PRIVACY POLICY

Last updated:
Dec 10th, 2025

website & Platforms Privacy policy

We know that your privacy is important to you, and we work hard to earn and keep your trust. ChainGPT AI S.A., a company incorporated and existing under the laws of the Republic of Panama (collectively with its subsidiaries and affiliates, “Company,” “we,” “us,” and “our”), respects your privacy and is committed to protecting your privacy through our compliance with this Privacy Policy (the “Policy”).

The words “you” and “your” refer to you as a user of the Services (defined below), either as a visitor, registered customer, employee, or representative of a Company customer.

This Policy describes:

  • The types of information we collect from you or that you may provide when you visit or use:
  • Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect:

  • On or through the Services;
  • In email, text, and other electronic messages between you and the Services; and
  • From your interaction with our advertising and marketing on third‑party websites and services, if such communications include links to this Policy.

This Policy does not apply to information collected:

  • Offline or through any other means, including on any other website or application operated by the Company or any third party, unless this Policy is expressly posted or linked there; or
  • By any third party, including through any application or content (including advertising) that may link to or be accessible from the Services (see Third‑Party Websites below).

For the avoidance of doubt, the Company does not control the underlying blockchain protocols on which various digital assets are deployed or used, and cannot control use of, activity on, or data on those protocols.

Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, please do not use the Services. By using the Services, you agree to the terms of this Policy. This Policy may change from time to time (see Changes to this Policy below). Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check this page periodically for updates.

1. TERMS OF SERVICE

This Policy is incorporated by reference into, and should be read in conjunction with, the Company’s Terms of Service (collectively, the “Terms of Service”). If any provision in this Policy conflicts with the Terms of Service, the Terms of Service will control to the extent of the conflict, unless applicable law requires otherwise.

2. THE INFORMATION WE COLLECT

You may choose to deal with us on an anonymous basis or to use a pseudonym, unless it is not practicable for us to deal with individuals whom we cannot identify or we are required by law to deal only with identified individuals (for example, for KYC verification purposes). The information described below may be collected from you if you choose to provide it as part of your use of the Services; except as otherwise described in this Policy (including for KYC purposes), providing this information is not strictly required to use all parts of the Services.

a. Personal Information

To ensure that we provide you with the best possible experience, we store, use, and disclose personal information about you in accordance with this Policy.

“Personal Information” means information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household, or device. The Personal Information that we receive and collect depends on what you do when you visit or use the Services.

b. KYC Verification (Launchpads and Campaigns)

In certain circumstances, you may be required to complete a know-your-customer (“KYC”) or similar identity verification check provided by an independent third-party service (such as Blockpass) before you can participate in a token sale, Buzzdrop, Initial Buzz Offering (IBO), or other campaign on our launchpads and Platforms. The KYC provider collects and verifies your identification documents and other information directly from you and stores this information on its own systems in accordance with its own terms and privacy policy. We are able to access and view this KYC information in the provider’s dashboard in order to review and manage your eligibility, respond to support requests or disputes, and meet our compliance obligations, but we do not generally download or maintain copies of your full KYC file (such as images of identity documents or proof-of-address) in our own infrastructure.

The only elements of your KYC result that are routinely transferred to and stored in our own systems are: (i) a confirmation of your KYC status (for example, pass/fail or similar flags required for sanctions and AML checks), (ii) your country of residence, and (iii) the wallet address(es) that have been approved for participation. We treat this limited information as Personal Information and use it only to operate and secure our products, confirm your eligibility (including jurisdictional restrictions), prevent fraud and multi-account abuse, and comply with applicable laws. If you wish to exercise your rights with respect to Personal Information held directly by the KYC provider (including your full KYC documents), please refer to that provider’s privacy policy or contact it directly; we may assist in coordinating your request where appropriate.

Contact and marketing information: If you choose to sign up for newsletters, waitlists, product updates, or other marketing communications, we collect the email address and any other contact details you provide. You can unsubscribe from marketing emails at any time by following the instructions in those communications. Even if you opt out of marketing, we may still send you non-promotional messages relating to your account or your use of the Services.

