PART I — LEGAL NOTICE

1. Company Information

Company Name: Needlestack Technologies Ltd.

Registration Number: HE488065

VAT Number: CY60326735G

Registered Office:

Andrea Kelpi 37, Ethel Court, Block B, Office 302

7104 Larnaca, Larnaca, Cyprus

Director: Sebastian Niehaus

Email: [email protected]

2. Regulatory Information

Needlestack Technologies Ltd. is registered with the Department of Registrar of Companies and Intellectual Property of the Republic of Cyprus.

This website and all services offered thereon are provided in accordance with applicable Cyprus law and European Union legislation, including but not limited to the Electronic Commerce Law (Law 156(I)/2004).

3. Disclaimer — Technology & Financial Services

Our products and services are intended exclusively for professional investors and traders who possess the requisite experience, knowledge, and expertise to understand and evaluate the risks involved. Direct or indirect distribution to retail clients is strictly prohibited.

Needlestack Technologies Ltd. acts solely as a technology provider. We do not provide investment advice, financial advice, trading recommendations, or portfolio management services of any kind. All content, tools, and systems are offered for informational and technical purposes only and do not constitute an offer, solicitation, or recommendation to buy or sell any financial instruments.

4. Risk Warning

Important Notice: Trading and investing in financial instruments — including derivatives, cryptocurrencies, and leveraged products — involves significant risk and may result in the total loss of invested capital. Past performance is not indicative of future results.

Users are solely responsible for their own investment decisions. Independent financial advice should be sought where appropriate.

5. Limitation of Liability

The content of this website has been prepared with the greatest possible care. However, Needlestack Technologies Ltd. makes no representations or warranties — express or implied — regarding the accuracy, completeness, or timeliness of any information provided.

Use of this website is entirely at your own risk. To the fullest extent permitted by applicable law, Needlestack Technologies Ltd. disclaims all liability for any direct, indirect, incidental, or consequential damages arising from the use of, or inability to use, this website or its content.

6. External Links

This website may contain hyperlinks to third-party websites. These links are provided for convenience only. Needlestack Technologies Ltd. has no control over the content of linked sites and accepts no liability for their content, accuracy, or availability.

7. Intellectual Property

All content, trademarks, logos, software, and technologies published on this website are the intellectual property of Needlestack Technologies Ltd. or its licensors and are protected under applicable intellectual property laws. Any reproduction, distribution, or use without prior written consent is strictly prohibited.

8. Governing Law & Jurisdiction

This Legal Notice is governed by and construed in accordance with the laws of the Republic of Cyprus. Subject to applicable law, exclusive jurisdiction for any disputes arising out of or in connection with this Legal Notice is conferred upon the courts of Larnaca, Cyprus.

PART II — PRIVACY POLICY

1. Data Controller

The data controller responsible for the processing of your personal data is:

Company Name: Needlestack Technologies Ltd.

Registration Number: HE488065

VAT Number: CY60326735G

Registered Office: Andrea Kelpi 37, Ethel Court, Block B, Office 302, 7104 Larnaca, Cyprus

Director: Sebastian Niehaus

Contact Email: [email protected]

2. Legal Framework

This Privacy Policy is prepared in compliance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and applicable Cyprus data protection legislation. By using our website and services, you acknowledge that you have read and understood this Privacy Policy.

3. Personal Data We Collect

Depending on how you interact with our website, we may collect the following categories of personal data:

a) Data you provide directly:

•        Full name

•        Email address

•        Other contact details

•        Any information you voluntarily submit via forms or correspondence

b) Technical data collected automatically:

•        IP address

•        Browser type and version

•        Device and operating system information

•        Date and time of access

c) Usage data:

•        Pages visited and navigation paths

•        Interactions with website features and services

4. Purposes of Processing

We process personal data for the following purposes:

•        To provide, operate, and improve our services

•        To respond to enquiries and provide customer support

•        To ensure the technical security and integrity of our systems

•        To comply with applicable legal and regulatory obligations

•        To perform internal analytics and service optimisation

5. Legal Basis for Processing

The legal bases under which we process your personal data are:

•        Consent (Article 6(1)(a) GDPR) — where you have given explicit consent

•        Contract performance (Article 6(1)(b) GDPR) — where processing is necessary to fulfil a contract

•        Legal obligation (Article 6(1)(c) GDPR) — where processing is required by law

•        Legitimate interests (Article 6(1)(f) GDPR) — e.g. security, fraud prevention, and service optimisation

6. Data Sharing & Disclosure

We do not sell, rent, or trade your personal data. We may share data with trusted third-party service providers solely to the extent necessary to operate our services, including:

•        Hosting and infrastructure providers

•        IT support and maintenance service providers

•        Analytics providers

•        Competent authorities, where required by law or court order

All third-party partners are contractually required to process data only on our instructions and to maintain appropriate data protection standards.

7. International Data Transfers

Where personal data is transferred outside the European Economic Area (EEA), we ensure that appropriate safeguards are in place, such as the use of Standard Contractual Clauses (SCCs) approved by the European Commission, to ensure an equivalent level of data protection.

8. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. Once data is no longer required, it is securely deleted or anonymised.

9. Your Data Protection Rights

Under applicable data protection law, you have the following rights in relation to your personal data:

•        Right of access - to obtain a copy of the personal data we hold about you

•        Right to rectification - to request correction of inaccurate or incomplete data

•        Right to erasure - to request deletion of your data in certain circumstances

•        Right to restriction of processing - to request that we limit how we use your data

•        Right to data portability - to receive your data in a structured, machine-readable format

•        Right to object - to object to processing based on legitimate interests

•        Right to withdraw consent - to withdraw consent at any time, without affecting prior processing

To exercise any of these rights, please contact us at: [email protected]

10. Cookies

Our website may use cookies and similar tracking technologies to:

•        Ensure proper functionality of the website

•        Analyse traffic and usage patterns

•        Improve the overall user experience

You may control or disable cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the website. A separate Cookie Policy may be made available where required by applicable law.

11. Data Security

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or misuse. These measures are regularly reviewed and updated in line with industry best practices.

12. Third-Party Services

Certain functionality on this website may be provided by third-party service providers. These providers process personal data only under strict contractual confidentiality and data processing agreements, in accordance with GDPR requirements.

13. Updates to this Privacy Policy

We reserve the right to update or revise this Privacy Policy at any time to reflect changes in our practices or applicable law. The revised version will be published on this page with an updated effective date. We encourage you to review this page periodically.

14. Complaints

If you believe that your personal data has been processed unlawfully or that your data protection rights have been violated, you have the right to lodge a complaint with the competent supervisory authority in Cyprus:

Authority: Office of the Commissioner for Personal Data Protection

Website: www.dataprotection.gov.cy

Email: [email protected]

You may also contact us directly at [email protected] and we will do our utmost to address your concerns promptly.