PRIVACY POLICY

This Privacy Policy (the “Privacy Policy”) applies to your use of any websites, applications, or services provided, owned, or operated by Veranta Labs, Inc and Veranta Protocol Foundation (collectively, “Veranta”), as applicable, that link to this Privacy Policy. Veranta values your privacy and that of other users (“Users”), and wants you to be familiar with how it collects, uses, and discloses personal information from and about you. By visiting Veranta's website and disclosing personal information, you are accepting the practices described in this Privacy Policy, to the extent permitted by law.

For purposes of data protection laws, Veranta Foundation, with a registered office at Leeward Management Limited of Suite 3119, 9 Forum Lane, Camana Bay, PO Box 144, George Town, Grand Cayman KY1-9006, Cayman Islands, is the “data controller” or the “business” with respect to your information collected in connection with Veranta's services.

You may share personal information when using the Veranta website. One example is when you provide information about yourself through a link on the Veranta website. All information provided by you, including information about User activity such as, but not limited to, your IP address, may be collected and used for things like keeping your information secure and providing you information about Veranta's services. Veranta encourages you to be mindful of this when considering your activity on the Veranta Website.

Information about you

Veranta obtains information about you through the means discussed below. Please note that Veranta needs certain types of information so that it can provide services to you. If you do not provide Veranta with such information, or ask Veranta to delete it, you may no longer be able to use Veranta services.

User Provided Information: You may provide a variety of information about yourself to Veranta, such as your email address and digital asset wallet address. If you decline to share certain information with Veranta, Veranta may not be able to provide to you certain services. For requests to review, update, delete, or otherwise limit Veranta's use of information that you have provided directly to Veranta, you may contact [email protected]. In your request, please include your email address and name, and specify all relevant information about your request. To protect your privacy and security, Veranta may take steps to verify your identity before granting you access or making corrections to your information.

Automatically Collected Information: When you access Veranta, Veranta may automatically records and stores certain information about your system by using cookies and other types of technologies, such as your IP address, device and browser types and identifiers, referring and exit page addresses, software and system type, and information about your usage of Veranta.

Use of personal information: Veranta uses your information to operate, maintain, enhance, provide, create, and develop all of the features, functionality, and services (new or existing) found on Veranta; provide security for its website, software, and applications; manage relationships with Users; improve Users' experience on Veranta; prevent fraud and abuse; and understand the usage trends of Users like you.

In certain cases, Veranta may have a legal obligation to collect and process your personal information (such as an obligation to share data with law authorities). Veranta will rely on legal grounds to process your personal information to the extent permitted by applicable law, which may include, without limitation: to honor contractual commitments, to take steps in anticipation of entering into contracts, to fulfill legal obligations, with your consent, and for Veranta's legitimate interests.

Veranta may share certain information with service providers working on Veranta's behalf, such as, to: provide website hosting, maintenance, and security services; conduct data analysis and create reports; offer certain functionality; or assist Veranta in improving Veranta platforms and creating new services and features. Veranta requires that these parties process such information in compliance with this Privacy Policy, and Veranta authorizes them to use the information only for the purposes for which it is provided to them. Veranta also requires them to use reasonable confidentiality measures.

Veranta may disclose User information if Veranta believes, in good faith, that such disclosure is necessary to comply with applicable laws, or respond to a court order, judicial or other government request, subpoena, or warrant in the manner legally required. Veranta also reserves the right to disclose information that Veranta believes, in good faith, is appropriate or necessary to protect Veranta from potential liability or from fraudulent, abusive, or unlawful uses; investigate and defend Veranta against third-party claims, or allegations; protect the security or integrity of Veranta; or protect the rights, property, or safety of Veranta, Veranta Users, or others. Other than as set out in this Privacy Policy, you will receive notice when personal information about you might be shared with third parties and you will have an opportunity to choose not to share the information.

Non-personal information: Veranta shares or discloses non-personal data, such as aggregated information like the total number of Users or the number of Users who clicked on a particular link (even if only one did).

Global operations and privacy: As a website Veranta operates globally. Where the laws of your country allow you to do so, you authorize Veranta to transfer, store, and use your data In any country determined by Veranta in which Veranta conducts business. In some of the countries to which Veranta transfers personal data, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those of your country.

