PRIVACY & COOKIES POLICY
Last Updated: January 2026
This Privacy and Cookies Policy (the “Privacy Policy”) applies to Your use of the Reassure Alliance Website (content and features) and any activities conducted from or via the Website (‘Services’) branded as Reassure Alliance (“Reassure Alliance”, “we”, “our”, “us”) and referring to
the domain https://reassurealliance.com/ (or any associated portal domains). This Policy applies to all visitors and/or users (“User”, “you”, “your”) who act in their own personal capacity. Please read this Policy along with our Buyback Program Purchase Agreement carefully, and note that by enrolling in the Buyback Program or using our services, you are consenting to the collection, storage, processing, and transfer of your Personal Data in accordance with this Policy.
1. DEFINITIONS
1.1. “Account” refers to the User’s account opened on the Third-Party Partner platform and linked to the Reassure Alliance portal, subject to the applicable terms and conditions.
1.2. “Third-Party Partner” means the service providers and Third-Parties with which we have service agreements to deliver the Buyback Program. Each is governed by their own terms and policies. We do not exercise any control or management over these Third-Party Partners’ websites. Users should display their own due diligence to read and understand the legal documentation governing those products and Services.
1.3. “Personal Data” is defined as any information that relates directly or indirectly to a natural person whether living or deceased, who is identified or identifiable from that information, or from
that and other information.
1.4. “User” refers to any natural or legal person purchasing Buyback Coverage, submitting a claim, or accessing the Reassure Alliance portal according to applicable terms and conditions.
1.5. “Platform” refers to the domain “https://reassurealliance.com/”, its subdomains (including the
Claims Portal).
1.6. “Cookies” refers to a piece of information sent to your browser by a website you visit. You can set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it or otherwise. This Policy may be made available in several languages; all versions are legally binding, but in the
event of inconsistency between the English version and a translated version, the English version prevails.
2. PURPOSE OF THIS POLICY
2.1. We at Reassure Alliance know and understand how important it is for you to understand how we collect, store, process, share and use your Personal Data. We respect and protect the privacy of our Users’ Personal Data in our Platform.
2.2. The purpose of this Policy is to describe how Reassure Alliance collects, processes and manages Users’ Personal Data through the Platform, which is developed to offer the Buyback Coverage Program.
3. ACCEPTANCE
3.1. By accessing and using our Platform or purchasing uyback Coverage, you are consenting and accepting the terms of this Policy, the terms and conditions of the Buyback Program Purchase Agreement, and any other supplementing document provided related to the present document. If you do not agree or consent to receive our cookies, then this may in some cases preclude you from using the Platform or Services, or negatively affect the display or function thereof.
3.2. In any case, Reassure Alliance will not hold any responsibility for any errors, bugs, or malfunctions on the Platform regarding the information displayed and/or its functions, caused by your lack of consent to receive our cookies or by any restrictions imposed on the use of tracking
technologies necessary for the proper operation of the Platform.
4. USER LOGIN CREDENTIAL INFORMATION
4.1. Users understand and acknowledge that when they access specific Services provided by Third-Party Partners, they shall be subject to the individual privacy policy of each respective Third- Party Partner. The privacy practices, data collection, processing, and usage of information by the
Third-Party Partners are governed solely by their own privacy policies. Reassure Alliance does not have any discretion or control over the privacy practices of the Third-Party Partners.
4.2. Users grant Reassure Alliance permission to use their data and information as required to issue the Soulbound NFT Certificate, track the Guarantee Amount ledger, and process claims.
5. PERSONAL INFORMATION OF THE USERS THAT WE COLLECT AND PROCESS
5.1. Some of your Personal Data is collected, processed and stored with us in order to provide, develop and to enhance our products and Services including technical infrastructure, security, compliance, fraud prevention and customer support. We are committed to exercise due diligence when dealing with every User and in the course of conducting business, we ensure that we are able to comply with all the applicable laws and regulations that are required to prevent the facilitation of money laundering and terrorist financing.
