Privacy Policy

1. GENERAL

1.1 At [ADEN] (“we,” “our,” “us”), we value the privacy of our users and are dedicated to protecting your personal information. This Privacy Policy (the “Policy”) is designed to help you understand how we collect, use, and disclose your data.

1.2 We provide a non-custodial technical interface only and do not operate, control, or execute blockchain transactions. This Policy applies solely to Personal Data processed by us in connection with the operation of the Interface and the Sites, and does not apply to data processed directly by decentralized protocols or blockchain networks.

1.3 This Policy applies to your use of our websites, associated Application Programming Interfaces (“APIs”), mobile applications, and any related software, forums, blogs, social media pages, and other platforms operated or maintained by us (collectively, the “Sites”), as well as all services made available through the Sites (the “Services”). Before accessing or using our Sites or Services, you must read this Policy carefully.

1.4 All natural persons or other entities who access our Sites and/or use our Services shall be considered users. For the convenience of wording, users are referred to as “you” or any other applicable second-person pronouns. You and we are collectively referred to as the “Parties” and individually as a “Party”.

1.5 Unless otherwise defined herein, all capitalized terms used shall have the same meanings ascribed to them in the User Agreement.

2. PURPOSE OF THIS POLICY

This Policy explains the types of data we may collect when you connect your wallet to, access, or use our Sites and Services. This includes information you provide, information we obtain from third parties, and information collected automatically. Such data, which identifies a natural person or relates to an identifiable natural person, is referred to as “Personal Data”.

3. YOUR CONSENT

To ensure you have full confidence in our handling of your Personal Data, you are advised to read and understand the terms of this Policy in detail. By accessing our Sites, you signify your acceptance, understanding, and confirmation of the following:

• (a) You agree, voluntarily and with your requisite consent, to disclose your Personal Data to us;

• (b) You will comply with all terms and conditions of this Policy;

• (c) You consent to our collection of your information through your access to the Sites and/or your use of the Services;

• (d) You acknowledge that this Policy may be updated from time to time, and that continued access to or use of the Sites or Services following publication of an updated Policy constitutes acceptance of such updates;

• (e) You agree that our affiliates and employees may contact you regarding products and Services that we reasonably believe may be of interest to you (unless you have indicated in writing that you do not wish to receive such information).

4. INFORMATION WE COLLECT

We collect, process, and store Personal Data through your use of the Services or where you have given your consent. We may actively or automatically collect, use, store, or transfer your Personal Data, which may include the following categories:

• (a) Transaction and Wallet Information: Information related to transactions you conduct on the Sites, including but not limited to public blockchain data and wallet addresses.

• (b) Service information: Information we automatically collect when you use our Services, including but not limited to your IP address, browser type and version, device information, and other usage data related to your interaction with our Sites.

• (c) Correspondence information: Information provided during your communications with us or our customer support team, or through your responses to surveys.

• (d) Other information: When you use the Sites or Services, we may collect additional necessary information from our designated mailboxes or in other manners compliant with relevant requirements. This may be for the purpose of improving the functions of the Sites, enhancing your user experience and security, or as required by a court order, applicable law, administrative regulation, or order from a competent government authority.

• (e) Third-Party websites: If you visit any third-party websites, pages, or content accessible through links on our Sites, you must agree to and comply with the separate and independent privacy policies of such third parties. This Policy does not apply to third-party websites, and we bear no liability for their content and activities.

5. HOW WE USE PERSONAL DATA

We will use the Personal Data we collect for the following purposes:

• (a) To provide and maintain Services: To provide you with our Services pursuant to our User Agreement.

• (b) To improve and enhance Services: To improve our Services and the functionality of our Sites, using your feedback to respond more effectively to your inquiries and needs.

• (c) To maintain Security: To maintain the security of the Sites, and to detect, prevent, and address fraud, security breaches, and other harmful activities.

• (d) To personalize your experience: To better understand how users’ access and use the Sites in order to personalize and improve your experience.

• (e) To support User-initiated Transactions To support your use of the Interface in initiating interactions with smart contracts and blockchain networks, including displaying transaction-related information associated with your wallet address. We do not execute, settle, clear, or control any transactions.

• (f) For communication and marketing (if applicable): To communicate with you about your activities, and policy changes, and to carry out product marketing, including newsletters and updates (you may opt out of marketing communications at any time).

• (g) For legal and regulatory compliance: To comply with applicable laws, regulations, and orders issued by competent authorities, including but not limited to requests from judicial authorities in various jurisdictions for information related to specific wallet addresses.

