This Privacy Policy (this “Policy”) explains the data that Polyshares, Inc. and its affiliates (“Polyshares,” “Company,” “we,” “us,” or “our”) may collect, use, and share in connection with our website at polyshares.com (including any subdomains and sub-pages), and all of our other properties, products, tools, features, and services (collectively, the “Services”). Your use of the Services is subject to this Policy as well as our Terms of Use.

If you do not agree with any part of this Policy or the Terms of Use, do not access or use any of the Services. By using the Services, you consent to all actions we take concerning your information in compliance with this Policy.

1. DATA WE MAY COLLECT

1.1 Information You Provide.

• Contact Information: Your email address, social media usernames (such as Twitter/X, Telegram, or Discord), and other contact details.
• Wallet and Account Information: Blockchain wallet addresses, public keys, and app preferences.
• Transaction Information: Details about purchases, swaps, transfers, and other transactions you make through the Services, whether on-chain or otherwise.
• Marketing Information: Your preferences for receiving marketing communications and details about how you engage with them.
• Form and Survey Responses: Information you provide in surveys, questionnaires, feedback forms, or other forms.
• Communications and Correspondence: Messages, information, notes, transcripts, and recordings from communications you have with us via email, customer support, social media, or other channels.
• User Contributions: Information that you provide, at your own risk, to be published or transmitted to other users or third parties. We cannot control others' actions regarding your contributions and do not guarantee they will not be viewed by unauthorized persons.
• Job Applications: If you apply for a position, we collect information you provide through our application process, including notes from future rounds.
• Other Information: Any other information not specifically listed here, which we will use as described in this Policy or as otherwise disclosed at the time of collection.

1.2 Information Collected Automatically.

• Usage Details: Total time spent on the Services, time per page, navigation paths, pages visited, links clicked, features used, referring websites, and general geographic location.
• Performance and Technical Data: Page load times, CPU/memory usage, network request logs, error logs, and performance metrics.
• Device and Connection Information: Your IP address, operating system, browser type and version, device identifiers, mobile device ID, and network connection details.

We may use cookies, local storage, device identifiers, mobile device IDs, web beacons, pixels, and similar tracking technologies to collect some of the above data automatically.

2. HOW WE MAY USE DATA

We may use information that we collect from or about you, including any personal information, for the following purposes:

• Providing the Services: Maintaining, customizing, and improving our Services and features.
• Customer Support: Offering support and answering inquiries about the Services.
• Safety and Security: Ensuring safety by addressing risks and preventing fraudulent or illegal activities.
• Aggregated Data and Analytics: Compiling aggregated, anonymized, or de-identified data to learn about usage patterns, improve the user experience, and for any other business purpose.
• Communication and Marketing: Managing our relationship with you, communicating about the Services, and marketing our Services, including adding you to our newsletter mailing list.
• Legal Compliance: Complying with laws, regulations, and requests from government entities or law enforcement.
• Enforcement: Carrying out our obligations and enforcing our rights under our Terms of Use.
• Interactive Features: Enabling participation in interactive features through our Services.
• Service Development and Research: Facilitating ongoing development, research, and improvement of our Services and new products.
• Internal Business Operations: We reserve the right to use collected data for any legitimate internal business purpose, including but not limited to operational analysis, strategic planning, internal research, product optimization, training, benchmarking, financial analysis, and any other purpose that advances our business interests.
• Data Monetization: We may use aggregated, anonymized, or de-identified data derived from your information for any commercial purpose, including sharing with third parties, without restriction. Such data does not identify you personally.
• Other Purposes: Using the information in any other way we may describe when you provide it, or for any other purpose with your consent or as permitted by applicable law.

3. HOW WE SHARE DATA

We may share or disclose the data we collect from or about you, including any personal information, for the following purposes:

• With Service Providers: Sharing your information with service providers, vendors, contractors, and partners to assist us in providing, delivering, improving, and marketing the Services.
• Legal Obligations: Disclosing your data in the course of litigation, regulatory proceedings, compliance measures, and when compelled by subpoena, court order, or other legal procedures, and to comply with anti-money laundering, counter-terrorism financing, or other regulatory obligations.
• Safety, Security, and Enforcement: Sharing data to protect against, investigate, and stop fraudulent, unauthorized, or illegal activity, enforce agreements, and protect the rights, property, or safety of our users, Company, and ecosystem.
• Business Transactions: Transferring or sharing data to another entity in the event of a merger, acquisition, bankruptcy, dissolution, reorganization, asset or stock sale, or other business transaction.
• To a Buyer or Successor: Disclosing personal information to a buyer or successor in the event of a transfer of some or all of our assets.
• Affiliates and Related Entities: Sharing data with our affiliates, subsidiaries, parent companies, and related entities for any purpose consistent with this Policy.
• Aggregated and De-Identified Data: Sharing aggregated, anonymized, or de-identified data with any third party for any purpose without restriction, as such data does not personally identify you.
• With Your Consent or at Your Direction: Sharing your information for any other purpose disclosed by us when you provide the information, or for any purpose with your consent.

