Last revised: 14.03.2023

This is the Privacy Notice of GlobiancePay PTE. LTD. limited by shares (hereinafter – “Company”, “we’, “us “,”our”). This document together with our [Terms of Use](indicate the terms of use link) sets out the basis on which any personal data we collect from you, or that you provide to us as a user of our services, will be processed by us for provision of our services to you through our website and/or other applicable software. The website can be accessed via the following link: []( (hereinafter – the “Website”). Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our Website, you are accepting and consenting to the practices described in this Privacy Notice.

We take the protection of our user’s (“user/you/your”) personal data very seriously and strictly comply with applicable data protection laws and regulations. In this Privacy Notice below we provide you with an overview of what data we collect for what purpose and how we ensure the protection of such data.
1) Purpose and Legal Basis of Processing Data; Legitimate Interests

1.1. Legal basis for collection and processing of your personal data.

We will only collect, use and/or pass on Personal Data if this is permitted by law or if the user consents to the data processing. Applicable legal provisions are in particular those of the regulation the General Data Protection Regulation (EU) 2016/679, the Data Protection Act, the Data Protection Regulations. We will only collect, use and/or pass on Personal Data if this is permitted by law or if the user consents to the data processing.

1.2. Your data will be used for the following purposes:

- To implement this Privacy Notice and carry out the contractual relationships between you and us regarding our services available via the Website and/or our other software;
- To contact you in any matters regarding our services (also using emails and messaging), and to ensure the technical functionality of our services and fulfillment of contractual or pre-contractual obligations;
- To prevent fraudulent behavior by any of our users;
- To analyze your use of our services and improve our services;
- With your express consent or instruction to carry out our business activities or send you newsletters and other advertising materials;
- To follow our internal policies and protect our legitimate interests;
- To save your blockchain data (e.g. your wallet address) on the distributed ledger;
- To comply with our legal obligations before third parties involved in the process of provision of our services;
- To provide you with information about other goods and/or services we offer that are similar to those that you have already purchased or enquired about;
- To provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. You have the right to request we not process your data for direct marketing;
- To notify you about changes to our services;
- To ensure that content from our Website is presented most effectively for you and your device;
- For other purposes otherwise explained in this Privacy Notice or by any further communication from us;
- To comply with any applicable ‘know your customer’, anti-money laundering, or anti-terrorist financing laws and regulations in any jurisdiction in which we operate.

2. Your Consent

We can collect and process your data with your consent. By clicking the “I Agree” button on any of our resources or using our Website, or other of our services you confirm that you fully agree with this Privacy Notice and provide explicit and full consent to us for the collection, processing, and transferring of your data.

3. Recipient(s) of Your Data

We, as well as our external service providers, receive your data for the provision of our services. We may need to share your information with our external service providers, affiliates, and/or agents. We require that third-party organizations who handle or obtain personal information as service providers acknowledge its confidentiality and undertake to respect an individual’s right to privacy and comply with data protection principles including this Privacy Notice.

Information We May Collect From You

4.1. We may collect and process the following data about you:

- Your name;
- Physical address;
- E-mail address and phone number;
- Credit card information, XDC wallet address, and other financial information applicable for the provision of our services;
- Date of birth;
- Gender and nationality.
To obtain the above-mentioned information we may either ask you during your filling of any forms (e.g. registration forms) to access our services. Or, we may ask you to provide us with copies of respective documents by phone, e-mail, or otherwise. Such documents include but are not limited to:
- Passport;
- Driver’s license;
- Transaction history;
- Certificates.

4.2. Company may also gather data about you:

- When you engage with us on social media;
- When you enter prize draws or competitions;
- When you book any kind of appointment with us or book to attend an event;
- When you choose to complete any surveys we send you;
- When you comment on or review our products and services;
- When you’ve given a third-party permission to share with us the information they hold about you;
- When Company suppliers and partners share information with us.

4.3. We may collect your data from publicly-available sources when you have given your consent to share information or where the information is made public as a matter of law in relation to KYC and AML regulations.