• (h) To enforce our rights: To enforce and/or defend our rights, agreements, and policies.

• (i) For other business purposes: To carry out other purposes specified in the User Agreement or other reasonably expected business purposes as permitted by applicable law.

6. DISCLOSURE OF PERSONAL DATA

We do not sell, trade, or otherwise transfer your Personal Data to outside parties for marketing or advertising purposes. However, you agree that we may disclose and transfer your Personal Data in the following circumstances (If applicable):

• (a) To our Affiliates: To our subsidiaries, parent companies, and companies under common control, including their respective contractors and representatives.

• (b) To Service Providers: To trusted third-party service providers who assist us in operating our Sites, managing our business, or providing Services to you, provided that such parties agree to keep this information confidential. This may include third-party data and service providers used to analyze publicly available on-chain data for security, risk monitoring, and fraud detection purposes related to wallet addresses, without providing such service providers with control over user assets or transaction execution.

• (c) To Professional Advisors: To our professional advisors, such as legal counsel, accountants, and auditors, for purposes of complying with our legal obligations or for audits.

• (d) In Connection with Corporate Transactions: To entities involved in any merger, acquisition, due diligence, reorganization, receivership, or sale of all or a portion of our business or assets.

• (e) For Legal Compliance and Protection: When we believe disclosure is necessary or appropriate to comply with any applicable law, regulation, subpoena, court order, or request from law enforcement or other competent authorities; to enforce our policies; or to protect the rights, property, or safety of us or others.

• (f) With Your Consent: For any other purpose disclosed by us when you provide the information, or with your explicit consent.

7. INTERNATIONAL TRANSFERS OF PERSONAL DATA

Data we collect from you may be transferred to, and stored at, servers outside of your jurisdiction of residence. You consent that your Personal Data may be transferred to such jurisdictions for the purposes described in this Policy, in accordance with applicable data protection laws for the purpose of providing the Services to you, even if such jurisdictions have a lower level of data protection than your own. We will take all reasonably necessary steps, including implementing appropriate contractual safeguards , to ensure that your Personal Data is treated securely and in accordance with this Policy and applicable data protection laws.

8. COOKIE POLICY

8.1 Cookies are small text files and/or identifiers that are placed in your device browsers when you visit a website. Cookies store information about the user’s visit, which may include browsing history, preferences, time and duration of each visit and advertisement accessed for facilitation and enhancement of the user’s experience.

8.2 Cookies are classified into two categories, namely session cookies and persistent cookies. Session cookies exist only during an online session on our Sites and these cookies will disappear once the browser is closed. We use session cookies to allow our systems to identify you uniquely during a session or while you are interacting with the Sites. Persistent cookies are added when you start to browse our Sites or interact with a specific feature but may remain stored on your device after you have closed your browser. We use persistent cookies to track statistical and aggregate information about your activity. Please note that we do not respond to or honor Do Not Track signals or similar mechanisms transmitted by browsers.

8.3 We may use cookies and similar tracking technologies to record general usage patterns, preferences, and interactions of visitors accessing the Sites and Interface. The information collected through such technologies is generally aggregated or anonymized and does not, by itself, identify you as an individual. Where such information constitutes Personal Data under applicable law, it will be processed in accordance with this Policy. We use cookies and similar technologies to operate and improve our Sites, enhance functionality and user experience, perform usage analytics, and detect irregular or suspicious activities for security and risk-management purposes, including to help identify potential compromise of wallet interactions. Some cookies, web beacons and other tracking and storage technologies may be provided by third-party service providers that assist us with website analytics, performance measurement, and security monitoring. We do not use cookies or similar technologies to access, control, or compromise your wallet, private keys, or Digital Assets, and we do not use such technologies for behavioral advertising or targeted marketing unless expressly stated otherwise.

8.4 Most browsers are designed to accept cookies automatically. You may restrict the placement of cookies on your devices or remove them by adjusting your preferences as your browser or device permits. However, if you set your browser to disable cookies, it is possible that you may not be able to access and/or use certain functions of our Sites and/or Services.

9. PROTECTION OF PERSONAL DATA

9.1 We implement appropriate physical, electronic, administrative, and technical measures to protect and safeguard the security of your Personal Data. These measures include, but are not limited to: using encrypted storage for electronic data with strict access controls, enforcing need-to-know access for authorized employees subject to confidentiality obligations, and using encryption techniques like Secure Socket Layer (SSL) and firewalls.

