Privacy Policy

Last Modified: January 19, 2024

This website is owned and operated by Project 76. We respect your privacy and understand that you have a right to know why we collect your personal information and what we do with it. This Privacy Policy applies to information we collect through our Website (as defined below) as well as information we may collect offline.

This policy describes the type of information we collect from you and/or that you may provide us when you visit and/or use this or related websites, any of our mobile applications, and any related services (individually or collectively, "Website"). "You/your/user(s)" means you as a user of our Website.

By accessing the Website, you acknowledge this Privacy Policy and agree to be bound by the terms hereof, the Website Terms and Conditions, and any other terms or policies we post on the Website. If there is anything you do not understand, please email any inquiry to support@project76.com. If at any time you do not agree to this Privacy Policy, please do not use the Website or provide us with any Personal Information.

We reserve the right to change or update this Privacy Policy by posting such changes or updates to the Website or emailing you notice of the changes. Amendments to this Privacy Policy will be posted at this URL and will be effective when posted. You can tell if this Privacy Policy has changed by checking the last modified date that appears at the end of this Privacy Policy. Your continued use of the Website following the posting of any amendment, modification or change shall constitute your acceptance thereof.

YOUR SECURITY

We strive to keep your Personal Information private and safe. We take commercially reasonable physical, electronic and administrative steps to maintain the security of Personal Information collected, including limiting the number of people who have physical access to database servers, as well as employing electronic security systems and password protections that guard against unauthorized access.

Unfortunately, despite our best efforts, the transmission of data over the Internet cannot be guaranteed to be 100% secure. While we will use reasonable means to ensure the security of information you transmit through the Website, any transmission of Personal Information is at your own risk.

BLOCKCHAIN AND WALLET INTERACTIONS

When you interact with our Website through a Web3 wallet:

• Your public wallet address becomes visible to us and is collected as part of your Personal Information

• Transaction data on public blockchains is visible to anyone and we are not responsible for protecting such public information

• We do not collect or store your private keys or seed phrases

• Smart contract interactions are executed on public blockchains and are not private

• We may collect information about your wallet balance and transaction history that is publicly available on the blockchain

Please note that blockchain transactions are irreversible and public. Exercise caution when connecting your wallet or conducting transactions.

INFORMATION WE COLLECT

We collect various information that identifies you as a person ("Personal Information") in two ways. First, we collect Personal Information that you provide to us. Second, we collect certain Automated Information that may contain Personal Information when you use our Website.

Personal Information You Provide to Us

The Personal Information you provide to us includes, by way of example:

• Contact details including email, wallet address, and other contact information

• Login and account information

• Personal preferences including marketing preferences

• Interaction history with our Website

• Any transaction information related to website features

• Communication preferences and responses

We collect Personal Information directly from you when you:

• Connect your wallet

• Sign up for our email list

• Send us an email or other communication

• Register for an account with us

• Participate in our community activities, surveys, and/or contests

We may also collect additional information, which may be Personal Information, as otherwise described to you at the point of collection or pursuant to your consent.

Automated Information

We also may collect information through automated means when you visit our Website ("Automated Information") such as:

• The IP address of the device you use to connect to the internet (which may include information about your geographic location)

• The unique identifiers of your device

• Your browser characteristics

• Your device characteristics

• Your operating system

• Your language preferences

• The websites you visited before coming to our Website or through which you were referred to our Website

• Information on actions taken by you on our Website

• Dates and times of your visits to our Website

• The pages you accessed on our Website

HOW WE USE YOUR PERSONAL INFORMATION

We do not engage in automated decision making. We may use Personal Information (including information that has been de-identified and/or aggregated) to better understand who uses the Website and how we can deliver a better user experience. Most commonly we will use your Personal Information in circumstances such as:

• To enable wallet connections and blockchain interactions

• To provide Website functionality and features

• To communicate with you about Website updates and community activities

• To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity

• Where you have asked us to do so, or consented to us doing so

• Where we need to comply with a legal or regulatory obligation

By providing your email and checking a box, clicking the "complete" button, or some other affirmative act, you are consenting to receive emails at that address.

SHARING PERSONAL INFORMATION WITH THIRD PARTIES

We are committed to maintaining your trust and we want you to understand when and with whom we may share Personal Information and other information collected about you. We do not share your Personal Information with any third parties except as set forth herein.

We do not sell your Personal Information to third parties. We may share your Personal Information with our affiliates or other parties for their direct marketing purposes. We may also disclose your Personal Information to third parties that help us bring you the products and services we offer and to create, operate, and maintain our Website. For example, we may work with third parties to:

• Manage customer information

• Assist with direct marketing and data collection

• Provide data storage and analysis

• Provide fraud prevention

• Provide customer service

• Assist with blockchain analytics and wallet services

• Provide other services designed to assist us in developing and running our Website

If we seek investors or go through a business transition, including but not limited to, a merger, acquisition by another company, or a sale of all or a portion of our assets, your Personal Information may be shared as part of the negotiation of the transaction and will likely be among the assets transferred.