4.4. We may collect notes from our conversations with you, details of any complaints or comments you make, details of investments you made, and how and when you contact us.

4.5. Concerning each of your visits to our Website we may automatically collect the following information:

- Technical information, including the internet protocol (IP) address, used to connect your computer to the internet;
- Browser type and version;
- Time zone setting;
- Browser plug-in types and versions;
- Operating system and platform;
- Information about your visit, including the full uniform resource locators (URL) clickstream to, through, and from our Website (including date and time);
- Products you viewed or searched for;
- Page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs);
- Methods used to browse away from the page and any phone number used to call our customer service number.

4.6. Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment, and delivery services, advertising networks, analytics providers, search information providers, and credit reference agencies) and may receive information about you


GlobiancePay PTE. LTD. limited by shares

Terms of Use

Last revised: 14.03.2023

These GlobiancePay PTE. LTD.Terms of Use (hereinafter – the “Terms of Use”) apply to and govern your permitted users’ access to and use of the XDC based application (the – “Platform”) and the services and tools made available on the Platform (collectively, the “Services”).

These Terms form the agreement between GlobiancePay PTE. LTD. limited by shares (“we”, “us”, “our”) and you as a physical person or the legal entity which you represent (“you” or “your”), and constitute a binding legal agreement. ‍

Please read these Terms of Use carefully, as they govern your use of our Services, and expressly cover your rights and obligations, and our disclaimers and limitations of legal liability, relating to such use. By clicking “I Agree” to the Terms of Use or using the Services, you accept and agree to be bound by and to comply with these Terms of Use. If you do not agree to these Terms of Use, you must not access or use our Services.

For clarity and understanding, the terms listed below shall have the following meaning:

“Account” – a user account assigned to you after completion of the registration procedure, available via the

“Affiliate” means, concerning a party to these Terms of Use, any legal entity that, directly or indirectly controls, is controlled by or is under common control with such party.

“Applicable Law” has the meaning set out in Section 12.

GBPAY – means the native token of XDC Blockchain that may be used to purchase computational resources to run decentralized applications or perform actions on the XDC Blockchain.

XDC means the underlying blockchain infrastructure that Company utilizes to provide its Services.

“Governmental Authority” includes any domestic or foreign federal, provincial or state, municipal, local or other governmental, regulatory, judicial, or administrative authority.

“Investor” – a user who has a registered Account, has access to the Platform, and utilizes the Services to purchase a portion of GBPAY tokens.

“Services” has the meaning set out in article 3.1 below.

GBPAY – a security token which is a form of Company’s digital non-voting shares, which can be purchased by the Investors via Platform (the terms of which are more fully set out in Memorandum).

“Usage Fees” has the meaning set out in article 3.2 below.

2. MODIFICATIONS TO THE GlobiancePay PTE. LTD. limited by shares TERMS

We reserve the right, in our sole discretion, to modify Terms From time to time. Any and all such modifications are effective immediately upon posting. By clicking “I Agree” to any modified terms or by continuing to access or use the Services, you accept and agree to be bound to the modified terms. You agree to frequently review the Terms to ensure that you are aware of any such modified terms.

3. Company’s Platform SERVICES, FEES

3.1. Provision of access to a set of instruments that allows you to purchase and utilize our tokenized securities via the Platform. The mentioned Services consist of the following actions and items (but not limited to them): tools to validate yourself as an investor, including but not limited to completion of our Know Your Customer (“KYC”) procedures;
tools to purchase our GBPAY token and enjoy other available services.

3.2 Usage Fees – We may charge fees to you in consideration of your use of certain Services, including, but not limited to, access to the Platform. The details of the Usage Fees, including the amount of each Paid Service costs, when Usage Fees apply and how they are calculated can be found here. GlobiancePay PTE. LTD.reserves the right to change the Usage Fees at any time, and will provide you with a notice of any such fee changes before they become effective.

