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Website Privacy Policy 

This Website Privacy Policy (“policy”) describes the types of personal information we may collect about you in the context of your use of sc3.ltd (the “site”), the purposes for which we use the information, and the circumstances in which we may share such information. As used throughout this policy, the term “Sc3,” “we”, “our” or “us” refers to Smart City Clearing Company Ltd. 

When you visit the site, we collect certain personal information about you. As used in this policy, “personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you or your household. 
 
COLLECTION OF PERSONAL INFORMATION 

The categories below describe the personal information we collect about you and the sources from which we collect those categories of personal information. 

Personal Identifiers 
Description:  email address 
Sources:   You 

Device and Online Identifiers 
Description: IP address; session ID (session start time) 
Sources:  You; devices associated with you; third-party information providers 

Internet, Browser, and Network Activity 
Description:  clickstream/online website tracking information; data related to user activity, e.g., browser visits, page views, visits, and unique visitors data; and cookies or other similar technologies 
Sources:  You; devices associated with you; third-party information providers 
 
Location Data 
Description: Region, country, and city 
Sources:  You; devices associated with you; third-party information providers 

USE OF PERSONAL INFORMATION 

We may use your information for the following purposes: 

• Providing information to you: We use the e-mail address you provide through the site to deliver our “Briefings” weekly e-mail to you. If you wish to request historical financial documents from within the Investor Relations section of the site, we will use the e-mail address you provide through the site to enable your request to us. 

• Improving the site: We use your device and online identifiers, information about your internet, browser, and network activity, and location data to measure technical site performance. 
• Marketing: We use information about your internet, browser, and network activity for marketing purposes. 
• Operating the site: We use your IP address, location data, and internet, browser, and network activity to enable our site metrics for site administration and management purposes. 
    

SHARING OF PERSONAL INFORMATION WITH OTHER ENTITIES 

We may share personal information about you with other entities, including entities that provide services to us. We do not disclose your personal information collected through the site to other entities, except as described in this policy. 

We may share your information with the following types of entities: 

• Service providers: We engage service providers to assist us with operating the site. These service providers analyze information about our site and your use of the site. Information disclosed for these purposes may include device and online identifiers, information about your internet, browser, and network activity, and location data. 
• Other entities related to legal process and emergency situations: We may disclose personal information to third parties as permitted by, or to comply with, applicable laws and regulations. Examples include responding to a subpoena or similar legal process, protecting against fraud and cooperating with law enforcement or regulatory authorities.  Information disclosed for these purposes may include device and online identifiers, information about your internet, browser, and network activity, and location data. 

Applicable law requires that we identify the categories of personal information we share for business purposes. We disclose the following categories of personal information for business purposes: Personal identifiers, device and online identifiers, information about your internet, browser, and network activity, and location data. 

INFORMATION SECURITY: HOW WE PROTECT YOUR PRIVACY 

Smart City Clearing Company Ltd. is committed to protecting the privacy and confidentiality of your personal information. We limit access to your personal information to authorized Sc3 employees or agents and the third parties described above in Sharing of Personal Information With Other Entities. We also maintain physical, electronic and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure. Some of the other central features of our information security program may include: 

• A dedicated group – the Information Security Department – that designs, implements and provides oversight to our information security program; 
• The use of specialized technology such as firewalls; 
• Testing of the security and operability of products and services before they are introduced to the Internet, as well as ongoing scanning for publicly known vulnerabilities in the technology; 
• Internal and external reviews of our Internet sites and services; 

• Monitoring of our systems infrastructure to detect weaknesses and potential intrusions; 
• Implementing controls to identify, authenticate and authorize access to various systems or sites; 
• Protecting information during transmission through various means including, where appropriate, encryption; and 
• Providing Sc3 personnel with relevant training and continually updating our security practices in light of new risks and developments in technology. 

PRIVACY AND THE INTERNET 

The following additional information will be of interest to you as a visitor to this site: 

“Cookies” are small text files that may be placed on your Web browser when you visit our Web sites or when you view advertisements we have placed on other Web sites. For more information about cookies, how our Web sites use them, and your options with respect to their use, please see our cookies policy. 

“Clickstream” data (e.g., information regarding which of our Web pages you access, the frequency of such access, and your product and service preferences) may be collected by Sc3 itself, or by our service providers, using cookies, Web beacons, page tags, or similar tools that are set when you visit the site or when you view an advertisement we have placed on another Web site. Clickstream data and similar information may be shared internally within Sc3 and used: for administrative purposes; to assess the usage, value and performance of our online products and services; to improve your experience with the site; and as otherwise permitted by applicable law or regulation. This information may be processed by us for the purposes described above, or on our behalf by other entities, solely in accordance with our instructions. 