5.2. Users’ Personal Data we collect and process is as follows:
Users:
● Full name
● Email address
● Wallet Addresses
● Identity Verification Documents (Passport/ID for KYC)
Browser/Log Information:
● IP address
● Device specific information
● System activity
● Browser type and version
● Access Time stamps
● Referral URL
6. HOW USERS’ PERSONAL DATA IS USED
6.1. To communicate with User regarding coverage status, maturity dates, and claims;
6.2. To comply with legal and regulatory compliance, including but not limited to anti-money laundering (AML), Counter Terrorism Financing (CTF) laws and know-your-customer (KYC) requirements;
6.3. To detect and prevent frauds, wash trading, and artificial transaction creation;
6.4. To provide, troubleshoot and improve Reassure Alliance Services and the NFT ledger integration;
6.5. To enforce our terms in our Buyback Program Purchase Agreement;
6.6. To provide customer Services and dispute resolution;
6.7. To ensure quality control;
6.8. To ensure network and information security;
6.9. To enhance and personalize User experience;
6.10. To facilitate corporate acquisitions, mergers or transactions;
6.11. To engage in marketing activities (with consent);
6.12. For Transaction Services (processing premium payments and claim payouts);
6.13. Purposes for which we seek User’s explicit consent.
7. DATA TRANSFER
7.1. We may share your Personal Data with specific third parties, which include Third-Party Partners in accordance with our Agreements. Such sharing of data becomes essential for the effective delivery of our Services or in instances where a legal basis mandates such sharing. The aforementioned third parties are authorized to collect, utilize, and disclose your information as directed by us. This ensures that the services provided are comprehensive and aligned with our standards.
7.2. Your Personal Data may be subject to transfers between integrated Third-Party Partner platforms based on the needs to provide efficiency, verify liquidity contributions, and update the NFT ledger. Please be aware that these transfers may be conducted without prior notice to you as they are automated via API/smart contract. Your continued engagement with our Services signifies your acknowledgment and acceptance of this data transfer mechanism.
7.3. We further ensure that we comply with the applicable data protection legal norms and we shall only share information in the following circumstances:
7.3.1. With applicable regulatory bodies of the Republic of the Marshall Islands. In the event of suspicious activities or transactions such as any fraud, tax, money laundering or errorist financing activities, Reassure Alliance is obliged to share the User’s personal information with the applicable regulatory bodies.
7.3.2. With third party KYC/AML service providers of Reassure Alliance to perform verification
Services in the claim submission process and in ongoing transaction monitoring.
7.3.3. Reassure Alliance intends to uphold and implement the strictest standards of compliance, security and transparency in its operation. We acquire the User’s information via Third Party Partners who conduct KYC/AML on our behalf, with global coverage, Politically Exposed Person
(PEP) database screening, financial crime screening, and legality of assets verification.
7.3.4. With service providers under contracts for operational purposes, for instance:
7.3.4.1. Cloud storage;
7.3.4.2. Network Infrastructure;
7.3.4.3. Security;
7.3.4.4. Customer Support;
7.3.4.5. PandaDoc (for agreement execution);
7.3.4.6. Data analytics.
7.3.5. We transfer only the minimum amount of data necessary for a particular outsourced service provider(s) and we only cooperate with the outsourced service providers who can provide and ensure adequate level of Personal Data protection.
7.3.6. With our affiliates or business partners as a general part of conducting business to offer Services.
7.4. Reassure Alliance ensures that the service providers and affiliates or business partners who process Personal Data acknowledge the confidentiality of this information and to protect the User’s right to privacy by complying with all applicable privacy and data protection laws.
7.5. Each Third-Party Partner website may have its own data transfer clauses, terms of use, and privacy policies governing how your information is handled, processed, and shared. By using our Platform to access the services of Third-Party Partner websites, you acknowledge and agree to adhere to the data transfer clauses and privacy policies of those Third-Party Partner websites.
8. PROTECTION AND STORAGE OF PERSONAL DATA
8.1. Reassure Alliance maintains physical, technical, administrative and procedural safeguards in connection with the collections, storage and disclosure of User’s Personal Data. We use firewall barriers, encryption techniques and authentication procedures to maintain the security of User’s
online sessions.
8.2. You are requested to protect your account password and wallet private keys from unauthorized access to avoid unnecessary authentication issues. In order to circumvent loss,misuse, unauthorized acquisition or alteration of your data, you are further requested to choose the strongest password and to protect the account privacy data from any third-parties. In the event of unauthorized access, we insist you notify Customer Support immediately.
