Privacy Policy

This Privacy Notice ("Notice") explains how World Liberty Financial, Inc., a Delaware corporation with registration 4943581 (collectively, "World Liberty," "we," "us") collects and uses your Personal Information and how we keep it secure. By accessing or using our various websites and services including this website (collectively the "Website"), you agree to the terms of this Notice and all of the terms incorporated herein by reference. Any privacy-related questions or complaints should be directed to [email protected].

By using the Website and/or submitting or collecting any Personal Information via the Website, you accept and expressly consent and agree to our practices surrounding the collection, use, and sharing of your Personal Information in accordance with this Privacy Notice. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY NOTICE, WE RECOMMEND YOU NOT ACCESS OUR WEBSITE.

Depending on how you interact with us and where you are located, we may process Personal Information from or about you. "Personal Information" for purposes of this Notice means by way of example and not of limitation such information as your name, address, e-mail address, or telephone number. To the extent applicable, we will process Personal Information consistent with applicable privacy laws including but not limited to the California Consumer Privacy Act (as amended "CCPA"), the EU General Data Protection Regulation ("GDPR"), the UK General Data Protection Regulation ("UK GDPR"), and the Canadian Personal Information Protection and Electronic Documents Act ("PIPEDA").

Please review this Notice carefully to understand what we do in regards to your Personal Information and:

• If you are a California resident, please review Additional Disclosures for California Residents for additional disclosures, our notice at collection and a description of your rights under the CCPA.
• If your Personal Information is subject to the GDPR or UK GDPR, please review Additional Disclosures for Data Subjects in the European Economic Area and the United Kingdom.

1. Information Collection

A. Information You Provide

We may collect the following Personal Information about you when you use the Website or through our services:

• Correspondence and Content. Within any messages you send to us (such as feedback and questions to information support), we may collect your name, email address, wallet address, and other contact information you provide to us as well as any other content included in the message.
• Other Information. You may choose to voluntarily provide other Personal Information to us that we have not solicited from you and in such instances, you are solely responsible for such information.

B. Information Collected Automatically

We may collect the following Personal Information automatically through your interactions with our Website:

• Wallet Address. We may collect the wallet address you use to connect to the Website to block wallets that are associated with certain legally prohibited conduct from the Website. Separately, we may collect your wallet address as part of "Usage Information" (as described below) to improve the Website and user experience of the Website.
• Device Information. We may collect information about the device you use to access the Website such as the device type, operating system, browser type, and screen height and width. This information helps us optimize the Website for different devices and troubleshoot any technical issues.
• Usage Information. We may collect information about how you use the Website including your wallet address, the time you access the Website, pages you visit, the features and assets you interact with, the links you click, and the search queries you make. By analyzing this data, we gain a deeper understanding of user behavior which in turn allows us to make continuous improvements to the Website and enhance the overall user experience.

We may collect this information through cookies and similar tracking technologies. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our "Cookies Policy" below.

C. Information Collected from Other Sources

Our service providers or other third parties that we partner with may collect certain Personal Information from or about you, including certain identifiers (e.g., driver's license number or passport number), names, and requests. Depending on how you interact with us, we may receive some of this information.

2. Use of Information

We may collect and use Personal Information for business purposes in accordance with the practices described in this Notice. Our business purposes for collecting and using information include:

• Provide Our Services and Communicate with You. We use the Personal Information we have about you to provide our services and communicate with you, including responding to inquiries and providing notices.
• Operating and managing the Website (including through authorized service providers). To make the site available to you and perform Website actions requested by you such as responding to your comments, questions, and requests and providing information support; sending you technical notices, updates, security alerts, information regarding changes to our policies and support administrative messages; detecting, preventing, and addressing fraud, breach of terms, and threats or harm; and compliance with legal and regulatory requirements.
• Improving the Website. To continually improve the Website and fulfill any other legitimate business purpose as permitted under applicable laws.
• Merger or Acquisition. In connection with or during negotiations of any proposed or actual merger, purchase, sale, or any other type of acquisition, financing, reorganization, or business combination of all or any portion of our assets or transfer of all or a portion of our business to another business.
• Security and Compliance with Laws. As we believe necessary or appropriate to operate and maintain the security or integrity of the Website, including to prevent or stop an attack on our computer systems or networks, investigate possible wrongdoing in connection with the use of the Website, enforce our terms, and comply with applicable laws, lawful requests, and legal processes such as responding to subpoenas or requests from government authorities.
• Facilitating Requests. To comply with your requests or directions.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.

