Raffaello

Privacy Policy of Raffaello

Last Updated Date: September 4, 2026

This Privacy Policy (this “Policy”) explains how we may collect, use, disclose and protect personal data through Raffaello’s portal website ("Site") in connection with your access and/or use of the Site.

This Policy does not apply to any products, services, websites, or content offered or provided by third parties and we are not responsible in any way for those third party offerings. Please review any separate privacy policies made available by those third parties.

1. Information We Collect

We collect the following personal data from users of the Site:

(a) Information you give us:

When you access the Site, we may collect the following information:

Your name, email address, company/organization and role: this is provided if you contact us via email via the Site.

(b) Information collected automatically

We may collect automatically certain limited information when you access, use, or interact with the Site or complete and submit certain enquiry forms via the Site, such as:

Device type, browser type and version

Operating system and version

IP address

Publicly available blockchain data

Cookies – see "Cookies" below

We may also collect analytics about aggregate numbers of users and usage types (i.e., number of page views, event counts, and aggregate acquisition metrics); and aggregate location data across users including countries and regions from which users access the Site, but this will not identify you (i.e. it will be on an anonymous basis).

For personal data collected via cookies and similar technologies that remember preferences and help detect irregular or fraudulent activity, see section 3 below.

We will indicate (e.g. by an asterisk on a form) where it is mandatory for you to provide personal data to us. If you do not provide such mandatory personal data, we may not be able to provide any services or otherwise engage with you.

If you provide personal data of any other individuals to us, you must give them a copy of this Policy and ensure that you have their consent to provide their personal data to us to process in accordance with this Policy.

2. How We Use Your Information

We may use your personal data to:

  • Communicate essential service-related information;
  • Provide, maintain, support and improve the Site and respond to inquiries related to the same;
  • Comply with our applicable legal and regulatory obligations;
  • Prevent, detect and investigate fraudulent, abusive or harmful activities;
  • Allow you to personalize or personalize your experience with the Site;
  • Send direct marketing communications to you about the Site, our product or services, and events, and/or our affiliates or selected third parties that we believe may be of interest to you, but we can only do so with your consent. You can unsubscribe at any time;
  • Provide support for our services, including resolving issues and responding to your questions and feedback;
  • Analyze usage trends to permit access to the Site;
  • Enforce our Terms of Use, this Policy and/or other policies; and
  • Take other actions that you have asked us to and provided consent for us to take.

You agree and acknowledge that we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.

3. Cookies

While you access the Site, we may use the industry practice of placing a small amount of data that will be saved by your browser (“cookies”). This information can be placed on your computer or other devices used to visit our Site. As described above in this Policy, we collect and may permit third parties to collect information using cookies and other similar technologies.

We use cookies for purposes such as providing content or features on the Site, helping us remember you and your preferences, and improving your user experience by making the Site more efficient and relevant to you. We, our service providers, and/or agents acting on our behalf, use the following persistent and session cookies on the Site:

  • Strictly necessary cookies: these cookies are essential because they enable the Site to work properly, and they cannot be disabled. Without these cookies, some functions on the Site cannot be provided. These cookies do not gather information about you for advertising purposes. For example, these cookies are used to:
  • Remember the information that you fill in when performing certain activities on the Site (if you click “remember me”);
  • Pass information from one page to the next, for example when filling out forms;
  • Read your browser and device settings to optimize the display of the Site;
  • Identify misuse of the Site;
  • Load the Site uniformly to maintain accessibility; and
  • Prevent fraud.
  • Functional cookies: we use functional cookies to remember your choices so we can tailor the functions on the Site to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your preferences on the Site. We do not use functional cookies for online advertising. While these cookies can be disabled, this may result in less functionality during your use of the Site. For example, we use these cookies to:
  • Provide you with a personalized experience, such as remembering how you have customized the Site;
  • Remember the information that you fill in when performing certain activities on the Site; and
  • Store your preferences such as language and location, dark/light mode, webpage layout and scroll-down settings.
  • Performance or analytics cookies: these cookies help us understand how the Site is being accessed, used, or is performing. These performance or analytics cookies may collect information about the content you view, whether this is your first visit to the Site, what websites you visit immediately before and after visiting the Site, and your system and geographic information. The information generated by these cookies will be transmitted to and stored by the applicable analytics services. For example, we may use performance or analytics cookies to:
  • Maintain and continually improve the Site and our services;
  • Keep track of the number of visitors to the pages within the Site;
  • Keep track of the length of time that each visitor spends on the pages within the Site;
  • Determine the order in which a visitor visits the various pages or features within the Site;
  • Identify performance issues with the Site; and
  • Assess which parts of the Site need improvement.