Community and social profile information: If you choose to connect or provide your Telegram username, Discord handle, X (Twitter) username, or similar community and social-media accounts to our Services (for example, when creating a launchpad profile or joining a Buzz campaign), we collect the associated usernames, profile identifiers, and basic account metadata necessary to verify eligibility for tasks and track campaign participation. We only access the information that the relevant platform makes available to us in accordance with your settings and the platform’s own terms.

c. Aggregated and De‑Identified Data

We may also collect, use, and disclose aggregated and de‑identified data, such as statistical or demographic data, for any purpose. Aggregated and de‑identified data could be derived from your Personal Information, but is not considered Personal Information under applicable law because this data does not directly or indirectly reveal your identity. However, if we combine or connect aggregated or de‑identified data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information, which will be used in accordance with this Policy.

d. Blockchain Data, Wallet Addresses and On-Chain Activity.

When you connect a blockchain wallet to our Services, interact with our smart contracts, or otherwise use our products on-chain, we may associate your public wallet address(es) with your account or profile. Because most blockchains are public, the transactions associated with your wallet address are visible to anyone. We may use third-party blockchain analytics tools to read publicly available on-chain data and derive information about your activity (for example, token balances, staking positions, historical transactions, and interactions with our or other projects’ contracts) in order to provide our Services, run campaigns, verify eligibility, and detect fraud or abuse. For example, we may combine on‑chain data and analytics to provide features such as CryptoGuard security scores, risk labels, alerts, and similar assessments.

We may link publicly visible on-chain information (such as your wallet address and relevant transactions) with other Personal Information we hold about you (such as your email address, country of residence, campaign participation history, or KYC status from our third-party provider) where this is necessary for the purposes described in this Policy.

We do not control and cannot delete, modify, or “erase” information that is recorded directly on public blockchains. Where privacy rights such as the right to deletion apply, they relate to the Personal Information we store off-chain in our own systems, not to records on the blockchain itself.

e. Free‑Text Boxes and Communications

The information that you provide will vary by context. In some cases, you may be able to provide Personal Information via email or free‑text boxes (for example, when you contact the Company to request further information, submit feedback, or open a support ticket). When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information (such as government ID numbers, full payment card details, or other highly sensitive personal data) unless it is expressly required for our services or requested as part of a secure KYC or payment process.

f. Information About Other Individuals

You may have the opportunity to provide information about other individuals (for example, when you refer a friend or submit contact information for representatives of your business). When providing such information, you are solely responsible for obtaining any necessary consents and authorizations from those individuals in accordance with applicable data‑protection laws and regulations, and the Company shall not be responsible or liable for your failure to obtain such consents.

g. Credit Card and Payment Information

For any credit or debit card payments on our Websites or Platforms (for example, when purchasing credits for our AI products), we use trusted third-party PCI-DSS compliant payment processors, such as Stripe, to process your transactions. These providers collect and maintain the payment card information needed to complete your transactions. We do not store your full payment card number in our own systems. We may receive limited information related to your transactions (such as the last four digits of your card, the transaction date and time, and the payment amount) for recordkeeping, fraud prevention, customer support, and accounting purposes.

h. Recording Use of the Services

We partner with trusted third‑party vendors to analyze performance and traffic on the Services. This may include information such as the buttons you click, mouse movements and scrolling, date and time of access, pages visited, web beacons, and cookie or pixel‑tag information. These vendors help us understand how users interact with the Services so we can improve functionality, performance, and user experience.

AI Interactions and Model Content. When you use our AI-powered products and services (for example, ChainGPT chat interfaces, APIs, agents, tools embedded in third-party applications, or AI features on our launchpads and Platforms), we collect the prompts, instructions, uploads, and other content you submit (“Model Inputs”), as well as the responses generated by our systems (“Model Outputs”). We also log technical details about your use of these features, such as timestamps, session identifiers, feature flags, approximate location derived from your IP address, and usage metrics (for example, which tools or features you use and how often).

We use this information to provide the services you request, operate and secure our AI systems, troubleshoot issues, monitor for abuse and fraud, enforce our Terms of Service, and improve the performance, reliability, and user experience of our products. A limited number of authorized personnel and service providers may review Model Inputs and Model Outputs for these purposes (for example, to investigate abuse reports, debug a technical issue, or evaluate system performance).

