Privacy Policy

This website-hosted user interface (this "Interface") is made available by NT Labs Limited, a corporation organized and existing under the laws of the British Virgin Islands (the "Company" "us" "we" or "our").

This Privacy Policy (the "Policy") governs the manner in which we make the Interface available and how we collect, use, maintain and disclose information collected from our users (each, a "user", "you", or "your") through the Company's websites, including Hashmarket, the Interface, web applications, mobile applications and all associated sites linked thereto by the Interface, or by us or our affiliates (the "Site"). This Policy further applies to all information we collect through our Site and otherwise obtain in connection with products and Services, content, features, technologies, functions and all related websites we may provide to you or to which we may provide access (collectively with the Site, the "Services").

Please read this Policy carefully. We strive to describe our practices consistently with this Policy, but nothing herein creates warranties, guarantees of a particular security outcome, or duties beyond those required by applicable law.

Privacy-related questions: support@hashmarket.app.

Our Terms of Service ("Terms") govern all use of our Services and, together with the Privacy Policy, constitute your agreement with us (the "Agreement"). If you do not agree with the terms of this Policy, please do not access our Site.

By accessing or using our Services, you agree to the terms of this Policy. Specifically, by (i) using, visiting, or accessing the Services, (ii) using, accessing, establishing an account through or purchasing any of the Services, and/or (iii) clicking "accept", "agree", or "OK" (or a similar term) with respect to any of our Terms or similar policies, you consent and agree to be legally bound by each of the terms and conditions contained in this Policy.

In operating the Site and providing the Services we may collect (and/or receive) certain information about you and your activities. You hereby authorize us to collect and/or receive such information to operate the Site and provide the Services, subject to Applicable Law.

This Policy applies to all information we collect from you in connection with the Site and offering the Services. This Policy does not apply to information collected by us offline or through any other means, including on any other website made available by us or by any third party (including our affiliates and subsidiaries), or to data solely processed on public blockchains or by wallet providers outside our control.

Throughout this Policy, we use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been aggregated and/or anonymized so that it does not identify a specific user. Personal information may also include the personal information of third parties that may be contained in information you provide to us through your use of the Site.

When you visit the Site and use the Services, we collect your IP address and standard web log information, such as your browser type and pages you accessed on our Site. We may also collect certain geolocation information (as defined below). If you do not agree to our collection of this information, you may not be able to use the Services.

We collect information:

• Directly from you when you provide it to us;
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies; and
• In certain instances, from third parties, such as our business partners, third-party providers (e.g., MetaMask) or other networks where you have connected your account and authorized the Site to access this information. We do not control and are not responsible for the privacy practices of your wallet provider.

If you create an account with us, we may collect the following information from you:

Personal information. Information by which you may be personally identified, such as your name, postal address, registration at place of residence, e-mail address, telephone number, date of birth, and other demographic information, such as your age, gender, hometown, and interests that you voluntarily provide to us as part of your registration with the Site to use our Service (collectively, "Personal Information"). There is no obligation for you to provide us with personal information of any kind, but your refusal to do so may prevent you from using the Services.

Derivative information. Information our servers may collect automatically when you access the Site, such as your IP address, browser type, operating system, access times, and pages you viewed directly before and after accessing the Site. This may also include other information about your internet connection and the equipment you use to access our Site, and usage details.

Financial information. If applicable to your use of the Site and the Services, in order for us to process payments of any fees owed to us in connection with your use of the Services and the Site, you may be required to provide certain bank account online login information, bank account and routing numbers, credit card information (e.g., card brand, expiration date, and credit-card numbers) and other data related to your payment method. You authorize our third-party payment vendors and wallet providers (e.g., MetaMask) to collect, process, and store your financial information in accordance with their respective privacy policies.

Mobile device information. If you access the Site from a mobile device we may obtain information automatically about you from your mobile device such as your device type, mobile device identification number, geolocation information, time zone, language setting, browser type. If you provide it directly to us, we may also collect your telephone number.

Geolocation information. We collect information that identifies, with reasonable specificity, your location by using certain longitude and latitude coordinates obtained through GPS, Wi-Fi, cell-site triangulation, or other locational data. We may collect this data for fraud prevention and risk management purposes, among other reasons.

Correspondence and recordkeeping. We will retain records and copies of your correspondence (including e-mail addresses), if you contact us. We retain personal information only for as long as necessary to provide the Services or to comply with applicable legal obligations.

Surveys. If you decide to participate in surveys available via the Services, you may be asked to provide certain information which may include personal information. We may store such responses.

We may require additional information from you (including for instance government-issued identity documents such as passport number, driver's license details or national identity card details) that we can use to verify your identity, address or other information, prevent fraud or to manage risk and compliance throughout our relationship, where permitted by law.