9. DATA RETENTION
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
10. DATA PROTECTION LAW AND THE EUROPEAN DATA PROTECTION RIGHT
10.1. This Policy is governed by and shall be construed in accordance with the data protection laws of the Republic of the Marshall Islands. Additionally, the highest standard of data protection, as set forth in the General Data Protection Regulation (“GDPR”), shall also apply to the processing of Personal Data covered by this Policy.
10.2. According to the GDPR, Reassure Alliance provides privacy notice:
10.2.1. In a concise, transparent, intelligible and easily accessible form,
10.2.2. Written in clear and plain language,
10.2.3. Delivered in a timely manner; and
10.2.4. Provided free of charge.
10.3. European Union Users are advised to read the important information provided below about
the transfer of your Personal Data outside of the European Economic Area (EEA), you will have
the rights as described below:
10.3.1. You may request access to and receive information about the Personal Data we maintain about you, update and correct inaccuracies in your Personal Data, restrict or object to the processing of your Personal Data, have the information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Data to another company.
10.3.2. You may withdraw any consent you previously provided to us regarding the processing of your Personal Data, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdraw your consent.
10.3.3. If you are located in the EEA, we will comply with applicable GDPR law when transferring your Personal Data outside of the EEA.
11. YOUR RIGHTS PROTECTED UNDER THE GENERAL DATA PROTECTION REGULATION
11.1. If you are located in the EEA, you have rights under data protection laws in relation to your Personal Data which are set out in more detail below:
11.1.1. Request access – This enables you to receive copies of the Personal Data we hold about you and to check that we are lawfully processing it. This is also commonly known as a “data subject access request”.
11.1.2. Request erasure – This enables you to request us to delete or remove Personal Data where there is no good reason for us continuing to process it. Please note that there may be circumstances where we may be legally entitled to retain your Personal Data (e.g., for AML audit trails).
11.1.3. Request to Restrict Processing – This enables you to object to the processing of your Personal Data, which is processed based on our legitimate interests. In the event of such an
objection, we will no longer process your Personal Data, unless we demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.
11.1.4. Request to Object Processing – You have the right to object to the processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
11.1.5. Request to transfer – We will provide you, or a third party you have authorized, with a copy of your Personal Data in a structured, commonly used, machine-readable format.
11.1.6. Right to data rectification: This gives you the authority to request correction or amendment of your Personal Data. If you discover that your Personal Data is incorrect, incomplete, or outdated, you can exercise this right by submitting a formal request to us.
11.1.7. Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certai products or services to you (e.g., claim payouts).
12. COOKIES POLICY
12.1. Whenever you visit our Platform, the Platform sends a cookie to the device you are using to access our Platform, which may place tracking technologies on your device, browser, or the webpage you are viewing, in order to ersonalize your experience, understand usage patterns,
provide, improve, and secure Reassure Alliance Platform.
12.2. Your device automatically stores the Cookie in a file located within your browser allowing us to recognize your device upon future access. Cookies set by our operators are called “First-party cookies”. Cookies set by parties other than our Platforms are called “Third-party cookies”. Third-
party cookies enable third-party features or functionality to be provided on or through the website (e.g., PandaDoc signing, analytics).
12.3. We use the following Cookies to operate our Platform:
12.3.1. Session Cookies are temporary and expire once you close your browser. It stores information for the time, or session when you are on our Platform.
12.3.2. Essential Cookies are strictly necessary to provide you with services available through our Platform and to use some of its features, such as access to secure areas.
12.4. You reserve the right to decide whether to accept or reject Cookies from our Platform. You can exercise your Cookie rights by setting your preferences in the Cookie Consent Manager. However, you will not be able to reject the Essential Cookies and still access the Platform, as they
are strictly necessary to provide you with our Services.
13. MODIFICATIONS
13.1. We reserve the right, at our sole discretion, to modify, amend, supplement, or replace this Policy at any time and such update details shall be indicated at the top of this page. Our Platform Policies and Terms may be revised or updated periodically to meet the necessary requirements
and standards. We encourage you to regularly visit our Platform to stay informed about any changes to these Policies and the Terms. Your continued access to the Platform means that you agree to the updated content and to abide by the updated Policy.
14. CONTACT INFORMATION
14.1. In the event of any comments, questions, inquiries or complaints regarding this Policy, the User has the right to submit questions and/or concerns, please raise a ticket via the Platform or reach out to us at [email address].
