# Luganodes - Full Institutional Offering

This document contains the complete text of Luganodes' key pages, stripped of navigation and formatting, for AI consumption.

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## Terms of Service

# TERMS OF SERVICE

These Terms of Service for Boldfit Tech Solutions Ltd. ("Terms") regulate the services provided by Luganodes, a private limited company based in Cayman Islands ("Luganodes"), and the user ("User") as described in "Boldfit Tech Solutions Ltd. SERVICES" below.

User agrees to be bound by these Terms by delegating Tokens to Luganodes (= action suggesting intent). If the User does not agree with, understand, or is unable to comply with these Terms, the User shall not delegate its Tokens to Luganodes. As a result, before delegating Tokens to Luganodes, please carefully read these Terms.

Please contact us at info@luganodes.com for any questions or issues.

HENCE, acknowledging the mutual agreements contained below, Luganodes and User hereby agree as follows:

### 1. IMPORTANT TERMS AND RULES OF INTERPRETATION

**1.1 Certain Definitions and Rules of Interpretation.**

The terms defined in this section, whenever used in these Terms shall have the meanings defined below:

- **"Affiliate"** implies, concerning any Person, any other Person directly or indirectly controlling, controlled by, or under common control with such Person.
- **"Block Rewards"** means additional tokens that are newly minted as an increase to the total supply of tokens.
- **"Disputes"** has the meaning assigned to such a term in section 6.2.
- **"Governmental Authority"** means any nation or government, any state or other political subdivision thereof, any entity exercising legislative, judicial, or administrative functions of or pertaining to government, including, without limitation, any government authority, agency, department, board, commission or instrumentality, and any court, tribunal or arbitrator(s) of competent jurisdiction, and any self-regulatory organization.
- **"hereof," "herein," "hereunder," "hereby"** and words of similar import will unless otherwise stated, be construed to refer to these Terms as a whole and not to any particular provision of these Terms.
- **"include(s)"** and **"including"** shall be construed to be followed by the words "without limitation" unless the context requires otherwise.
- **"Laws"** means all laws, statutes, legal requirements, ordinances, rules, rulings, regulations, judgments, injunctions, orders, and decrees enacted, promulgated, or issued by any Governmental Authority.
- **"Network"** means a "Proof-of-Stake Network" is a digital blockchain ledger whereon transactions in digital tokens are recorded and stored as a result of the coordinated activities of a distributed, peer-to-peer network ("Network") of software clients ("Nodes") running a consensus protocol.
- **"or"** shall be construed to be the "inclusive or" rather than "exclusive or" (i.e., shall be read as "and/or") unless the context requires otherwise.
- **"Person"** means an individual or legal entity or person, including a government or political subdivision or an agency or instrumentality thereof.
- **"Service Fees"** means the amount paid to Validator Nodes for exercising Users' Validation Rights on the Network. Service Fees are usually expressed as a percentage of the total Block Rewards and Transaction Fees earned.
- **"Token"** means any amount (including any fractional amount) of digital tokens transacted on the Network with transactions being recorded on the blockchain.
- **"Transaction Fees"** means any amount of digital tokens paid to the Network by transactions. A part or the entirety of digital tokens paid in that way may be distributed to Users exercising their Validation Rights and Validator Nodes on the Network.
- **"User"** is a holder of Tokens who delegates Tokens to Luganodes to be eligible to receive Block Rewards and Transaction Fees by exercising its Validation Rights on the Network.
- **"Validator Node**" for purposes of network efficiency, only a limited number of Nodes are permitted to exercise Validation Rights on the Network at any given time.
- **"Validation Rights**" users owning Tokens native to a specific Network can participate in maintaining the Network, where the amount of Tokens owned in relation to the total supply of Tokens in the Network is indicative of their Validation Rights within the Network. Validation Rights can be delegated to Validator Nodes on the Network allowing any Token holder to participate in maintaining the Network.

The parties hereto agree that any rule of construction to the effect that ambiguities are to be resolved against the drafting party shall not be applied in the construction or interpretation of these Terms.

### 2. Boldfit Tech Solutions Ltd. SERVICES

**2.1 Services:**

The software and infrastructure required to run a Validator Node on the Network are managed by Luganodes. When Luganodes is chosen to run a Validator Node on the Network, Luganodes provides services to the User by allowing the User to exercise its Validation Rights on the Network via Luganodes' Validator Node in exchange for Service Fees. The User is a Token holder who ceded tokens to Luganodes in order to receive Block Rewards and Transaction Fees by exercising its Validation Rights on the Network.

**2.2 Responsibility:**

Subject to these Terms, including the User Eligibility Conditions, Luganodes will use commercially reasonable efforts to operate the Validating Node in a way that facilitates the exercise of the User's Validation Rights with regard to the User's Tokens, if any, that are Delegated to Luganodes as of such times, during the times, if any, that Luganodes is one of the Persons chosen on the Network to operate a Validating Node (such operation of the Validating Node, the "Services"). In accordance with relevant industry standards, Luganodes runs the Service with diligence and professionalism.

**2.3 Conditions Precedent to Luganodes' Service Obligations**

Luganodes shall not have any obligation to perform the Services at any time if any one or more of the following conditions precedent is not satisfied as of such time:

* The representations and warranties of User set forth in the "REPRESENTATIONS AND WARRANTIES OF USER", hereunder are accurate and complete as of all times on and after agreeing to these Terms while User possesses Validation Rights that are Delegated to Luganodes.
* The Maximum Validator Number of Persons authorized to Operate a Validator Node on the Network includes Luganodes.
* Neither User's Delegation of Validation Rights to Luganodes, nor Luganodes' performance of Services for User, constitutes or is reasonably expected to result in a breach, default, contravention, or violation of any Law applicable to User or Luganodes, or contract or agreement to which User or Luganodes is a party or by which User or Luganodes is bound, including these Terms and the Network Agreements.

The User understands and agrees that the Network's technologies and activities are unique, experimental, and speculative and that there is significant uncertainty regarding the application of existing Law to them. As a result, without limiting the generality of the foregoing or any other provision of these Terms, circumstances in which one or more of the aforementioned conditions precedents may fail to be met or Luganodes may have a claim against User for an improper delegation include, but are not limited to:

* that tokens, one or more tokens involved in the Network are considered to be securities under any potentially applicable Law, and therefore the practice of operating as a Validating Node may require specific registrations, licenses, or permits not held by Luganodes;
* that User is or becomes subject to sanctions imposed by any applicable Governmental Authority (such as being added to the "OFAC list"); and
* that under relevant anti-money laundering, "know-your-customer," or similar standards or regulations, Luganodes is regarded to be a "money transmitter," but cannot adequately comply with the accompanying duties due to the Network's decentralized, open-source, permissionless nature.