As of the “Last Updated” date of this Policy, we do not use your Model Inputs or Model Outputs to train or fine-tune our models in a way that generalizes across users, beyond what is necessary to provide the services to you (for example, caching results, safety filtering, and spam and abuse prevention). In the future, we may use de-identified or aggregated Model Inputs and Model Outputs to develop and improve our models and services, in which case we will do so in accordance with applicable law and this Policy and, where required, will provide additional notice or obtain your consent.

You should not include any information in your Model Inputs that you would not want us to store or review for these purposes, and you should avoid providing highly sensitive personal data (such as full payment card numbers, bank account numbers, government-issued identification numbers, or detailed health information) unless it is explicitly requested and strictly necessary for a particular feature.

i. Categories of Personal Information We May Collect

Depending on how you interact with the Services, we may collect the following categories of Personal Information (examples are illustrative only):

  • Identifiers: Real name, alias, postal address, unique personal or online identifiers, Internet Protocol (IP) address, email address, account name, or similar identifiers.
  • Customer Records (California Customer Records statute, Cal. Civ. Code § 1798.80(e)): Name, signature, physical characteristics or description, address, telephone number, passport number or other ID number, education, employment, employment history, bank account number, credit or debit card number, wallet information, or other financial information.
  • Internet or Other Network Activity: Browsing history, search history, information regarding your interaction with the Services or our advertising, log data, device identifiers, and similar data.

We may obtain these categories of Personal Information from:

  • Directly from you, for example, when you:
    • Register an account on the Services;
    • Participate in an IDO or token sale;
    • Place an online order;
    • Subscribe to newsletters;
    • Submit content, feedback, or reviews;
    • Apply for a job; or
    • Otherwise, communicate with us.
  • Indirectly from you, for example, through information we collect in the course of providing our services to you.
  • Directly and indirectly from your activity on the Services, including through automated information collection technologies as described below.

3. AUTOMATED INFORMATION COLLECTION

When you visit or use the Services, we may collect certain information about your device and usage through automated tools. These tools may collect information about your behavior and your computer or device, such as your IP address, the pages you view, and the actions you take while using the Services.

Some of the tools we use include:

a. Cookies

A “cookie” is a small data file that a website or other online service stores on your device’s hard drive or memory. Cookies typically fall into two categories:

  • Session cookies, which do not remain on your device after you close your browser; and
  • Persistent cookies, which remain on your device until you delete them or they expire.

We may use the following categories of cookies on the Services:

  • Strictly Necessary Cookies – These cookies are essential to enable you to move around the Services and use their features. Without these cookies, certain services you have requested cannot be provided.
  • Performance Cookies – These cookies collect anonymous information about how you use the Services, such as how you arrive at the Services, navigate them, and use their features. This helps us understand usage patterns and identify areas for improvement.
  • Functionality Cookies – These cookies remember choices you make (for example, your country, language, or search parameters) and help provide a more personalized experience.
  • Targeting or Advertising Cookies – These cookies collect information about your browsing habits to deliver advertising more relevant to your interests, limit the number of times you see an ad, and help measure the effectiveness of ad campaigns. These cookies are typically placed by third‑party advertising networks.

You can modify your browser settings to refuse cookies or alert you when cookies are being sent. However, if you disable cookies, certain parts of the Services may not function properly or you may lose access to some features.

b. Google Analytics

The Services may send aggregated, non‑Personal Information to Google Analytics (or similar analytics providers) to allow us to perform technical and statistical analysis of Service performance. For more information on how Google Analytics uses data, please review Google’s policies at:

https://policies.google.com/technologies/partner-sites.

Other analytics, measurement, and advertising tools. In addition to Google Analytics, we may use other analytics, measurement, attribution, and advertising partners across our Websites and Platforms to help us understand how users find and interact with our products, attribute conversions, and reach relevant audiences with our marketing campaigns. These partners may place their own cookies, pixels, tags, or similar technologies on our Services and on third-party sites, and may receive information about your browser or device, the pages you visit, actions you take, hashed identifiers (such as hashed email addresses), and your approximate location derived from your IP address.