We do not sell your identifiable personal information to third parties for direct monetary compensation. However, we reserve the right to share information as described above, which may constitute a 'sale' or 'share' under certain privacy laws. To the extent applicable law requires notice or consent for such sharing, your continued use of the Services constitutes such consent.

4. THIRD-PARTY SERVICES AND TECHNOLOGIES

The Services may integrate or interact with technologies operated or controlled by third parties, including blockchain networks (such as Solana), wallet providers, decentralized exchanges, liquidity protocols, analytics platforms, hosting services, and other external tools. When you interact with these third parties, they may independently collect information about you, use cookies or similar technologies, serve you advertisements, and apply their own terms and privacy practices. We do not control, endorse, or assume responsibility for any third-party privacy practices, security, or content.

We encourage you to review the privacy policies of any third-party services before engaging with them. We are not responsible for any loss, damage, or liability arising from your use of third-party services.

5. PRIVACY AND THE BLOCKCHAIN

Blockchain networks are inherently transparent and publicly accessible. Information stored on-chain, including wallet addresses, transaction history, and asset holdings, may be publicly visible, immutable, and permanently recorded. Your wallet address and associated data can potentially be correlated with your identity by any party, including law enforcement, both now and in the future.

Polyshares cannot modify, delete, restrict access to, or control information recorded on a public blockchain. Such data is beyond our technical control. By using the Services, you acknowledge and accept the inherent transparency of blockchain technology.

6. DATA SECURITY

We implement and maintain reasonable administrative, physical, and technical safeguards to help protect data from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet is not completely secure, and we cannot guarantee the security of information about you. You are responsible for all of your activity on the Services, including the security of your blockchain network addresses, wallets, and cryptographic keys. We are not responsible for circumvention of any privacy settings or security measures on the Services.

WE MAKE NO REPRESENTATIONS OR WARRANTIES REGARDING THE SECURITY OF YOUR DATA. YOU ACKNOWLEDGE THAT NO SYSTEM IS ENTIRELY IMMUNE FROM SECURITY THREATS AND YOU ASSUME ALL RISKS ASSOCIATED WITH TRANSMITTING INFORMATION OVER THE INTERNET AND INTERACTING WITH BLOCKCHAIN-BASED SYSTEMS. YOU HEREBY RELEASE AND HOLD HARMLESS THE COMPANY AND ITS OFFICERS, DIRECTORS, EMPLOYEES, AND AFFILIATES FROM ANY DAMAGES, LOSSES, CLAIMS, OR LIABILITY ARISING FROM ANY SECURITY INCIDENT, DATA BREACH, UNAUTHORIZED ACCESS, OR LOSS OF DATA, REGARDLESS OF CAUSE.

7. DATA BREACH

In the event of a security incident resulting in unauthorized access, disclosure, or loss of personal information, Polyshares will take reasonable steps to investigate. Where required by applicable law, we will notify affected users and relevant authorities within prescribed timeframes. However, we do not guarantee that all breaches will be detected or that notification will be provided in every instance. Our sole obligation in the event of a data breach is limited to notification where legally required, and we expressly disclaim any additional liability, responsibility, or obligation arising from or related to any data breach or security incident.

8. DATA RETENTION

We retain your information for as long as we deem reasonably necessary or useful for any purpose, including to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, prevent fraud, enforce our agreements, protect our interests, and for any other legitimate business purpose. We may retain data indefinitely at our sole discretion. Retention periods may vary depending on the type of data and our operational or legal requirements.

9. DATA DELETION REQUESTS

If you would like to request the deletion of your personal information from our internal databases, please contact us at official@polyshares.com. We will review your request and process it in accordance with applicable law. Please note:

• (a) We may retain any data that we are required or permitted to retain by law, or that we determine is necessary for legitimate business purposes including fraud prevention, dispute resolution, regulatory compliance, enforcement of our agreements, internal record-keeping, and protection of our legal rights.
• (b) Information recorded on a public blockchain is beyond our ability to modify, edit, or delete.
• (c) Aggregated, anonymized, or de-identified data may be retained and used indefinitely without restriction.
• (d) We are under no obligation to delete data that has been shared with third parties prior to your request, and we bear no responsibility for data held by third parties.
• (e) Deletion requests may take up to ninety (90) days to process, and certain data may persist in backup systems for a reasonable period thereafter.

