# 🔏 Privacy Policy

# Privacy Policy for RampX

This privacy notice provides information on how EPHELIA US PS LLCis a company incorporated under the laws of New York, with registered office at 333 E 46th ST Apt 1F New York, NY 10017-7426 (“Ephelia”, “we” or “us”), collects and processes your personal data. Ephelia is the data controller and is responsible for your personal data. If you have any questions about this privacy notice or our data protection practices, please contact our compliance office: privacy@epheliagroup.

This document concerns data subjects (“Data Subject”, “you”, “your”) whose personal information is collected by us when you act as user of our websites or provide us your information as explained below.

Ephelia recognises the importance of the protection of personal information. This Privacy Policy (“Policy”) sets out our practices in relation to information that is gathered from persons who visit our websites Rampx App and Rampx Website (“Sites”), use of our mobile applications (“Apps”) (both as amended from time-to-time), or otherwise where information that is shared with us and is defined as Personal Information (collectively: “Users”).

# 1. Important information and who we are

This Privacy Notice (“Notice”) describes how we collect and use personal information about you during and after your contractual relationship with us, in accordance with applicable data protection and privacy legislation in force in compliance with applicable U.S. federal and New York State laws and also the European General Data Protection Regulation (EU) 2016/679 (“GDPR”); the Privacy and Electronic Communications Directive 2002/58/EC (as updated by Directive 2009/136/EC) and the Privacy and Electronic Communications Regulations 2003 (SI 2003 No. 2426) as amended.

# 2. The data we collect about you

Personal Information is information, when taken individually, or collectively, has the ability, by reasonable means, to identify a person, whether that be a User or any other person. In particular, we may collect, use, store and transfer different kinds of personal data about you as follows:

Identity Data.
Contact Data.
Financial Data.
Transaction Data.
Technical Data.
Profile Data.
Usage Data.
Blockcahin wallet address
Geolocation data
Marketing and Communications Data.

# 3. How we use your personal data

We will only use your personal data for the purpose for which we collected it which include the following:

To register you as a new customer.
To process and deliver your order.
To manage your relationship with us.
To enable you to participate in a prize draw, competition or complete a survey.
To improve our websites, products/services, marketing or customer relationships.
To recommend products or services which may be of interest to you
To recommend products or services which are nearby your geolocation.

We also collect information that you made public or that you provide us by completing forms in writing, email, through our websites, by registering to our events, or social media. This includes information provided at the time of registering with us, to use our websites, to connect with us via our LinkedIn page, to participate to our events (webinar, fair, conference), to receive newsletters, to request materials or information or to request further services, when you respond to a survey and/or when you report a problem with any of our communication channels or services.

Navigation data are acquired by the computer systems and procedural software used to operate this websites during their normal operation. This is personal data whose transmission is implicit in the use of Internet communication protocols. This category includes IP addresses, addresses in URI/URL (Uniform Resource Identifier/Locator) notation, the time of the request, the type of request, the size of the outgoing packet, the status of the response given by the server (received, error, etc.) and other parameters relating to the operating system.

We store your personal data in accordance with our internal data retention policy. This policy is reviewed and updated internally to ensure we do not store your data for longer than is necessary. We also review how and where we store any data to ensure that we meet our obligation to store data securely. We process and store your personal data to the extent that it is required to fulfil our contractual and legal obligations or for the purposes pursued by the processing, which means, for example, for the entire duration of the business relationship (from the initiation and performance of a contract to its conclusion) and beyond that in accordance with legal obligations for storage and documentation.

We may share your personal data within the Ephelia Group, Ephelia employees and external third parties if necessary to perform our agreement with you.

Our websites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Our data of any kind are never binding. We reserve the right to change or update the information on this site at any time without notice. Our company is not responsible for internet malfunctions, damage caused by third parties, data imports of any kind (viruses, worms, Trojan horses) nor for links from or other sites on the Web. We have no control over the content and form of external Web pages. We cannot guarantee the flawless operation of hardware and software. In no event shall our company be liable to you or any third party for any direct, indirect, special, or consequential damages of any kind whatsoever resulting from the use of this Web site or another site linked to it. Any liability for loss of income, business interruption, loss of programs or other data in your computer systems is also excluded. The transmission of communications, documents and other information by e-mail is considered less reliable, secure, and confidential than by letter or fax. Against viruses and spam, we employ modern identification technologies. However, we recommend that you also employ a virus scanner, and we disclaim any liability for any damage resulting from e-mails or loss thereof. We reserve the right to reject e-mails with potentially dangerous attachments. In principle by visiting our Internet page you do not leave any personal information behind. However, in some cases we need your name and address. For our part we are committed to protecting the confidentiality of your personal data. On this site we make available to you through links (links) contents or services of other Internet sites. Such other sites are not subject to our data protection guidelines. We recommend that you check each such site and ascertain how your data is protected.

The user is made aware of that (i) the use of e-mail does not ensure the confidentiality and integrity of data in transit, (ii) many e-mail service providers are located or hold their data in countries that do not guarantee adequate protection of personal data, (iii) the use of such an e-mail service results in the transfer and storage of data in a country that does not guarantee adequate protection of such data. The user authorizes the company to transmit by ordinary (non-secured) e-mail documents and/or information, including those containing personal and/or confidential data, using the e-mail address provided by the user in response to user requests received by fax, telephone or e-mail. The user, in full awareness of the risks mentioned above, releases the company from any liability in the event of unauthorized access by third parties to personal and/or confidential documents and/or information transmitted or received via e-mail from the company.

# 5. Blockchain and Data Privacy

Certain features of our Services may utilise blockchain technology, which is a decentralised, distributed ledger designed to record transactions across multiple computers. Due to the immutable nature of blockchain technology, data recorded on the blockchain cannot be modified or deleted once confirmed. This characteristic affects your rights and our obligations concerning personal data under applicable data protection laws.

‍by using our services, you acknowledge that your personal data is stored on publicly searchable blockchains and neither we, nor any third party, has any power to delete such data published by its users to the blockchain. You hereby release and indemnify us of any data privacy liability associated with data that are published on the blockchain by using our platform

# 6. International transfers

We may transfer the personal information we collect about you to recipients located outside Switzerland such as UK/Germany/Netherlands and other EEA countries in order to perform our contract with you. There are adequacy regulations in respect of those countries. This means that the countries to which we transfer your data are deemed to provide an adequate level of protection for your personal information, mainly complaying with GDPR regulations.

However, to ensure that your personal information does receive an adequate level of protection we have put in place the appropriate measure[s] to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects Swiss law on data protection and the GDPR: If you require further information about these protective measures, you can request it from privacy@epheliagroup.

# 7. Your legal rights

Under certain circumstances, you have rights under FADP and GDPR in relation to your personal data including the right to receive a copy of the personal data we hold about you and the right to make a complaint at any time:

to the Swiss Federal Data Protection and Information Commissioner IFPDT

https://www.edoeb.admin.ch/edoeb/it/home/deredoeb/kontakt/anzeigeformular_betroffene.html

By law you have the right to:

Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact: privacy@epheliagroup.com.

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact: privacy@epheliagroup.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

# 9. Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

# 10. Further details

If you are looking for more information on how we process your personal data including on data security, data retention and lawful processing bases, please contact: privacy@epheliagroup.com

Version 1.0 May 2025