PRIVACY POLICY

Sincere Systems Group asks you to read thoroughly this Policy. When we use
"We", “Sincere Systems Group” in the text of this Policy we mean Sincere
Systems Group LTD, a company registered in 71-75 Shelton Street, London,
Greater London, United Kingdom, WC2H 9JQ, registration number 12695421,
which is the developer and
the owner of the different products and services under the brand “Sincere Systems
Group”, including but not limited to Sincere Systems Group platform, bot, website
and software in general (hereinafter collectively referred to as the "Sincere Systems
Group").

Sincere Systems Group is the controller of the personal data of the users of the
Sincere Systems Group (hereinafter referred to as the "Clients"). The controller of
the personal data is the person or entity who determines the purposes and means of
the processing of personal data.

We have prepared this new Policy, taking into account the latest changes in the
legislation regulating the protection of personal data, in particular, taking into account
the requirements of the General Data Protection Regulation (GDPR).

Sincere Systems Group is committed to transparency in the collection and use

of your personal information. We recognize the right of all our Clients for
confidentiality. Protection of personal data of our Clients is our top priority.

This Policy sets forth a description of how we collect, store, use and protect
personal information, and the circumstances under which we may share this
information. This Policy also describes your data protection rights, including your
right to object to some of the processing which Sincere Systems Group carries out.
More information about your data protection rights and how to exercise them is set
out below. This Policy applies to all visitors to the Sincere Systems’s Group official
website, located at https://s-group.io (the “Website”).

DATA COLLECTION

You are not obliged to provide us any personal data that we might need, but your
refusal to provide personal information necessary, which is for us, might be the
reason why we will not be able to provide you all Sincere Systems Group entirely,
such as opening of User Account, virtual currency exchange and wallet services,
participation in a bonus program and technical support.

On our part, we state that we will not sell your personal data and will use
your personal data in accordance with the requirements of this Policy and for
the purposes specified herein.
The following information will be collected from you when you use our services
through the following:

Registration and Verification: While registering on our Website to establish a User

Account, we will request for the necessary personal data to avail the services
requested. Such personal data may include; name, website, telephone number,
address, electronic mail address, business registration/incorporation certificates,
utility bill, location/IP address, identity card, payment details. We may as well request
for additional personal data as you use our services.

Third Party Sources: Depending on the nature of the services provided by us to our
partners or suppliers, we may receive personal data either from you directly or from
our partner or supplier who provides us with the personal data to fulfill a service to
you on their behalf.

Customer Support: When interacting with our customer service, you may be asked
to provide us with additional personal data.

LEGAL GROUNDS

Sincere Systems Group collects and processes your data based on the
following legal grounds:

1. Existence of a contract between the Client and Sincere Systems Group: By

creating a User Account and using Sincere Systems Group, you and Sincere
Systems Group conclude a contract for the provision of services. In order to
provide you with Services as a whole, as well as with a separate component, we
must collect and process certain data about you.

2. Legitimate interest: Sincere Systems Group uses a legitimate interest in

processing your data, for example, when Sincere Systems Group processes your
data to fix bugs in the Sincere Systems Group and to ensure its smooth operation,
to improve the work of the Sincere Systems Group, to develop and to introduce
new functions and services, to ensure security of Clients when using the Sincere
Systems Group, and to ensure secure work of the Sincere Systems Group, to
transfer data within the organizational structure of Sincere Systems Group, for
example, to affiliated companies, to transfer certain information at the request of the
intellectual property rights holders who claim that a particular Client has placed
illegal content. We will not use legitimate interest as a basis for processing of the
Client data if the rights, freedoms and interests of the Client override the interest of
Sincere Systems Group or third party.
3. Legislative requirements: Sincere Systems Group may process Client’s data, if
it is required by the law that applies to Sincere Systems Group. For example,
Sincere Systems Group may provide data on Clients at the request of courts or
other authorized bodies.

4. Consent: Sincere Systems Group relies solely on your consent when uses
personal data for the purpose of opening and activation of User Account, providing
virtual currency exchange and wallet services, participation in a bonus program,
technical support, marketing, notification and promotional mailing, or for other
purposes for which a specific Client’s consent must be granted.

USE OF PERSONAL DATA

Personal information obtained from you can be used by Sincere Systems Group
only to the extent necessary in order for opening, activation and further
maintenance of a User Account, providing virtual currency exchange and wallet
services, participation in a bonus program and technical support and communication
with you regarding the status of your account, verification of your identity and further
cooperation, to process any of your transactions, personalize your experience,
analyze usage Sincere Systems Group by the Clients, or help with any service the
Client requests.

Sincere Systems Group may provide references or links to other websites

("External Websites"), which Sincere Systems Group does not control.
External Websites have separate and independent privacy policies. Clients
are encouraged to review the policies, rules, terms, and regulations of each
site that they visit.

In case of User Account deactivation, Sincere Systems Group keeps information

about you in secret except for cases when disclosure is required in accordance with
regulatory requirements, to prevent fraud, and when it use it to contact you from
time to time to inform you about the possibility to re-open your User Account and
take advantage of attractive offers.

