Privacy Policy

1. Introduction

This privacy notice (the “Notice”) has been issued by CPI DEV TEAM LTD having its registered office at Main Street 6-8, GX11 1AA, GIBRALTAR, acting (“CPI”; “we”; “us”; “our”). CPI has launched the CPI project, accessible via {INSERT LINK TO WHITE PAPER}. The CPI project will involve the issue and sale of CPI tokens which will represent a unit of value within CPI (the “Tokens”). The purpose of this Notice is to explain how we process personal data about individuals who: • invest in CPI and subscribe to the Tokens that we have issued (subject to our approval); or • apply to invest in CPI and to subscribe to our issued Tokens, in accordance with out Token Purchase Agreement (the “TPA”), accessible via {INSERT LINK TO THE AGREEMENT}which sets out the terms upon which you can subscribe to our issued Tokens. Where the applicant, or investor, is an institutional investor, then we will process personal data about the directors, legal representatives, officers, authorised signatories, shareholders and ultimate beneficial owners (UBOs) of that institutional investor. This Notice also explains how we process personal data about those individuals and should therefore be circulated accordingly. It should also be read in conjunction with our Cookie Policy available on the following link: In this Notice, “you” is used to refer to any of the above individuals, i.e. the investor (if a natural person) and in the case of institutional investors, their directors, representatives, officers, authorised signatories, shareholders and UBOs.

2. Controller

We (CPI) are the controller of your personal data. We process your data in an appropriate and lawful manner, in accordance with the Data Protection Act (Chapter 586 of the Laws of Malta) (the “Act”) and the General Data Protection Regulation (Regulation (EU) 2016/679) (the “Regulation” or the “GDPR”). This Notice aims to ensure that you are fully informed on how CPI will collect and process your personal data. It informs you about the items of personal data that we may collect about you and how we will handle it, and in turn, also tells you about (i) our obligations to process your personal data responsibly, (ii) your data protection rights as a data subject and (iii) how the law protects you. Our full details are as follows. Contact details Full name of legal entity: CPI DEV TEAM LTD **Email address: [email protected] Postal address: The Penthouse, Carolina Court, Giuseppe Cali Street, Ta’ Xbiex, XBX 1425, Malta We have a dedicated data protection team which serves as our data protection contact point and is responsible for overseeing queries in relation to this Notice and for handling any data subject requests (which are outlined in Section 11). If you have any question about this Notice, including any requests to exercise your legal rights, please contact our data protection team using the contact details set out above. Please use the words ‘Data Protection Matter’ in the subject line.

3. Some key definitions

Set out below are key definitions of certain data protection terms which appear in, and apply to, this Notice. “data subjects” means living individuals (i.e. natural persons) about whom we collect and process personal data. “data controller” or “controller” means any entity or individual who determines the purposes for which, and the manner in which, any personal data is processed. “data processor” or “processor” means any entity or individual that processes data on our behalf and on our instructions (we being the data controller). “legitimate interest” means our interest to conduct and manage our business affairs appropriately and responsibly, to protect the reputation of our business, and to provide our applicants, investors and subscribers with the best possible service. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at the following email address: [email protected]. “performance of a contract” means processing your data where it is necessary for the performance of a contract to which you or your respective entity are a party, or to take steps at your request before entering into such a contract. In the present case, this primarily relates to subscription to our Tokens (including applications to that effect). “personal data” means data relating to a living individual (i.e. natural person) who can be identified from the data (information) we hold or possess. This includes, but is not limited to, your name and surname (including maiden name where applicable), address, date of birth, nationality, gender, civil status, tax status, identity card number & passport number, contact details (including mobile and home phone number and personal email address), photographic image, bank account details, emergency contact information as well as online identifiers. The term “personal information”, where and when used in this Notice, shall be taken have the same meaning as personal data. “processing” means any activity that involves use of personal data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including, organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties. “sensitive personal data”, “sensitive data” or “special categories of personal data” includes information about a person's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. This type of sensitive data can only be processed under strict conditions. “Comply with a legal obligation” means processing your personal data where it is necessary to comply with a legal or regulatory obligation to which we are subject. Note that personal data does not include information relating to a legal person (such as institutional investors). Information such as a company name, its company number, registered address and VAT number does not amount to personal data under applicable data protection legislation, including the GDPR. Consequently, the collection, use and processing of information which strictly relates to a legal person does not give rise to ‘controller obligations’ at law. We will still naturally treat any and all such information in a confidential manner, in accordance with our standard applicant and investor practices and obligations at law.

4. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). The personal data that we process about you is collected and generated from a variety of sources, in in accordance with applicable laws and regulations, as follows: (i) When you complete and submit to us, by email, phone, registered mail or otherwise, our ‘Subscription Forms’, ‘Token Sale Agreement’, ‘Purchaser Questionnaire’ and other related applications, declaration forms and documents (as part of our application process for subscription to the Tokens). This will, by and large, include your: • name, address, marital status and personal and business contact details (both electronic and mailing), e.g. work and residential address, phone number and e-mail; • proofs of name, address or authority to act (verification); • date of birth, gender and nationality; • identity document or passport number; • signature job title and employment details (industry role, business activities, name of current employer); • financial details, such as bank account details, tax calculations and/or returns, history of investment holdings and transactions, credit checks and other similar information; • tax information, such as tax residency and tax identification information; and • the due diligence and KYC documentation detailed in our Subscription Form, including information on your source of funds and/or assets in accordance with our AML/KYC Policy available on the following link: (ii) In the ordinary course of managing and administering our business relationship with you. For instance, we will create records of (i) our interactions with you (including copies of electronic communications exchanged between you and us), (ii) details of your investments and subscriptions with us and (iii) details about payments made to and received from you. (iii) We also receive your personal data from third parties, such as your advisors, intermediaries, regulatory and from publicly available sources such as public court documents, the RoC, company house and company registers of other jurisdictions, and from electronic data searches, online KYC search tools (which may be subscription or license based), anti-fraud databases and other third party databases, sanctions lists and general searches carried out via search engines (e.g. Google). This generally relates to information which we obtain for the purposes of our “know-your-client” procedures (which includes anti-money laundering procedures, counter-terrorist financing procedures, politically-exposed-persons checks, sanctions checks, amongst others). If you fail to provide personal dataWhere we need to collect personal data about you by law, or pursuant to the terms of our agreement with you and/or your respective entity, and you fail to provide that data when requested, we may not be able to (i) accept you or your respective entity as an investor or subscriber or (ii) continue the business relationship (if already commenced). We will duly inform and notify you if this is the case at the time. Sensitive Personal DataWe do not seek to collect or otherwise process your sensitive personal data; save for instances where we receive personal data relating to your political affiliations as part of our politically-exposed-persons (PEP) checks and/or sanctions information. Any processing of such sensitive personal data about you will be necessary for reasons of substantial public interest, on the basis of an applicable law that is proportionate to the aim pursued and provides for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject. There may be other exceptional occasions where we may need to process your sensitive personal data, namely where: • the processing is necessary for the detection or prevention of crime (including the prevention of fraud) to the extent permitted by applicable law or regulation; • the processing is necessary for the establishment, exercise or defence of legal rights.

5. Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely upon to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data pursuant to more than one lawful ground or basis, depending on the specific purpose for which we are using your data. | Purpose/Activity | Lawful basis for processing including basis of legitimate interest || ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ || (a) ‘New investor / subscriber onboarding’
- to onboard new business relationships and comply with our internal policies and procedures; and
- to assess and take an informed decision on whether we will enter into a business relationship with you.
(b) To decide on your or your entity’s application to invest with us and/or to subscribe to our Tokens;
(c) To enter into a business relationship with you. | (a) Performance of a contract with you or in order to take steps at your request prior to entering into such a contract.
(b) Necessary for our legitimate interests (to determine whether we want to enter into a relationship with you, to determine whether we can take you on as investor, to verify ability to meet financial commitments || (a) To establish and verify your identity;
(b) To fulfil our other due diligence and KYC internal compliance policies and requirements;
(c) To fulfil any external mandatory reporting obligations that we may, from time to time, have to the local and overseas public and regulatory authorities and/or law enforcement agencies; | (a) Necessary for our legitimate interests (to establish and verify the identity of our subscribers and investors (including UBOs, shareholders, directors and representatives), including screening against global sanctions lists - even where the requested assistance does not amount to a ‘relevant activity’ in terms of AML and CFT regulations, for internal risk management and to detect and protect against fraud).
(b) Necessary to comply with a legal obligation. || (a) To process, review and assess your subscription application/s for our Tokens;
(b) To administer your investments and subscriptions and any other interests which you may hold in CPI;
(c) To perform investor servicing functions in respect of your investments and subscriptions to our Tokens;
(d) To maintain an up-to-date and accurate register of:
- members / shareholders;
- debenture-holders
(e) To receive and make payments to you. | (a) Performance of a contract with you or in order to take steps at your request prior to entering into such a contract.
(b) Necessary to comply with a legal obligation. || (a) For accounting purposes;
(b) To collect and recover money which is owed to us (debt recovery).
(c) Internal record keeping (including files). | (a) Performance of a contract with you.
(b) Necessary to comply with a legal obligation (accounting and other record-keeping requirements).
(c) Necessary for our legitimate interests (to recover debts due to us, to keep track of your investments and subscriptions, including their status and outcome, and to be able to revisit such matters if new issues arise). || Relationship management: to enable us to manage our business relationship with you in an efficient manner
- to keep our records up to date;
- to maintain records of your investments and subscriptions with us our interactions with you; and
- to respond to any queries or complaints we may receive from you and to seek to resolve these. | (a) Performance of a contract with you
(b) Necessary for our legitimate interests (for client relationship handling and management). || (a) To detect, investigate and prevent and/or report
- breaches of internal and regulatory policies; and/or
- fraudulent activity and/or any other criminal activity.
(b) To assist and cooperate in any criminal or regulatory investigations against you, as may be required of us.
(c) Risk Management: to effectively operate our audit, compliance controls and other risk management functions. | (a) Necessary to comply with a legal obligation.
(b) Necessary for our legitimate interests (to maintain and protect the reputation of our business). || Business and financial management
(a) To run our business in an efficient and proper manner,
(b) To enable third parties to provide us (or our investors / subscribers or prospective investors / subscribers) with services or financial products;(c) To respond to investor due diligence requests; and (d) To investigate and respond to investor complaints; | (a) Necessary for our legitimate interests (for administering, managing and operating the affairs of our business properly, including managing our financial position, business capability, planning, communications, corporate governance (such as company registers and other company secretarial functions), audit, insurance, sales, to prevent fraud and to maintain the confidentiality of communications, and in the context of a business reorganisation or group restructuring exercise).
(b) Necessary to comply with a legal obligation. || (a) To manage the performance and security of our equipment, IT systems and electronic platforms, including administering access rights;
(b) To operate IT security audits; | (a) Necessary for our legitimate interests (for running and administering our business (including IT support), to ensure systems administration and network security). || To permit CPI to pursue available remedies or limit any damages that CPI may sustain. | (a) Performance of a contract with you.
(b) Necessary for our legitimate interests. | Please contact us at [●] if you need details or wish to enquire about the specific lawful basis we are relying on to process your personal data where more than one lawful basis has been set out in the table below. Change of purpose We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose, or we are obliged to process your data by applicable laws or court or regulatory orders. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at [email protected]. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without the need to obtain your consent, in compliance with the above rules, where this is required or permitted by law.

6. Marketing

You may receive marketing communications from us (which may consist of [insert]) where: • you or your respective entity have entered into a business relationship with CPI; and • provided you have not opted out of receiving marketing from us (see your right to object below). Where the above does not apply to you, we will only send you our marketing communications where you have expressly consented to receive them from us.

7. Disclosures of your personal data

We may have to grant access to, disclose or share your personal data with the parties set out below, including your submitted applications, questionnaires and declaration forms, for the purposes set out in the table in Section [X] • other entities with the CPI group. • Suppliers and external agencies that we engage to process information on our or your behalf, including to provide you with the information and/or materials which you may have requested. • Third party service providers to CPI and those companies which our service providers appoint to assist them with the administration of our business, including technology service providers; • To any relevant party in connection with our anti-money laundering, anti-bribery, anti-fraud or ‘KYC’ requirements or policies (including third party service providers which carry out sanctions checks on our behalf); • Third-party payment processors, such as payment services providers and banks; • Our Professional Advisers (such as our auditors, accountants, financial advisers and legal counsel); • To regulators, government bodies and tax authorities (local and overseas) when required by applicable laws and/or regulations; • To any relevant party, claimant, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims in accordance with applicable law and regulation; and • To any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences in accordance with applicable law and regulation. • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets (successors in title). Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your personal data in the same way as set out in this Notice. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Furthermore, we do not allow our third-party service providers, to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our documented instructions.

