PRIVACY STATEMENT

At Net Element, Inc. (“Net Element”), we are committed to safeguarding your privacy and protecting your information against unauthorized use. The following statements explain the policies we adhere to regarding the collection of data, information, security, and privacy standards.

About the Information We Collect

Net Element is a holding company whose subsidiary entities provide payment products and services for commercial and non-commercial enterprises. Those products and services include payment card processing, point-of-sale terminal management and support, merchant accounting and funds transfer. As a part of our business operations, we routinely collect and retain information about our customers. This information is necessary in allowing us to provide our services or provide information about our services and company. Use of this information by Net Element includes, but is not limited to: administration of records; execution of accounting and funding; compliance with laws or regulations; and/or the development of future products. Net Element is the sole owner of the information collected. We will not sell, share, trade, or rent this information to others in ways inconsistent with this statement. Many of our customers are businesses or other non-person legal entities. While most of the information we receive and collect is not of a personal nature, portions of the transaction information we receive may include public and non-public information about individuals as well as about the entities with which they conduct business activities. Regardless of the nature of the information, whether it is information we solicit directly from our customers, from visitors to our Web site, or whether we collect the information during the processing of transactions, we regard all such information as "private" and take steps to protect its integrity and confidentiality.

No private information regarding specific persons will be provided to any third party except:

to obtain commercial and credit information to establish, maintain or renew a customer's contract(s),
as may be required to provide any of the services for which a customer has subscribed,
as may be legally permitted,
to assist in preventing or prosecuting fraud, or to otherwise comply with a requirement or request of the government,
to comply with the rules and regulations of any credit or debit card payment network, or
with the person's written consent.

This policy does not preclude Net Element' unrestricted use of non-personal, summarized, derived, or aggregate information (i.e., volumes, totals, averages, etc.). In addition, Net Element may provide information, from time to time and as allowed by our customers' respective contracts, to entities that may have products or services that may be of interest to them.

Information Collected via Our Web Site

We may solicit, collect or retain public or personal information regarding customers or visitors to our Web site(s) in order to allow Net Element to respond to requests about products and services, for investor information, etc. Such information (e.g., name, address, telephone number, e-mail address) is voluntarily supplied by the visitor and will be used to contact the visitor to follow up on the visitor's request.

Third Parties

Portions of our services may be provided by organizations with which Net Element has a contractual relationship. In such cases, Net Element may provide collected information to these organizations. These vendors and service companies agree to respect the confidentiality of such information, safeguard it, and abide by applicable law. In the event our business relationship requires Net Element to perform credit-reporting activities, we may share your information with third parties. We may also be required to disclose personal information in response to requests by legal, governmental, or regulatory agencies with proper jurisdiction.

Commitment to Security, Privacy, and Standards

At Net Element, we take seriously our responsibility to protect the security and privacy of the information we receive. We have established effective policies that define our commitment to data security and the information technology we administer. We continually review our policies and procedures to assure that they are appropriate and effective in meeting our commitments to our community, our customers, and ourselves.

Strict internal procedures and control mechanisms require that individuals access to information is controlled according to job responsibility and legitimate "need to know." To the degree reasonably possible, access controls are narrowly defined in order to restrict information access to that which is necessary and consistent with the respective job function(s) of our personnel.

Any suspected attempt to breach our policies and procedures, or to engage in any type of unauthorized action involving our information systems, is regarded as potential criminal activity. All suspected computer mischief will be reported to the appropriate authorities.

Security Practices

Net Element uses a variety of controls and measures to protect personal or sensitive information. These include industry-standard encryption, physical access security, secured networks and servers, anti-virus protection, vulnerability scans, firewalls, intrusion detection, defense monitoring and other appropriate technology.

We test, review, and update this technology from time to time to time to improve and enhance our security systems.

Cookies

The Net Element site may create a file, or "cookie," on the hard drive of your computer in order to retain information that is used by our Web site. These files are used during your online session to ensure access to our site is authorized and to control certain parameters of your communication session with our site. We do not use these files to monitor the behavior of visitors to our sites.

IP Addresses

An IP (Internet protocol) address is a number assigned to your computer for accessing the Internet. All computer identification on the Internet is conducted using IP addresses to allow other computers and servers to recognize and communicate with each other. If a visitor requests pages from the Net Element Web site, the Net Element servers enter the visitor's IP address into a log. We do not associate IP addresses with personal information received from visitors. Net Element collects IP addresses in order to conduct site analysis. We also use IP address information to conduct system administration, manage communication traffic patterns and to investigate threats, mischief, or "attacks" directed at our site or to our visitors.

External Links

Net Element may provide links on the Web site, via advertising and otherwise, to third-party Web sites that are not under Net Element's control. Net Element does not endorse or make any warranty of any type regarding the content contained on such third-party Web sites or products and services offered therein. Net Element makes no representation regarding your use of such Web sites. Please be aware that Net Element is not responsible for the privacy practices of such third-party Web sites. Users should be aware when they leave the Net Element site and should read the privacy statements of each and every Web site that may collect personally identifiable information. The privacy statement set forth herein applies solely to information collected by Net Element.

Children

Our Web sites do not provide content intended to attract or encourage the participation of children. We do not solicit or knowingly accept information from persons under the age of 18.

Customer Responsibility

As a customer of Net Element, you may be provided with a unique identifier such as a merchant number, password, or "PIN" (personal identification number), which is intended to authenticate your identity when accessing our systems. Such identifying items are intended to be secret and to be known, possessed, and used only by you. The effectiveness of these mechanisms for authenticating your identity depends on maintenance of the confidentiality of these identifying items. Accordingly, these identifying items should be kept in your exclusive possession, carefully protected from the discovery, access, or possession of others. Failure to keep such identifying information in your exclusive possession renders you responsible for the actions of other persons who use this information to access Net Element's systems. Should you become aware or have reason to suspect that a personal identifier has been lost or disclosed to a third-party, you should immediately notify Net Element.

Changes to Net Element' Information Security and Privacy Statement

In order that Net Element's information security and privacy policies are appropriate and effective and that these policies reflect the ongoing changes in our industry, Net Element reviews its policies and practices from time to time and may make changes to these policies and practices as it determines them to be warranted. When changes are made that affect Net Element' Privacy Statement, this Web site will reflect such changes.

Inquiries

If you have a question or comment regarding this Privacy Statement, please contact:

Net Element Inc.
Attention: Corporate Compliance
3363 NE 163rd Street, #705
North Miami Beach, FL 33160

Or, via email at: info@netelement.com

This privacy statement is currently applicable to only U.S. customers and visitors to this Web site. International businesses have specific laws, rules, and regulations that may be unique to their geographic location. This Privacy Statement may be amended to comply with local laws and requirements. Responses to inquiries for privacy-related issues will be redirected for response from Net Element's individual business units.