SECURITY OF YOUR PERSONAL INFORMATION

We have implemented reasonable administrative, technical and physical measures

in an effort to safeguard the personal information in our custody and control
against theft, loss and unauthorized access, use, modification and disclosure. Put
please note that transmission of data or information (including communications by
e-mail) over the Internet or other publicly accessible networks may not always be
secure, and may be subject to possible loss, interception, or alteration while in
transit. Accordingly, Sincere Systems Group does not assume any liability, without
limitation, for any loss or damage you may experience or costs you may incur as a
result of any transmissions over the Internet or other publicly accessible networks,
containing your personal information. While Sincere Systems Group will take
commercially
reasonable efforts to safeguard the privacy of the information you provide to Sincere
Systems Group and will treat such information in accordance with the Policy
contained herein, in no event will the information you provide to Sincere Systems
Group be deemed to be confidential, create any fiduciary obligations for Sincere
Systems Group, or result in any liability for Sincere Systems Group in the event that
such information is accessed by third parties without Sincere Systems`s Group
consent.

Sincere Systems Group security measures include security feature such as

password entry requirement for User Account.

Sincere Systems Group uses two-tier authentication measures to ensure secure

access to your User Account.

Please remember: you are responsible for the security of your User Account number,
your Initial Wallet ID and password. We strongly recommend that you do not disclose
this information to anyone else.

STORAGE OF YOUR PERSONAL INFORMATION

We store your personal data only when it is necessary for you or Sincere Systems
Group for the purposes indicated in this Policy. If Sincere Systems Group does
not need certain information about you and does not need to store information
about you in accordance with the requirements of the law, we will delete it or will
store it in anonymized way.

We also keep a record of the fact that you have asked us not to send you direct
marketing so that we can respect your request in future.

Please note, if you delete your User Account, some personal data will remain in
Sincere Systems`s Group system in anonymized form, it will be stored in such a way
that it will be impossible to identify the Client. This is necessary to give Sincere
Systems Group an opportunity to check whether a Client was previously registered
or not. Sincere Systems Group will use such data only in order to prevent fraud,
when a Client who violates the Sincere Systems Group Terms and Conditions and
whose User Account was deleted will attempt to re-register within the Sincere
Systems Group system again. By saving such data, Sincere Systems Group will rely
on its legitimate interest.

DISCLOSURE OF PERSONAL INFORMATION

We do not transfer, sell, rent, trade or otherwise disclose your personal

information, except as described in this Policy.

We may transfer or disclose your personal information as follows:

1. Service Providers: Your personal information may be disclosed, stored and / or
transferred (or otherwise made available) to our affiliates, subsidiaries, third parties
who provide services such as identification and background checks, website hosting;
to third parties — processors, namely, companies, which help Sincere Systems
Group collect, record, store, analyze, structure and process information or perform
other actions according to Sincere Systems Group instructions; and to exchanges,
trading platforms and financial institutions. Abovementioned persons adhere to
confidentiality rules with regard to your information to the same extent as Sincere
Systems Group according to this Policy.

2. Legal and Compliance: Sincere Systems Group may share your personal
information with law enforcement, data protection authorities, government
officials, and other authorities if (i) compelled by subpoena, court order, or other
legal procedure, (ii) disclosure is necessary to prevent physical harm or financial
loss, (iii) necessary to report suspected illegal activity, or (iv) disclosure is
necessary to investigate violations of Clients’ obligations or potential violations of
law.

3. Sale of Business: Your personal information may be provided to third parties in

the case of carrying out mergers and acquisitions operations, including for the
purpose of determining whether to proceed or continue with such transaction or
business relationship.

4. International Transfer: The data of the Clients from the EU can be transferred to
third countries outside the EU and the European Economic Area. If such data is
transferred outside the countries of the EU and the European Economic Area to the
third countries, Sincere Systems Group will use appropriate measures to ensure
that such a transfer is legal. The measures might include the standard contract
clauses approved by the European Commission.

USE OF COOKIES

Sincere Systems Group uses cookies. Cookies are small text files that are placed
on your computer by websites that you visit. They are widely used in order to make
websites work, or work more efficiently, as well as to provide information to the
owners of the site. Cookies are typically stored on your computer's hard drive.

Sincere Systems Group uses cookies in order to enhance the security of your
operations on the Platform, evaluate the effectiveness of its Services, analyze
trends, work of referral links, and administer the Sincere Systems Group platform.
Cookies used by Sincere Systems Group do not contain personal information, nor
User Account or password data. With their help, the Website can determine that a
request to view the page comes from a person who has already performed the
entry.
In order to mark viewed pages, so-called “pixel tags” (also known as “clear gifs”
or “web beacons”) are used. Information gathered by advertising companies with
the help of “pixel tags” does not enable to establish identity.

The information collected from cookies allows Sincere Systems Group to determine
such things as which parts of the website are most visited and difficulties our
Clients may experience in accessing our site. With this knowledge, Sincere
Systems Group can improve the quality of Clients’ experience on the Sincere
Systems Group platform by recognizing and delivering more of the most desired
features and information, as well as by resolving access difficulties.