The user acknowledges and understands that due to the permissionless, decentralized design of the Network:

* any Person holding tokens can anonymously Delegate their Validation Rights to Luganodes on the Network, and thus Luganodes cannot prevent any such Person from receiving the Services under normal circumstances; and
* Luganodes may be unable to ascertain important information regarding Users, such as the User's name, country of origin, country of residence, age, good standing, legal status, affiliations, entity type, and criminal history.
* As a result, there may be times when one or more of the conditions specified in clause "(a)" above are not met, but Luganodes is oblivious to this fact and continues to provide Services to the User.

(c) If User can reasonably expect that any of the conditions described in clause "(a)" above will not be satisfied before Delegating Validation Rights to Luganodes, User shall not Delegate any Validation Rights to Luganodes, and if User can reasonably expect that any of such conditions will no longer be satisfied after Delegating Validation Rights to Luganodes, User shall immediately revoke such Delegation.

(d) Without limiting the generality of Section 8.9, User acknowledges and agrees that by providing Services to User while having no specific knowledge that such condition is not satisfied with respect to User, the Network shall not be deemed to have waived any of the conditions described in clause "(a)" above, or waived or released any claim, right, power, privilege, or remedy related thereto, and may terminate its Services to User after learning of such non-satisfaction. User may be responsible to Luganodes for monetary or other damages if it Delegates its Validation Rights to Luganodes or fails to rescind a previously made Delegation when any of the conditions mentioned in clause "(a)" above is not met.

**2.4 Validator Node Status is not guaranteed:**

There can be no guarantee or assurance that Luganodes will function as a Validator Node at all or for any certain amount of time, and Luganodes makes no representation, warranty, or promise to that effect. The failure of Luganodes to become or remain a Validator Node shall not constitute a violation of any part of these Terms or create any liability or obligation of Luganodes to the User.

**2.5 Fork Handling:**

Like other decentralized, open-source blockchains and blockchain protocols, the Network may experience "forks." Forks occur when some or all of the people running the software clients for a specific blockchain adopt a new client or a new version of an existing client that: (a) changes the protocol rules in a backward-compatible or backward-incompatible way that affects which transactions can be added into later blocks, how later blocks are added to the blockchain, or other matters relating to the protocol's future operation; or (b) reorganizes or changes past blocks to alter the history of the blockchain. Some forks are "contentious," and as a result, two or more lasting alternate versions of the protocol or blockchain may be perceived or claimed to be the genuine continuation of the original. Luganodes may be unable to predict, control, or influence the incidence or result of Network or other blockchain splits, and assumes no risk, responsibility, or duty in this regard. Without limiting the extent of the foregoing, Luganodes assumes no duty for informing Users of pending, threatened, or actual forks. Luganodes will respond to any forks in its full and absolute discretion, and Luganodes shall have no duty or liability to the User if such action benefits Luganodes at the expense of the User. Without limiting the generality of the preceding, Luganodes' possible and permissible responses to a fork include, among other things, (i) continuing to serve as a Validating Node on both chains; (ii) serving as a Validating Node only on one chain; (iii) ceasing to serve as a Validating Node on both chains; or (iv) switching from serving as a Validating Node on one such chain to serving as In the case of a Network fork, the same amount of tokens/Validation Rights that were bonded/Delegated to Luganodes on the original chain will be bonded/Delegated to Luganodes on the forked chain by default. If Luganodes does not choose to support both chains, the User's Validation Rights and Voting Rights on the unsupported chain may go unexecuted, and the User may temporarily or permanently lose tokens, Block Rewards, or Transaction Fees on the unsupported chain. User assumes full responsibility for autonomously staying informed about prospective forks and managing User's interests in connection with them, including possibly withdrawing a Delegation to the public key of Luganodes' Validator Node on a fork that Luganodes does not support.

**2.6 Selective Code Deference:**

Except as otherwise specified in these Terms, the outcomes of Network operation shall be determinative of the rights and duties of and shall be final, binding on, and non-appealable by, each of the parties to these Terms. Without limiting the generality of the foregoing, User acknowledges and agrees that taking any action or exercising any right, power, or privilege that a Validating Node on the Network may take or exercise shall not constitute a breach, violation, or contravention of these Terms or any duty or obligation owed by Luganodes to User and that any percentage of Block Rewards, Transaction Fees, or other rewards paid to Luganodes as a consequence of Network operation constitute Service Fees and shall be the exclusive and exclusive property of Luganodes, with no claim, rights, or interests in them. In the event that any legally binding contract or agreement between or involving User and Luganodes that is implied by, or embodied in, the machine, assembly, or other code involved in, or the results of operation of, the Network or any blockchain thereof conflicts or is inconsistent in any manner with these Terms, these Terms shall take precedence over such other contract or agreement.

### 3. REPRESENTATIONS AND WARRANTIES OF USER

User represents and warrants to Luganodes that, as of the date of entering into these Terms and any subsequent date, User possesses any Validation Rights Delegated to Luganodes:

**3.1 Status:**

If User is an individual, User is of legal age in the jurisdiction where User resides and is of sound mind and body. If User is a business entity, it is properly organized, legitimately existing, and in good standing under the laws of the jurisdiction in which it is organized, and it possesses all of the necessary power and authority for a business entity of its kind to carry on its business as it is presently carried on.

**3.2 Power and Authority:**

The User possesses all of the necessary ability, power, and authority to accept the terms and conditions of these Terms, as well as to carry out and execute its duties under these Terms. These Terms are a legal, legitimate, and binding obligation of User that can be enforced against User in line with their terms.

**3.3 No Conflict; Compliance with Law:**

User's acceptance of these Terms and delegation of its Validation Rights to Luganodes do not constitute, and cannot reasonably be expected to result in (with or without notice, a lapse of time, or both) a breach, default, contravention, or violation of any Law, regulation, decree, or legal restriction, tax regulation or obligation, or any order or judgment of any court or other government agency applicable to User, or contract or agreement to which User is a party. User specifically acknowledges that it will completely comply with all applicable laws and regulations, including the Swiss Anti-Money Laundering Act, the Swiss Banking Act, the Swiss Financial Services Act, the Swiss Collective Investment Schemes Act, and the Swiss Collective Investment Schemes Act, and any other equivalent laws and regulations.

**3.4 Persons Subject to Sanctions:**

User is not, and is not owned or controlled by, or acting on behalf of, any other Person identified on any list of prohibited parties maintained by any Law or by any Governmental Authorities, such as, for example, the lists maintained by the United Nations Security Council, the United States government (including the U.S. Treasury Department's Specially Designated Nationals list and Foreign Sanctions Evaders list), the European Union (EU) or its member states, and the government of User's country of citizenship. User is not situated, habitually resident, organized, established, or domiciled in Cuba, Iran, North Korea, Sudan, Syria, the Crimea area (including Sevastopol), or any other nation or jurisdiction against which the United States maintains economic sanctions or an arms embargo. Tokens issued by Users are not sourced from, or otherwise represent the proceeds of, any unlawful or illegal activity.