9.2 Despite these measures, no system is 100% secure. We cannot guarantee that information transmitted via the Sites is absolutely secure. To the fullest extent permitted by applicable law, we shall not be held liable for any loss or damage arising from any unauthorized access to your Personal Data.

9.3 If you become aware of any security flaw in our Sites, please contact us immediately so that we can take appropriate remedial action as soon as possible.

10. DATA RETENTION

10.1 We retain Personal Data only for as long as is reasonably necessary to fulfill the purposes for which it was collected, including to provide the Services, comply with legal, accounting, or reporting requirements, pursue legitimate business purposes, enforce our agreements, and resolve disputes.

10.2 To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, and applicable legal requirements. In some circumstances, we may anonymize your Personal Data so that it can no longer be associated with you, in which case we may use such information indefinitely without further notice.

10.3 At the end of the retention period, we will securely delete or destroy the retained data and require our sub-processors or service providers to do likewise.

11. YOUR RIGHTS

11.1 Under applicable data protection laws, you have certain rights regarding the Personal Data we hold about you. To the extent permitted by law, and depending on your jurisdiction, these rights may include the following:

• (a) Right of Access: The right to obtain confirmation as to whether we process your Personal Data and to access that data.

• (b) Right to Rectification: The right to have inaccurate or incomplete Personal Data corrected.

• (c) Right to Erasure (Deletion): The right to request the deletion of your Personal Data, subject to our legal obligations to retain certain data. You acknowledge that certain data, including public blockchain data, cannot be deleted or altered due to the immutable nature of blockchain technology, and that we may be unable to comply with deletion or modification requests relating to such data.

• (d) Right to Restrict Processing and Right to Object: The right to object to or request the restriction of our processing of your Personal Data under certain circumstances.

• (e) Right to Withdraw Consent: Where processing is based on your consent, the right to withdraw that consent at any time. This will not affect the lawfulness of processing conducted before your withdrawal.

• (f) Right to Data Portability: The right to receive your Personal Data in a structured, commonly used, and machine-readable format and to request its transmission to another controller.

• (g) Right to Lodge a Complaint: The right to lodge a complaint with the competent data protection authority in your jurisdiction if you have a concern about our processing of your Personal Data.

11.2 How to Exercise Your Rights:

To exercise any of these rights, please contact us. We will assess all requests and provide a timely response in accordance with applicable law. To fulfill our security obligations and prevent unauthorized data disclosure, we may ask you to verify your ownership of the relevant information, for example, by signing a message with the private key associated with your wallet address or by verifying control of an email address you used to contact us.

11.3 Limitations and Our Response:

Please note that the rights listed above are not absolute and may be subject to limitations under applicable law. We may have legitimate legal reasons to refuse your request, such as for the establishment, exercise, or defense of legal claims, or where we are legally required to retain your data. If we deny your request, we will inform you of the reason. A reasonable administrative fee may be charged for requests that are clearly unfounded, repetitive, or excessive.

12 MINORS

12.1 Our Sites and Services are not directed to persons under the age of 18 or who may be defined as minors under applicable laws. If you are a minor, please terminate all access to our Sites and Services immediately. We do not knowingly collect Personal Data from minors.

12.2 To clarify, we do not knowingly collect Personal Data from minors, however, through the internet, we are unable to ascertain on our end whether such individuals are minors. It is thus the responsibility of parents or guardians to ensure that their minors do not access or use our Sites and/or Services, enroll for any of our events, download or access our related applications, email us, or provide us with Personal Data. If a parent or guardian becomes aware that their minor has accessed our Sites or provided us with Personal Data, please contact us promptly so we can take appropriate action.

13. MODIFICATION TO THE POLICY

We reserve the right to amend this Policy from time to time in our sole discretion. We will inform you of any modifications by updating and publishing the revised version on the Sites. You should review this Policy regularly. Your continued access to or use of the Sites and/or Services after such changes constitutes your acknowledgment and acceptance of the amended Policy.

14. CONTACT US

14.1 If you have any questions regarding this Policy or our processing of Personal Data, you may contact us through the communication channels made available on the Sites from time to time. All official announcements and information relating to this Policy will be published on the Sites. We shall not be responsible for communications made through unofficial channels

14.2 All official announcements and information regarding our Policy will be published on the Sites. We shall not be held liable for any losses arising from your reliance on information obtained through channels other than our designated email or the Sites.

15. LANGUAGE

This Policy may be published in different languages. In the event of any discrepancy between different language versions, the English version shall prevail.