RIGHT TO ACCESS TO PERSONAL DATA

If you want to find out an exhaustive list of data, which Sincere Systems Group has
about you, you may use your right to access information about yourself. To
exercise this right, please send a request to the following email address:
[email protected]. Sincere Systems Group may ask you to carry out additional
verification procedures to ensure that the information is provided to the right Client.
Sincere Systems Group responds to such requests for free, but a Client abuse can
lead to the fact that Sincere Systems Group will refuse to process the request or
will ask such a Client to pay a fee.

RIGHT TO WITHDRAW YOUR CONSENT

If Sincere Systems Group asks you to give the consent, you can always
withdraw your consent to processing personal data by changing the
appropriate settings. By withdrawing your consent to processing data, you still
have an access to the Sincere Systems Group, but some functions or
components may not be available to you.

In case you do not want that Sincere Systems Group processed your data for any
purpose, you can always easily delete your User Account and in this case, please,
contact us for the returning of funds.

Please note, if you delete your User Account, some personal data will remain in
Sincere Systems’s Group system in anonymized form, it will be stored in such a way
that it will be impossible to identify the Client. This is necessary to give Sincere
Systems Group an opportunity to check whether a Client was previously registered
or not. Sincere Systems Group will use such data only in order to prevent fraud,
when a Client who violates the Sincere Systems Group Terms and Conditions and
whose User Account was deleted
will attempt to re-register within the Sincere Systems Group system again. By
saving such data, Sincere Systems Group will rely on its legitimate interest.
You can revoke consent and/or request deletion of your personal data by the way of
contacting us by E-mail at: [email protected].

THE RIGHT TO DATA PORTABILITY

You have the right to send data, which Sincere Systems Group collects about you
based on your consent and on the contract that exists between you and Sincere
Systems Group, to another organization. Sincere Systems Group can independently
transmit such data to another organization according to your instructions, but only if
Sincere Systems Group has a technical ability to do so. To exercise this right, please
send a request to the following email address: [email protected]. Sincere
Systems Group may ask you to carry out additional verification procedures to make
sure that the data is provided to the right Client. Sincere Systems Group responds to
such requests for free, but a Client abuse can lead to the fact that Sincere Systems
Group will refuse to process the request or will ask such a Client to pay a fee.

THE RIGHT TO DATA CORRECTION

You have the right to change your personal data if data, that Sincere Systems
Group has at its disposal, are outdated or inaccurate. You can change your profile
information in your User Account settings. In case you have difficulties in changing
your information, please contact us at [email protected].

THE RIGHT TO BE FORGOTTEN

In certain cases, i.e., if you withdraw your prior consent or if you object to processing
of your personal data based on legitimate interest, and we do not have any interest
that prevails over your rights, freedoms and interests, you have the right to ask us to
remove the data that we have about you. To exercise this right, please contact us at
the following email address: [email protected]. Sincere Systems Group may ask
you to perform additional verification procedures to make sure that the appropriate
Client has contacted it. There are certain cases in which the above described right
cannot be exercised. We will inform you if they occur.

Please note if you will execute your right to be forgotten and delete your User
Account, some personal data will remain in Sincere Systems’s Group system
in anonymized form, it will be stored in such a way that it will be impossible to
identify the Client. This is necessary to give Sincere Systems Group an
opportunity to check whether a Client was previously registered or not.
Sincere Systems Group will use such data only in order to prevent fraud,
when a Client who violates the Sincere Systems Group Terms and
Conditions and whose User Account was deleted will attempt to
re-register within the Sincere Systems Group system again. By saving
 such data, Sincere Systems Group will rely on its legitimate interest.

SUBMITTING A REQUEST

Sincere Systems Group will process your request and will respond to it within 7
business days from the receipt of the corresponding request from you. In some
cases, this period may be extended by two months. This might occur, for example,
for technical reasons or because of a big inflow of requests. You will be notified of
such extension and the reasons for it within 7 business days from the receipt of
your request.

Sincere Systems Group accepts and processes the requests for personal data
free of charge. However, if there are reasons for Sincere Systems Group to
believe that requests are sent unfairly, we reserve the right to refuse processing
such requests or to establish a reasonable fee for such processing.

CHANGES TO THE POLICY

In the event of changes made to this Policy, the modified version will be immediately
published on the Website. You should regularly review this Policy. If the changes in
this Policy are significant, we will do our best to inform you about the changes and to
make such changes clearly introduced to you. If changes to this Policy are not
significant, we will notify you of such changes by posting the updated Policy on our
Website.

CONTACT US

You understand and agree that all communication with you will be via email. Please
contact us if:

● you have any questions, inquiries or comments about this Policy;

● you wish to access, update, and/or correct inaccuracies in your
personal information; or
● you otherwise have a question or complaint about the manner in which we
or our service providers treat your personal information.
You may contact us by E-mail at [email protected].

MISCELLANEOUS

This Privacy Policy comes into force on June 1, 2019.