You can set your browser to block or alert you about these cookies, but this may affect the functionality of our services or your user experience. Session Cookies are added when a user starts to browse the Site or interacts with a specific feature and are deleted when the browser is closed. Persistent Cookies are added when a user starts to browse the Site or interacts with a specific feature but may remain stored on your device until a certain termination date is reached.

4. Sending your personal data internationally

We may share certain of your personal data, subject to (where appropriate) applicable or appropriate confidentiality and security obligations, as follows:

(a) our affiliates where doing so is necessary to provide or improve our services, to comply with a legal obligation, where they provide services to support the Site, our services or otherwise our operations, to prepare consolidated internal reporting, and/or to operate or manage our business; and

(b) with third party service providers to support operation of the Site, our services and/or our operations, including banks, accountants, auditors, professional advisors and those providing IT marketing, event hosting, logistics planning, analytics, email delivery and database management services, as well as other professional service providers providing services to us.

We may share your personal data with third parties when we enter into a business transaction, including mergers, acquisitions, reorganizations, or a sale or transfer of all or part of our organization or assets.

We may disclose your personal data where required by applicable law, regulation, court order, subpoena or other binding request from a competent authority, or to establish, exercise or defend legal claims, in each case in any jurisdiction.

We may transfer your personal data to other jurisdictions that are not the country or jurisdiction in which you live. The jurisdictions to which your data may be transferred may not have comparable data protection laws to those which apply in your own country or jurisdiction. In such cases, we will take reasonable measures to implement appropriate and suitable safeguards to afford your personal data a level of protection that is at least comparable to that law in the jurisdiction in which you live.

You may permit us to share your information with other entities or individuals of your choosing. Those uses will also be subject to the privacy policies of the entities or individuals receiving the information.

5. Data Security

We implement reasonable technical and organizational measures to protect your personal data against unauthorized or accidental access, processing, erasure, loss or use.

We transmit data using the internet, wirelessly and via other networks. Therefore, we cannot ensure the privacy and security of data transmitted using such methods.

6. Children’s Information

The Site and our services are intended for general users who are 18 years of age or older, and are in no way directed at children. We do not knowingly collect personal data from minors. If you believe such information has been collected in error, please email support@raffaellogroup.xyz to notify us of this. If a user submits personal data with respect to a person suspected of being a minor, we will take steps to delete the individual’s personal data as soon as possible.

7. Changes to This Policy

We reserve the right to change this Policy from time to time by updating this Policy on the Site, so please check frequently to see if there are any changes. We will obtain your consent to such changes if required by applicable law.

8. Your Rights

You have certain rights under applicable data protection law as regards your Personal Data, for example to request to access, correct or delete your personal data, request information about how your personal data is processed, exercise your right to withdraw your consent to processing of your personal data, and to complain about our processing of your personal data. You can exercise your rights by contacting us (see "Contact Us" below). We will respond to your request in accordance with applicable law.

9. Contact Us

To exercise your data subject rights (see "Your Rights" above), or if you have any questions or concerns about how we handle your personal data, please contact our data privacy team by sending an email to us at: support@raffaellogroup.xyz