Betelgeuse Astro OÜ (the “Company”) respects the privacy of its online visitors andcustomers of its products and services (including, but not limited to BENEFIC APP) andcomplies with applicable laws for the protection of your privacy, including, withoutlimitation, the European Union General Data Protection Regulation ("GDPR") and theSwiss and EU Privacy Shield Frameworks.

1. Definitions

Wherever we talk about Personal Data below ("Personal Data"), we mean anyinformation that can either itself identify you as an individual ("Personally IdentifyingInformation") or that can be connected to you indirectly by linking it to Personally Identifying Information, for example:

(i) your account registration information on our website and in our App;

(ii) when you request any support from us or report any problem to us;

(iii) information provided from using certain services or features;

(iv) information from completion of survey or questionnaire;

(v) technical information, including the Internet protocol (IP) address used

(vi) and your log-in information, browser, time zone setting, browser plug-in types, andversions, operating system, and platform;

(vii) details of any transactions, purchases, and payments you made;

(viii) your general interaction with the website, including the full Uniform ResourceLocators (URLs), clickstream to, through, and from our site, products you viewed orsearched for, page response times, download errors, length of visits to certain pages,page interaction information;

(ix) information received from third parties, such as business partners, sub-contractors,payment and delivery services, referrals by other users.

The Company also processes anonymous data, aggregated or not, to analyze andproduce statistics related to the habits, usage patterns, and demographics ofcustomers as a group or as individuals. Such anonymous data does not allow theidentification of the customers to which it relates. the Company may share anonymousdata, aggregated or not, with third parties. Please be aware that the Company maychoose to permit third parties to offer subscription and/or registration-based servicesthrough the Company's site. The Company shall not be responsible for any actions orpolicies of such third parties and you should check the applicable privacy policy of suchparty when providing personally identifiable information.By using the Company's website, you signify your assent to the Company's privacypolicy. If you do not agree to this policy, please do not use the Company's website(s).

2. Why the Company Collects and Processes Data

The Company collects and processes Personal Data for the following reasons:

(a) performing our agreement with you to provide content and services, includingproviding, improving, and developing our services;

(b) researching, designing, and launching new features or products;

(c) providing you with alerts, updates, materials, or information about our services or other types of information that you requested or signed up to;

(d) collecting overdue amounts;

(e) responding or taking part in legal proceedings, including seeking professional advice, or for the legitimate and legal interests of the Company or a third party (e.g.the interests of our other customers);

(f) compliance with legal obligations that we are subject to;

(g) communicating with you and responding to your questions or requests;

(h) direct marketing - we require your consent specifically for this purpose and youmay opt-out any time;

(i) purposes directly related or incidental to the above; or

(j) where you have given consent to it.These reasons for collecting and processing Personal Data determine and limit whatPersonal Data we collect and how we use it (section 3. below), how long we store it(section 4. below), who has access to it (section 5. below) and what rights and othercontrol mechanisms are available to you as a user (section 6. below).

3. What Data We Collect and Process

3.1 Basic Account Data

When setting up an Account, the Company will collect your email address and countryof residence. You are also required to choose a user name and a password. Theprovision of this information is necessary to register a User Account. You areresponsible for keeping this password confidential. We ask you not to share apassword with anyone.During setup of your account, the account is automatically assigned a number (the"ID") that is later used to reference your user account without directly exposingPersonally-Identifying Information about you.

3.2 Transaction and Payment Data

In order to make a transaction online, you may need to provide payment data to theCompany to enable the transaction. If you pay by credit card, you need to providetypical credit card information (name, address, credit card number, expiration date,and security code) to the Company, which the Company will process and transmit tothe payment service provider of your choice to enable the transaction and performanti-fraud checks. Likewise, the Company will receive data from your payment serviceprovider for the same reasons.

3.4 Your Use of the Websites

We collect a variety of information through your general interaction with the websites,Content, and Services offered by us. Personal Data we collect may include, but is notlimited to, browser and device information, data collected through automatedelectronic interactions, and application usage data. Likewise, we will track your processacross your websites and applications to verify that you are not a bot and to optimizeour services.

3.5 Your Use of Services and other Subscriptions

In order to provide you with services, we need to collect, store and use variousinformation about your activity in our Content and Services. "Content-RelatedInformation" includes your ID, as well as information about your preferences, progress,time spent, as well as information about the device you are using, including whatoperating system you are using, device settings, unique device identifiers, and crashdata.