3. Sharing and Disclosure of Information

We may share or disclose information that we collect in accordance with the practices described in this Notice and for the purposes set out in the "Use of Information" section above. The categories of parties with whom we may share information include:

• Affiliates. We share Personal Information with our affiliates and related entities, including where they act as our service providers or for their own internal purposes.
• Professional Advisors. We share Personal Information with our professional advisors for purposes of audits and compliance with our legal obligations.
• Service Providers. We share Personal Information with third-party service providers for business purposes including fraud detection and prevention, security threat detection, data analytics, information technology and storage, and blockchain transaction monitoring. Any Personal Information shared with such service providers is subject to the terms of this Notice. All service providers that we engage with are restricted to only utilizing the information on our behalf and in accordance with our instructions.

Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law.

4. Third-Party Websites

We may also integrate technologies operated or controlled by other parties into parts of the Website. For example, the Website may include links that hyperlink to websites, platforms, and other interfaces or services not operated or controlled by us.

Please note that when you interact with other parties, including when you leave the Website, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their website and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

For example, by using a third-party wallet to engage in transactions on public blockchains, your interactions with any third-party wallet provider are governed by the applicable terms of service and privacy policy of that wallet provider.

5. Cookies Policy

We may use cookies and similar technologies on our Website to improve the functionality, security, and performance of our Website. This Cookie Policy explains what cookies are, how we use them, and how you can manage your preferences.

A. What is a cookie?

A cookie is a small text file that is placed on your hard drive by a web page server. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. Some of the cookies will only be used if you use certain features or select certain preferences, and some cookies will always be used. You can find out more about each cookie by viewing "What types of cookies do we use" below. We update this list periodically, so there may be additional cookies that are not yet listed.

B. Why would we use cookies?

We use cookies and other similar identifiers only to compile aggregate data about Website traffic and site interaction to offer better user experiences and tools in the future.

C. What types of cookies do we use?

• Strictly Necessary Cookies: These cookies are essential for the Website to function properly and enable basic features such as page navigation and access to secure areas of the site.
• Analytical/Performance Cookies: These cookies allow us to analyze how visitors use the Website, which helps us improve its functionality and performance.
• Functional Cookies: These cookies enable enhanced functionality and personalization of the Website. They may remember your preferences, such as the wallet you previously used to connect.
• Session Replay Cookies. We may use cookies, which may be provided by our vendors, for purposes of session replay. These cookies record your interactions with our Website, including mouse movements, text, and other information, associated with your visit to our Website. This information is used to help us improve our website and better provide you with information you are interested in when you visit our website. They may be set by us or by third party providers whose services we have added to our pages. This information is used to help us improve our Website and better provide you with information you are interested in when you visit our Website.

D. How to disable cookies?

You can manage the use of cookies through functionality built into your web browser or as provided on the Website, including through our cookie management system, available here: Manage analytics. Although you are not required to accept the Website's cookies, if you block or reject them, you may not have access to all features available through the Website.

If you want to learn more about cookies or how to control, disable, or delete them, please visit http://www.aboutcookies.org for detailed guidance.

E. "Do Not Track" (DNT) and Universal Opt-Out Preference Signals

Some web browsers (including Safari, Internet Explorer, Firefox, and Chrome) incorporate a "Do Not Track" (DNT) or similar feature that signals to web services that a visitor does not want to have their online activity and behavior tracked. If a web service operator elects to respond to a particular DNT signal, the web service operator may refrain from collecting certain Personal Information about the browser's user. Not all browsers offer a DNT option, and there is currently no industry consensus as to what constitutes a DNT signal. World Liberty supports DNT signals received from web browsers. For more information about DNT signals, visit http://allaboutdnt.com.

New standards are being developed for a Universal Opt-Out Mechanism, such as the Global Privacy Control (GPC), which allows users with GPC-enabled browsers and devices to send a signal that will communicate the user's request to opt-out of sales of their Personal Information and to opt-out of certain sharing of their Personal Information. If we detect and recognize such a signal from your device or browser, we will honor it.