**3.5 No Claim, Loan, Ownership Interest, or Investment Purpose:**

User understands and agrees that neither User's Delegation of Validation Rights and Voting Rights to Luganodes, nor Luganodes' provision of Services hereunder: (a) represents or constitutes a loan or contribution of capital to, or other investment in, Luganodes; or (b) provides User with any ownership interest, equity, security, or right to or interest in Luganodes' assets, rights, properties, revenues, or profits, or any voting rights whatsoever in, Luganodes; or (c) creates or suggests any fiduciary or other agency connection between Luganodes and any of its directors, officers, employees, agents, or Affiliates, or entitles User to any fiduciary or similar responsibility on the behalf of any of the above Persons. User is not engaging in these Terms or delegating Validation Rights or Voting Rights to Luganodes to make an investment in Luganodes or its securities, but rather to obtain the Services from Luganodes. User acknowledges and accepts that Luganodes will not receive or hold any Block Rewards or Transaction Fees on User's behalf and that the Network has no obligation or control over whether the Network delivers Block Rewards or Transaction Fees to User. The sole responsibility of Luganodes under these Terms is to execute the Services in accordance with the terms and circumstances set out in these Terms, which may, but is not guaranteed to, result in the User obtaining Block Rewards and Transaction Fees directly through Network operations.

**3.6 Non-Reliance:**

The user is well-versed, experienced, and intelligent in the use and evaluation of the Network and related technologies. In deciding to Delegate any Validation Rights or Voting Rights to Luganodes and enter into these Terms, User has conducted its own thorough independent investigation and analysis of the Network and the other matters contemplated by these Terms, and has not relied on any information, statement, omission, representation or warranty, express or implied, written or oral, made by or on behalf of Luganodes in connection therewith.

### 4. LIMITED WARRANTY OF LUGANODES

Luganodes represents and warrants to the user that it will make reasonable commercial efforts to provide the service without introducing errors or otherwise corrupting any data submitted by the user. The user acknowledges and agrees that, except as expressly provided in these terms, the service, including, without limitation, the blockchain data and the information contained therein, is provided "as is" and "as available" with all faults and without warranty of any kind. Luganodes makes no representations or warranties that the service will comply with any obligations that the user may have under applicable laws, rules, regulations, or similar obligations. Luganodes shall not be liable or responsible for any damages, liabilities, slashing penalties, losses, costs, out-of-pocket costs, or expenses (including attorneys' fees), whether direct, indirect, special, incidental, consequential, punitive, or otherwise arising out of, in connection with or relating to the user's compliance with any obligations under any applicable laws, rules, regulations, or similar obligations. Without limiting the generality of the foregoing, Luganodes does not represent or warrant that (i) the service will be error-free, uninterrupted, or available at all times; or (ii) the service will remain compatible with, or operate without interruption on, any equipment provided by user. (iii) The user acknowledges and agrees that technical problems may prevent Luganodes from providing all or a portion of the service and (iv) except as expressly stated in the first sentence of this section, makes no warranties and the user receives no warranties regarding or relating to the service, and Luganodes hereby specifically disclaims, overrides, and excludes to the fullest extent permitted by law, all implied warranties of merchantability, satisfactory quality, fitness for a particular purpose and all other warranties, conditions, other contractual terms, representations, indemnities and guarantees regarding the service, whether express, implied, or statutory, resulting from law, custom, prior oral or written statements by Luganodes or any of its agents or affiliates, or otherwise (including but not limited to, title, satisfactory quality, accuracy, completeness, uninterrupted use, noninfringement, timeliness, truthfulness, sequence, and any implied warranties, conditions, and other contractual terms arising from transaction usage, course of dealing, or course of performance).

### 5. LIMITATIONS OF LIABILITY

The User acknowledges and agrees that Luganodes shall not be liable or responsible for any damages, liabilities, losses, costs, out-of-pocket costs, or expenses (including attorneys' fees), whether direct, indirect, special, incidental, consequential, punitive, or otherwise of any kind, to the extent permitted by law (including, without limitation, any loss of revenue, loss of actual or anticipated profits, loss of contracts, loss of the use of money, loss of anticipated savings, loss of business, loss of opportunity, loss of goodwill, loss of reputation or loss of, damage to or corruption of data), in each case arising out of or relating to claims of breach of contract, tort, including negligence, strict liability, negligent misrepresentation, restitution, breach of statutory duty, or any other cause of action whatsoever relating to these Terms, the Service, or any other matters or services contemplated hereby. Without limiting the foregoing, the User acknowledges and agrees that Luganodes shall not be held liable for: any loss or theft of digital assets, including but not limited to private keys; transaction errors made by the User; late execution or settlement of any transaction whatsoever; incorrect booking of transactions or the presence of an error in ordering the booking of transactions in a blockchain; any security breach or any problem in the technology stacks employed, including but not limited to programming languages and open-source libraries; any User configuration or installation difficulties. Luganodes' liability for damages under these Terms shall in any case be limited to, and under no circumstances shall exceed, the portion of Service Fees received by Luganodes that demonstrably arose as a result of the User's particular Delegation of its particular Validation Rights to Luganodes.

### 6. FEES

Luganodes will be paid a Service Fee for their services. The Network normally charges and distributes this Service Fee to Luganodes automatically, with certain exceptions for Networks that do not automate this procedure (e.g. Tezos, Mina, and Helium). The Service Fee is stored and documented in the metadata of each Luganodes Validation Node on each separate Network's digital ledger and/or accessible by Network observation toolings (block explorers). It is also available on the Luganodes website, https://www.luganodes.com.

### 7. TERM AND TERMINATION

The Service under these Terms will start on the Start Date. The Start Date of the Service is the date on which the User first delegates any Token(s) to Luganodes.

Either party may terminate these Terms: (a) at any time for any or no reason (i) by delivering written notice of termination to the other Party, (ii) in the case of User, by retracting their Tokens, or (iii) in the case of Luganodes, by taking steps to shut down the Validator Node or, if technically possible, denying/terminating User's delegation of Tokens to Luganodes, (b) if the other party substantially breaches a condition of these provisions, with immediate effect; in each event, the termination is subject to any restrictions on termination contained in the Additional Terms and the terms of the Supported Blockchain.

Upon termination, the User must (i) discontinue usage of the Service; (ii) initiate re-delegation and unbonding of the Tokens, if applicable; and (iii) pay to Luganodes any fees and costs owed up to the termination date. Luganodes shall pay to the User its applicable Block Rewards less Luganodes costs upon termination. Furthermore, the termination of these Terms for any reason shall not affect Luganodes' claim to any fees and costs owed. All licenses to access and use the Services will also expire upon termination of these Terms, and the User will immediately cease all such access and use.

Any responsibilities and liabilities that, by their nature, continue beyond the expiration or termination of these Terms, including, without limitation, accrued rights to payment, warranty disclaimers, and limits of liability, will survive the expiration or termination of these Terms.

### 8. MISCELLANEOUS

**8.1 Governing Law:**

These Terms are regulated by and construed in line with Swiss substantive law.