3.6 Tracking Data and Cookies

We use "Cookies", which are text files placed on your computer, to help us analyzehow users use our services, and similar technologies (e.g. web beacons, pixels, ad tags,and device identifiers) to recognize you and/or your device(s) on, off and acrossdifferent devices and our services, as well as to improve the services we are offering,to improve marketing, analytics or website functionality. The use of Cookies isstandard on the internet. Although most web browsers automatically accept cookies,the decision of whether to accept or not is yours. You may adjust your browsersettings to prevent the reception of cookies, or to provide notification whenever acookie is sent to you. You may refuse the use of cookies by selecting the appropriatesettings on your browser. However, please note that if you do this, you may not beable to access the full functionality of our websites. When you visit any of our services,our servers log your global IP address, which is a number that is automatically assignedto the network your computer is part of.

3.7 Third Party Services

This website uses Google Analytics / Google Pay / Apple Pay ("Third Party Service").Third-Party Service uses "cookies", which are text files placed on visitors' computers, tohelp the website operators analyze how visitors use the site. The informationgenerated by the cookie about the visitors' use of the website will generally betransmitted to and stored by Third-Party Service on servers in the [United States].Please be aware that Company cannot or does not control the use of cookies or theresulting information by the Third Party Service.On behalf of the website operator, Third Party Service will use this information for thepurpose of evaluating the website / location / credentials for its users, in order tocompile reports on website activity and to provide other services relating to websiteactivity and internet usage for website operators. Third-Party Service will not associate the IP address transferred any other data held bythe Company. You may refuse the use of cookies by selecting the appropriate settingson your browser. However, please note that in this case, you may not be able to usethe full functionality of this website.

3.8 Content Recommendations

We may process information collected under section 3 so that content, products andservices shown on the pages and in update messages displayed when launching theservice can be tailored to meet your needs and populated with relevantrecommendations and offers. This is done to improve your customer experience. Subject to your separate consent or where explicitly permitted under applicable lawson email marketing, the Company may send you marketing messages about productsand services offered by the Company to your email address. In such a case we may alsouse your collected information to customise such marketing messages as well ascollect information on whether you opened such messages and which links in their textyou followed.You can opt out or withdraw your consent to receive marketing emails at any time byeither withdrawing the consent on the same page where you previously provided it orclicking the "unsubscribe" link provided in every marketing email. Notwithstanding anyopt out of promotional or marketing emails by you, we reserve the right to contact youregarding account status, changes to the user agreement and other matters relevantto the underlying service and/or the information collected.

3.9 Information Required to Detect Violations

We collect certain data that is required for our detection, investigation and preventionof fraud, cheating and other violations of the applicable laws ("Violations"). This datais used only for the purposes of detection, investigation, prevention and, whereapplicable, acting on of such Violations and stored only for the minimum amount oftime needed for this purpose. If the data indicates that a Violation has occurred, wewill further store the data for the establishment, exercise or defence of legal claimsduring the applicable statute of limitations or until a legal case related to it has beenresolved. Please note that the specific data stored for this purpose may not bedisclosed to you if the disclosure will compromise the mechanism through which wedetect, investigate and prevent such Violations.

4. How We Store Data

4.1 Period of Storage

We will store your information as long as necessary to fulfil the purposes for which theinformation is collected and processed or — where the applicable law provides forlonger storage and retention period — for the storage and retention period requiredby law. In particular, if you terminate your User Account, your Personal Data will bemarked for deletion except to the degree legal requirements or other prevailinglegitimate purposes dictate a longer storage. All your data and credits will be lost afterdeletion.

4.2 Deletion of Data

In cases where Personal Data cannot be completely deleted in order to ensure theconsistency of the system, the user experience or the community, your informationwill be permanently anonymized. Please note that the Company is required to retaincertain transactional data under statutory commercial and tax law for a period of up toten (10) years.If you withdraw your consent on which a processing of your Personal Data, we willdelete your Personal Data without undue delay to the extent that the collection andprocessing of the Personal Data was based on the withdrawn consent.If you exercise a right to object to the processing of your Personal Data, we will reviewyour objection and delete your Personal Data that we processed for the purpose towhich you objected without undue delay, unless another legal basis for processing andretaining this data exists or unless applicable law requires us to retain the data.

4.3 Location of Storage

The data that we collect from you may be transferred to, and stored at Germany,Finland, USA, or a destination outside of your jurisdiction. It may also be processed bythird parties who operate outside of your jurisdiction. By submitting your personaldata you agree to this transfer, storing or processing of data outside of yourjurisdiction. We will take all steps reasonably necessary to ensure that your data istreated securely in accordance with this privacy policy.

5. Who Has Access to Data

5.1 The Company and its subsidiaries may share your Personal Data with each otherand use it to the degree necessary to achieve the purposes listed in section 2 above.This includes our overseas offices, affiliates, business partners and counterparts (on aneed-to-know basis only). In the event of a reorganization, sale or merger we maytransfer Personal Data to the relevant or proposed transferees of our operations (or asubstantial part thereof) in any part of the world.

5.2 We may also share your Personal Data with our third party providers that providecustomer support services in connection with goods, Content and Services distributedvia us. Your Personal Data will be used in accordance with this Privacy Policy and onlyas far as this is necessary for performing customer support services.