3.3 Acceptance of payment – notwithstanding the amount of tokens you have indicated in the appropriate line on the Platform, we will transfer you tokens only in the amount that you have paid for, meaning that if there is a discrepancy between the amount of tokens that you put in the appropriate line on the Platform and the amount of money you have paid, we will transfer you an amount of tokens equal to the amount of received payment.

3.4. Return of payments – Please note, that we will transfer your funds back in the following cases:

– if you have provided payment in the amount which is less than the established minimum cap for token purchase;
– if you have provided payment via any bank, wallet address or other payment instrument which is different from the whitelisted one during the registration procedure;
– in the event that you fail to complete any KYC procedure required or undertaken by GlobiancePay PTE. LTD. at any time (including, without limitation, any KYC procedure required or undertaken subsequent to any initial KYC procedure pursuant to which GlobiancePay PTE. LTD. requires any additional or updated documentation).

4.1 Account – You must have a registered account on our website to use the Services. During registration, to create an Account, we will ask you to provide certain information, including, but not limited to: your name, your physical address, your email address, and/or your blockchain Address.

4.2 Your Responsibilities – As a condition to accessing or using the Services, you shall:

4.2.1 only use the Services for lawful purposes and under these Terms of Use;

4.2.2 ensure that, at all times, all information that you provide for the Services, including the information in your Account, is complete and accurate;

4.2.3 maintain the security and confidentiality of your Account and XDC Address.

4.3 Unacceptable Use or Conduct – As a condition to accessing or using the Services, you will not:

4.3.1 violate any Applicable Law, including, without limitation, any relevant and applicable anti-money laundering and anti-terrorist financing regimes;

4.3.2 infringe on or misappropriate any contract, intellectual property, or other third-party rights using the Services;

4.3.3 use the Services in any manner that could interfere with, disrupt, negatively affect, or inhibit other users from fully enjoying the Services, or that could damage, disable, overburden, or impair the functioning of the Services in any manner;

4.3.4 attempt to circumvent any content filtering techniques or security measures that GlobiancePay PTE. LTD. employs for the Services, or attempt to access any service or area of the Services that you are not authorized to access;

4.3.5 use any malware or other automated means not provided by us, to access the Services or to extract any data which can be gained utilizing the Services;

4.3.6 use or attempt to use another user’s Account without authorization;

4.3.7 post content or communications using the Services that we, in our sole discretion, consider to be libelous, defamatory, profane, obscene, pornographic, sexually explicit, indecent, lewd, vulgar, suggestive, harassing, hateful, threatening, offensive, discriminatory, bigoted, abusive, inflammatory, fraudulent, deceptive or otherwise objectionable;

4.3.8 use the Services from a jurisdiction that we have, in our sole discretion, or a relevant Governmental Authority has determined is a jurisdiction where the use of the Services is prohibited;

4.3.9 encourage or induce any third party to engage in any of the activities prohibited under Section

4.4 Your Assumption of Risks – You represent and warrant that you:

4.4.1 have the necessary technical expertise and ability to review and evaluate the security, integrity and operation of any tokens, including GBPAY, that you decide to interact with;

4.4.2 have the knowledge, experience, understanding, professional advice and information to make your own evaluation of the merits, risks and applicable compliance requirements under Applicable Law of any security token activity you engage in and are able to incur a complete loss of any amounts invested using the Platform without impairing your financial condition;

4.4.3 know, understand and accept the risks associated with your blockchain Address, the XDC Network, GBPAY

4.4.4 accept the risk of purchasing GBPAY exchanging them and otherwise utilizing the Services, and are responsible for conducting your own independent analysis of the risks specific to your use of the Services;

4.4.5 understand and accept that the Services are software applications consisting of code subject to flaws and that you acknowledge that you are solely responsible for evaluating any code provided and for evaluating the functioning of any Services accessed without any liability to GlobiancePay PTE. LTD.

4.5 Account Activities – You acknowledge and agree that you will be bound by, and hereby authorize GlobiancePay PTE. LTD. limited by shares to accept and rely on any agreements, instructions, orders, authorizations and any other actions made, provided or taken by anyone who has accessed or used your Account, regardless of whether such access is authorized or unauthorized. You further acknowledge and agree that GlobiancePay PTE. LTD. limited by shares will not be liable for any of its actions that you have authorized it to take.