Finally, we may collect additional information from or about you in other ways not specifically described here. For example, we may collect information related to your contact with our customer support team.

Our Site is not intended for users under twenty-one (21) years of age, in line with the Hashmarket Terms. No one under 21 may provide any personal information to or on the Site. If we obtain actual knowledge that we have collected personal information from a person under 21, we will promptly delete it, unless we are legally obligated to retain such data. If you believe we may have mistakenly or unintentionally collected any information from or about a person under 21, please contact us at support@hashmarket.app.

A cookie is a small file placed on the hard drive of your computer. When you visit our Site, use our Services, we and certain business partners and vendors may use cookies and other tracking technologies (collectively, "Cookies"). We use Cookies to recognize you as a customer, to customize the Services, other content and advertising, to measure the effectiveness of our promotions, to perform a wide range of analytics, to mitigate risk and prevent potential fraud, and to promote trust and safety across our Services.

Most browsers are set to accept cookies by default. You can remove or reject cookies. However, certain Services are only available through the use of Cookies. Therefore, if you choose to disable or decline Cookies, your use of the Services may be limited or not possible.

Pages of our Site may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser's settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.

Do Not Track. Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not respond to DNT signals.

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Site to:

• Administer sweepstakes, promotions, and contests;
• Compare information for accuracy and verify it with third parties;
• Compile anonymous statistical data and analysis for our use internally or with third parties;
• Contact you regarding your account with us, use of the Site and Services, and questions regarding the Services;
• Create and manage your account, including a personal profile about you to make future visits to our Site and your use more personalized;
• Customize, personalize, measure, and improve our Services and the content and layout of our Services;
• Deliver the Services and provide customer support to you;
• Enable user-to-user communications;
• Enhance the efficiency and operation of the Site and the Services we deliver to you for our legitimate interests including: detecting security incidents; protecting against malicious, deceptive, fraudulent or illegal activity; measuring interest and engagement; undertaking research for technological development; researching and developing products and services; improving or enhancing our Services; ensuring internal quality control; verifying your identity and preventing fraud; debugging; enforcing our terms and policies; and complying with our legal obligations, protecting your vital interest, or as may be required for the public good;
• Fulfill any other purpose for which you may provide us with your information;
• Improve the security of the Site and, if you share geolocation information, provide you with location-specific options, functionality, offers, advertising, search results, or other location-specific content;
• Monitor and analyze usage and trends to improve your experience with the Services;
• Notify you of updates to the Services;
• Perform such other duties as may be required by law;
• Prevent potentially fraudulent, prohibited or illegal activities, and enforce our Terms through the use of our risk and fraud tools;
• Process transactions (including payments and refunds) and send notices about your transactions or your network activity;
• Provide and improve the Services;
• Provide targeted advertising, coupons, newsletters, and other promotional information regarding the Services;
• Request feedback, resolve disputes, collect fees, and troubleshoot problems; and
• Respond to your inquiries or fulfill requests and provide customer services.

We may use information we collect about you to fulfill any other purpose for which you may provide us with your information. We may also use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

You also authorize us to use and/or share information as described below:

• We may, from time to time, share your information with other companies, who may provide you information about the products and services they or their partners offer. You may be entitled to prevent us from sharing and/or licensing your personal information to other companies under applicable law. If you wish to exercise this right, please send an e-mail to support@hashmarket.app with the subject line, "Privacy Policy." We reserve the right to ask for information verifying your identity before we begin complying with your request.
• We will access, use, and share your information as required to fulfill our contractual obligations to you, provide you with support, and to address your questions or requests regarding our Services;
• We may employ other companies and individuals to perform functions on our behalf. Examples may include providing technical, customer services and marketing assistance. In particular, we use third-party cloud hosting providers to store user information and configurations;
• We may analyze your information in anonymized and/or aggregate form in order to operate, maintain, manage, and improve the Services. This anonymous information does not identify you personally. We may use this anonymous information and share it with our affiliates, agents, business and promotional partners, and other third parties;
• We may share some or all of your information with any of our parent companies, affiliates, subsidiaries, joint ventures, or other companies under common control with us;
• As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, liquidation, or bankruptcy or similar event, your information may be part of the transferred assets; and
• To the extent permitted by law, we may also disclose your information: (i) in response to lawful requests by public authorities, including for national security or law enforcement requirements, (ii) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (iii) whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of us or others.

If we intend to use your information in any manner that is not consistent with this Policy, you will be informed of such anticipated use prior to or at the time at which information is collected.

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. We strive to ensure security on our systems and use administrative, technical, and other physical security measures to help protect your personal information. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our safeguards. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

We do not collect, store, or have access to your private keys, seed phrases, or non-custodial wallet credentials. You are solely responsible for managing and securing your wallet.

