Privacy Policy

Last Revised on May 7th, 2023

This Privacy Policy for Prime Protocol Inc. (“Company”, “we”, “us” “our”) describes how we collect, use and disclose information about users of the Company’s websites (https://www.primeprotocol.xyz/ and https://app.primeprotocol.xyz/), the Company’s cross-chain decentralized finance protocol, and any other applications, services, tools and features offered by the Company (collectively, the “Services”). For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Services.

Please read this Privacy Policy carefully. By using, accessing, or downloading any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use, access or download any of the Services.

1. UPDATING THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date at the top of this Privacy Policy. If we make material changes [A1] to the way in which we use information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Services, or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Policy please do not access or continue to use the Services.

2. COMPANY’S COLLECTION AND USE OF INFORMATION

When you access or use the Services, we may collect certain categories of information about you from a variety of sources.

Some features of the Services may require you to directly enter certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Services may include:

• The following third-party wallet (“Wallet”) information: public wallet address and token IDs that you own. We collect third-party Wallet information in order to facilitate your use of the Services.

• Any other information you choose to include in communications with us, for example, when sending a message through the Services.

We also automatically collect certain information about your interaction with the Services (“Usage Data”). To do this, we may use cookies, web beacons/clear gifs and other tracking technologies. (“Tracking Technologies”). Usage Data may include:

• Unique device identifier

• Device type, such as your phone, computer, or tablet

• IP address

• Browser type

• Date and time stamps, such as the date and time you first accessed the Services

• Operating system

• Log data

• Other information regarding your interaction with the Services, such as clickstream data[A4]

We use the information we collect automatically to tailor features and run analytics and better understand user interaction with the Services.

In addition to the foregoing, we may use any of the above information to comply with any applicable legal obligations, to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

3. HOW THE COMPANY SHARES YOUR INFORMATION

In certain circumstances, the Company may share your information with third parties for legitimate purposes subject to this Privacy Policy.Such circumstances may include:

• With vendors or other service providers, such as

  • Know-your-customer and other identity verification service providers

  • Blockchain analysis service providers

  • Data analytics vendors

  • Cloud storage providers

  • IT service management vendors

  • Email marketing services vendors

  • Security vendors

• With our affiliates or otherwise within our corporate group

• To comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries

• In connection with an asset sale, merger, bankruptcy, or other business transaction

• To enforce any applicable terms of service and investigate any potential violation thereof

• To protect the rights, safety and security of the Company, its users, a third party or the public as required or permitted by law

• To detect, prevent or otherwise address security, fraud or technical issues

• When you request us to share certain information with third parties, such as through your use of social media widgets or login integrations

• With professional advisors, such as auditors, law firms, or accounting firms

4. COOKIES AND OTHER TRACKING TECHNOLOGIES

Do Not Track Signals

Your browser settings may allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our website is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/.

Cookies and Other Tracking Technologies

Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including any portal features and general functionality, to work incorrectly.

To opt out of tracking by Google Analytics, click here

If you have questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.

5. THIRD PARTY WEBSITES AND LINKS

We may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of these sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms (such as Facebook or Twitter) may also be viewable by other users of the Services and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.

6. THIRD PARTY WALLET EXTENSIONS

Certain transactions conducted via our Services will require you to connect a Wallet to the Services. By using such Wallet to conduct such transactions via the Services, you acknowledge that any collection, use and/or disclosure of your personal information in connection with your interactions with such third party Wallets are governed by the privacy policy for the applicable Wallet.

7. CHILDREN’S PRIVACY

We do not seek or knowingly collect any personal information about children under 13 years of age. If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database. If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.

8. DATA SECURITY

Please be aware that, despite our reasonable efforts to protect your information, no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” Please further note that any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us.

9. HOW TO CONTACT US

Should you have any questions about our privacy practices or this Privacy Policy, please contact us at [e-mail] and/or ‪[phone]‬.

10. EUROPEAN USERS

If you are located in the European Union (“EU”) or United Kingdom (“UK”):

• Data Controller. The Company is the data controller.

• Lawful Basis of Processing. We process Wallet information in order to provide you with the Services. We process information you choose to include in communications with us because it is in our legitimate interest to run a successful business and be responsive to you as a user. We process Usage Data and Tracking Data because it is in our legitimate interest to run a successful business and to improve, protect and tailor our Services. We collect certain contact information with your consent for marketing purposes.

• Data Transfers. The personal data that we collect from you will be transferred to, and stored at/processed in countries outside the EU and UK. Your personal data is also processed by staff operating outside the EU and the UK who work for us or one of our third party service providers or partners. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy. For any transfers of data outside the EU or the UK, the data transfer will be under the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses) or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined by the European Commission or the relevant UK authorities, as applicable, to provide an adequate level of protection for individuals’ rights and freedoms for their personal data. Please contact us should you wish to examine a copy of these clauses.

• Retention. We will retain and use your personal data to the extent necessary to comply with our legal obligations, resolve disputes and enforce our terms of service. If you stop using our Services, we will store your information in an aggregated and anonymized format; we may use this information indefinitely without further notice to you.

• Rights. You have certain rights in relation to your personal data. Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. To exercise any of these rights, you can email [e-mail]:

  • Access. You have the right to access personal data we hold about you.

  • Portability. You have the right to receive a copy of the personal data we hold about you and to request that we transfer it to a third party, in certain circumstances.

  • Correction. You have the right to correct any of your personal data we hold that is inaccurate.

  • Erasure. In certain circumstances, you have the right to delete the personal data we hold about you.

  • Restriction of processing to storage only. You have the right to require us to stop processing the personal data we hold about you, other than for storage purposes, in certain circumstances.

  • Objection. You have the right to object to our processing of your personal data.

  • Objection to or withdrawal of consent for marketing. You can object to marketing at any time by opting-out using the unsubscribe/ opt-out function displayed in our communications to you.

  • Complaints. You have the right to complain to your local data protection authority about how we process your personal data. Of course, we hope you will contact us first at [e-mail] so we can resolve any issues.