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AML Policy

Last updated: May 2024

This Anti-Money Laundering and Combating the Financing of Terrorism Policy (AML/CFT Policy) (the
"Policy") has been adopted by Shining Capital Ltd (hereinafter referred to as “Shining Capital Ltd “,
“we“, “Company”) to prevent the use of its products and services for money laundering and terrorist
financing activities. The Company is committed to complying with all applicable laws, regulations, and
guidance regarding AML and Combating the Financing of Terrorism (CFT). This AML/CFT Policy is an
essential part of our Terms of Use.
1. Purpose
This Policy is intended to protect the Company from being used as a tool for illegal activities such as
money laundering or terrorist financing by establishing guidelines for identifying and mitigating the risks
of such activities in its interactions with External Parties. The Policy sets out specific procedures that the
Company will follow to achieve this goal, including the implementation of robust client and business
partner identification processes, ongoing Transaction Monitoring to detect Suspicious Activity, and
mandatory Reporting of any Suspicious Activity to the relevant authorities. By taking these steps, the
Company will be better equipped to safeguard its Reputation, protect its assets, and avoid any
implication in Financial Crime.
The Policy also set out the specific responsibilities of employees, senior management and the Board of
Directors in ensuring that the company's AML/CFT Compliance program is effective and up to date.
Additionally, it also provides the company's internal controls and procedures for ensuring Compliance
with applicable laws, regulations, and standards. It also includes the requirement for the Company to
conduct regular internal audits, Risk Assessments, and Training Programs for employees to ensure that
they are aware of their responsibilities and the company's AML/CFT Compliance program.
Overall, the goal of this Policy is to ensure that the Company is able to identify and prevent any illegal
activities from taking place within its operations and to maintain the integrity of its Financial Systems by
adhering to the best practices for Anti-Money Laundering and Combating the Financing of Terrorism.
2. Scope
This Policy is designed to ensure that the Company is compliant with laws and regulations related to
money laundering and terrorist financing, and that it is not unknowingly involved in any illegal activities.
To achieve this, the Company will conduct Due Diligence on all External Parties with which it has
relationships. This will involve evaluating potential risks and assessing the Reputation and past behavior
of these parties to ensure that they are not involved in any illegal activities.
The Company will also establish procedures for identifying and Reporting Suspicious Activity, and for
verifying the identity of Users and other External Parties. This includes implementing know-your-User
(KYC) procedures and Anti-Money Laundering (AML) protocols. Additionally, the Company will ensure
that its employees are trained to recognize and report Suspicious Activity, and that they are aware of
the company's policies and procedures in this regard.
The Policy outlines the steps and procedures the Company will take to evaluate and manage the risks
associated with External Parties, including conducting Due Diligence, implementing KYC and AML
protocols, and training employees to recognize and report Suspicious Activity. The goal is to ensure that
the Company is not unknowingly involved in any illegal activities and is in Compliance with all laws and
regulations related to money laundering and terrorist financing.
3. Definitions
● AML/CFT laws and regulations: The laws, regulations and guidance related to Anti-Money
Laundering and Combating the Financing of Terrorism that the Company is committed to comply with.
● Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Compliance
Program: The Company's internal program for ensuring Compliance with AML and CFT laws and
regulations.
● Audits and Assessments: Regular internal Audits and Risk Assessments to ensure the effectiveness
of the company's AML/CFT Compliance program.
● Company refers to Island Ring Road, TB office, NRU68, Yeren, Nauru, Republic of Nauru
● Compliance Department: A Department within the Company responsible for reviewing and
investigating reports of Suspicious Activity and determining whether the reported activity is indicative of
money laundering or terrorist financing. They also take necessary steps to report Suspicious Activity to
the appropriate authorities.
● User Due Diligence (CDD): A thorough process of identifying and assessing the risks associated with
new relationships, which includes a variety of steps to verify the identity of the User or business partner,
assess the risk of money laundering or terrorist financing, and obtain information about the User's or
business partner's Source of Funds and intended use of the company's products or services.
● Due Diligence: A process of evaluating potential risks and assessing the Reputation and past
behavior of External Parties to ensure that they are not involved in any illegal activities, such as money
laundering or terrorist financing.
