contact Us

For questions about this Privacy Policy or your personal information, please contact us at:

• Email: contact@vesterai.com