5.3 We may also share your information with our personnel, agents, advisers, auditors,contractors, financial institutions, and service providers in connection with ouroperations or services (for example staff engaged in the fulfilment of your order, theprocessing of your payment and the provision of support services); persons under aduty of confidentiality to us; or persons to whom we are required to make disclosureunder applicable laws and regulations in any part of the world.

5.4 In accordance with internet standards, we may also share certain information(including your IP address and the identification of content you wish to access) withour third party network providers that provide content delivery network services andserver services in connection with us. Our content delivery network providers enablethe delivery of digital content you have requested, by using a system of distributedservers that deliver the content to you, based on your geographic location.

5.5 The Company may allow you to link your User Account to an account offered by athird party. If you consent to link the accounts, the Company may collect and combineinformation you allowed the Company to receive from a third party with informationof your User Account to the degree allowed by your consent at the time. If the linkingof the accounts requires the transmission of information about your person from theCompany to a third party, you will be informed about it before the linking takes placeand you will be given the opportunity to consent to the linking and the transmission ofyour information. The third party's use of your information will be subject to the thirdparty's privacy policy, which we encourage you to review.

5.6 The Company may release Personal Data to comply with court orders or laws andregulations that require us to disclose such information.

6. Your Rights and Control Mechanisms

You have the right to:

(a) check whether we hold personal data about you;
(b) access any personal data we hold about you;
(c) require us to correct any inaccuracy or error in any personal data we hold aboutyou;
(d) request for the deletion of your personal data through the deletion of the useraccount.

The data protection laws of the European Economic Area and other territories granttheir citizens certain rights in relation to their Personal Data. While other jurisdictionsmay provide fewer statutory rights to their citizens, we make the tools designed toexercise such rights available to our customers worldwide.As a resident of the European Economic Area you have the following rights in relationto your Personal Data:

6.1 Right of Access

You have the right to access your Personal Data that we hold about you, i.e. the rightto require free of charge (i) information whether your Personal Data is retained, (ii)access to and/or (iii) duplicates of the Personal Data retained. You can use the right toaccess your Personal Data through the Privacy Dashboard. If the request affects therights and freedoms of others or is manifestly unfounded or excessive, we reserve theright to charge a reasonable fee (taking into account the administrative costs ofproviding the information or communication or taking the action requested) or refuseto act on the request.6.2 Right to RectificationIf we process your Personal Data, we shall endeavour to ensure by implementingsuitable measures that your Personal Data is accurate and up-to-date for the purposesfor which it was collected. If your Personal Data is inaccurate or incomplete, you canchange the information you provided via the Privacy Dashboard.

6.3. Right to Erasure

You have the right to obtain deletion by us of Personal Data concerning you bydeleting your User Account via the support page.As a result of deleting your User Account, you will lose access to services, including theUser Account, Subscriptions and service-related information linked to the UserAccount and the possibility to access other services you are using the User Account for.We allow you to restore your User Account during a grace period of 30 (thirty) daysfrom the moment you request deletion of your User Account. This functionality allowsyou not to lose your account by mistake, because of your loss of your accountcredentials or due to hacking. During the suspension period, we will be able to finalizefinancial and other activities that you may have initiated before sending the UserAccount deletion request. After the grace period, Personal Data associated with youraccount will be deleted subject to section 4. above.In some cases, deletion of your User Account, and therefore Personal Data deletion, iscomplicated. In some cases, considering the complexity and number of the requests,the period for Personal Data erasure may be extended, but for no longer than twofurther months.

6.4 Right to Object

When our processing of your Personal Data is based on legitimate interests accordingto Article 6(1)(f) of the GDPR / section 2.c) of this Privacy Policy, you have the right toobject to this processing. If you object we will no longer process your Personal Dataunless there are compelling and prevailing legitimate grounds for the processing asdescribed in Article 21 of the GDPR; in particular if the data is necessary for theestablishment, exercise or defence of legal claims.You also have the right to lodge a complaint at a supervisory authority.

7. Children

The minimum age to create a User Account is 18. the Company will not knowinglycollect Personal Data from children under this age. Insofar as certain countries apply ahigher age of consent for the collection of Personal Data, the Company requiresparental consent before a User Account can be created and Personal Data associatedwith it collected. The Company encourages parents to instruct their children to nevergive out personal information when online.

8. Contact Info

You can contact the Company's data protection officer at the address below.

support@benefic.guru.

9. Revision Date

This privacy policy was last updated on 15 February 2023 ("Revision Date"). If youwere a user before the Revision Date, it replaces the existing Privacy Policy. TheCompany reserves the right to change this policy at any time by notifying the users ofthe existence of a new privacy statement. This policy is not intended to and does notcreate any contractual or legal rights in or behalf of any party.