● External Parties: Users, business partners, suppliers, and other third parties with whom the
Company has relationships.
● Financial Crime: Illegal activities that involve financial transactions, such as money laundering and
terrorist financing.
● Financial Systems: The processes and infrastructure that enable financial transactions, such as
banking and payment systems.
● Ongoing Monitoring: Regularly reviewing and assessing the activities of External Parties and
transactions to detect Suspicious Activity and ensure Compliance with AML/CFT policies and procedures.
● Purpose: This Policy is intended to protect the Company from being used as a tool for illegal
activities such as money laundering or terrorist financing by establishing guidelines for identifying and
mitigating the risks of such activities in its interactions with External Parties.
● Reputation: The perception of a Company held by the public, Users and other stakeholders.
● Risk Assessment: A process of evaluating the potential risks of money laundering and terrorist
financing associated with the company's external relationships, by considering a range of factors,
including the nature of the relationship, the products or services provided, the location of the User or
business partner, and the User's or business partner's industry or sector.
● Risk-Based Approach: A methodology in which the Company applies more stringent measures for
higher-risk relationships and less stringent measures for lower-risk relationships.
● Sanctions Compliance: Procedures for screening Users, business partners and transactions against
Sanctions Lists to ensure that the Company is not doing business with individuals or entities that are
prohibited by sanctions laws.
● Sanctions Lists: Lists of individuals or entities that have been designated by government agencies as
being subject to sanctions, embargoes, or other restrictions on trade or financial transactions.
● Sanctions Screening: Procedures implemented by the Company to check the names of individuals
and entities against lists of individuals and entities that have been designated by government agencies
as being subject to sanctions, embargoes, or other restrictions on trade or financial transactions.
● Source of Funds: The origin of the money or assets that a User or business partner uses to conduct
transactions or activities.
● Suspicious Activity: Any unusual or suspicious financial transactions or activities that may indicate
money laundering or terrorist financing.
● Third-Party Service Providers: External companies or individuals that provide services to the
company, such as accounting, legal, or IT services.
● Training Programs: Programs for educating employees on how to recognize and report Suspicious
Activity and their responsibilities under the company's AML/CFT Compliance program.
● Transaction Monitoring: The process of reviewing and analyzing financial transactions to detect
Suspicious Activity and ensure Compliance with AML/CFT policies and procedures.
● Verification of Identity: The process of confirming the identity of a User or business partner through
government-issued identification documents or by checking their creditworthiness.
4. Risk Assessment
The Company recognizes that different external relationships present varying levels of risk for money
laundering or terrorist financing activities. Therefore, it will conduct a comprehensive Risk Assessment
of all its external relationships to identify and evaluate any potential risks. This Risk Assessment will
consider a range of factors, including the nature of the relationship, the products or services provided,
the location of the User or business partner, and the User's or business partner's industry or sector.
Based on the results of the Risk Assessment, the Company will take appropriate measures to mitigate
any risks identified. These measures include enhanced Due Diligence procedures, such as additional
Verification of the User's or business partner's Identity or the source of their funds. The Company also
implements Ongoing Monitoring procedures to detect any Suspicious Activity or changes in the risk
profile of the external relationship.
Additionally, the Company implements a Risk-Based Approach for its AML/CFT Compliance program,
which means the Company will apply more stringent measures for higher-risk relationships and less
stringent measures for lower-risk relationships.
5. Requirements for Users
The Company has established rules to prevent illegal operations in all Applications created by the User.
The person making and receiving payment must be the same individual, and transfers to third parties
are strictly prohibited. Contact information and personal data provided by the User must be accurate
and up-to-date. Additionally, the use of anonymous proxy servers or anonymous Internet connections to
create Applications is strictly prohibited.
6. User Due Diligence (CDD)
The Company is committed to conducting thorough User Due Diligence (CDD) on all new Users and
business partners to ensure that it is not unknowingly facilitating money laundering or terrorist
financing activities. CDD is a critical process for identifying and assessing the risks associated with new
relationships, and it includes a variety of steps to verify the identity of the User or business partner,
assess the risk of money laundering or terrorist financing, and obtain information about the User's or
business partner's Source of Funds and intended use of the company's products or services.