8. International Transfers

CPI DEV TEAM LTD. Other International Transfers Due to the international nature of our business and service providers, your personal data may be transferred and stored in countries outside of the EEA. Some of these countries may have been deemed by the European Commission to have the same level of protection as countries in respect of which EU data protection law applies. For any such transfer, we will ensure that at least one of the following safeguards applies or is otherwise implemented: • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. • In the absence of an adequacy decision, we will use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. • Where we use providers based in the U.S., we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. Please contact us at [email protected] if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

9. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed (safeguard its integrity and confidentiality). We also regularly review and, where practicable, improve upon these security measures. Additionally, we have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, i.e. the performance and management of our business relationship with you (whilst ongoing), and thereafter: • for the purpose of satisfying any legal, accounting, tax or reporting obligations to which we may be subject; and/or • to the extent that we may also need to retain your personal data to be able to assert, exercise or defend possible future legal claims against or otherwise involving you. By and large, we will maintain and retain your personal data throughout the period of your business relationship with us and for a further period of six (6) years from the date of its termination. This retention period enables us to make use of your personal data to satisfy any applicable reporting obligations to public authorities and/or for the assertion, filing or defence of possible legal claims by or against you or your respective entity (taking into account applicable prescriptive periods). In certain cases, we may need to retain personal data for a period of up to eleven (11) years in order to comply with applicable accounting and tax laws (this will primarily consist of your transactions records). There may also be other instances where the need to retain certain items of personal data about you for longer periods, as dictated by the nature of the business relationship and the products and/or services provided. In some circumstances you can ask us to delete your data. See Request erasure below for further information. Kindly contact us at [email protected] for further details about the retention periods that we apply.

11. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. • Request access to your personal data. • Request correction (rectification) of your personal data. • Request erasure of your personal data. • Object to processing of your personal data. • Request restriction of processing your personal data. • Request transfer of your personal data. • Right to withdraw consent. If you wish to exercise any of the rights set out above, please contact us at [email protected].No fee is usually chargedYou will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may simply refuse to comply with your request in such circumstances. What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Time limit to respond We try to respond to all legitimate requests within a period of one month from the date of receiving your request. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. You have the right to: (i) Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are processing it in a lawful manner.. You may send an email to [email protected] requesting information as the personal data which we process. You shall receive one copy free of charge via email of the personal data which is undergoing processing. Any further copies of the information processed shall incur a charge of €10.00. (ii) Right to information when collecting and processing personal data about you from publicly accessible or third party sources. When this take places, we will inform you, within a reasonable and practicable timeframe, about the third party or publicly accessible source from whom we have collected your personal data. (iii) Request correction or rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected and/or updated, though we may need to verify the accuracy of the new data you provide to us. As mentioned, it is in your interest to keep us informed of any changes or updates to your personal data which may occur during the course of your business relationship with us. (iv) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where:• there is no good reason for us continuing to process it; • you have successfully exercised your right to object to processing (see below); • we may have processed your information unlawfully; or • we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. These may include instances where the retention of your personal data is necessary to: • comply with a legal or regulatory obligation to which we are subject; or • establish, exercise or defend a legal claim. (v) Object to 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes (as under the ‘Marketing’ in Section 6 above). In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal information that override your rights and freedoms. (vi) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: • if you want us to establish the data's accuracy; • where our use of the data is unlawful but you do not want us to erase it; • where you need us to hold onto the data even if we no longer require it, as you need it to establish, exercise or defend legal claims; or • where you have objected to our use of your personal data, but we need to verify whether we have overriding legitimate grounds to use it. (vii) Request the transfer (data portability) of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. (viii) Withdraw your consent at any time where we are relying on consent to process your personal data (which will generally not be the case). This will not however affect the lawfulness of any processing which we carried out before you withdrew your consent. Any processing activities that are not based on your consent will remain unaffected. Kindly note that none of these data subject rights are absolute, and must generally be weighed against our own legal obligations and legitimate interests. If a decision is taken to override your data subject request, you will be informed of this by our data protection team along with the reasons for our decision.

12. Complaints

You have the right to lodge a complaint at any time to a competent supervisory authority on data protection matters, such as in particular the supervisory authority in the place of your habitual residence or your place of work. In the case of Malta, this is the Office of the Information and Data Protection Commissioner (the “IDPC”) ( We would, however, appreciate the opportunity to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

13. Conclusion

We reserve the right to make changes to this Notice in the future, which will be duly notified to you. If you have any questions regarding this Notice, or if you would like to send us your comments, please contact us today or alternatively write to our data protection team using the details indicated in this Notice.