PRIVACY POLICY

1. Introduction and Data Controller

This Privacy Policy explains how J.Labs OOD, a company registered with the Bulgarian Commercial Register at the Registry Agency, Unified Identification Code 206970829, with seat and registered office at Sofia 1766, 251E Okolovrasten pat Str., “Ring Tower”, fl. 12 (“JungleTrade”, “Company”, “we”, “us” or “our”), collects and processes personal data when you use JungleTrade.

This Privacy Policy applies when you:

• visit www.jungletrade.ai;
• use the services and functionality available through JungleTrade;
• contact us through a contact form;
• communicate with us in relation to our products, APIs or services;
• enter into or discuss a potential business relationship with us.

For the purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), J.Labs OOD is the data controller for the personal data described in this Privacy Policy, except where another party acts as an independent controller for its own services.

If you have questions concerning this Privacy Policy or the processing of your personal data, you can contact us at:

[email protected]

2. Scope of this Privacy Policy

This Privacy Policy describes:

• what personal data we collect;
• how and why we process it;
• the legal bases on which we rely;
• when personal data may be processed by third-party service providers;
• how long we retain personal data;
• how we protect personal data;
• your rights under the GDPR.

JungleTrade does not currently provide user account registration or user profiles. Accordingly, we do not collect personal data for the purpose of creating or maintaining user accounts.

JungleTrade does not currently operate a newsletter or marketing mailing list.

If these functionalities are introduced in the future, this Privacy Policy will be updated as appropriate.

3. Personal Data We Collect

The personal data we collect depends on how you interact with JungleTrade.

3.1 Information You Provide to Us

When you contact us through a contact form, we may collect:

• your name;
• your email address;
• your telephone number;
• the content of your message;
• any other information that you voluntarily include in your communication.

Please do not provide personal data that is not necessary for your inquiry.

3.2 Business Communications

If you contact us regarding our products, API access, commercial cooperation or another potential business relationship, we may process information contained in the resulting correspondence.

This may include:

• your name;
• business contact information;
• company or organization;
• position or professional role, where provided;
• information relating to your inquiry;
• subsequent business correspondence.

We process only the information necessary to communicate with you and manage the relevant inquiry or business relationship.

3.3 Information Collected Automatically

When you access JungleTrade, certain technical information may be processed automatically by our systems or by services used to operate, secure and analyze the website.

Depending on the relevant service and your consent preferences, this information may include:

• IP address;
• browser type and version;
• device type;
• operating system;
• language settings;
• referring URL;
• pages visited;
• date and time of access;
• interaction and usage information;
• diagnostic and security information.

We do not use the JungleTrade website to request precise GPS location from your device.

Certain services may derive approximate geographic information from technical information such as an IP address.

4. Contact Forms and Communications

When you submit a contact form through JungleTrade, the information you provide is transmitted through a third-party email processing service and delivered to our business email account.

The information may include:

• name;
• email address;
• telephone number;
• message content.

The third-party email processing service forms part of the technical infrastructure used to deliver the communication.

Contact-form information is not currently stored in a separate JungleTrade customer-account database.

Copies of communications may remain within the email processing service and our business email system for as long as reasonably necessary for the purposes described in this Privacy Policy.

We use this information primarily to:

• respond to your inquiry;
• provide requested information;
• discuss JungleTrade products and services;
• respond to requests concerning API access;
• manage potential or existing business relationships;
• maintain relevant business correspondence.

5. Analytics, Cookies and Similar Technologies

JungleTrade uses cookies and similar technologies for website security, consent management, analytics and, where applicable, advertising measurement.

Some technologies are necessary for the operation and security of the website. Other technologies, including Analytics and Marketing technologies, are controlled according to your consent preferences.

JungleTrade uses Google Consent Mode v2 to communicate your consent choices to applicable Google services.

Unless you have provided the relevant consent, optional Analytics and Marketing storage is set to denied.

Analytics

Where you provide Analytics consent, JungleTrade uses Google Analytics 4 (GA4) to help us understand how visitors interact with the website.

Depending on your consent and the operation of the service, information processed for analytics may include:

• pages visited;
• session and interaction information;
• browser and device information;
• approximate geographic information;
• referring sources;
• technical information associated with website usage.

We use this information to understand website usage, evaluate performance and improve JungleTrade.

Advertising and Conversion Measurement

Where you provide Marketing consent, technologies associated with advertising and conversion measurement may be used to understand the effectiveness of advertising campaigns and related interactions.