To conduct CDD, the Company takes several steps such as verifying the User's identity through
government-issued identification documents.
The Company may also request additional documents for the User's identification such as a bank
statement or utility bill from the past three months showing the User's full name and current address.
The Company reserves the right to request photo/video verification of the User if there are suspicions of
false information being provided. In turn, the Company verifies the authenticity of documents and
information provided by the User.
If the User's identification information has been altered or their activity appears suspicious, the
Company has the right to request updated documents from the User, even if they have already been
verified.
Additionally the Company might also assesses the risk of money laundering or terrorist financing by
researching the User's or business partner's background, including their financial history, and by
evaluating their indust ry or sector, obtains information about the User's or business partner's Source of
Funds and intended use of the company's products or services to understand their business activities.
The Company also recognizes the importance of Ongoing Monitoring to ensure that its Users and
business partners do not pose a risk of money laundering or terrorist financing. Therefore, it will
conduct Ongoing Monitoring of its Users and business partners to ensure that their activities do not
change and become a higher risk. This includes monitoring transactions for Suspicious Activity,
reviewing User information for any changes, and conducting additional CDD when necessary.
Overall, the company's CDD process and Ongoing Monitoring are essential tools for identifying and
managing the risks associated with its external relationships and for ensuring that it is complying with
applicable laws and regulations related to Anti-Money Laundering and Combating the Financing of
Terrorism.
7. Sanctions Screening
The Company has a responsibility to ensure that it is not doing business with individuals or entities that
are prohibited by sanctions laws. To achieve this, the Company will implement procedures to screen all
Users and business partners against Sanctions Lists. This will include checking the names of individuals
and entities against lists of individuals and entities that have been designated by government agencies
as being subject to sanctions, embargoes, or other restrictions on trade or financial transactions.
The Company will also screen transactions to ensure that they do not involve prohibited individuals or
entities. This will involve reviewing transaction details, such as the names of parties involved, the
amounts, and the location of the transaction, to ensure that they are not connected to any individual or
entity that is subject to sanctions.
Additionally, the Company will have procedures in place to investigate and report any potential
sanctions violations to the appropriate authorities.
8. Reporting Suspicious Activities
The Company recognizes the importance of having a process in place for employees to report any
suspicious activities or transactions that indicate money laundering or terrorist financing. To achieve
this, the Company will establish a process for employees to confidentially report any suspicious activities
or transactions that they encounter in the course of their work. This process will be clearly
communicated to all employees, and they will be encouraged to report any suspicious activities or
transactions as soon as they become aware of them.
To aid employees in recognizing and Reporting suspicious activities, the Company will provide training
on the various red flags that indicate money laundering or terrorist financing. This training will include
information on how to recognize patterns of behavior or transactions that are indicative of illegal
activities, as well as the procedures for Reporting such activities.
Reports of suspicious activities will be reviewed and investigated by the company's Compliance
Department, which will be responsible for determining whether the reported activity is indicative of
money laundering or terrorist financing. If it is determined that the reported activity is suspicious, the
Compliance Department will take the necessary steps to report the Suspicious Activity to the
appropriate authorities.
The Company will establish a process for employees to report suspicious activities or transactions, and
provide them with training to recognize red flags that indicate money laundering or terrorist financing.
The Compliance Department will review and investigate these reports and take necessary steps to
report Suspicious Activity to the appropriate authorities.
9. Third-Party Service Providers
The Company will take steps to ensure that all Third-Party Service Providers comply with its Anti-Money
Laundering (AML) and Combating the Financing of Terrorism (CFT) policies and procedures. This will
involve conducting thorough Due Diligence on these providers, reviewing their Reputation and past
behavior, and evaluating their own AML and CFT policies and procedures. To ensure Sanctions
Сompliance, the Company will include specific provisions related to AML and CFT in contracts with
Third-Party Service Providers. Additionally, the Company will conduct regular monitoring of these
providers to confirm they are adhering to the AML and CFT policies and procedures set forth in the
contract.
10. Training
The Company will provide training to its employees on the policies and procedures, and best practices
for preventing money laundering and terrorist financing in its external relationships. The training will be
conducted on a regular basis, at least once a year, and will be tailored to the specific roles and
responsibilities of each employee. The Company will also keep its employees updated on any changes in
regulations or guidance related to AML and CFT.