Please refer to our Privacy Notice or information about how we collect, use, and share your information.


6.1 Ownership of Services – Excluding any open source software or third-party licensed software that the Services incorporate, GlobiancePay PTE. LTD. limited by shares owns the Services, including all technology, content, intellectual property objects and rights in them and other materials used, displayed or provided on or in connection with the Services.

6.2 Licence; Open Source Software Licence; Limitations – The source-code for our Services are governed by the source-code licence available on github repository available via the link and any other applicable licensing terms for the Services mentioned in these Terms. You acknowledge that the Services may use, incorporate or link to certain open-source components and that you will comply with any applicable open-source licences that govern any such open-source components.

6.3 Trademarks – Any of our product or service names, logos, and other marks used in or as a part of the Services, including our name and logo are trademarks owned by GlobiancePay PTE. LTD. limited by shares, its Affiliates or its applicable licensors. You may not copy, imitate or use them without our (or the applicable affiliate’s or licensor’s) prior written consent.

7.1 Changes to Services – We may, at our sole discretion, from time to time and without prior notice to you, modify, suspend or disable, temporarily or permanently, the Services, in whole or in part, for any reason whatsoever.

7.2 No Liability – We will not be liable for any losses suffered by you resulting from any modification to any Services or from any suspension or termination, for any reason, of your access to all or any portion of the Services.

7.3 Effect of Termination – In the event we terminate your Account or your complete access to the Services, we may delete or suspend your Account and all related information and files in such Account.


You agree to receive all communications, agreements, documents, receipts, notices, and disclosures electronically (collectively, “Communications”) that we provide in connection with these Terms of Use, your Account or any Services. You agree that we may provide our Communications to you by, in our sole discretion, posting them on our web-site or by emailing them to you at the email address linked to your Account.


You will defend, indemnify, and hold harmless us, our Affiliates and our Affiliates’ respective shareholders, members, directors, officers, employees, attorneys, agents, representatives, suppliers and contractors (collectively, “Indemnified Parties”) from any claim, demand, lawsuit, action, proceeding, investigation, liability, damage, loss, cost or expense, including, without limitation, reasonable attorneys’ fees, arising out of or relating to (a) your use of, or conduct in connection with, the Services; (b) the transfer of your tokens to third parties; (c) any Blockchain assets associated with your Polygon Address; (d) any feedback or user content you provide when accessing the Services, if any; (e) your violation of these Terms; or (f) your infringement or misappropriation of the rights of any other person or entity. If you are obligated to indemnify any Indemnified Party, GlobiancePay PTE. LTD. limited by shares (or, at its discretion, the applicable Indemnified Party) will have the right, in its sole discretion, to control any action or proceeding and to determine whether GlobiancePay PTE. LTD. limited by shares wishes to settle, and if so, on what terms.


10.1 To the maximum extent permitted under Applicable Law, the Services (and any of their content or functionality) provided by or on behalf of us are provided on an “AS IS” and “AS AVAILABLE” basis, and we expressly disclaim, and you waive, any representations, conditions or warranties of any kind, whether express or implied, legal, statutory or otherwise, or arising from statute, otherwise in law, course of dealing, or usage of trade, including, without limitation, the implied or legal warranties and conditions of merchantability, merchantable quality, quality or fitness for a particular purpose, title, security, availability, reliability, accuracy, quiet enjoyment and non-infringement of third party rights. Without limiting the foregoing, we do not represent or warrant that the Services (including any data relating thereto) will be uninterrupted, available at any particular time or error-free. Further, we do not warrant that errors in the Services are correctable or will be correctable.

10.2 You acknowledge that your data may become irretrievably lost or corrupted or temporarily unavailable due to a variety of causes, and agree that, to the maximum extent permitted under Applicable Law, we will not be liable for any loss or damage caused by denial-of-service attacks, software failures, viruses or other technologically harmful materials (including those which may infect your computer equipment), protocol changes by third party providers, Internet outages, force majeure events or other disasters, scheduled or unscheduled maintenance, or other causes either within or outside our control.