TARGETED ADVERTISING AND REMARKETING

You may see advertisements for our products/services on other websites and mobile applications because we work with third party advertisers to engage in remarketing and retargeting activities. Through our relationships with these advertisers, we can target messaging to our users by interest-based, demographic, contextual, and other means. These third party advertisers track your online activities over time and across websites and mobile applications by collecting information through automated means, including through the use of third-party cookies, web server logs, and web beacons. They use this information to show you advertisements that may be tailored to your individual interests. The information our advertising partners may collect includes data about your visits to websites and mobile applications that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites or apps. This data collection takes place both on our Websites and on third-party websites and mobile applications that participate in the advertising networks. This process also helps us track the effectiveness of our marketing efforts.

OTHER WEBSITES

Our Website may contain links or references to websites operated by third parties, or you may have come to our Website using a link found in another website. This does not mean that we endorse these websites or the goods or services they provide. We do not make any representations or warranties about any website that may be linked to the Website. Such other websites are independent from us, and we have no control over, or responsibility for, their information, products or activities. Our privacy practices may differ from those of these other websites. If you provide Personal Information at one of these third party websites, you are subject to the privacy policy of the operator of that website, not our Privacy Policy. Please make sure you understand the other website's privacy policy before providing such website with any Personal Information.

YOUR CHOICES ABOUT HOW WE USE YOUR INFORMATION AND OPTING OUT

You can choose whether or not to provide Personal Information through the Website. We will not discriminate against you for exercising any of your rights relating to your Personal Information and will not (i) deny you goods or services, (ii) provide you with a different level or quality of services, or (iii) charge you different prices for services for doing so.

Tracking Tools

We may use the tools outlined below in order to provide the Website or our services, advertise to, and better understand users.

Cookies: "Cookies" are small computer files transferred to your device that contain information such as user ID, user preferences, lists of pages visited and activities conducted while using the Website. We use Cookies to improve and tailor the Website, customize advertisements, measure performance, store authentication so re-entering credentials is not required, customize user experiences, and for analytics and fraud prevention. For more information on Cookies, including how to control your Cookie settings and preferences, visit http://www.allaboutCookies.org.

Web Beacons: "Web Beacons" (a.k.a. clear GIFs or pixel tags) are tiny graphic image files embedded in a web page or email that may be used to collect information about the use of the Website. The information collected by Web Beacons allows us to analyze how many people are using the Website, using selected publishers' websites or opening emails, and for what purpose.

Web Service Analytics: We may use third-party analytics services in connection with the Website, including, for example, to register mouse clicks, mouse movements, scrolling activity and text typed into the Website. We use the information collected from these services to help make the Website easier to use and as otherwise set forth herein.

Mobile Device Identifiers: As with other Tracking Tools, mobile device identifiers help us learn more about our users' demographics and Internet behaviors in order to personalize and improve the Website. Mobile device identifiers are data stored on mobile devices that may track activities occurring on and through it, as well as the applications installed on it.

Additional Analytics Information

Our Website may use Google Analytics, a web analysis service of Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, www.google.com ("Google Analytics" or "Google"). Google Analytics employs cookies that are stored to your computer in order to facilitate an analysis of your use of the site. The information generated by these cookies, such as time, place and frequency of your visits to our Website, including your IP address, is transmitted to Google's location in the US and stored there.

Google may also transfer this information to third parties where required to do so by law or where such third parties process this data on Google's behalf. Google states that it will never associate your IP address with other data held by Google. You can prevent cookies from being installed by adjusting the settings on your browser software accordingly as noted elsewhere in this Privacy Policy. You should be aware, however, that by doing so you may not be able to make full use of all the functions of our Website.

For more information about Google Analytics' IP anonymization and opt-out features, please visit:

https://support.google.com/analytics/answer/2763052?hl=en

https://tools.google.com/dlpage/gaoptout?hl=en

INFORMATION PROVIDED ON BEHALF OF CHILDREN AND OTHERS

We do not knowingly permit persons under 18 years of age to use the Website, and we do not knowingly collect, use or disclose Personal Information from anyone under 18 years of age. If we determine upon collection of Personal Information that a user is under 18 years old, we will not use or maintain his/her Personal Information without the parent/guardian's consent. If we become aware that we have unknowingly collected Personal Information from a child under the age of 18, we will make reasonable efforts to delete such information from our records.

NOTICE TO CALIFORNIA CONSUMERS

The following applies to you only if you are a California resident.

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of Personal Information we share with third parties or corporate affiliates for those third parties or corporate affiliates' direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. At this time, we do not share any Personal Information with third parties or affiliates for their direct marketing purposes.

We do not use or disclose sensitive personal information for purposes other than those specified in the CCPA/CPRA.

Your Rights

If you are a California resident you may have the following rights under the CCPA/CPRA in relation to Personal Information we have collected about you, to the extent required by the CCPA/CPRA and subject to verification:

• Right to Know/Access

• Right to Delete

• Freedom from Discrimination

• Right to Correct

• Right to Restrict the Use of Sensitive Personal Information

• Right to Access Information on Automated Decision-Making

To make a request in relation to the above rights, please contact us using the contact information provided below.

DISPUTES

In any action arising out of or relating to this Privacy Policy, the laws of the State of Colorado shall be applied, without regard to choice of law.

CONTACT

If you have any questions about your privacy or security at the Website, or wish to update your Personal Information, please send an email to founders@project76.io