11. Restricted jurisdictions
The Company do not serve Clients from: Afghanistan, Albania, Algeria, Andorra, Anguilla, Antigua and
Barbuda, Argentina, Bahamas, Bahrain, Bangladesh, Barbados, Benin, Bermuda, Bolivia, Botswana,
Brazil, Brunei, Burkina Faso, Burundi, Cambodia, Cameroon, Cape Verde, Cayman Islands, Central African
Republic (CAR), Ceuta, Chad, Chile, China, Colombia, Comoros, Congo, Cook Islands, Costa Rica, Cuba,
Democratic People's Republic of Korea (DPRK), Democratic Republic of Congo, Djibouti, Dominican
Republic, Ecuador, Egypt, El Salvador, Equatorial Guinea, Eritrea, Eswatini, Ethiopia, French Guiana,
Gabon, Gambia, Ghana, Grenada, Guadeloupe, Guatemala, Guinea, Guinea-Bissau, Haiti, Honduras,
Iceland, India, Iran, Iraq, Ivory Coast, Jamaica, Japan, Jordan, Kenya, Korea, Kuwait, Laos, Lebanon,
Lesotho, Liberia, Libya, Macao, Madagascar, Maldives, Mali (Melilla), Marshall Islands, Martinique,
Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Nepal, Nicaragua, Niger,
Nigeria, Pakistan, Palestine, Panama, Paraguay, Peru, Puerto Rico, Qatar, Republic of Congo, Republic of
Kosovo, Republic of Liberia, Reunion, Russia, Rwanda, Sahara Arab Democratic Republic, Samoa, Sao
Tome and Principe, Sark, Saudi Arabia, Senegal, Serbia, Sierra Leone, Somalia, South Africa, South Sudan,
Sri Lanka, St. Barth, Senegal, St. Maarten, State of Palestine, Sudan, Switzerland, Syria, Taiwan, Tanzania,
temporarily occupied territories of Ukraine: Crimean Peninsula, Donetsk Oblast, Kharkiv oblast, Kherson
oblast, Luhansk Oblast, Zaporizhzhya oblast, Togo, Transnistrian Moldavian Republic, Trinidad and
Tobago, Tunisia, Turkey, Turkmenistan, Uganda, United Arab Emirates (UAE), United States of America
(USA), Uruguay, Vanuatu, Venezuela, Western Sahara, Yemen, Zambia, Zimbabwe.
12. Specific restrictive measures
Monitoring of the User's transactions and analysis of the received data is one of the tools for assessing
the risk and detecting suspicious transactions. In case of suspicion of money laundering, the Company
controls all transactions and reserves the right to:
• suspend or terminate the User's account;
• suspend the exchange and freeze assets until the circumstances are clarified;
• return the User's funds by canceling the Order;
• if during the transaction/wallet check for cleanliness of cryptocurrency assets, it is found that the coins
are marked with the SCAM, STOLEN, RANSOMWARE label or a risk analysis of 50% or more, the
transaction is not eligible for exchange and refund.
The Company may freezes assets owned, held, or controlled directly or indirectly by individuals and
entities and any benefits derived from these assets, as per Due Diligence. This freeze applies to
individuals and entities listed:
1. In the lists published by the Inspector General based on United Nations Security Council
resolutions issued under Chapter VII of the United Nations Charter, regarding threats to international
peace and security caused by terrorism, particularly in Resolution 2253 (2015) and Resolution 1988
(2011).
2. In the list of individuals and entities subject to specific restrictive measures kept by the Inspector
General and published in the Public Information Bulletin on the website of the minister responsible for
public finance.
The Company must provide information about the frozen assets to the General Inspector within 2
business days by submitting it electronically.
13. Conclusion
The Company is committed to complying with all applicable laws and regulations related to AML and
CFT in its external relationships. By implementing this Policy, the Company aims to prevent its products
and services from being used for money laundering or terrorist financing activities. The Company will
review and update this Policy regularly to ensure that it remains effective in addressing the risks of
money laundering and terrorist financing.