10.3 The disclaimer of implied warranties contained herein may not apply if and to the extent, such warranties cannot be excluded or limited under the Applicable Law of the jurisdiction in which we reside.


In no event shall we (together with our Affiliates, including our and our Affiliates’ respective shareholders, members, directors, officers, employees, attorneys, agents, representatives, suppliers or contractors) be liable for any incidental, indirect, special, punitive, consequential or similar damages or liabilities whatsoever (including, without limitation, damages for loss of data, information, revenue, goodwill, profits or other business or financial benefit) arising out of or in connection with the Services (and any of their content and functionality), any performance or non-performance of the Services, GBPAY Platform or any other product, service or other item provided by or on behalf of us, whether under contract, tort (including negligence), civil liability, statute, strict liability or under any other theory of liability, and whether or not we have been advised of, knew of or should have known of the possibility of such damages and notwithstanding any failure of the essential purpose of these Terms of Use or any limited remedy hereunder.


The interpretation and enforcement of these Terms of Use, and any dispute related to these Terms of Use or the Services, will be governed by and construed and enforced in accordance with the laws of the Liechtenstein, as applicable, without regard to conflict of law rules or principles that would cause the application of the laws of any other jurisdiction. You agree that we may initiate a proceeding related to the enforcement or validity of our intellectual property rights in any court having
jurisdiction and you waive any objection to venue in any such court.


13.1 Remedies – Any right or remedy of GlobiancePay PTE. LTD. set forth in these Terms of Use is in addition to, and not in lieu of, any other right or remedy whether described in these Terms of Use, and terms incorporated by reference herein, under Applicable Law, at law or in equity.

13.2 Affiliates and Contractors – The Services may be operated or provided by us, our Affiliates, or our or our Affiliates’ respective subcontractors. To the extent that one of our Affiliates or subcontractors, is operating or providing any Services, the Affiliate or subcontractor’s provision of such Services will be under terms identical to these Terms, substituting the Affiliate or subcontractor’s name wherever we are referenced in these Terms of Use.

13.3 Non-waiver – Our failure or delay in exercising any right, power, or privilege shall not operate as a waiver thereof.

13.4 Severability – The invalidity or unenforceability of any of these Terms of Use shall not affect the validity or enforceability of any other of these Terms of Use, all of which shall remain in full force and effect.

13.5 Force Majeure – We will have no responsibility or liability for any failure or delay in performance of the Services, or any loss or damage that you may incur, due to any circumstance or event beyond our control, including without limitation any flood, extraordinary weather conditions, earthquake, or other act of God, fire, war, insurrection, riot, labor dispute, accident, action of government, communications, power failure, or equipment or software malfunction.

13.6 Assignment – You may not assign or transfer any right to use your Account or the Services, or any of your rights or obligations under these Terms of Use, without our prior written consent, including by operation of law or in connection with any change of control. We may assign or transfer any or all of our rights or obligations under these Terms of Use, in whole or in part, without notice or obtaining your consent or approval.

13.7 Restrictions – We may, at any time and in our sole discretion, restrict your access to, or otherwise impose conditions or restrictions upon your use of the Services without prior notice. For example, we may restrict access to or certain transaction requests from certain locations if we have a reasonable suspicion of fraud, diminished capacity, inappropriate activity or a dispute in connection with your Account.

13.8 No Broker, Legal or Fiduciary Relationships – the Company is not a provider of a broker, legal, intermediary, agent, or advisory services and has no fiduciary relationship or obligation to you regarding any of your decisions or activities that you affect when using the Services. Neither our communications nor any information that we provide to you is intended as, or shall be considered or construed as an advice.

13.9 Headings – Headings of sections are for convenience only and shall not be used to limit or construe such sections.

13.10 Entire Agreement – These Terms contain the entire agreement, and supersede all prior and contemporaneous understandings between the parties regarding the Services.