6. Analytics

We may use third-party analytics platforms such as Google Analytics to track user interactions, preferences, and behavior during browsing sessions for users who have opted in for analytics. This data helps us improve our Website and analyze trends in our user base. For more information on how Google Analytics collects and processes data, please see www.google.com/policies/privacy/partners/. You can prevent the use of Google Analytics relating to your use of our website through this browser plug in provided by Google: https://tools.google.com/dlpage/gaoptout?hl=en-GB.

7. Data Security

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you 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.

8. Data Retention

We retain information we collect as long as it is necessary to fulfill the purpose for which it was collected as outlined in this Notice and to the extent permitted by applicable legal requirements. Where you request the deletion of your information, we may continue to retain and use your information as permitted or required under applicable laws for legal, tax, or regulatory reasons or legitimate and lawful business purposes.

9. Your Rights

Depending on where you are located, you may have the following rights related to the processing of your Personal Information:

• Request access to your Personal Information. A "Data Subject Access Request" enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
• Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate Personal Information we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.
• Request erasure / deletion / removal of your Personal Information. This enables you to ask us to delete or remove your Personal Information where we do not have a valid reason to continue to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully, or where we are required to erase your Personal Information to comply with local law.
• Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a 3rd Party).You may choose to exercise this right if there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Object to sharing of your Personal Information. You may have the right to limit the sharing of Personal Information, particularly for marketing purposes depending on where you live and the type of Personal Information in question.
• Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios:
  • If you want us to establish the data's accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims;
  • You want us to restrict the use of any "sensitive data" (as defined under applicable law); or
  • You have objected to our use of your Personal Information, but we need to verify whether we have overriding legitimate grounds to process it.
• Data Portability / Request the transfer of your Personal Information to you or directly to another controller. We will (unless there is an exemption) assist you by securely transferring your Personal Information directly to another controller where technically feasible or by providing you with a copy in a structured, commonly used, machine-readable format.

To exercise any of these rights, please submit a request by emailing us at [email protected] and include "Data Subject Rights Request" in the subject line. In the request, please specify which right you are seeking to exercise and the scope of the request. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

10. International Transfers

Please be aware that information collected through the Website may be transferred to, processed, stored, and used in the European Economic Area, the United Kingdom, and other jurisdictions. Data protection laws in the EU and other jurisdictions may be different from those of your country of residence. Your use of the Website or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the EU and other jurisdictions as set out in this Notice. Where applicable, we will transfer your Personal Information to third parties subject to appropriate or suitable safeguards such as standard contractual clauses.

11. Children

The Website is intended for general audiences and are not directed at children. To use the Website, you must legally be able to enter into the Agreement. We do not knowingly collect Personal Information (as defined by the U.S. Children's Privacy Protection Act or "COPPA") from children. If you are a parent or guardian and believe we have collected Personal Information in violation of COPPA, please contact us at [email protected] and we will remove the Personal Information in accordance with COPPA.

12. Additional Disclosures for California Residents

To the extent applicable, the CCPA poses certain obligations on us and grants certain rights to California residents ("California Resident," "you" or "your") with regard to Personal Information. If you are a California Resident, please review the following information about your potential rights with regard to your Personal Information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.

A. Notice of Collection

For further details on the information we may collect, including the sources from which we receive information, review the "Information Collection" section above. Depending on how you interact with us, we may collect and use these categories of Personal Information for the business purposes described in the "Use of Information" section above, including to manage the Website.

We do not "sell" or "share" Personal Information as defined under the CCPA, if applicable. Please review the "Sharing and Disclosure of Information" section above for further details about the categories of parties with whom we share information.

We retain your Personal Information as described above in Data Retention.

B. Our Collection, Use, and Disclosure of Personal Information

In the preceding 12 months, depending on how you interact with us, we may have collected and disclosed for a business purpose the following categories of Personal Information to the following categories of third parties:

In addition, we may disclose and in the preceding 12 months, may have disclosed all of the categories of Personal Information identified above in the section "Information Collection" to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our affiliates, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted by law. We may disclose personal information to all of the third parties listed above to comply with our legal obligations or for the business or commercial purposes identified above in "Use of Information".

We may disclose your Personal Information to our service providers such as IT providers, or email providers, other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in or as otherwise permitted by the CCPA. We also may disclose Personal Information to a third party at your request or direction or with your consent.