We may share your information with our business partners to offer you certain products, services, and promotions. We may also use third-party advertising companies to serve ads when you visit the Site. These companies may use information about your visits to the Site and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

Some information is public information (this may include your web3-enabled wallet's public address, username, profile photo, profile first and last name, month, and year of account creation, and public transactions in which you've been involved), and may be seen by anyone on the Internet due to the nature of the blockchain, whether or not they have an account with us. Public information may also be seen, accessed, reshared or downloaded through APIs, SDKs, or third-party services that integrate with our products.

We may share your personal information with:

• Law enforcement, government officials, or other third parties if we are compelled to do so by a subpoena, court order or similar legal procedure, when it is necessary to comply with law, or where the disclosure is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the Terms, or as otherwise required by law;
• Third-party service providers who assist us in providing the Services to you or who provide fraud detection or similar services on our or any vendor's behalf;
• Other third parties with your consent or at your direction, including if you authorize an account connection with a third-party account or platform. An "account connection" is a connection you authorize or enable between your account and a payment instrument or platform that you lawfully control or own. When you authorize such a connection, we may exchange your personal information and other information directly with such third-party. If you connect your account to other financial accounts, we may have access to your account balance and transactional information. Information we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party's privacy practices—review their notice before authorizing.

We will not disclose your credit card number or bank account number to anyone except with your express, written permission or if we are required to do so to comply with a subpoena or other legal process.

We do not send your personal information to third-party social networks unless you have specifically requested or authorized us to do so.

Transactions on public blockchains are inherently transparent; any information linked to your wallet address, including transaction history, may become publicly available and is outside our control.

The Services may contain links to (or allow you to link to) unaffiliated third-party services, applications, or websites. We do not control information collection of any third-party services, applications, or websites that can be reached through such links. Any information you provide to any third party is not covered by this Policy and we cannot guarantee the safety and privacy of your information.

Third parties may use cookies or other tracking technologies to collect information about you when you use our Services. We do not control these third parties' tracking technologies or how they may be used.

We may use third-party analytics (such as Google Analytics) to evaluate your use of the Services, compile reports on activity and events, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Services, and mobile and Internet usage. These third parties use cookies, pixel tags, and other related tracking technologies to help analyze and provide us the data.

By visiting and using the Services, you consent, to the extent permitted under applicable law, to the processing of data about you by these analytics in the manner and for the purposes set out in this Privacy Policy.

For Google Analytics: https://www.google.com/analytics. Google privacy: https://policies.google.com/privacy?hl=en. Safeguarding data: https://support.google.com/analytics/answer/6004245.

We may also use third-party retargeting services to advertise on third-party websites to previous visitors to our Services. For Google Ads preferences: https://adssettings.google.com/authenticated.

To the extent you have registered for the Services, you may access, review, make changes to, and delete your personal information by following the instructions found on the Site or by sending an e-mail to us at support@hashmarket.app with the subject line, "Privacy Policy." We reserve the right to ask for information verifying your identity before we begin complying with a request.

You may manage marketing communications by clicking "Unsubscribe" in marketing e-mails, or by emailing us at support@hashmarket.app with the subject line, "Unsubscribe from Marketing." Registered users cannot opt out of receiving transactional or administrative e-mails related to their account.

Your personal information may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. By using the Services, you consent to the transfer of your information outside of your country of residence. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.

We will take steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy, subject to applicable law.

Depending on applicable law where you reside, you may be able to assert certain rights related to your personal information. Your rights are not absolute; we may deny requests where required or permitted by law. We may ask you to verify your identity before responding.

• Access / deletion. Email support@hashmarket.app to request a copy of or deletion of personal information in our databases, subject to legal exceptions.
• Correction. Subject line: "Correction or Rectification".
• Object. Subject line: "Object to Processing".
• Restrict processing. Subject line: "Restrict Processing".
• Portability. Subject line: "Portability / Personal Information".
• Withdraw consent. Subject line: "WITHDRAW CONSENT".
• Erasure. Subject line: "Erasure / Personal Data Deletion".

If you are located in the European Economic Area, the UK, Switzerland or Brazil you may have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

Upon your request we will endeavor to: (i) return all personal information processed in connection with the Services to you in a structured, commonly used, and machine-readable format, and will delete existing copies and backups; or, (ii) destroy and delete all personal information processed in connection with the Services, including materials or media containing such personal information, and including all copies and backups, subject to legal retention requirements.

We may update this Policy at any time. When we do, we will revise the updated date at the top of this page. We encourage users to frequently check this page for any changes. Your continued use of the Site following the posting of changes will be deemed your acceptance of those changes where permitted by law. If you do not agree to this Privacy Policy, please do not use our Site.

The Services, including the Site, are made available by us from the BVI and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the BVI, except as required by mandatory applicable law.