**8.2 Jurisdiction:**

All issues arising out of or in connection with these Terms, including those concerning its completion, binding effect, revision, and termination, shall be decided exclusively by the regular courts of Luganodes.

**8.3 Successors and Assigns:**

1. These Terms will benefit the parties and their respective permitted successors, assigns, transferees, and delegates, and will be binding on all of the foregoing persons as well as any Person who may otherwise succeed to any right, obligation, or liability under these Terms by operation of law or otherwise. User shall not share, provide a copy of, or transfer to any Person the private key associated with any tokens for which Validation Rights have been Delegated to Luganodes without first notifying such Person that such Person shall be bound by and become a party to these Terms by making any use of such private keys while such Delegation is in effect.
2. Except as provided in 6.3(1), no rights, responsibilities, or liabilities of User may be assigned, transferred or delegated to any Person without Luganodes' prior written agreement. To the greatest extent authorized by applicable Law, Luganodes may freely assign, transfer, or delegate its rights, responsibilities, and liabilities under these Terms.

**8.4 Entire Terms:**

These Terms comprise the parties' complete agreement relating to the subject matter hereof and supersede all prior or contemporaneous agreements and understandings, both written and oral, between the parties.

**8.5 Severability:**

Should any portion or term of these Terms be deemed illegal by any competent court, governmental or administrative authority with jurisdiction, the other sections of these Terms will continue in effect. In this situation, the Parties shall make every effort to negotiate a substitute provision that best represents the Parties' economic purposes while being enforceable, and shall execute all agreements and papers needed in this regard. The same shall apply if and to the extent that any gaps or omissions are discovered in these Terms.

**8.6 Notices:**

All notifications under these Terms must be in writing (including e-mail). Notices shall be regarded as given when they are received.

**8.7 Force Majeure:**

Luganodes shall not be liable or penalized for failing to perform any act or fulfill any obligation under this agreement due to any occurrence beyond its control (including any provision of any present or future law or regulation or any act of any Governmental Authority, any act of God or war or terrorism, or the unavailability, disruption or malfunction of the Internet, the World Wide Web or any other electronic network the Network or any aspect thereof, or any consensus attack, or hack, or denial-of-service or other attacks, on the Network or any aspect thereof, or on the software and infrastructure that enables Luganodes to operate the Validating Node.); provided, however, that Luganodes shall use commercially reasonable efforts, consistent with accepted practices in the industries in which Luganodes operates, as applicable, to resume performance as soon as reasonably practicable under the circumstances.

**8.8 Amendments:**

Luganodes reserves the right to alter these Terms at any moment under justified circumstances. Such changes must be communicated in advance and in a suitable way by Luganodes. The User is assumed to have accepted the revisions unless an objection is submitted in writing within one month of notification, but in any case when the service is first utilized. In the case of an objection, the customer may, subject to particular agreements, immediately discontinue the business relationship.

**8.9 No Waiver:**

No failure or delay on the part of any Person in exercising any power, right, privilege, or remedy under these Terms shall be construed as a waiver of such power, right, privilege, or remedy; and no single or partial exercise of any such power, right, privilege, or remedy shall preclude any other or further exercise thereof or of any other power, right, privilege, or remedy. No Person shall be deemed to have waived any claim arising out of these Terms, or any power, right, privilege, or remedy under these Terms, unless such waiver is expressly outlined in a written instrument duly executed and delivered on such Person's behalf; and any such waiver shall not be applicable or have any effect except in the specific instance in which it is given.

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## Privacy Policy

# PRIVACY POLICY

**Updated:** September 04, 2024

The following Privacy Policy governs the online information collection practices of **Luganodes**
("Company," "we" or "us"). It outlines the types of information that we gather about you while
you are using our website luganodes.com (the "website") and/or when you use our terminal
staking platform (the "Services").

**Luganodes** is a institutional-based staking provider which helps users who have created
**Luganodes**  accounts ("User(s)") to share their content such as information, files and folders
("Content") and analyse their pre-existing customers, prospective customers and third parties
("Viewer(s)") on the basis of the content viewed by them. The viewers may be the non-
registered users or registered users of the web-services and product offerings ("Service(s)")
provided by **Luganodes**. We process your data in accordance with the applicable laws and
regulations following industry best practices.

We may collect some identifying information about the user when the user visits our website [https://www.luganodes.com](https://www.luganodes.com) to enhance our service, contact the user, or identify the user. Personal information submitted by the user, such as name, address, email address, and other personally identifiable information, will not be sold, rented, distributed, or otherwise made commercially accessible to third parties, except as specified in this policy. You consent to the use of your data by accepting the terms of service and this data protection declaration. We collect, store, and handle personal data solely in compliance with existing legal regulations and only to the extent necessary to fulfill our contractual performance duties to the user or to supply the purchased items on our website. This also covers data storage for any warranty claims after the contract has been fulfilled.

Luganodes has no responsibility or obligation for the security of your data while it is being transferred over the Internet. All activities taken by a user while on this website may be collected and evaluated for a variety of reasons, including security, marketing, and system monitoring.

### Why does Luganodes collect data?

When you use our website, our web servers automatically record information (such as your IP address). When you provide us with personal information, we only use it for the following purposes:

- As a foundation for future information regarding Luganodes' services and goods, and to enhance their quality.
- Managing the Provider-User relationship with you.
- To fulfill our legal duties (e.g. compliance with national and international legal, regulatory, and internal bank requirements, verifying the identity and suitability of customers for certain products and services).
- For other lawful commercial objectives (marketing and promotional activities; technical administration, research, and development of the Luganodes website; analysis of user behavior and navigation within the website).

### Consent Withdraw Policy

You have the right to withdraw your consent to the collection, processing, and use of your personal information at any time. If you wish to withdraw your consent, please contact us at **info@luganodes.com**. Upon receiving your request, we will stop processing your data and take steps to delete your personal information, unless there is a legitimate legal basis for us to retain certain data (such as to comply with legal obligations or to enforce our agreements). Please note that withdrawing consent may limit our ability to provide you with certain services or respond to inquiries.

### Quesries and complaints

We have appointed a data protection officer ("DPO") who is responsible for overseeing
questions in relation to this Notice and our processing activities in general.

If you have any questions or requests, including any requests to exercise your legal
rights as a data subject, please contact the DPO using the details set out below.

**Contact Details:-**

Name of DPO: Sanjeev

Email address: sanjeev@luganodes.com

Postal address: N/A

### The types of information we collect and store

We may collect personal and sensitive personal information about you and store this
information in connection with the provision and fulfilment of our services to you. Personal
information may include:

- Name (First and Last)
- Email address
- Company name
- Role in the company

### How we protect your data?

Our business operations revolve around the security of your data. To secure information kept by us against loss, data misuse, unauthorized access, disclosure, modification, and destruction, we employ suitable technological, organizational, and administrative security measures.