C. Use and Disclosure of Sensitive Personal Information

Certain Personal Information that we may collect and process may be considered "sensitive personal information" under the CCPA. The CCPA requires that we provide you with a right to limit our use or disclosure of such sensitive personal information in certain circumstances. Currently, we are not using or disclosing your sensitive personal information for purposes that would require that we provide you with a right to limit.

D. Your Rights Under the CCPA

If you are a California resident, you may have the following rights under the CCPA in relation to Personal Information we have collected about from or about you to the extent required by the CCPA:

• Right to be Informed. You have the right to be informed, at or before the point of collection, of the categories of Personal Information to be collected and the purposes for which the categories of Personal Information shall be used.
• Right to Know/Access: You have the right to request certain information about our collection and use of Personal Information about you as described below:
  • The specific pieces of your Personal Information collected.
  • The categories of your Personal Information collected.
  • The categories of sources from whom your Personal Information is collected.
  • The purpose for collecting your Personal Information.
  • The categories of third parties with whom we have shared your Personal Information.
• Right to Delete: You have the right to request that we delete certain Personal Information we have about you.
• Freedom from Discrimination: You have a right of non-discrimination for the exercise of any of your privacy rights guaranteed by law such as the right to access, delete, or opt- out of the sale of your Personal Information.
• Right to Correct: You have the right to request that we correct inaccurate Personal Information regarding the information you provide us.
• Right to Restrict the Use of Sensitive Personal Information: You have the right to restrict the use of your sensitive Personal Information.
• Right to Access Information on Automated Decision-Making: You have the right to access information collected through automated decision-making. Additionally, you can opt-out of our use of automated decision-making related to your Personal Information.
• Opt-Out of Sale. Request that we do not "sell" (as that term is defined in the CCPA) your Personal Information (we do not).
• Opt-Out of Sharing. Request to opt-out of the "sharing" (as that term is defined in the CCPA) of your Personal Information (we do not).
• Limit Use and Disclosure of Sensitive Personal Information. Request to limit the use and disclosure of sensitive personal information where required by the CCPA (we are not currently using sensitive personal information for purposes that would require we provide you with such a right to limit).

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. We also reserve the right to retain, and not to delete, certain Personal Information after receipt of a Request to Delete from you where permitted by the CCPA or another law or regulation.

E. How to Exercise Your Rights Under the CCPA

You can submit a Request to Know, Request to Correct, or Request to Delete ("Consumer Rights Request") or to access this notice in an alternative format, please submit a request using any of the methods:

• [email protected]
• https://forms.gle/fA8YaEYuPCrKo9oq9

We are only required to respond to verifiable Consumer Rights Requests made by you or your legally authorized agent. When you submit a Consumer Rights Request, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address. Any information gathered as part of the verification process will be used for verification purposes only.

You are permitted to designate an authorized agent to submit a Consumer Rights Request on your behalf and have that authorized agent submit the request through the aforementioned methods. In order to be able to act, authorized agents have to submit proof that they are authorized to act on your behalf or have a power of attorney.

F. Shine the Light

Customers who are residents of California may request:

• A list of the categories of Personal Information disclosed by us to third parties during the immediately preceding calendar year for those third parties' own direct marketing purposes.
• A list of the categories of third parties to whom we disclosed such information.

To exercise a request, please write to us at the email or postal address set out in the "Contact Us" section above and specify that you are making a "California Shine the Light Request." We may require additional information from you to allow us to verify your identity and are only required to respond to requests once per calendar year.

13. Additional Disclosures for Data Subjects in the European Economic Area and the United Kingdom

A. Roles

The GDPR and UK GDPR distinguish between organizations that process Personal Information for their own purposes (known as "controllers") and organizations that process Personal Information on behalf of other organizations (known as "processors"). We act as a controller with respect to Personal Information collected as you interact with the Website.

B. Lawful Basis for Processing

The GDPR requires a "lawful basis" for processing Personal Information. Our lawful bases include where:

• Consent: You have given consent to the processing of your Personal Information for one or more specific purposes either to us or to our service providers or partners.
• Contractual Necessity: Processing your Personal Information is necessary for the performance of a contract between you and us.
• Legal Obligation: Processing your Personal Information is necessary for compliance with a legal obligation.
• Legitimate Interests: Processing your Personal Information is necessary for the purposes of the legitimate interests pursued by us or a third party provided that your interests and fundamental rights and freedoms do not override those interests.

14. How to Contact Us

Please contact [email protected] with any questions about this notice or our data privacy and data protection practices.