We use this information, often in aggregated or de-identified form, to measure the effectiveness of our campaigns, understand usage patterns across our ecosystem, prevent fraud and abuse, and improve our products and Services. Where required by law, we will obtain your consent before using cookies or similar technologies for analytics, advertising, or personalization purposes. You can usually control cookies through your browser settings and, depending on your jurisdiction, through additional tools we make available (such as a cookie banner, preference center, or “opt-out” links).

c. Web Beacons

A “web beacon” is an electronic image (also known as a clear GIF, pixel tag, or single‑pixel GIF) that can be used to recognize certain information on your device, such as cookies, time and date of page view, and a description of the page where the beacon is placed.

If you choose to receive emails from us, we may use web beacons to track your reaction to our emails (for example, whether you open them and which links you click). Our third‑party marketing partners may also use web beacons to track your interaction with online advertising banners on the Services. This information is collected in aggregate form and is not typically linked to your Personal Information.

d. Embedded Web Links

Links in our emails and sometimes on third‑party websites may contain embedded tracking technology. When you click such a link, it may be routed through a redirection system that allows us to understand how the link is being used. Some of these links may enable us to identify that you have personally clicked on the link and associate that information with the Personal Information we hold about you. We use this data to improve our services and measure the effectiveness of our marketing campaigns.

e. Third‑Party Websites and Services

We work with various third‑party service providers of marketing and communications technology. These providers may use data‑collection methods to improve the performance of marketing campaigns. The information collected may be gathered both on our Services and on third‑party sites where our marketing communications appear (for example, where our banner advertisements are displayed).

4. HOW WE USE YOUR INFORMATION

The information we gather and that you provide is collected and used to provide you with information and the services you request, and for a variety of other purposes, including but not limited to:

  • Security, credit, or fraud‑prevention purposes;
  • Providing you with effective customer service, including monitoring, managing, and updating your accounts, services, and products;
  • Providing you with a personalized experience when you use the Services;
  • Developing and improving our products, services, and features;
  • Contacting you with special offers, marketing communications, and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
  • Contacting you with information and notices related to your use of the Services (for example, changes to the Services or this Policy);
  • Inviting you to participate in surveys and to provide feedback (in accordance with your preferences);
  • Better understanding your needs, interests, and preferences;
  • Improving the content, functionality, and usability of the Services;
  • Improving our marketing and promotional efforts; and
  • Any other purpose identified at the point of data collection, in an applicable privacy notice, in a click‑through agreement, or in any other agreement between you and us.

Buzz, Launchpad and Allocation Scoring. For certain features—such as Buzz campaigns, Buzzdrops, Initial Buzz Offerings (IBOs), staking programs, IDOs, and other launchpad or incentive activities—we generate scores, reward allocations, and risk indicators based on data about how you use our Services, interact on connected platforms, and perform eligible tasks. This may include, for example:

  1. your participation in campaigns (registration status, completed tasks, timestamps, and related metadata);
  2. your connected X (Twitter) handle and engagement metrics for posts that we track as part of a campaign (such as impressions, likes, reposts, replies, quoted posts and similar signals);
  3. your connected Telegram or other community handles and whether you have joined or engaged in particular channels required by a campaign;
  4. your wallet address, staking activity, and relevant on-chain transactions linked to our products or campaign smart contracts; and
  5. technical and security-related signals (such as IP address, device and browser identifiers, and usage patterns) that help us detect bots, proxies, and multi-account abuse.

We use this information to calculate Buzz Points and similar metrics, determine allocations and rewards, operate referral programs, maintain and display leaderboards, filter out suspected fraudulent or low-quality activity, and generally ensure our campaigns are fair and consistent with their rules. We may update our scoring formulas, weighting, and anti-abuse logic from time to time to reflect new products, market conditions, or fraud patterns.

In some jurisdictions, this type of scoring may be considered “profiling.” Where applicable law gives you rights in relation to profiling (such as the right to object or to request more information), you can exercise those rights as described in the Additional Rights in Certain Jurisdictions section of this Policy.