We do not share or sell your personal information with other parties since we value both your privacy and our reputation. We will keep your information just as long as necessary and/or as required by relevant laws and regulations for the reasons at hand (e.g. to protect the personal safety of the users or employees of Luganodes, protect the rights or intellectual property of Luganodes).

### How we use your personal information?

The above personal information may be used for the following purposes:

- To provide you with information about our offerings and/or our periodic newsletters;
- To respond to your requests;
- For creation or development of business intelligence or data analytics in relation to the Offerings provided by us (for this purpose we may share the Personal Information with certain software or tools available online);
- To manage our relationship with you;
- For internal record keeping;
- To provide you with authorization to login and use your user account;
- To verify your identity;
- To maintain correct and up-to-date information about you;
- To identify you as a contracting party;
- To improve our website;
- To enable automated handling of the subscriptions;
- To otherwise be able to provide the services to you and
- To comply with our legal or statutory obligations.

### Who has access to your data within our organization?

Within our organization, access to your data is limited to those persons who require access in
order to provide you with the Products and Services, which you purchase from us, to contact
you, and to respond to your inquiries, including requests for refund. Those staff members may
be on teams such as: marketing, events, development, executive, customer support.
Employees only have access to data that is relevant to their team, on a 'need to know' basis.

### Who do we share your data with outside our organization and why?

**Processors**

We may use service providers & third parties for operating and improving the Sites, to assist
with certain functions, such as payment processing, email transmission, conducting surveys or
contests, data hosting, managing our ads, third-party solutions for marketing and analytics,
and some aspects of our technical and customer support. We take measures to ensure that
these service providers access, process, and store information about you only for the
purposes we authorize, through the execution of Data Processing Agreements or Addenda.

**Authorities**

We may access, preserve, and disclose information about you to third parties, including the
content of messages if we believe disclosure is in accordance with or required by, applicable
law, regulation, legal process, or audits. We may also disclose information about you if we
believe that your actions are inconsistent with our Terms of Service or related guidelines and
policies, or if necessary to protect the rights, property, or safety of, or prevent fraud or abuse of,
Company or others.

**Transfer of business**

If we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through
some other change of control, personal information could be one of the assets transferred to or
acquired by a third party.

### Why and for how long do we store information we collect from you?

We retain certain information collected from you while you are a member on the Site, and in
certain cases where you have deleted your account, for the following reasons:

- So that you can use our Sites;
- To ensure that we do not communicate with you if you have asked us not to;
- To provide you with a refund, if entitled;
- To better understand the traffic to our Sites so that we can provide all members with the best possible experience;
- To detect and prevent abuse of our Sites, illegal activities and breaches of our Terms of Service; and
- To comply with applicable legal, tax or accounting requirements.

We retain user data for as long as necessary for the purposes described above. This means
that we retain different categories of data for different periods of time depending on the type of
data, the category of user to whom the data relates to, and the purposes for which we collected
the data.

### Security

We implement a variety of administrative, managerial, and technical security measures to help
protect your personal information. Our Company has various internal control standards which
relate specifically to the handling of personal information. These include certain controls to
help safeguard the information we collect online. Our employees are trained to understand and
comply with these controls and we communicate our Privacy Policy practices and guidelines to
our employees. However, while we strive to protect your personal information, you must also
take steps to protect your information. We urge you to take every precaution to protect your
personal information while you are on the Internet.

### Yours rights under GDPR

You have certain rights if you are within the EU this includes:

- **Right to access.** This right allows you to obtain a copy of your personal data, as well as other supplementary information.
- **Right to restrict processing.** You have the right to restrict the processing of your personal data in certain circumstances.
- **Right to rectification.** You have the right to have any incomplete or inaccurate information we hold about you corrected.
- **Right to object to processing.** The right to object allows you to stop or prevent us from processing your personal data. This right exists where we are relying on a legitimate interest as the legal basis for processing your Personal Data. You also have the right to object where we are processing your Personal data for direct marketing purposes.
- **Right to erasure.** You have the right to ask us to delete or remove Personal data when the personal data is no longer necessary for the purpose which you originally collected or processed.

To exercise your rights, you can contact us at info@luganodes.com.

### Our policy concerning children & their data

Our Sites are not directed to children under the age of sixteen and we do not knowingly collect
personally identifiable information from children or distribute such information to third parties.
We screen users who wish to provide personal information in order to prevent children from
providing such information. If we become aware that we have inadvertently received
personally identifiable information from a child, we will delete such information from our
records. If we change our practices in the future, we will obtain prior, verifiable parental
consent before collecting any personally identifiable information from children.

### Links to other websites

Our Sites may contain links to other websites that are not operated by us. If you click on a third-
party link, you will be directed to that third party's site. We strongly advise you to review the
Privacy Policy of every site you visit.

Third parties are under no obligation to comply with this Privacy Policy with respect to Personal
Data that you provide directly to those third parties or that those third parties collect for
themselves. We do not control the third-party sites that may be accessible through our
Services. Thus, this Privacy Policy does not apply to information you provide to third-party
sites or gathered by the third parties that operate them.

### Logfiles

The type and version of the browser used to visit our website are communicated by the individual's internet browser and recorded in log files on the hosting server. After usage, the IP addresses of the users are removed or anonymized. Anonymization involves changing IP addresses in such a way that particular details of personal or factual situations cannot be attributed to a specific or identifiable real person, or can only be done with a disproportionate amount of time, money, and effort. This usage data serves as the foundation for statistical, anonymous evaluations to develop and make our website more user-friendly. This information is not combined with information from other sources.

### Google Analytics

Google Analytics, a web analytics tool supplied by Google Inc., is used on this page (Google). Google Analytics uses cookies to help us understand how the website is used and make necessary technical, UX, and marketing optimizations. The cookie's information about your use of this website is typically sent to and stored on a Google server in the United States. If IP anonymization is enabled on this page, Google will first abbreviate your IP address inside European Union member states or other contracting states of the Agreement on the European Economic Area. In unusual instances, the complete IP address will be transferred to a Google server in the United States and abbreviated there. Google will use the information on behalf of the site operator to analyze website usage, generate reports on website activity, and offer the site operator other services relating to website and internet use. The legitimate interest in data processing lies in the optimization of this website, the analysis of the use of the website, and the adaptation of the content. The interests of the users are adequately protected by pseudonymization.

The collection by Google Analytics can be prevented by the page visitor adjusting the cookie settings for this website. However, please note that if you do so, you may not be able to take full advantage of all the functions of this website. The collection and storage of the IP address and the data generated by cookies can also be objected to at any time with effect for the future. The corresponding browser plug-in can be downloaded and installed from the following link: [https://tools.google.com/dlpage/gaoptout](https://tools.google.com/dlpage/gaoptout).

