Privacy Policy
Effective as of [November 14 2024].
This Privacy Policy describes how FirstMate Labs, Inc. (“FirstMate,” "we", “us” or "our) processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, mobile application and social media pages) as well as our marketing activities, live events and other activities described in this Privacy Policy (collectively, the “Service”). FirstMate may provide additional or supplemental privacy notices to individuals for specific products or services that we offer at the time we collect personal information.
Index
Personal information we collect
Information you provide to us or that we generate about you. Personal information you may provide to us through the Service or otherwise includes:
Third-party sources. We may combine personal information we receive from or about you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

• Public sources, such as blockchains, government agencies, public records, social media platforms, public blockchains, and other publicly available sources.
  Service providers. We may combine personal information we receive from or about you with personal information we receive from service providers that provide services on our behalf or help us operate the Service or our business.
  Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
  For more information concerning our automatic collection of data, please see the Tracking technologies section below.
  Tracking Technologies
  Cookies and other technologies. Some of the automatic collection described above is facilitated by the following technologies:
  How we use your personal information
  Service delivery and operations. We may use your personal information to:
  Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services. [For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.]
  Marketing. We, our service providers and our marketing partners may collect and use your personal information for marketing and advertising purposes. For example, we may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
  Compliance and protection. We may use your personal information to:
  Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.
  To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you and we will not attempt to reidentify any such data. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
  Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:
  Retention. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
  How we share your personal information
  Your choices
  Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.
  Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
  Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.
  Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
  Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
  Linked third-party platforms. If you choose to connect to the Service through or with a third-party platform or service, you may be able to use your settings in your account with that platform or service to limit the information we receive from it. If you revoke our ability to access information from a third-party platform or service, that choice will not apply to information that we have already received from that third party. Other sites and services
  The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
  Security
  We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
  International data transfer
  We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
  Children
  The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
  Changes to this Privacy Policy
  We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.
  How to contact us
  Additional information for California residents
  To [privacy@holdsensible.com], California residents may send us requests for information regarding to whom we have disclosed certain personal information (as defined under the Shine the Light, Cal. Civ. Code Section 1798.83) during the preceding calendar year for their own direct marketing purposes and the categories of personal information disclosed. In your request, you must include the statement “Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
  Personal information we collect
  Information you provide to us or that we generate about you. Personal information you may provide to us through the Service or otherwise includes:

• Contact data, such as your first and last name, salutation, email address, and mailing addresses.

• Profile data,** **such as the wallet address and username and password that you may set to establish an online account on the Service.

• Communications data based on our exchanges with you, including when you contact us through the Service or otherwise.

• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.

• Blockchain transaction data, such as information relating to or needed to complete your transactions on or through the Service, including wallet address, trading activity, deposits, withdrawals, account balances, token holdings, transaction number, transaction sender and recipient, transaction amount, and transaction history.

• Financial data, such as your virtual currency or wallet account balances and other associated information.

• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
  Third-party sources. We may combine personal information we receive from or about you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

• Public sources, such as blockchains, government agencies, public records, social media platforms, public blockchains, and other publicly available sources.

• Data providers,** **such as information services and data licensors.

• Partners or linked third-party services, such as marketing partners and third parties with which we integrate or otherwise connect in order to provide the Service, such as Privy, Coinbase and third-party blockchains and other services. If you link or connect the Service with another third-party service, we may receive data such as Blockchain transaction data and Financial data and other information associated with your account on that third-party service. Please refer to the relevant partner or linked third-party services operator for their relevant privacy practices.
  Service providers. We may combine personal information we receive from or about you with personal information we receive from service providers that provide services on our behalf or help us operate the Service or our business.
  Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data,** **such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.

• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

• Communication interaction data such** as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
  For more information concerning our automatic collection of data, please see the Tracking technologies** section below.
  Data about others. We may offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.
  Tracking Technologies
  Cookies and other technologies. Some of the automatic collection described above is facilitated by the following technologies:

• Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.

• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.

• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

• Software development kits. An SDK is third-party computer code that may be used for a variety of purposes, including to provide us with analytics regarding the use of Service, to integrate with third-party platforms, and to add features or functionality to the Service.
  
  For information concerning your choices with respect to the use of tracking technologies, see the Your choices section, below.
  
  How we use your personal information
  We may use your personal information for the following purposes or as otherwise described at the time of collection:
  Service delivery and operations. We may use your personal information to:

• provide the Service and operate our business;

• enable security features of the Service;

• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;

• communicate with you about events or contests in which you participate; and

• provide support for the Service, and respond to your requests, questions and feedback.
  Service personalization, which may include using your personal information to:

• understand your needs and interests;

• personalize your experience with the Service and our Service-related communications; and

• remember your selections and preferences as you navigate webpages.
  Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services. [For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.]
  Marketing. We, our service providers and our marketing partners may collect and use your personal information for marketing and advertising purposes. For example, we may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.**
  Compliance and protection. **We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;

• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);

• audit our internal processes for compliance with legal and contractual requirements or our internal policies;

• enforce the terms and conditions that govern the Service; and

• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
  Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.
  To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you and we will not attempt to reidentify any such data. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business. **
  Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies** described above for the following purposes:

• Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.

• Functionality. To enhance the performance and functionality of our services.

• Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. [For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.]
  
  Further uses. In some cases, we may use your personal information for further uses, in which case we will ask for your consent to use of your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.
  
  Retention. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
  How we share your personal information
  We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.
  Affiliates. As applicable, our corporate parent, subsidiaries, and affiliates.
  Service providers. Third parties** that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).
  Third parties designated by you and linked third-party services. We may share your personal information with third parties where you have instructed us or provided your consent to do so such as the relevant blockchains and third parties with which we integrate or otherwise connect in order to provide the Service, such as Privy, Coinbase and other services. These third parties’ use of the shared information may be governed by their own privacy policies and/or the settings associated with any third-party account you link to or integrate with the Service.
  Partners. Third parties with whom we partner, including parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you. Our partners’ use of the shared information may be governed by their own privacy policies.
  Professional advisors.** Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
  Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
  Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in or financings of FirstMate, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of FirstMate as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
  Other users and the public. Due to the nature of blockchain technologies, any data posted to a blockchain will be visible to other users of the Service and the public. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.
  Your choices
  In this section, we describe the rights and choices available to all users.
  Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.
  Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
  Cookies and other technologies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.You can also configure your device to prevent images from loading to prevent web beacons from functioning.
  Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.
  Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
  Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
  Linked third-party platforms. If you choose to connect to the Service through or with a third-party platform or service, you may be able to use your settings in your account with that platform or service to limit the information we receive from it. If you revoke our ability to access information from a third-party platform or service, that choice will not apply to information that we have already received from that third party. Other sites and services
  The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
  Security
  We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
  International data transfer
  We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
  Children
  The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
  Changes to this Privacy Policy
  We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.
  How to contact us

• Email: [privacy@holdsensible.com]
  Additional information for California residents
  To [privacy@holdsensible.com], California residents may send us requests for information regarding to whom we have disclosed certain personal information (as defined under the Shine the Light, Cal. Civ. Code Section 1798.83) during the preceding calendar year for their own direct marketing purposes and the categories of personal information disclosed. In your request, you must include the statement “Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.