Duration. We retain Personal Information, including any sensitive personal information if collected, for as long as reasonably necessary to carry out the business purposes for which it was collected, to comply with legal and regulatory obligations, to resolve disputes, and to enforce our agreements.

5. HOW WE DISCLOSE YOUR INFORMATION

We do not sell your Personal Information as that term is generally understood under applicable data‑protection laws. We may disclose your Personal Information to third parties for legitimate business purposes, in the ways described in this Section 5 (for example, to our affiliates, service providers, other business partners, and, where relevant, project teams and launch partners in connection with specific campaigns).

a. Our Affiliates

We may disclose information collected through the Services with our affiliates in order to provide our products and services, support our operations, and provide effective customer support.

b. Third‑Party Service Providers

We disclose Personal Information collected through the Services with third‑party service providers who act for or on behalf of the Company. These may include, without limitation:

  • KYC/AML verification providers;
  • Website and platform hosting providers;
  • Software development and maintenance providers;
  • Payment processors;
  • Data analytics providers;
  • Order fulfillment and logistics providers;
  • Information technology and infrastructure providers;
  • Customer service and support providers;
  • Email delivery and marketing providers; and
  • Auditors and professional advisors.

These third parties may need information about you to perform their functions, and they are typically contractually obligated to keep such information confidential and to use it only for the purposes for which we disclose it to them.

c. Other Carefully Selected Business Partners

From time to time, we may disclose limited Personal Information with selected third‑party business partners (other than our service providers). For example, we may partner with third parties to sponsor contests, promotions, loyalty programs, or joint marketing activities, and may disclose the Personal Information you submit to participate. Where required by law, we will offer you an opportunity to opt in or opt out of such sharing.

d. Businesses / Enterprise Customers

If you access the Services through a business, enterprise customer, or other organization (for example, via a business‑managed account or subscription), we may disclose your information to that organization as needed to manage such accounts, comply with contracts, or support administrative functions. The Company is not responsible or liable for any uses of your information by such organizations.

e. In Aggregate or De‑Identified Form

We may aggregate or otherwise anonymize the data we collect for analytics, research, marketing, and other business interests of the Company. Such use will not include Personal Information or information that can reasonably be used to identify you as an individual.

f. Legal Reasons

We may disclose your information without your consent if we believe such disclosure is reasonably necessary to:

  • Comply with any applicable law, regulation, subpoena, or court order;
  • Respond to duly authorized information requests from law enforcement or other governmental authorities;
  • Enforce our agreements or policies;
  • Investigate and help prevent security threats, fraud, or other malicious activity; or
  • Respond to an emergency that we believe in good faith requires disclosure to help prevent the death or serious bodily injury of any person.
g. Sale of Business or Merger

There may be circumstances in which the Company decides to buy, sell, or reorganize some or all of its business. Under these circumstances, it may be necessary to disclose or receive Personal Information with prospective or actual purchasers, acquisition targets, partners, or affiliates. In such cases, we will ensure your information is used in accordance with this Policy.

h. Project teams and launch partners

When you participate in a launchpad event, Buzz campaign, Buzzdrop, Initial Buzz Offering (IBO), IDO, staking program, giveaway, airdrop, or similar initiative that we host for or together with a third-party project, we may share with the relevant project team or issuer the information they reasonably need to operate the campaign, fulfill allocations and rewards, and comply with their own obligations. This may include, for example:

  1. The full wallet addresses that are eligible for participation and/or rewards;
  2. The allocations, rewards, staking amounts, or similar figures associated with those wallet addresses; and
  3. Public-facing identifiers and metrics used in the campaign (for example, X (Twitter) usernames that appear on campaign leaderboards or are required to verify that tasks have been completed), and aggregated or de-identified campaign analytics and performance statistics.

We do not share your KYC documents or other sensitive identification data collected by our third-party KYC providers, and we do not provide your private contact details (such as your email address or phone number) to project teams or launch partners for their own independent marketing purposes, unless we clearly tell you otherwise at the point of collection or you provide that information directly to the project yourself. In some jurisdictions, wallet addresses and social media handles may still be considered Personal Information when linked to you. We share this information only where it is necessary to run the relevant campaign, deliver rewards or allocations, operate staking or similar mechanisms, or comply with applicable laws.