### Cookies

A cookie is a little file that is kept on the hard disk of your computer. When you visit a website again, it identifies your machine thanks to this file. Furthermore, the cookie may hold information about the computer user's preferences from past visits to the relevant website. We gather, handle, and analyze data regarding how our websites are used. Traffic data includes information on website visitors as well as information utilized in communication fields to transmit, forward, or deliver messages. We use cookies and other similar technologies to offer you products and services, to administer our marketing and to ensure a safe online experience, to assess the performance of our website, and to make the content of our website more relevant to you. Individual visitors are not identified using the data. You may configure your Internet browser's security settings to allow or reject cookies. If you disable cookies, you may still be able to use our websites and some services, but access to some features and parts of our websites or services may be considerably limited.

Our website provides you with the option to accept or reject various categories of cookies based on your preferences. Upon your first visit, you will be prompted with a cookie consent banner that allows you to choose which types of cookies you would like to allow, such as necessary, performance, functional, or marketing cookies. You can also modify your preferences at any time by accessing the cookie settings available on our website. Please note that changing these settings may affect your experience, and certain features or services may not function properly if specific cookies are disabled.

### Changes to the privacy policy and cookie policy

Luganodes may periodically post changes to this Privacy Policy on this page. When required by law, Luganodes will notify you of changes to this privacy policy.

### Contact for privacy

The responsible body for the collection, processing, and use of personal data via data protection is:

**Boldfit Tech Solutions Ltd., Cayman Islands**

**info@luganodes.com**

---

## Cookie Policy

# COOKIE POLICY

**Updated:** April 24, 2023

In using Luganodes' services you provide your consent in the collection and/or receipt of information from software applications such as tracking technologies or cookies. Luganodes will always attempt to ensure that the below information is current and accurate to our policies and procedures.

### Cookies and Tracking Technologies

Whenever you visit a website (e.g., Luganodes, Bing, etc.), the website stores a small amount of information on your web browser that enables the website's owner as well as other third parties to learn unique information about your device, activity, and use of not only the site you're currently on (using "session cookies") but sites you subsequently visit (using "persistent cookies"). Cookies help us enhance your experience using the platform or website and third-party retargeting service providers use cookies to serve ads based on a past visit to the platform or website. Furthermore, the cookie may hold information about the computer user's preferences from past visits to the relevant website. Luganodes gathers, handles, and analyses data regarding how our website is used.

Below is a list of tracking technologies that Luganodes uses and their functions.

| Tracking Technology | Function/Use |
| :- | :- |
| Essential Cookies | These cookies are necessary for the operation of our Services, or for legal compliance (e.g., the security requirements of data protection law). We do not need to obtain your consent in order to use these cookies and these cookies cannot be turned off as our Services can't be provided without them. |
| Functionality Cookies | These cookies enable us to keep track of your preferences, thereby, assisting us to provide enhanced and personalized features (e.g., auto login, theming, etc.) |
| Performance Cookies | These cookies enable us to keep track of your preferences, thereby, assisting us to provide enhanced and personalized features (e.g., auto login, theming, etc.) |
| Local storage / HTML5 local storage | Local storage enables us to store data (e.g., the last time you visited a webpage) on your hard disk. This allows information to be stored in your browser after the browser has been closed and reopened. Luganodes also uses HTML5 to store information such as the previous page you viewed, the name of the current page you are viewing, and some of your preferences. |
| Google Analytics | Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. |
| Pixels | Pixels are small portions of code that we use as part of our Services. We use them to learn whether you have clicked on certain web content. Pixels help us measure and improve our services and personalize your experience. |




### How to Manage Cookies?

You can choose the cookies you want to accept or reject by changing your preferences by clicking the button below:



The best way to clear cookies is to frequently restart your browser and/or clear your cache. This is done through your browser and device settings, the location and thoroughness of which will vary depending on the browser or device. If you disable one or more cookie settings, we will still use information collected prior to your disabling, but will not collect further information.

Most browsers allow you to change your settings so that you can:

1. View and delete all non-essential cookies for the sites you visit.
2. Block third-party cookies and other tracking technologies from particular sites.
3. Delete all cookie and tracking technologies when you quit your browser.

If you disable cookies, you may still be able to use our websites and some services, but access to some features and parts of our websites or services may be considerably limited.

### Changes to this Cookie Policy

Luganodes reserves the right to make changes to this Cookie Policy at any time. We will notify you of any changes by posting the new Cookie Policy on this page. You are advised to review this Cookie Policy periodically for any changes. Changes to this Cookie Policy are effective when they are posted on this page.

### Contact Us

If you have any questions about this Cookie Policy, please contact us at support@luganodes.com with "Cookie Policy" in the subject line.

---

## Data Processing Addendum

# DATA PROCESSING ADDENDUM (DPA)

**Updated:** September 04, 2024

This Data Processing Addendum ("**Addendum**"), dated September 03, 2024. You accept this Addendum, and effective as of the Addendum Effective Date (as defined below), forms part of the Terms of Service ("**Terms**") between (i) Boldfit Tech Solutions Ltd. ("**Luganodes**") and (ii) You ("**Client**"), each being a "**Party**" and together the "**Parties**".

The Parties hereby agree that the terms and conditions set out below shall be added as an Addendum to the Terms and references in this Addendum to the Terms are to the Terms as amended by, and including, this Addendum.

### 1. Definitions

**1.1** In this Addendum, the following terms shall have the meanings set out below and cognate terms shall be construed accordingly:

(a) **"Addendum Effective Date"** has the meaning given to it in section 2;
(b) **"Affiliate"** means an entity that owns or controls, is owned or controlled by or is or under common control or ownership with either Client or Luganodes (as the context allows), where control is defined as the possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of an entity, whether through ownership of voting securities, by contract or otherwise;
(c) **"Client Personal Data"** means any Personal Data Processed by Luganodes (i) on behalf of Client (including for the sake of clarity, any Client Affiliate), or (ii) otherwise Processed by Luganodes, in each case pursuant to or in connection with instructions given by Client in writing, consistent with the Terms;
(d) **"Controller to Processor SCCs"** means the Standard Contractual Clauses (processors) for the purposes of Article 26(2) of Directive 95/46/EC set out in Decision 2010/87/EC as the same are revised or updated from time to time by the European Commission;
(e) **"Data Protection Laws"** means (i) Directive 95/46/EC and, from May 25, 2018, Regulation (EU) 2016/679 **("GDPR")** together with applicable legislation implementing or supplementing the same or otherwise relating to the processing of Personal Data of natural persons, and (ii) to the extent not included in sub-clause (i), the Data Protection Act 1998 of the United Kingdom, as amended from time to time, and including any substantially similar legislation that replaces the DPA 1998;
(f) **"Privacy Shield"** means the EU-US Privacy Shield Framework; and
(g) **"Services"** means the services to be supplied by Luganodes to Client or Client Affiliates pursuant to the Terms.

**1.2** The terms "**Controller**", "**Data Subject**", "**Personal Data**", "**Personal Data Breach**", "**Process**", "**Processor**" and "**Supervisory Authority**" have the same meanings as described in applicable Data Protection Laws and cognate terms shall be construed accordingly.

