Privacy Policy

‍Effective date: 30.09.2026

Introduction

Mint Group ("Mint", "we", "our" or "us") respects your privacy. This Policy explains what personal data we gather when you use the Mint website: [TBD] (the "Site") and our related services (together, the "Services"). It also covers why we use that data, when we may disclose it, how long we hold it, how we protect it, and what choices you have. Questions about this Policy can be sent to [TBD].

At a Glance

• Data we collect. The data depends on how you engage with the Services and which features you use.
• Special categories of data. We do not collect or handle sensitive personal data.
• Third-party sources. We obtain personal data only from you. We do not receive it from external sources.
• Why we use it. We use it to operate and improve the Services, to stay in touch with you, to prevent fraud and misuse, and to meet our legal duties. We use it for any other purpose only with your consent.
• Security. We apply technical and organisational safeguards. No system is fully immune to breaches, though.
• Your choices. Depending on the laws of your country, you may have specific rights over your data.

Contents

• Personal Data We Collect
• Purposes of Processing
• Disclosure of Personal Data
• Data Retention
• Data Security
• Your Rights and Choices
• Tracking Prohibition
• Changes to This Policy
• Contact Us

1. Personal Data We Collect

We collect only the data you choose to give us. This happens, for example, when you ask about Mint or our Services, take part in activities offered through the Services, or get in touch with us in any other way.

What we collect depends on the nature of your interaction with us. It may include:

• your name;
• your telephone number;
• your email address;
• other provided by you data for conclusion agreement.

We do not ask for, and do not process, any sensitive personal data. Please make sure the information you give us is accurate, complete and up to date. Let us know if any of it changes.

2. Purposes of Processing

We rely on a valid legal ground whenever we process your personal data. We use it to:

• provide the Services you have asked for;
• send you service-related notices, including information about our offerings and updates to our terms and policies;
• legal, when it allows under applicable law;
• send you marketing communications, where this matches the marketing preferences you have set.

We may also use your data for other purposes if you have agreed to this.

3. Disclosure of Personal Data

We disclose personal data only in the limited cases set out below.

Corporate transactions. We may transfer your data as part of a merger, acquisition, financing, sale of company assets, or transfer of all or part of our business to another entity. This also applies while such a transaction is being negotiated.

Authorities. We may provide personal data on government authorities request.

4. Data Retention

We keep your data only as long as needed for the purposes in this Policy. We keep it longer only if the law requires or allows us to, for example for tax or accounting reasons.

Once we no longer have a legitimate business reason to hold your data, we delete it or make it anonymous. Sometimes immediate deletion is not technically possible, for instance when data sits in backup archives. In that case we store it securely and keep it out of any further use until it can be erased.

5. Data Security

We have appropriate technical and organisational measures in place to protect the personal data we handle. Even so, no online transmission or storage method is completely secure. We therefore cannot guarantee that unauthorised parties will never access, alter or misuse your data. You send data to and from the Services at your own risk. We recommend using the Services only from a secure environment.

6. Your Rights and Choices

Withdrawal of consent. Where we process your data based on your consent, you may withdraw it at any time by contacting us at the address in Section 9. Withdrawing consent does not affect processing that took place before you withdrew it. It also does not affect processing we carry out on other lawful grounds, where the law allows this.

Marketing opt-out. You can stop receiving our marketing emails at any time. Use the unsubscribe link in any such email or contact us directly, and we will remove you from our marketing lists. We may still send you non-promotional messages, such as replies to your requests or notices needed to provide the Services.

For any questions about your rights, write to [TBD].

7. Tracking Prohibition

Some browsers, operating systems and apps have a Tracking Prohibition ("TP") setting that tells websites you do not want your online activity tracked. There is currently no agreed industry standard for recognising TP signals. For this reason, the Site does not respond to them or to similar mechanisms. If a binding standard is adopted in the future, we will explain how we handle it in an updated version of this Policy.

8. Changes to This Policy

We review this Policy periodically and update it when needed to comply with applicable law. Each revision will show a new effective date and applies as soon as it is published. If we make significant changes, we may tell you through a prominent notice on the Site or by contacting you directly. We encourage you to check this Policy from time to time.

9. Contact Us

If you have any questions, please email us at [TBD].

10. Law

Any disputes arising out of or in connection with this Policy shall be governed by the laws of Cyprus, and the courts of Cyprus shall have exclusive jurisdiction over any such disputes.

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