14. Contact Us
If You have any questions about this Agreement, You can contact us:
● By email: ax@shining.capital

PRIVACY POLICY

Shining Capital Ltd
Business license number: 003012024
Island Ring Road, TB office, NRU68, Yeren, Nauru, Republic of Nauru
e-mail: ax@shining.capita

Last Updated: January 2025.

This Privacy Policy (“Policy”) explains the information collection, use, and sharing practices of
Shining Capital Ltd (“we,” “us,” and “our”).
Unless otherwise stated, this Policy describes and governs the information collection, use, and
sharing practices of Shining Capital Ltd with respect to your use of our website (shining.capital)
and the services (“Services”) we provide and/or host on our servers.
Before you use or submit any information through or in connection with the Services, please
carefully review this Privacy Policy. By using any part of the Services, you understand that your
information will be collected, used, and disclosed as outlined in this Privacy Policy.
If you do not agree to this privacy policy, please do not use our Services.
Our Principles
Shining Capital Ltd has designed this policy to be consistent with the following principles:
 Privacy policies should be human readable and easy to find.
 Data collection, storage, and processing should be simplified as much as possible to
enhance security, ensure consistency, and make the practices easy for users to
understand.
 Data practices should meet the reasonable expectations of users.
Information We Collect
We collect information in multiple ways, including when you provide information directly to us;
when we passively collect information from you, such as from your browser or device; and from
third parties.
Information You Provide Directly to Us
We will collect any information you provide to us. We may collect information from you in a
variety of ways, such as when you: (a) create an online account, (b) make a donation or
purchase, (c) contact us or provide feedback, (d) subscribe to our newsletter. This information
may include but is not limited to your name, email address, phone number, mailing address,
payment information and your geographic location.
Information that Is Automatically Collected
Device/Usage Information
We may automatically collect certain information about the computer or devices (including
mobile devices or tablets) you use to access the Services. As described further below, we may
collect and analyze (a) device information such as IP addresses, location information (by country
and city), unique device identifiers, IMEI and TCP/IP address, browser types, browser language,
operating system, mobile device carrier information, and (b) information related to the ways in
which you interact with the Services, such as referring and exit web pages and URLs, platform
type, the number of clicks, domain names, landing pages, pages and content viewed and the
order of those pages, statistical information about the use of the Services, the amount of time
spent on particular pages, the date and time you used the Services, the frequency of your use of
the Services, error logs, and other similar information. As described further below, we may use
third-party analytics providers and technologies, including cookies and similar tools, to assist in
collecting this information.
Cookies and Other Tracking Technologies
We also collect data about your use of the Services through the use of Internet server logs and
online tracking technologies, like cookies and/or tracking pixels. A web server log is a file where
website activity is stored. A cookie is a small text file that is placed on your computer when you
visit a website, that enables us to: (a) recognize your computer; (b) store your preferences and
settings; (c) understand the web pages of the Services you have visited and the referral sites that
have led you to our Services; (d) enhance your user experience by delivering content specific to
your inferred interests; (e) perform searches and analytics; and (f) assist with security
administrative functions. Tracking pixels (sometimes referred to as web beacons or clear GIFs)
are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email,
and that are designed to provide usage information like ad impressions or clicks, measure
popularity of the Services and associated advertising, and to access user cookies. We may also
use tracking technologies in our license buttons and/or icons that you can embed on other
sites/services to track the website addresses where they are embedded, gauge user interaction
with them, and determine the number of unique viewers of them. If you receive email from us
(such as the CC newsletter, campaign updates, or other ongoing email communications from
CC), we may use certain analytics tools, such as clear GIFs, to capture data such as whether you
open our message, click on any links or banners our email contains, or otherwise interact with
what we send. This data allows us to gauge the effectiveness of our communications and
marketing campaigns. As we adopt additional technologies, we may also gather additional
information through other methods.
Please note that you can change your settings to notify you when a cookie is being set or
updated, or to block cookies altogether. Please consult the “Help” section of your browser for
more information. Please note that by blocking any or all cookies, you may not have access to
certain features or offerings of the Services.
For more information about how we use cookies, please read our Cookie Policy.
Information from Third Parties
To the extent permitted by law, we may also collect information from third parties, including
public sources, social media platforms, and marketing and market research firms. Depending on
the source, this information collected from third parties could include name, contact information,
demographic information, information about an individual’s employer, information to verify
identity or trustworthiness, and information for other fraud or safety protection purposes.
