PRIVACY AND DATA SECURITY POLICY

Last Updated: [16/03/2026]

Licorael Holdings Ltd. (“Company”, “We”) is committed to protecting the privacy and security of our investors’ personal data to the highest standards of financial technology. This Privacy Policy describes how data of users participating in our digital token (LCR Token) ecosystem is collected, used, and protected.

1. DATA COLLECTION AND KYC (KNOW YOUR CUSTOMER) PROCESS

In accordance with international financial regulations and Anti-Money Laundering (AML) laws, we are obligated to verify the identities of our investors. The following data is processed in this context:

Identity Information: Name, surname, passport or identity number, date of birth.

Contact Information: Email address, phone number, and residential address.

Financial Information: Wallet addresses, virtual POS transaction records, and transfer history.

2. PURPOSE OF DATA USE

The collected data is used solely for the following purposes:

Registering digital token ownership and managing ISIN records.

Distributing dividends to legally entitled parties.

Ensuring the security of virtual POS and bank transfer transactions.

Preventing loss of rights in secondary market transactions on the platform.

3. SPECIAL CATEGORY DATA (DNA CHIP & HEALTH DATA)

Biometric or genetic data processed within the scope of our Health and FinTech integration (data from DNA Chip software) is stored end-to-end encrypted on the Spyrada blockchain infrastructure. This data:

Is never shared with third parties.

Is protected against unauthorized access, including by holding company personnel.

Is used only for the purpose of providing personalized services with the user's own consent.

4. DATA STORAGE AND SECURITY

Your data is stored on servers compliant with Dubai data protection laws and the European Union GDPR (General Data Protection Regulation) standards. Multi-layered firewalls, SSL certificates, and Two-Factor Authentication (2FA) systems are actively used to protect against cyberattacks.

5. DATA SHARING

Your data will not be shared for commercial purposes with any institution, organization, or individual without a legal court order or an official request from international financial supervisory authorities.

6. USER RIGHTS

Our investors have the right to access their data registered in our system at any time, request correction of erroneous information, or request the deletion of their data when the legal retention periods expire.

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Licorael Holdings Ltd.