Privacy Policy

• Incorporated in Malta with Company Reg. No. C85571

Last updated: 29 April 2025

1. Introduction

ShareRing Ltd is committed to protecting your privacy. This Privacy Policy explains how we collect, use, share, and protect your personal data when you use the ShareRing Platform, in compliance with applicable global privacy laws, including:

• UK General Data Protection Regulation (UK GDPR)
• EU General Data Protection Regulation (EU GDPR)
• California Consumer Privacy Act (CCPA)
• Digital Identity and Attributes Trust Framework (DIATF)
• Other applicable national data protection laws

This Privacy Policy applies to all personal information collected by ShareRing Ltd and its affiliates when you use our products and services or interact with the ShareRing Platform.

2. Information We Collect

Information You Provide to Us

• Account Information: Name, contact details, billing details, and authorized
  representatives.
• User Content: Messages, posts, or uploaded identity verification documents.
• Payment Information: Billing and payment details processed securely.

Information We Generate

• Device &; Connection Data: IP address, device identifiers, operating system,
  and browser details.
• Usage Data: Platform interactions, access times, and language preferences.
• Fraud Prevention &; Identity Verification Data: Securely generated identity
  attributes used to detect fraud.

Information from Third Parties

• Business Partners: Employers, channel partners, or service providers may
  provide relevant details.
• Fraud Databases &; Compliance Checks: We may verify identity data against
  fraud prevention and compliance databases.
• Public Sources: Regulatory or law enforcement data, where required.

3. Lawful Basis for Processing Personal Data

ShareRing processes personal data under multiple lawful bases, depending on the processing activity:

3.1 Legitimate Interest (Primary Basis for Fraud Prevention, IdentityVerification &; Age-Restricted Purchases)

We process personal data under Legitimate Interest for:

• Fraud prevention and risk mitigation
• Age verification for age-restricted goods and services (e.g., alcohol, gambling,
  adult content, online purchases)
• Platform security and abuse prevention
• Regulatory compliance in financial and identity-based transactions

Justification: Fraud prevention, identity verification, and age verification are necessary security measures, and processing identity data is proportionate to this purpose.

Users have the right to object to processing under Legitimate Interest, as outlined in Section 7 (User Rights).

3.2 Consent (For Data Sharing with Relying Parties – RPs)

We process personal data under Consent for:

• Identity verification and authentication

Also, users must still explicitly consent before sharing their verified identity data with
a Relying Party (RP) (e.g., banks, merchants, age verification services).

Justification: Users remain in control of their identity data and must approve any data
sharing for specific transactions.

Users can withdraw consent at any time, but this may impact their ability to complete
certain transactions.

4. How We Use Your Information

We use your information for:

• Providing and improving services – To operate and maintain the ShareRing
  Platform.
• Fraud prevention, age verification, and security – To verify identities and
  prevent fraudulent activity.
• Regulatory compliance – To comply with applicable laws and financial
  regulations.
• Communication – To send updates and service-related communications

5. Sharing Your Information

We may share your data in the following circumstances:

• With Service Providers – Payment processors, hosting providers, and fraud
  prevention services.
• With Relying Parties (RPs) – Only with explicit user consent.
• With Authorities – To comply with legal obligations or law enforcement
  requests.

6. International Data Transfers

Your data may be processed in countries outside your location, including Australia, the UK, the EU, and the US.

We apply:

• Standard Contractual Clauses (SCCs) for UK/EU transfers
• Adequacy decisions where applicable
• Industry-standard security measures to protect data integrity

7. User Rights &; Opt-Out Mechanism

Users have the following rights under GDPR and applicable privacy laws:

• Right to Object to Processing Under Legitimate Interest – Users may object where applicable.
• Right to Withdraw Consent – Users can withdraw consent for RP data sharing.
• Right to Access &; Correct Data – Users can request access to personal data processed under Legitimate Interest.
• Right to Lodge a Complaint – Users can report concerns to the UK Information Commissioner’s Office (ICO) or relevant authority.

8. Data Retention &; Security

• We retain personal information only as long as necessary for its intended
  purpose or legal obligations.
• Encryption, access controls, and security audits are used to protect data
  integrity.

9. Updates to This Policy

We may update this Privacy Policy periodically. The latest version will always be
available on our website.

10. Contact Us

For privacy inquiries or to exercise your rights, contact:

● Email: privacyofficer@sharering.network
● Website: sharering.network/contact