How We Use Your Information
We may use the information we collect from and about you to:
 Fulfil the purposes for which you provided it.
 Provide and improve the Services, including to develop new features or services, take
steps to secure the Services, and for technical and customer support.
 Fundraise, accept donations, or process transactions.
 Send you information about your interaction or transactions with us, account alerts, or
other communications, such as newsletters to which you have subscribed.
 Process and respond to your inquiries or to request your feedback.
 Conduct analytics, research, and reporting, including to synthesize and derive insights
from your use of our Services.
 Comply with the law and protect the safety, rights, property, or security of Shining
Capital Ltd, the Services, our users, and the general public.
 Enforce our Terms of Use, including to investigate potential violations thereof.
Please note that we may combine information that we collect from you and about you (including
automatically collected information) with information we obtain about you from our affiliates
and/or non-affiliated third parties, and use such combined information in accordance with this
Privacy Policy.
We may aggregate and/or de-identify information collected through the Services. We may use
de-identified and/or aggregated data for any purpose, including without limitation for research
and marketing purposes.
When We Disclose Your Information
We may disclose and/or share your information under the following circumstances:
Service Providers.
We may disclose your information with third parties who perform services on our behalf,
including without limitation, event management, marketing, customer support, data storage, data
analysis and processing, and legal services.
Legal Compliance and Protection of Creative Commons and Others.
We may disclose your information if required to do so by law or on a good faith belief that such
disclosure is permitted by this Privacy Policy or reasonably necessary or appropriate for any of
the following reasons: (a) to comply with legal process; (b) to enforce or apply our Terms of Use
and this Privacy Policy, or other contracts with you, including investigation of potential
violations thereof; (c) enforce our Charter including the Code of Conduct and policies contained
and incorporated therein, (d) to respond to your requests for customer service; and/or (e) to
protect the rights, property, or personal safety of Shining Capital Ltd, our agents and affiliates,
our users, and the public. This includes exchanging information with other companies and
organizations for fraud protection, and spam/malware prevention, and similar purposes.
Business Transfers.
As we continue to develop our business, we may engage in certain business transactions, such as
the transfer or sale of our assets. In such transactions, (including in contemplation of such
transactions, e.g., due diligence) your information may be disclosed. If any of our assets are sold
or transferred to a third party, customer information (including your email address) would likely
be one of the transferred business assets.
Affiliated Companies.
We may disclose your information with current or future affiliated companies.
Consent.
We may disclose your information to any third parties based on your consent to do so.
Aggregate/De-identified Information.
We may disclose de-identified and/or aggregated data for any purpose to third parties, including
advertisers, promotional partners, and/or others.
Legal Basis for Processing Personal Data
The laws in some jurisdictions require companies to tell you about the legal ground they rely on
to use or disclose information that can be directly linked to or used to identify you. To the extent
those laws apply, our legal grounds for processing such information are as follows:
To Honor Our Contractual Commitments to You.
Much of our processing of information is to meet our contractual obligations to provide services
to our users.
Legitimate Interests.
In many cases, we handle information on the ground that it furthers our legitimate interests in
ways that are not overridden by the interests or fundamental rights and freedoms of the affected
individuals, these include:
 Customer service.
 Marketing, advertising, and fundraising.
 Protecting our users, personnel, and property.
 Managing user accounts.
 Organizing and running events and programs.
 Analyzing and improving our business.
 Managing legal issues.
We may also process information for the same legitimate interests of our users and business
partners.
Legal Compliance.
We may need to use and disclose information in certain ways to comply with our legal
obligations.
Consent.
Where required by law, and in some other cases where legally permissible, we handle
information on the basis of consent. Where we handle your information on the basis of consent,
you have the right to withdraw your consent; in accordance with applicable law.
Online Analytics
We may use third-party web analytics services (such as Google Analytics) on our Services to
collect and analyze the information discussed above, and to engage in auditing, research, or
reporting. The information (including your IP address) collected by various analytics
technologies described in the “Cookies and Other Tracking Technologies” section above will be
disclosed to or collected directly by these service providers, who use the information to evaluate
your use of the Services, including by noting the third-party website from which you arrive to
our Site, analyzing usage trends, assisting with fraud prevention, and providing certain features
to you. To prevent Google Analytics from using your information for analytics, you may install
the official Google Analytics Opt-out Browser Add-on.