10. CONSENT TO DATA USE

BY USING THE SERVICES, YOU EXPRESSLY CONSENT TO THE COLLECTION, USE, PROCESSING, STORAGE, TRANSFER, AND DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS POLICY, INCLUDING FOR PURPOSES NOT YET CONTEMPLATED AT THE TIME OF COLLECTION. YOU ACKNOWLEDGE THAT POLYSHARES MAY USE YOUR DATA IN WAYS NOT SPECIFICALLY DESCRIBED IN THIS POLICY IF SUCH USE IS CONSISTENT WITH THE PURPOSE FOR WHICH THE DATA WAS COLLECTED OR AS OTHERWISE PERMITTED BY APPLICABLE LAW.

You acknowledge that you have no expectation of privacy with respect to any information you submit to or through the Services, except as expressly stated in this Policy. You waive any claims against the Company arising from the use of your information as described herein.

11. LIMITATION OF LIABILITY FOR DATA PRACTICES

TO THE FULLEST EXTENT PERMITTED BY LAW, THE COMPANY AND ITS AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, AND AGENTS SHALL NOT BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES ARISING FROM OR RELATED TO: (I) THE COLLECTION, USE, DISCLOSURE, OR PROCESSING OF YOUR DATA; (II) ANY UNAUTHORIZED ACCESS TO OR BREACH OF YOUR PERSONAL INFORMATION; (III) ANY INACCURACY, ERROR, OR OMISSION IN THIS POLICY; (IV) ANY THIRD PARTY'S USE OF YOUR DATA; OR (V) ANY OTHER DATA PRACTICE DESCRIBED OR CONTEMPLATED BY THIS POLICY. IN NO EVENT SHALL OUR AGGREGATE LIABILITY EXCEED ONE HUNDRED U.S. DOLLARS ($100.00).

12. AGE RESTRICTION

The Services are intended for individuals at least twenty-one (21) years of age. We do not knowingly collect personal information from anyone under twenty-one. If you are under twenty-one, do not use the Services or provide any personal information. If we learn that we have collected information from someone under twenty-one, we will take steps to delete it. Contact us at official@polyshares.com if you believe a minor has provided us with personal information.

13. NOTICE TO EUROPEAN UNION RESIDENTS (GDPR)

If you are located in the EU or EEA, the GDPR provides you with specific rights regarding your personal data. We may process your data on the following bases: (i) your consent; (ii) performance of a contract; (iii) compliance with a legal obligation; or (iv) our legitimate interests. Under the GDPR, you may: (a) request access to and a copy of your data; (b) request correction or erasure; (c) object to or restrict processing; (d) request data portability; and (e) withdraw consent at any time. We cannot modify or erase data stored on a public blockchain. To exercise GDPR rights, contact us at official@polyshares.com. We may retain information as necessary for legitimate interests, legal obligations, dispute resolution, fraud prevention, and agreement enforcement.

14. NOTICE TO CALIFORNIA RESIDENTS (CCPA)

If you are a California resident, the CCPA affords you certain rights. We do not sell identifiable personal information for direct monetary compensation as defined under the CCPA. You may request information about categories of data collected, purposes of collection, and categories of third parties with whom data is shared. You may request deletion of your personal information, subject to legal exceptions. We will not discriminate against you for exercising your rights. Submit requests to official@polyshares.com. We may verify your identity before processing. You may designate an authorized agent with written authorization.

15. INTERNATIONAL DATA TRANSFERS

Your information may be transferred to, stored, and processed in the United States and other jurisdictions where our service providers or affiliates operate. These jurisdictions may have different data protection laws than your jurisdiction. By using the Services, you consent to the transfer of your information to jurisdictions that may not provide the same level of data protection as your home jurisdiction.

16. CHANGES TO THIS POLICY

If we make changes, we will update the Last Updated date above. For material changes, we may notify you via the Services. Your continued use of the Services after any modification constitutes your acceptance. We are not obligated to provide individual notice of changes. You are responsible for periodically reviewing this Policy.

We cannot guarantee that this Policy is always error-free, current, or comprehensive. We disclaim any liability for errors, omissions, or inaccuracies, and shall not be held responsible for any consequences resulting from reliance on information herein.

17. INDEMNIFICATION

YOU AGREE TO INDEMNIFY, DEFEND, AND HOLD HARMLESS THE COMPANY AND ITS OFFICERS, DIRECTORS, EMPLOYEES, AFFILIATES, AND AGENTS FROM AND AGAINST ANY AND ALL CLAIMS, DEMANDS, LIABILITIES, DAMAGES, LOSSES, AND EXPENSES ARISING FROM OR RELATED TO YOUR PROVISION OF DATA, YOUR USE OF THE SERVICES, OR ANY BREACH OF THIS POLICY BY YOU.

18. CONTACT US

If you have questions about this Policy or how we handle your information, please contact us at:

official@polyshares.com

Polyshares, Inc.