Sc3 may make available on this Web site third party applications such as content linking or sharing facilities. Information collected by providers of such applications is governed by their privacy policies. 

The site is not currently configured to respond to “do not track” signals or similar mechanisms. 

OUR OTHER PRIVACY POLICIES OR NOTICES; CHANGES TO POLICY 

This policy provides a general statement of the ways in which Sc3 protects your personal information when you access and use the site. You may, however, in connection with specific products or services offered by Sc3, be provided with separate privacy policies or notices that describe the privacy practices associated with your use of those products or services. This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information related to your use of the site. If we make material changes to this policy, we will let you know by appropriate means, such as posting the revised copy on this page with a new effective date. The revised policy will be effective immediately upon posting to our Web site. This version of the policy is effective October 1, 2021. 

Our Use of Cookies and Your Options 

By using a Sc3’s Web site with your browser settings adjusted to accept cookies you consent to our use of cookies and other tools to provide the products and services available on those sites. If you would like to modify your browser to notify you when you receive a new cookie or to disable cookies altogether, please refer to Managing Cookies below. 

Cookies and How We Use Them 

Cookies are small text files that may be placed on your Web browser when you visit our Web sites or when you view advertisements we have placed on other Web sites. Cookies allow your browser to remember some specific information which the Web server can later retrieve and use.  When you quit your browser, some cookies are stored in your computer’s memory, while some expire or disappear. 

Cookies are used primarily for administrative purposes, to improve your experience with our Web sites. Examples of this would include the use of cookies: 

• To improve site security by “authenticating” you (i.e., verify that you are who you say you are) when you sign-in to our site. 
    
• To keep track of your specified preferences such as language, time zone and timeouts after periods of inactivity. 
    

• To allow you to navigate our sites more easily by “remembering” your identity so that you do not have to input your password multiple times as you move between pages or services. 

In addition to administrative uses, we may also use cookies in one or more of the following ways, depending on the Web site you are using: 

• To conduct research and analytics to improve our Web sites and our products and services. This includes compiling statistical information concerning, among other things, the frequency of your use of our Web sites, the pages visited and the length of each visit. 
    
• To display Smart City Clearing Company advertisements when you visit Web sites of third parties with whom we have marketing relationships and to help us gauge the effectiveness of our advertising efforts. These parties may gather information concerning your use of other Web sites and provide us with de-identified information about you (such as demographic information or the names of sites where you have been shown ads) which we may use to provide you with more relevant and useful advertising. 

This paragraph applies only to the www.sc3.ltd Web site. That site may use third parties to serve advertisements as described immediately above. To do so, these parties may place or recognize a unique cookie on your browser (including through the use of pixel tags) to gather information concerning your use of our that site and other Web sites and, based on that information, serve advertisements that may be of interest to you. If you would like more information about this practice, and to learn how to opt out of it on the particular device on which you are accessing this Privacy and Cookies Policy, please visit http://optout.aboutads.info/#/. The www.sc3.ltd site adheres to the interest-based advertising principles of the Digital Advertising Alliance, available at http://www.aboutads.info/principles.   

For more information on how we collect and use information that is identifiable to you, please refer to our Privacy Policy. 

Managing Cookies 

The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on’s settings or visiting the Web site of its manufacturer. Some of our sites employ “functionality cookies” that help the site remember your settings and preferences for use when you visit the site in the future. This provides a more tailored and pleasant user experience. These cookies store information in multiple places. On those site using functionality cookies, you will find a “Delete Cookies” feature on every page that will allow you to delete these cookies completely from your device. Please note that, if you decline to use cookies, you may experience reduced functionality and, for sites using authentication-related cookies, declining cookies will prevent you from using the Web site altogether. To learn more about what cookies are set on your computer as you browse the Web and how to manage or delete them, visit www.allaboutcookies.org. 

Terms & Conditions 

Access to the Smart City Clearing Company Ltd. Web site defined below is provided by Sc3. For purposes of this agreement, “Sc3”, “we,” “us” or “our” shall mean Smart City Clearing Company Ltd. and its affiliates, and their officers, directors, managing directors, partners, and employees. The “Sc3 Web site” shall mean the Web site of Smart City Clearing Company Ltd and available to the general public and located at sc3.td and select other domains. 
 