6. YOUR CHOICES AND SELECTING YOUR PRIVACY PREFERENCES

We want to provide you with the relevant information that you have requested. When possible, we will provide options regarding what information you provide and how you can manage any preferences that pertain to such information.

If we provide subscription‑based services, such as email newsletters, we will allow you to make choices about what information you receive at the point of information collection or at any time after you receive a communication from us while you are subscribed.

Transactional or service‑oriented messages (for example, account‑related notices, security alerts, and confirmations) are generally excluded from marketing preferences, as such messages are required to respond to your requests or to provide goods and services and are not primarily marketing communications.

From time to time, we may send you marketing emails or newsletters. You may opt out at any time by clicking the “unsubscribe” link at the bottom of such emails or by following any additional opt‑out instructions provided. Please note that, by opting out, you may affect other services you have requested from us where email communication is a necessary part of the service. Even if you opt out of receiving marketing communications, we may still need to contact you with important information about your account or to respond to your requests or questions.

7. ACCURACY AND ACCESS TO YOUR PERSONAL INFORMATION

We strive to maintain and process your information accurately and in accordance with relevant data‑governance frameworks and legal requirements. We use technologies and processes designed to help maintain information accuracy at input and during processing.

Where we can provide you access to your Personal Information in our possession, we will typically ask you for a username and password or other authentication to protect your privacy and security. We recommend that you keep your credentials safe, change them periodically, and do not disclose them to anyone else.

To view, update, or correct the Personal Information that you have provided to us, you can:

  • Log in to your account (if applicable) and follow the instructions on the relevant webpage; or
  • Contact us using the methods described in How to Contact Us below.

8. INFORMATION OF MINORS

We do not knowingly collect or use information from individuals under the age of eighteen (18) without parental or guardian consent. We encourage parents and guardians to take appropriate measures to prevent minors from providing information on the internet without permission.

If we become aware that we have collected Personal Information from a minor under the age of eighteen (18) without parental or guardian consent, we will take reasonable steps to securely remove such information from our systems.

9. SUBMISSIONS

We welcome inquiries or feedback on the services or products you might use or would like to use. Any inquiries, feedback, suggestions, ideas, materials, comments, or other information you provide to us (collectively, “Submissions”) will generally be treated as non‑proprietary and non‑confidential, unless otherwise agreed in writing.

Your Submissions on or through the Services may be available to others who visit or use the Services. We may use your Submissions in advertising campaigns and other promotions. We may or may not use your name in connection with such use, and we may or may not seek your consent before using the Submissions for such purposes. Therefore, you should have no expectation of privacy with respect to your Submissions on or through the Services.

You should not submit any content that you do not wish to make available to the general public, and you must take special care to ensure your Submissions comply with our Terms of Service and any other applicable agreements. Your Submissions must not violate the privacy or other rights of others. You may not use false identifying information or contact information, impersonate any person or entity, or otherwise mislead us as to the origin of any Submission.

10. THIRD‑PARTY WEBSITES

This Policy does not apply to websites, applications, or other domains that are maintained or operated by third parties or by our affiliates, unless this Policy is expressly posted there. The Services may contain links to third‑party websites and services (for example, advertisements or external project pages). If you click on a third‑party link, you may be taken to a website that we do not control. These links are not endorsements of those websites or services, and this Policy does not extend to them.

Because this Policy is not enforced on third‑party websites, we encourage you to read any posted privacy policy of the third‑party website or service before using it and before providing any information.

11. ADDITIONAL RIGHTS IN CERTAIN JURISDICTIONS

Depending on where you live, you may have additional rights under applicable data-protection or privacy laws with respect to your Personal Information. These rights may include, for example, the right to:

  1. Request access to the Personal Information we hold about you;
  2. Request that we correct or update inaccurate Personal Information;
  3. Request deletion or erasure of your Personal Information;
  4. Request that we restrict the processing of your Personal Information;
  5. Object to certain types of processing, including where we are relying on legitimate interests;
  6. Request that we provide a copy of your Personal Information in a structured, commonly used, and machine-readable format (“data portability”); and
  7. Not be treated in a discriminatory way for exercising your privacy rights.