**1.3** Capitalized terms not otherwise defined in this Addendum shall have the meanings ascribed to them in the Terms.

### 2. Formation of this Addendum

This Addendum is deemed agreed by the Parties, and comes into effect, on the "**Addendum Effective Date**", being the later of (i) the date that this Addendum is accepted by Client; and (ii) September 03, 2024.

### 3. Roles of the Parties

The Parties acknowledge and agree that with regard to the Processing of Client Personal Data, and as more fully described in **Annex 1** hereto, Client acts as a Controller or Processor, and Luganodes acts as a Processor or Other Processor (as defined in section 5.2.4 below).

The Parties expressly agree that Client shall be solely responsible for ensuring timely communications to Client's Affiliates or the relevant Controller(s) who receive the Services, insofar as such communications may be required or useful in light of applicable Data Protection Laws to enable Client's Affiliates or the relevant Controller(s) to comply with such Laws.

### 4. Description of Personal Data Processing

In **Annex 1** to this Addendum, the Parties have mutually set out their understanding of the details of the Processing of the Client Personal Data to be Processed by Luganodes pursuant to this Addendum, as required by Article 28(3) of the GDPR. Either Party may make reasonable amendments to **Annex 1** by written notice to the other Party and as reasonably necessary to meet those requirements. **Annex 1** does not create any obligation or rights for any Party.

### 5. Data Processing Terms

**5.1**
Client shall comply with all applicable Data Protection Laws in connection with the performance of this Addendum. As between the Parties, Client shall be solely responsible for compliance with applicable Data Protection Laws regarding the collection of and transfer to Luganodes of Client Personal Data. Client agrees not to provide Luganodes with any data concerning a natural person's health, religion or any special categories of data as defined in Article 9 of the GDPR.

**5.2**
Luganodes shall comply with all applicable Data Protection Laws in the Processing of Client Personal Data and Luganodes shall:

**5.2.1**
process the Client Personal Data relating to the categories of Data Subjects for the purposes of the Terms and for the specific purposes in each case as set out in **Annex 1** to this Addendum and otherwise solely on the documented instructions of Client, for the purposes of providing the Services and as otherwise necessary to perform its obligations under the Terms including with regard to transfers of Client Personal Data to a third country outside the European Union or an international organization (unless required by Union or Member State law to which Luganodes is subject, in which case Luganodes shall inform Client of that legal requirement before such Processing, unless that law prohibits such information on important grounds of public interest); Luganodes shall immediately inform Client if, in Luganodes's opinion, an instruction infringes applicable Data Protection Laws;

**5.2.2**
ensure that persons authorized to process the Client Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;

**5.2.3**
implement and maintain the technical and organizational measures set out in the Terms and, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of Processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, implement any further appropriate technical and organizational measures necessary to ensure a level of security appropriate to the risk of the Processing of Client Personal Data in accordance with Article 32 of the GDPR, and specifically:

(a) pseudonymization and encryption of Client Personal Data;

(b) ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services that process Client Personal Data;

(c) restoring availability and access to Client Personal Data in a timely manner in the event of a physical or technical incident; and

(d) regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing of the Client Personal Data.

Any amendment to such agreed measures that is necessitated by Client shall be dealt with via an agreed change control process between Luganodes and Client;

**5.2.4**
Client (on behalf of the relevant Controller(s), as applicable), hereby expressly and specifically authorizes Luganodes to engage another Processor to Process the Client Personal Data ("**Other Processor**"), and specifically the Other Processors listed in **Annex 2** hereto, subject to Luganodes':

(a) notifying Client of any intended changes to its use of Other Processors listed in **Annex 2** by emailing notice of the intended change to Client;

(b) including data protection obligations in its contract with each Other Processor that are materially the same as those set out in this Addendum; and

(c) remaining liable to the Client for any failure by each Other Processor to fulfill its obligations in relation to the Processing of the Client Personal Data.

In relation to any notice received under section 5.2.4 a., the Client shall have a period of 30 (thirty) days from the date of the notice to inform Luganodes in writing of any reasonable objection to the use of that Other Processor. The parties will then, for a period of no more than 30 (thirty) days from the date of the Client's objection, work together in good faith to attempt to find a commercially reasonable solution for the Client which avoids the use of the objected-to Other Processor. Where no such solution can be found, either Party may (notwithstanding anything to the contrary in the Terms) terminate the relevant Services immediately on written notice to the other Party, without damages, penalty or indemnification whatsoever;

**5.2.5**
to the extent legally permissible, promptly notify Client of any communication from a Data Subject regarding the Processing of Client Personal Data, or any other communication (including from a Supervisory Authority) relating to any obligation under the applicable Data Protection Laws in respect of the Client Personal Data and, taking into account the nature of the Processing, assist Client (or the relevant Controller) by appropriate technical and organizational measures, insofar as this is possible, for the fulfillment of Client's, Client's Affiliates' or the relevant Controller(s)' obligation to respond to requests for exercising the data subject's rights laid down in Chapter III GDPR; Client agrees to pay Luganodes for time and for out of pocket expenses incurred by Luganodes in connection with the performance of its obligations under this Section 5.2.5;

**5.2.6**
upon Luganodes's becoming aware of a Personal Data Breach involving Client Personal Data, notify Client without undue delay, of any Personal Data Breach involving Client Personal Data, such notice to include all information reasonably required by Client (or the relevant Controller) to comply with its obligations under the applicable Data Protection Laws;

**5.2.7**
to the extent required by the applicable Data Protection Laws, provide reasonable assistance to Client, Client's Affiliates' or the relevant Controller(s)' with its obligations pursuant to Articles 32 to 36 of the GDPR taking into account the nature of the Processing and information available to Luganodes; Client agrees to pay Luganodes for time and for out of pocket expenses incurred by Luganodes in connection with any assistance provided in connection with Articles 35 and 36 of the GDPR;

**5.2.8**
cease Processing the Client Personal Data upon the termination or expiry of the Terms, and at option of Client, Client's Affiliates or the relevant Controller(s) either return or delete (including by ensuring such data is in non-readable format) all copies of the Client Personal Data Processed by Luganodes, unless (and solely to the extent and for such period as) Union or Member State law requires storage of the Personal Data. Notwithstanding the foregoing or anything to the contrary contained herein, Luganodes may retain Personal Data and shall have no obligation to return Personal Data to the extent required by applicable laws or regulations obligations. Any such Personal Data retained shall remain subject to the obligations of confidentiality set forth in the Terms; and

**5.2.9**
make available to Client all information necessary to demonstrate compliance with this Addendum and allow for and contribute to audits, including inspections, by Client, or an auditor mandated by Client. For the purposes of demonstrating compliance with this Addendum under this section 5.2.9, the Parties agree that once per year during the term of the Terms, Luganodes will provide to Client, on reasonable notice, responses to cybersecurity and other assessments. Client agrees to pay Luganodes for time and for out of pocket expenses incurred by Luganodes in connection with assistance provided in connection with such audits, responses to cybersecurity and other assessments.

