Data Protection, Anti-Money Laundering, and Know Your Customer Policy for SITEnetwork (Xpedition z.o.o.) and Xpedition Token (XPED)

This Data Protection, Anti-Money Laundering (AML), and Know Your Customer (KYC) Policy outlines the internal practices and procedures adopted by SITEnetwork (legal name: Xpedition z.o.o.) to ensure compliance with the General Data Protection Regulation (GDPR), European Union anti-money laundering regulations, and KYC requirements in relation to our Initial Coin Offering (ICO) for the Xpedition crypto coin (XPED).

We are committed to maintaining the highest standards of transparency, accountability, and data security, and this policy is intended to clarify our approach to data processing, anti-money laundering, and customer identification to protect our customers, users, and stakeholders.

1. General Data Protection Regulation (GDPR) Compliance

Data Collection

For our ICO and related activities, we collect and process personal data from participants. This may include but is not limited to names, addresses, email addresses, payment information, and identification documents.

Data Use

We process personal data for the following purposes:

• To verify the identity of our users (KYC).
• To ensure compliance with AML regulations.
• To execute smart contracts and enable participation in our token sale.
• To provide customer support and communicate with users about their participation.

Data Retention

We retain personal data only for as long as is necessary to meet legal requirements and to serve the purposes for which it was collected. We implement procedures for the secure deletion of personal data after its retention period has expired.

Data Security

We have adopted industry-standard encryption and security protocols to safeguard personal data. Access to personal information is restricted to authorized personnel only, and we regularly review our security practices to ensure that they remain in line with best practices. Data processors for KYC have ISO and appropriate certification standards.

Data Subject Rights

Users have the following rights regarding their personal data:

• The right to access the data we hold about them.
• The right to request corrections to their data.
• The right to request the deletion of their data (subject to legal retention requirements).
• The right to restrict processing or object to the use of their data in certain cases.

2. Anti-Money Laundering (AML) and Know Your Customer (KYC) Compliance

Know Your Customer (KYC)

In accordance with EU law, SITEnetwork has implemented KYC procedures to verify the identity of all participants in our ICO. All participants are required to provide identification documents, such as passports or government-issued IDs, as part of the registration process.

We utilize a combination of manual and automated processes to:

• Confirm the authenticity of identification documents.
• Cross-check identity information with international watchlists and databases.
• Prevent identity theft, fraud, and other illicit activities.

Anti-Money Laundering Protections in Line with EU Legislation (AML)

SITEnetwork is committed to preventing the use of its services and platform for money laundering or terrorist financing. Our AML policy complies with the 5th Anti-Money Laundering Directive (AMLD5) of the European Union, as well as local regulations.

We monitor and assess transactions for suspicious activity, using both automated transaction monitoring tools and human oversight. If suspicious activity is detected, we may take actions including, but not limited to:

• Reporting suspicious transactions to relevant authorities.
• Freezing transactions or accounts pending further investigation.
• Terminating accounts found to be in violation of our policies.

Transaction Monitoring

We continuously monitor crypto transactions on our platform to detect patterns or behaviour indicative of money laundering. Users are required to provide additional information and documentation for transactions that meet certain thresholds or exhibit unusual patterns.

In keeping with EU directives, individuals from the following countries known as the “EU Country Sanctions List” may not participate in SITEnetwork XPED token offerings:

• Belarus, Russia, Guatemala, Nicaragua, Venezuela, Guinea, Mali, Niger, Libya, Sudan, South Sudan, DR Congo, Somalia, Zimbabwe, Turkey, Iraq, Iran, Afghanistan, Ukraine, Moldova, Myanmar, North Korea, Yemen.

Individuals from any of the following countries, either resident or who hold passports from these countries will be subject to additional screening or may be denied entry into the token sale at any time and without notice:

• Panama, Philippines, Senegal, South Africa, Tanzania, Trinidad and Tobago, Uganda, UAE, Vanuatu, Vietnam, Barbados, Burkina Faso, Cameroon, Haiti, Gibraltar, Jamaica, Mali, Mozambique, Nigeria.

Any individual or entity appearing on any of the following lists is also excluded from our sale and all blacklists will be searched:

• Council Regulation (EU) No. 833/2014 concerning restrictive measures in connection with Russia's actions destabilizing Ukraine.
• Council Regulation (EU) No. 269/214 on restrictive measures with regard to actions undermining Ukraine's integrity.
• Regulation (EC) No. 765/2006 concerning measures against Belarus' involvement in Russia's aggression against Ukraine.
• US BIS Denied Persons List, Polish Sanctions List, EU Sanctions List, UK Sanctions List, UN Sanctions List, World Bank Sanctions, EU Country Sanctions, Polish List of Restrictive Measures.

3. User Consent and Policy Updates

By participating in the ICO or using our services, users consent to the collection, processing, and retention of their personal data in line with this policy. We may update this policy periodically to reflect changes in legal requirements or internal procedures, and we will notify users of significant changes.

4. Contact Information

For any questions or concerns about this policy, or to exercise your GDPR rights, please contact us at:

SITEnetwork (Xpedition z.o.o.)
GDPR@sitenetwork.io

Our Data Protection Officer is - David Sime gdpr@sitenetwork.io

This policy is effective as of 16/09/2024.

Please contact us at info@Sitenetwork.io if you wish to make a request.

How to complain:

If you have any concerns about our use of your personal information, you can make a complaint to us at: info@SiteNetwork.io