We will handle any such requests in accordance with the laws that apply to us and to you. These rights may be limited, for example, where fulfilling your request would adversely affect the rights and freedoms of others, interfere with ongoing legal obligations, or prevent us from providing a service you have requested.

To exercise any rights you may have, please contact us using the methods described in the How to Contact Us section below. We may need to verify your identity before responding to your request. If your request relates to Personal Information processed directly by one of our third-party providers (such as our KYC or payment processors), we may direct you to contact that provider where appropriate.

12. LOCATION OF OUR SERVICES AND DATA PROCESSING

We do not warrant or represent that this Policy or our use of your Personal Information complies with the laws of every jurisdiction. Our Services are operated primarily from the Republic of Panama, and your Personal Information may be stored and processed in Panama and in other countries where we or our service providers maintain facilities, such as member states of the European Union, the United States, or other jurisdictions. These countries may have data-protection laws that are different from the laws of your country of residence and, in some cases, may not be as protective.

Regardless of where your Personal Information is processed, we will handle it as described in this Policy and will take reasonable measures to protect it in accordance with applicable law.

13. INTERNATIONAL DATA PROTECTION LAWS

Where you are located in the European Economic Area (“EEA”), the United Kingdom (“UK”), or another jurisdiction that applies similar data-protection laws (together, “International Data Protection Laws”), our processing of your Personal Information will be subject to those laws, and you may have additional rights as described in this section. For these purposes, the Company acts as a “controller” of your Personal Information.

Legal bases for processing: We rely on one or more of the following legal bases, depending on the circumstances, to process your Personal Information:

  1. Contract: Where we process Personal Information to provide our Services to you or to take steps at your request before entering into a contract (for example, creating and managing your account, processing your participation in a campaign or launch, or providing customer support).
  2. Legitimate interests: Where we process Personal Information for our legitimate business interests, and those interests are not overridden by your data-protection rights (for example, securing and improving our Services, running analytics, defending against legal claims, preventing fraud and abuse, or promoting our products in a proportionate way).
  3. Legal obligations: Where we must process Personal Information to comply with laws and regulations, such as financial crime, sanctions, tax, or accounting rules, or to respond to lawful requests from public and governmental authorities.
  4. Consent: Where we ask for your consent to process Personal Information for a specific purpose (for example, certain types of direct marketing or placing non-essential cookies on your device). When we rely on consent, you can withdraw it at any time as described in this Policy, without affecting the lawfulness of processing based on consent before its withdrawal.

Your rights. Subject to certain limitations and exemptions under International Data Protection Laws, you may have the right to request access to your Personal Information, to request correction or updating of inaccurate Personal Information, to request deletion or erasure of your Personal Information, to request that we restrict certain processing, to object to certain processing (including profiling based on legitimate interests), and to request portability of your Personal Information. You also have the right to lodge a complaint with your local data-protection authority.

To exercise these rights, please contact us using the methods described in the How to Contact Us section below. We may need to verify your identity before responding to your request, and our ability to fulfill your request may be limited by applicable law and our technical capabilities.

14. SAFEGUARDING THE INFORMATION WE COLLECT

We use reasonable technical, administrative, and physical safeguards designed to protect your Personal Information against accidental loss and unauthorized access, use, alteration, and disclosure. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee 100% security.

You are responsible for safeguarding your own information through the proper use and security of any credentials (for example, usernames and passwords) used to access the Services. If you believe your credentials or account have been compromised, please change your password immediately and notify us as soon as possible.

15. CHANGES TO THIS POLICY

This Policy describes our current policies and practices with regard to the information we collect through the Services. We are continually improving and adding to the features and functionality of the Services, and to the products and services we offer. If we make any changes to this Policy, we will post the revised Policy on this page and update the “Last updated” date at the top.

You can access this Policy from any of our sites or platforms where it is linked (usually in the footer or “Privacy” section). Your continued use of the Services after we make changes is deemed to be acceptance of those changes.

16. HOW TO CONTACT US

We value your opinions and welcome your feedback. If you have any questions or comments about this Policy, our privacy practices, or your Personal Information, or if you wish to exercise your rights, you can contact us here.