### 6. Transfers
Luganodes has implemented PIMS – Privacy Information Management System as per ISO 27701:2019 requirements for categories of Personal Data including Client Personal Data. Luganodes shall notify Client in writing without undue delay if it can no longer comply with its obligations under the Privacy Shield, and, in such a case, Luganodes will have the option of (i) promptly taking reasonable steps to remediate any non-compliance with applicable obligations under this Addendum, or (ii) engaging in a good faith dialogue with Client to determine a new data transfer mechanism to carry out the purposes of the Terms. Luganodes acts as a Processor with respect to Personal Data received pursuant to a data transfer covered by the Privacy Shield, and principles 1 (notice), 2 (choice), and 5b (retention) and related supplemental principles shall only apply to Luganodes to the extent that the Client has reasonably determined, after consultation with Luganodes, that Luganodes is the appropriate Party to implement the principle or related supplemental principle and Luganodes has agreed to implement measures to address those requirements. Anything additional implementation which is extremely specific and customized to clients requirements, only such cost will be borne by the client.

Luganodes shall inform Clients in a timely manner of the basis for PII transfers between jurisdictions and of any intended changes in this regard, so that Clients has the ability to object to such changes or to terminate the contract.

### 7. Precedence

The provisions of this Addendum are supplemental to the provisions of the Terms. In the event of any inconsistency between the provisions of this Addendum and the provisions of the Terms, the provisions of this Addendum shall prevail.

### 8. Indemnity

To the extent permissible by law, Client shall indemnify and hold harmless Luganodes against all (i) losses, (ii) third party claims, (iii) administrative fines and (iv) costs and expenses (including, without limitation, reasonable legal, investigatory and consultancy fees and expenses) reasonably incurred in relation to (i), (ii) or iii), suffered by Luganodes and that arise from any breach by Client of this Addendum or of its obligations under applicable Data Protection Laws.

### 9. Severability

The Parties agree that, if any section or sub-section of this Addendum is held by any court or competent authority to be unlawful or unenforceable, it shall not invalidate or render unenforceable any other section of this Addendum.

### 10. Others

The organization ensures that the contract to process PII addresses the organization's role in providing assistance with the customer's obligations.

The Agreement considers following and follows:

a. Privacy by Design and default

b. Achieving Security of Processing

c. Notification of breaches involving PII to a Supervisory authority

d. Notification of breaches involving PII to Customers and PII Principals

e. Conducting Privacy Impact Assessment

f. Assurance of Assistance by the PII Processors if prior consultations with relevant PII Protection authorities are needed.

g. Luganodes shall inform the customer if in its opinion a processing instruction infringes applicable legislation or regulation.

h. The organization does not use PII processed under a contract for the purposes of Marketing and Advertising

i. Coordinate with Clients for helping Audit the systems. The organization provides the customer with the appropriate information so that it can demonstrate compliance with their obligations

j. Luganodes shall use only the sub processors mentioned in Annex 2 with Security and Privacy requirements fulfilled.

k. The organization shall comply with all statutory and regulatory requirements, ISO 27001:2013, ISO 27701:2019 and EU GDPR requirements.

l. The Data shall be deleted or de-identified after the processing is complete (This is after the retention period selected is complete).

m. Luganodes shall inform 24 hours in advance to clients in case of any legally binding requests for disclosure of PII. In case if it is not legally binding then PII would not be disclosed and Luganodes should notify the client of such PII request rejection. A record of all legally binding PII disclosure requests shall be maintained.

n. For Access, Correction and/or Erasure of PII of Data subjects can be done by contacting the Data Protection Officer (DPO) below. Also for raising concerns and/or any complaints related with PII that can be done by contacting the Data Protection Officer below:

**Contact Details:-**

Name of DPO: Sanjeev

Email address: sanjeev@luganodes.com

Postal address: N/A

o. Luganodes shall inform the Client for Change of Processor and/or sub-processor atleast one week in advance and the client can object to processing. Any change in the sub-processor shall be made with the written approval from the client and providing opportunity to the client to object to such change in sub-processor

p. There are no Temporary files getting generated during processing.

q. Luganodes shall maintain the necessary records in support of demonstrating compliance with its obligations (as specified in the applicable contract) for the processing of PII carried out on behalf of the client.


## Annex 1: Description of Processing of Client Personal Data

This Annex includes certain details of the Processing of Client Personal Data as required by Article 28(3) GDPR and, as applicable, Controller to Processor SCC.

**Subject matter and duration of the Processing of the Personal Data**

SaaS Solution for Governance, Risk and Compliance.

The duration of processing shall be till the contract is active with the client.

**The nature and purpose of the Processing of the Personal Data**

The Processing of PII data is for imparting ISMS Awareness training.

**The categories of Data Subject to whom the Client Personal Data relates**

- Name and email IDs

**The types of Client Personal Data to be Processed**

Name and Email ID

**Special categories of data**

None

**The obligations and rights of Client**

The obligations and rights of Client are set out in the Terms and this Addendum.

**Data exporter (as applicable)**

The data exporter is: Client of Luganodes that uses the Services

**Data importer (as applicable)**

The data importer is: Luganodes, a company that provides services to the client, which requires receiving the Client's query data

**Processing operations (as applicable)**

The personal data transferred will be subject to the following basic processing activities: The provision of Luganodes Services to Client. In order to provide people data, Luganodes receives identifying Personal Data to permit Luganodes to query, cleanse, standardize, enrich, (when required) send to additional data to feed providers, and to store the query information.



## Annex 2: Authorized Other Processors

|**Name of Other Processor**|**Description of Processing**|**Location of Other Processor**|
| :- | :- | :- |
|Google Suite|Email services|IN|
|Slack|Internal Communication|USA|
|Brevo|Email services|USA|
|Monday.com|Internal task management|USA|

---

## Product & Service Summaries

### Staking
Delegate assets to secure Proof-of-Stake networks and earn rewards through a secure, compliant, and efficient staking infrastructure.

### Managed Nodes
Activate branded validator nodes, managed end to end by Luganodes to support reliable and scalable operations.

### RPC
Enterprise-grade blockchain RPC infrastructure for reliable data access.

### Staking API
Staking integration for platforms and exchanges.

### CESR
Fixed-rate ETH staking structured around the Composite Ether Staking Rate (CESR™), a transparent reference for network-wide staking performance.

### Clients
Infrastructure solutions for custodians, exchanges, ETP issuers, and DeFi protocols. Trusted by BitGo, Coinlist, Bitfinex, Hex Trust.

---
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## Compliance

Luganodes maintains ISO 27001:2022, SOC 2 Type II, and GDPR alignment. Quantstamp provides slashing risk assessment; Chainproof offers institutional insurance coverage.

## Contact

- info@luganodes.com
- DPO: sanjeev@luganodes.com