Marketing-related processing is controlled through your consent preferences.

Cookie Preferences

JungleTrade stores information about your cookie preferences so that your choices can be remembered.

You can change or withdraw your preferences at any time through Cookie Settings available on the website.

Detailed information about the cookies and similar technologies used by JungleTrade, including their categories, purposes, duration and available controls, is provided in our Cookies Policy.

6. Security and Website Protection

We process certain technical information where necessary to maintain the security, availability and integrity of JungleTrade.

This may include processing performed through website security and traffic-protection services.

Such processing may involve:

• IP addresses;
• request information;
• browser and device characteristics;
• security-related identifiers;
• information necessary to detect malicious or automated traffic;
• information associated with security challenges and verification.

This processing is intended to protect JungleTrade, our infrastructure and legitimate users from security threats, abuse, unauthorized access and malicious traffic.

7. Why We Process Personal Data

Depending on how you interact with JungleTrade, we may process personal data for the following purposes:

Responding to Inquiries

To receive, review and respond to communications submitted through our contact forms or other communication channels.

Providing Information and Services

To provide information you request concerning JungleTrade, our products, APIs or other services.

Business Relationships

To communicate with potential or existing customers, partners and other business contacts and to manage related correspondence.

Taking Steps Before Entering into a Contract

Where you inquire about purchasing or accessing a paid JungleTrade service, we may process information necessary to discuss the service, commercial terms and the steps required to establish the relationship.

Providing Contracted Services

Where a contractual relationship is established, we may process information necessary to provide the agreed service and administer the relationship.

Website Security

To protect JungleTrade, our infrastructure and users against security threats, abuse and unauthorized access.

Analytics

Where you have provided the relevant consent, to understand how JungleTrade is used, evaluate website performance and improve our products and services.

Advertising Measurement

Where you have provided the relevant consent, to measure advertising and campaign performance.

Legal and Regulatory Compliance

To comply with applicable legal, accounting, tax or regulatory obligations and to establish, exercise or defend legal claims where necessary.

8. Legal Bases for Processing

Under the GDPR, we must have a valid legal basis for processing personal data.

Depending on the particular processing activity, we may rely on the following legal bases.

Consent

We rely on your consent where processing requires your voluntary permission.

This applies, in particular, to optional Analytics and Marketing technologies where consent is required.

You may withdraw your consent at any time.

Withdrawal does not affect the lawfulness of processing carried out before the consent was withdrawn.

Steps Prior to Entering into a Contract and Performance of a Contract

We may process personal data where necessary:

• to take steps at your request before entering into a contract; or
• to perform a contract to which you are a party.

This may apply where you contact us regarding paid API access, products or other JungleTrade services.

Legitimate Interests

We may process personal data where necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your rights and freedoms.

These interests may include:

• responding to business inquiries;
• maintaining relevant business correspondence;
• operating and securing JungleTrade;
• preventing abuse and malicious activity;
• protecting our legal rights.

Legal Obligations

We may process personal data where necessary to comply with legal obligations applicable to us.

This may include accounting, tax, regulatory and legal requirements.

9. Payments

JungleTrade does not currently operate an integrated payment-processing system through the website.

Where a customer or potential customer needs to make a payment for a JungleTrade service, we may provide a link to a third-party payment service provider.

Payment information entered through the payment provider's website or service is processed by that provider according to its own terms and privacy practices.

JungleTrade does not require you to submit payment-card details through the JungleTrade website.

We may receive or retain information relating to a transaction where necessary for:

• confirming payment;
• providing the purchased service;
• business administration;
• invoicing and accounting;
• compliance with applicable legal obligations.

10. Service Providers and Recipients of Personal Data

We use a limited number of third-party service providers to support the operation, security, communication, analytics and commercial activities of JungleTrade.

Depending on your interaction with JungleTrade and your consent preferences, categories of recipients or processors may include:

Email Processing Service Providers

Used to transmit communications submitted through JungleTrade contact forms to our business email system.

Analytics and Advertising Service Providers

Where you have provided the applicable consent, these services may process technical and usage information for website analytics, advertising measurement and related purposes.

JungleTrade currently uses Google services for these purposes.

Website Security and Traffic-Protection Service Providers

Used to protect JungleTrade against malicious traffic, automated abuse and other security threats.

Payment Service Providers

Where a payment is required, a third-party payment service may process payment and transaction information through its own service.