Monitoring by Sc3: Your use of the products and services on this Web site may be monitored by Sc3, and that the resultant information may be used by Sc3 for its internal business purposes or in accordance with the rules of any applicable regulatory or self-regulatory organization. 
 
Information Made Available Through this Service: You are permitted to store, display, analyze, modify, reformat, and print the information made available to you via these services only for your own use. You are not permitted to publish, transmit, or otherwise reproduce this information, in whole or in part, in any format to any third party without the express written consent of Sc3. In addition, you are not permitted to alter, obscure, or remove any copyright, trademark or any other notices that are provided to you in connection with the information. Sc3 reserves the right, at any time and from time to time, in the interests of its own editorial discretion and business judgment to add, modify, or remove any of the information. These Terms and Conditions of Use are not intended to, and will not, transfer or grant any rights in or to the information other than those which are specifically described herein, and all rights not expressly granted herein are reserved by Sc3 or the third party providers from whom Sc3 has obtained the information. You are required to read and abide by any additional terms and conditions that may be posted on this service from time to time concerning information obtained from specific third party providers. Such third party providers shall have no liability to you for monetary damages on account of the information provided to you via this service. 
 
No warranties made as to content; no responsibilities to update: Sc3 makes no warranty, express or implied, concerning this service. The services provided by us and our third party providers are on an “AS IS” basis at your sole risk. Sc3 expressly disclaims any implied warranty of merchantability or fitness for a particular purpose, including any warranty for the use or the results of the use of the services with respect to their correctness, quality, accuracy, completeness, reliability, performance, timeliness, or continued availability. 
 
Neither Sc3 nor any of its third party providers shall have any responsibility to maintain the data and services made available on this Web site or to supply any corrections, updates, or releases in connection therewith. Availability of data and services are subject to change without notice. 
 
No liability for content; no liability arising from use: Sc3 shall have no liability, contingent or otherwise, to you or to third parties, or any responsibility whatsoever, for the failure of any connection or communication service to provide or maintain your access to this service, or for any interruption or disruption of such access or any erroneous communication between Sc3 and you, regardless of whether the connection or communication service is provided by Sc3 or a third party service provider. Sc3 shall have no liability, contingent or otherwise, to you or to third parties, for the correctness, quality, accuracy, timeliness, reliability, performance, continued availability, completeness or delays, omissions, or interruptions in the delivery of the data and services available on this Web site or for any other aspect of the performance of this service or for any failure or delay in the execution of any transactions through this service. In no event will Sc3 be liable for any special, indirect, incidental, or consequential damages which may be incurred or experienced on account of you using the data or services made available on this Web site, even if Sc3 has been advised of the possibility of such damages. Sc3 will have no responsibility to inform you of any difficulties experienced by Sc3 or third parties with respect to the use of the services or to take any action in connection therewith. 
 
No warranties made as to security: Sc3 makes no warranty whatsoever to you, express or implied, regarding the security of the site, including with respect to the ability of unauthorized persons to intercept or access information transmitted by you through this service. 
 
System Outages, Slowdowns, and Capacity Limitations/Delays in Order Routing, Executions, and Trade Reports: As a result of high Internet traffic, transmission problems, systems capacity limitations, and other problems, you may, at times, experience difficulty accessing the Web site or communicating with Sc3 through the Internet or other electronic and wireless services. Any computer system or other electronic device, whether, it is yours, an Internet service provider’s or Sc3s’ can experience unanticipated outages or slowdowns, or have capacity limitations. 
 
Content not to be construed as a solicitation or recommendation: This material has been prepared for informational purposes only without regard to any particular user’s investment objectives, financial situation, or means, and Sc3 is not soliciting any action based upon it. This material is not to be construed as a recommendation; or an offer to buy or sell; or the solicitation of an offer to buy or sell any security, financial product, or instrument; or to participate in any particular trading strategy in any jurisdiction in which such an offer or solicitation, or trading strategy would be illegal. Certain transactions, including those involving futures, options, and high-yield securities, give rise to substantial risk and are not suitable for all investors. Although this material is based upon information that Sc3 considers reliable and endeavors to keep current, Sc3 has not verified this information and does not represent that this material is accurate, current, or complete and it should not be relied upon as such. 