Your Choices and Data Subject Rights
You have various rights with respect to the collection and use of your information through the
Services. Those choices are as follows:
Email Unsubscribe
You may unsubscribe from our marketing emails at any time by clicking on the “unsubscribe”
link at the bottom of each newsletter or by emailing ax@shining.capital with your request.
Account Preferences
If you have registered for an account with us through our Services, you can update your account
information or adjust your email communications preferences by logging into your account and
updating your settings.
GDPR and EU Data Subject Rights
Individuals in the European Economic Area (“EEA”) and other jurisdictions have certain legal
rights with respect to the collection and use of their information through the Services. These
rights include:
 Right of Access: You have the right to obtain confirmation of whether we hold certain
information about you and to request a copy of that information.
 Right to Rectify: You can request the correction or updating of any inaccurate or
incomplete personal information we hold about you.
 Right to Object: You have the right to object to the processing of your personal data on
specific grounds, such as for marketing purposes or where we rely on legitimate interests.
 Right to Withdraw Consent: Where we process your information based on your
consent, you have the right to withdraw that consent at any time.
 Right to Complain: If you believe that your data protection rights have been violated,
you have the right to lodge a complaint with the relevant supervisory or legal authority.
To exercise any of these rights or if you have any questions about how we handle your data,
please email us at ax@shining.capital. We are committed to responding to your requests
promptly and within the timeframes required by GDPR. If necessary, this response time may be
extended in certain circumstances.
International Transfers
As described above in the “When We Disclose Your Information” section, we may share your
information with trusted service providers or business partners in countries other than your
country of residence in accordance with applicable law. This means that some of your
information may be processed in countries that may not offer the same level of protection as the
privacy laws of your jurisdiction. By providing us with your information, you acknowledge any
such transfer, storage or use.
If we provide any information about you to any third parties information processors located
outside of the EEA, we will take appropriate measures to ensure such companies protect your
information adequately in accordance with this Privacy Policy and other data protection laws to
govern the transfers of such data.
Security Measures
We have implemented technical, physical, and organizational security measures to protect
against the loss, misuse, and/or alteration of your information. These safeguards vary based on
the sensitivity of the information that we collect and store. However, we cannot and do not
guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose
your information since despite our efforts, no Internet and/or other electronic transmissions can
be completely secure.
Children
The Services are intended for users over the age of 18 and are not directed at children under the
age of 13. If we become aware that we have collected personal information (as defined by the
Children’s Online Privacy Protection Act) from children under the age of 13, or personal data (as
defined by the EU GDPR) from children under the age of 16, we will take reasonable steps to
delete it as soon as practicable.
Data Retention
We retain the information we collect for as long as necessary to fulfill the purposes set forth in
this Privacy Policy or as long as we are legally required or permitted to do so. Information may
persist in copies made for backup and business continuity purposes for additional time.
Third-Party Links and Services
The Services may contain links to third-party websites (e.g., social media sites like Facebook and
Twitter), third-party plug-ins (e.g., the Facebook “like” button and Twitter “follow” button), and
other services. If you choose to use these sites or features, you may disclose your information not
just to those third-parties, but also to their users and the public more generally depending on how
their services function. Creative Commons is not responsible for the content or privacy practices
of such third party websites or services. The collection, use and disclosure of your information
will be subject to the privacy policies of the third party websites or services, and not this Privacy
Policy. We encourage you to read the privacy statements of each and every site you visit.
Changes to this Privacy Policy
We will continue to evaluate this Privacy Policy as we update and expand our Services, and we
may make changes to the Privacy Policy accordingly. We will post any changes here and revise
the date last updated above. We encourage you to check this page periodically for updates to stay
informed on how we collect, use and share your information. If we make material changes to this
Privacy Policy, we will provide you with notice as required by law.
Questions About this Privacy Policy
If you have any questions about this Privacy Policy or our privacy practices, you can contact us
at: ax@shining.capital.