Residents of the European Economic Area, the United Kingdom, and residents of Brazil can exercise certain data subject rights available to them under applicable data protection laws. Veranta will comply with requests to exercise these rights in accordance with applicable law. If these rights apply to you, they may permit you to request that Veranta:

• Obtain access to or a copy of certain personal information Veranta holds about you
• Prevent the processing of your personal information for direct marketing purposes (including any direct marketing processing based on profiling)
• Update personal information that is out of date or incorrect
• Delete certain personal information Veranta holds about you
• Restrict the way that Veranta processes and discloses specific personal information about you
• Transfer your personal information to a third-party provider of services
• Revoke consent that you previously provided for the processing of your personal information

When you exercise these rights and submit a request to Veranta, Veranta will verify your identity by asking you for information such as your email address or telephone number. Veranta also may use a third-party verification provider to verify your identity.

Your exercise of these rights will have no adverse effect on the price and quality of Veranta goods or services.

For the 12-month period prior to the date of this Privacy Policy, Veranta has not sold any personal information about you; nor does it have any plans to do so in the future.

Veranta systems do not recognize Do Not Track (DNT) signals from browsers. DNT is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. However, many third-party services that collect this type of information permit you to opt out through a separate system. To learn more about this behavioral advertising practice or to opt-out of this type of advertising from participating third parties' providers, you can visit networkadvertising.org.

Retention of your information: Veranta maintains data related to your usage of Veranta for as long as it is required in order to fulfill the relevant purposes described in this Privacy Policy, as may be required (or permitted) by law such as for tax and accounting purposes, or as otherwise communicated to you. Once you have asked Veranta to delete your data, all information that is not required or permitted to be retained by law will be deleted.

Third-Party services and websites: Veranta may link to third-party websites or services. The privacy practices of those third parties are not governed by this Privacy Policy. Veranta encourages you to review the privacy policies of these third-party websites and services to understand their practices.

Analytics providers: Veranta may use third-party Web analytics services in connection with Veranta. These service providers use a variety of tracking technologies such as cookies to analyze how Users use Veranta. The information collected may be shared with or collected directly by these services and processed to evaluate your use of Veranta. Veranta may also work with third-party ad networks, advertisers, and advertising analytics providers to target (and measure the performance of) ads to you both on and off Veranta. Veranta may share with these third parties (or they may directly collect) data such as cookie and mobile ad identifiers in order to engage in advertising activity (including to understand how you respond to advertisements and to serve relevant ads). This Privacy Policy does not apply to, and Veranta cannot control the tracking technologies and activities of these third-party advertisers or analytics providers, and you should consult their respective privacy policies.

Data security: Veranta uses various measures to protect the integrity and security of your information. These measures may vary based on the sensitivity of your information. However, no security precautions or systems can be completely secure, and therefore Veranta cannot ensure or warrant the security of any information you transmit to it. You do so at your own risk.

Children's privacy: If you are under 13 years of age, you may not use or access Veranta at any time or in any manner. Veranta is not available to persons under the age of 13. If you are between the ages of 13 and the age of legal majority in your jurisdiction of residence, you may only use a Veranta website under the supervision of a parent or legal guardian who agrees to be bound by this Privacy Policy. If Veranta learns that personal information of persons under 13 has been collected on or through Veranta, Veranta will take appropriate steps to delete this information. If you are the parent or legal guardian of a child under 18 who has become a Veranta User, then please contact Veranta at [email protected] to have that child's account terminated and personal information deleted.

Merger or sale: In the event that Veranta, or some or all assets related to Veranta are acquired by or merged with a third-party entity or in connection with a contemplated change of ownership transaction, Veranta reserves the right, in any of these circumstances, to transfer or assign the information collected from Users as part of that merger, acquisition, sale, or other change of control event, including in the course of diligence.

International data transfers: Information collected by Veranta may be stored and processed in your region or in any other country where Veranta or its affiliates, subsidiaries, partners, or service providers are located or maintain facilities. If Veranta provides any information about you to any such entities, Veranta will take appropriate measures to ensure such companies protect your information adequately in accordance with this Privacy Policy and applicable law.

Changes and updates to this Privacy Policy: Veranta reserves the right to change, modify, add, or remove portions of this Privacy Policy at any time. Please check this Privacy Policy periodically for those changes. Your continued use of Veranta after the posting of changes constitutes your binding acceptance of such changes.

Veranta contact information: Please contact Veranta with any questions or comments about this Privacy Policy at [email protected].