No determination of suitability has been made; not all risks are disclosed; private advisors should be consulted: The fact that Sc3 has made the data and services provided on this Web site available to you constitutes neither a recommendation that you enter into a particular transaction nor a representation that any product described on this Web site is suitable or appropriate for you. Many of the products described on this Web site involve significant risks, and you should not enter into any transactions unless you have fully understood all such risks and has independently determined that such transactions are appropriate for you. Any discussion of the risks contained herein with respect to any product should not be considered to be a disclosure of all risks or complete discussion of the risks which are mentioned. You should neither construe any of the material contained herein as business, financial, investment, hedging, trading, legal, regulatory, tax, or accounting advice nor make this service the primary basis for any investment decisions made by or on behalf of you, your accountants, or your managed or fiduciary accounts, and you may want to consult your business advisor, attorney, and tax and accounting advisors concerning any contemplated transactions. 

User Content: 
a. The Web site may enable you to transmit, post, communicate or otherwise make available text, photos, videos, links, information, ideas, suggestions, content and other materials (“User Content”), including through the Web site’s interactive features or functionality, such as chat features, message boards, forums and other communications tools. User Content may be accessible to and viewable by other users of the Web site and the public. We do not claim ownership to User Content; however, by uploading or posting to the Web site, you hereby grant to us a worldwide, royalty-free, fully paid-up, nonexclusive, perpetual, irrevocable, transferable and fully sub-licensable (through multiple tiers) license, without additional consideration to you or any third party, to reproduce, transmit, print, publish, distribute, index, exhibit, perform, display (publicly or otherwise), create derivative works of, adapt, modify, translate, comment on, use, analyze and otherwise exploit User Content for any purpose, including the right to use your name and likeness as contained therein, in whole and in part, in any format, media or channels now known or hereafter developed (including in connection with the Web site and on third party applications, sites and platforms such as Facebook, Twitter and YouTube), without further notice to you and without further requirement of permission from or payment to you or any other person or entity. You acknowledge and agree that we may use any ideas, concepts, know how or techniques contained in User Content for any purposes whatsoever, including in advertising or informational articles.  

1. You are solely responsible for User Content. This means you, and not us, are entirely responsible and liable for any claims, loss or damages relating to User Content. When you post User Content, you represent and warrant you have permission to do so, including permission from any third parties whose names or likenesses are included.
2. In addition, if you provide to us any ideas, proposals, suggestions or other materials (detailed in section “e” below and referred to as “Feedback”), whether related to the Web Site, our programs or otherwise, such Feedback will be deemed to be User Content, and you hereby acknowledge and agree such Feedback is not confidential, and your provision of such Feedback is gratuitous, unsolicited and without restriction, and does not place us under any fiduciary or other obligation.
3. You represent and warrant you have all rights necessary to grant the licenses granted in this section, and User Content, and your provision thereof through and in connection with the Web site, are complete and accurate, and are not fraudulent, tortious or otherwise in violation of any applicable law or any right of any third party. You further irrevocably waive any other rights with respect to attribution of authorship or integrity of materials regarding User Content you may have under any applicable law under any legal theory.
4. A Few Rules of the Road Regarding User Content.  Sc3 does not endorse or control User Content, so we have to ask that you follow a few rules:
5. User Content Must Comply with Our Acceptable Use Policy (as set forth below). Don’t post content or materials that are obscene or that promote illegal activity, or that defame, abuse, harass, threaten or otherwise violate the legal rights of others (including rights of privacy and publicity). Any content or materials containing things like hate speech, nudity and violence (as examples) is strictly prohibited.
6. User Content Must Be Yours. This means you have created the content or materials containing User Content and, where applicable, you must have permission from everyone whose name or likeness is contained in your content or materials to share such content or materials. User Content should not contain any visible logos, phrases or trademarks or other third party materials. Do not post any content or materials that belong to a third party (including any content that you might have found elsewhere on the Internet).
7. User Content Must Be Accurate and Truthful. Do not impersonate any other user, person or company or upload or post any content or material that you know is inaccurate, fraudulent, or deceptive. If you are not authorized to speak on behalf of a company, please do not do so. Anything you say or post on the Web site should reflect your true opinions or experiences.
8. User Content Must Not Include Sensitive Information. Please avoid including your sensitive personal information (such as your social security number, credit card number, etc.) in any User Content posted.
9. User Content Must Not Be Commercial. Don’t post advertisements, offers, or other commercial content designed or intended to sell your or a third party’s goods or services.
10. No Obligation to Monitor User Content. Sc3 may and expressly reserve the right (but have no obligation) to monitor, scan, intercept, review, analyze, record, store, evaluate, alter or remove User Content (and any messages, information, content or other materials sent to you, or received by you, in connection with the Web site or its features or functionalities), at any time, including while it is in transit, and before and after it is stored or made available through the Web site, and to monitor, review, analyze or evaluate your access to or use of the Web site (including any Web site features or functionalities), in each case by manual, automated or other means, and in each case for any purpose (including analytics, advertising (including sharing with ad brokers), marketing and any purposes as may be described in our Privacy Policy).