Professional Advisers and Authorities

Where necessary, personal data may be disclosed to professional advisers, accountants, legal advisers, competent authorities or other recipients where required by law or necessary to establish, exercise or defend legal rights.

We do not sell your personal data.

11. How Long We Keep Personal Data

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, unless a longer retention period is required or permitted by law.

Contact Inquiries and Correspondence

Personal data contained in contact-form submissions and related email correspondence is retained for as long as reasonably necessary to:

• respond to the inquiry;
• maintain relevant correspondence;
• manage a potential or existing business relationship;
• establish, exercise or defend legal claims where applicable.

Information that is no longer reasonably required for these purposes will be deleted in accordance with our applicable data-management practices.

Contractual and Commercial Relationships

Where an inquiry results in a contractual or commercial relationship, relevant correspondence and business information may be retained for the duration of the relationship and for an appropriate period afterwards where necessary for legal, contractual or legitimate business purposes.

Accounting and Transaction Information

Information that forms part of accounting, invoicing or transaction records may be retained for the period required by applicable Bulgarian accounting, tax and other legal requirements.

Analytics and Cookies

Retention of information associated with cookies and Analytics technologies depends on the relevant technology, configuration and your consent preferences.

When personal data is no longer required, we will delete or anonymize it where appropriate, unless continued retention is required by law.

12. How We Protect Personal Data

We take appropriate technical and organizational measures designed to protect personal data against:

• unauthorized or unlawful access;
• unauthorized disclosure;
• alteration;
• loss;
• destruction;
• other unlawful processing.

Access to personal data is limited to persons who reasonably require access for the relevant business purpose.

No method of electronic transmission or storage can guarantee absolute security. We therefore seek to maintain safeguards appropriate to the nature of the information and the associated risks.

13. Your Rights Under the GDPR

Subject to the conditions and limitations established by applicable law, you may have the following rights concerning your personal data:

Right of Access

You have the right to request confirmation as to whether we process personal data concerning you and, where applicable, obtain access to that personal data and related information.

Right to Rectification

You have the right to request correction of inaccurate personal data and completion of incomplete personal data concerning you.

Right to Erasure

You may request deletion of your personal data where the requirements of Article 17 GDPR are satisfied.

This right is subject to applicable exceptions, including where processing is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.

Right to Restriction of Processing

You may request restriction of processing where the requirements of applicable data-protection law are satisfied.

Right to Data Portability

Where applicable, you may have the right to receive personal data you have provided to us in a structured, commonly used and machine-readable format and to transmit that data to another controller.

Right to Object

Where processing is based on legitimate interests, you may have the right to object to the processing on grounds relating to your particular situation.

Right to Withdraw Consent

Where processing is based on your consent, you may withdraw that consent at any time.

For Analytics and Marketing technologies, consent can be changed through Cookie Settings.

Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

Right to Lodge a Complaint

You have the right to lodge a complaint with a competent data-protection supervisory authority.

In Bulgaria, the competent supervisory authority is:

Commission for Personal Data Protection (CPDP) Sofia 1592 2 Prof. Tsvetan Lazarov Blvd. Bulgaria

Website: https://cpdp.bg/en/

You may also contact another competent supervisory authority where applicable under the GDPR.

14. Exercising Your Rights

To exercise your data-protection rights or ask questions about how we process your personal data, contact:

[email protected]

We may need to request sufficient information to verify your identity before responding to certain requests.

We will respond to valid requests within the periods required by applicable data-protection law.

Under the GDPR, this is generally within one month of receiving a request. Where permitted by law, this period may be extended by up to two additional months depending on the complexity and number of requests. Where an extension applies, we will inform you accordingly.

15. Children

JungleTrade is intended for adult users and is not directed at children.

Our services are intended for users who are at least 18 years old.

We do not knowingly seek to collect personal data from children through JungleTrade.

If we become aware that personal data has been collected from a child in circumstances where it should not have been collected, we will take appropriate steps to delete the information unless we are legally required to retain it.

16. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• changes to JungleTrade functionality;
• changes to our processing activities;
• changes to service providers;
• legal or regulatory requirements;
• changes to our products and services.

The latest version will be published on the JungleTrade website.

Where a change materially affects how we process personal data or requires new consent, we will take appropriate steps to inform users or obtain consent where required.

17. Contact

If you have questions, concerns or requests relating to this Privacy Policy or the processing of your personal data, please contact:

J.Labs OOD Sofia 1766 251E Okolovrasten pat Str. “Ring Tower”, fl. 12 Bulgaria

Email: [email protected]