DATA TRANSFER NOTICE GRNTECH - FAQ

Thank you for your attention to data protection. We want to provide complete
transparency about the recent transfer of your personal data.

REASON FOR THE CHANGE

We have transferred our business operations - including customer relationships - to GRNTech Solution Inc., an affiliated company registered in Canada. This transition allows us to optimize service delivery while maintaining the same level of security and compliance.

WHAT DATA WAS TRANSFERRED

Only data necessary to continue providing services were transferred:

• Identity and verification (KYC) data;
• Account history, wallet activity, and transaction records;
• Communication records related to your account;
• Contact and preference information.

No new categories of data are being collected as part of this process.

IMPORTANT: YOUR DATA IS NOW IN A NON-ADEQUATE THIRD COUNTRY

Canada does not have an EU adequacy decision under GDPR Article 45. Your data
transfer is based on EU Standard Contractual Clauses (SCCs) with supplementary
security measures to address Canadian legal requirements.

Key changes:

• Your data is now governed by Canadian privacy law (PIPEDA) and
  Privacy Policy;
• GRNTech Solution Inc. is now your data controller;
• Complaints can be lodged with the Canadian Privacy Commissioner.

HOW YOUR DATA IS PROTECTED

We protect your data through:

• Encryption in transit and at rest;
• Restricted access controls (only authorized personnel);
• Audit logging of all access;
• Contractual restrictions on government data requests;
• EU Standard Contractual Clauses (SCCs).

LEGAL BASIS FOR THE DATA TRANSFER

The transfer was performed under GDPR:

• Article 6(1)(f) — Legitimate interest in business continuity and operational
  efficiency;
• Chapter 5 safeguards — Standard Contractual Clauses with supplementary measures;
• Articles 13–14 — Full transparency via this notice and updated Privacy Policy.

YOUR RIGHTS

You continue to have rights under GDPR and Canadian privacy law:

• Access your personal data;
• Correct inaccurate information
• Request erasure ("right to be forgotten") — subject to AML legal retention;
• Restrict processing;
• Object to processing based on legitimate interest;
• Withdraw consent to this transfer.

To exercise these rights, contact: compliance@guardarian.com or support@guardarian.com