Acceptable Use: You accept sole responsibility for all of your activities using the Web site. You may not use the Web site in a manner that: 

1. i. Uses technology or other means not authorized by us to access the Web site or our systems;
2. Uses or launches any manual or automated device or system, including “robots,” “spiders,” or “offline readers,” to (a) retrieve, index, “scrape,” “data mine,” access or otherwise gather any Web site information or our systems; (b) reproduce or circumvent the navigational structure or presentation of the Web site; or (c) otherwise harvest or collect information about users of the Web site;

iii. Reverse engineers, decompiles or disassembles any portion of the Web site, except where such restriction is expressly prohibited by applicable law; 

1. Attempts to introduce viruses or any other computer code, files, or programs that interrupts, destroys, or limits the functionality of any computer software, hardware, or telecommunications equipment;
2. Attempts to gain unauthorized access to our computer network or user accounts;
3. Encourages conduct that would constitute a criminal offense or that gives rise to civil liability;

vii. Harasses, abuses, stalks, threatens, defames, or otherwise infringes or violates the rights of us or any other party (including rights of publicity or other proprietary rights); 

viii. Is unlawful, fraudulent, or deceptive; 

1. Attempts to damage, disable, overburden, or impair our servers or networks; 
2. Reproduces, modifies, adapts, translates, creates derivative works of, sells, rents, leases, loans, timeshare, distributes or otherwise exploits any portion of (or any use of) the Service except as expressly authorized herein, without our express prior written consent;
3. Fails to comply with applicable third-party terms; or

xii. Otherwise violates these Terms and Conditions of Use. 

DMCA Notice - How to Provide Notice of Alleged Copyright Infringement: 

1. You may not use the Web site for any purpose or in any manner that infringes the rights of any third party. In accordance with the Digital Millennium Copyright Act of 1998 (the “DMCA“), we have a designated agent for receiving notices of alleged copyright infringement and we follow the notice and take down procedures of the DMCA. We may terminate your access to the Web site in the event of repeated violations.
2. If you believe one of our users is, through the use of the Web site, unlawfully infringing the copyright(s) in your work, and wish to have the allegedly infringing material removed, the following information in the form of a written notification (pursuant to the DMCA) must be provided to our designated copyright agent: (i) a physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed; (ii) identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works on the Web site are covered by a single notification, a representative list of such works on the Web site; (iii) identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled; (iv) information reasonably sufficient to permit us to locate such material; (v) information reasonably sufficient to permit us to contact you, such as your address, phone number, and email address; (vi) a statement that you have a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law; and (vii) a statement that the information in the notification is accurate, and under penalty of perjury, that you are authorized to act on behalf of the copyright owner.
3. It is often difficult to determine if your intellectual property rights have been violated. Sc3 may request additional information before we remove any allegedly infringing material. Please note that, pursuant to 17 U.S.C. § 512(f), any misrepresentation of material fact (falsities) in a written notification automatically subjects the complaining party to liability for any damages, costs and attorney’s fees incurred by us in connection with the written notification and allegation of copyright infringement. Sc3 may request additional information before we remove any allegedly infringing material. Please direct copyright infringement notifications to our DMCA agent at info@sc3.ltd (please include “Notice of Infringement” in the subject line). 

No representations made as to other sites or links: This service may provide links to certain Internet sites (the “Sites”) sponsored and maintained by third parties. Sc3 is providing such links solely as a convenience to you. Accordingly, Sc3 makes no representations concerning the content of the Sites. The fact that Sc3 has provided a link to the Site does not constitute an endorsement, authorization, sponsorship, or affiliation by Sc3 with respect to the Site, its owners, or its providers. Sc3 has not tested any information, software, or products found on any of the Sites and therefore does not make any representations with respect thereto, including any representations regarding the content or sponsors of the Site, or the suitability or appropriateness of the products or transactions described therein.