Privacy Policy

At Nal (referred to here as “we”, “us” or “our”), we respect and protect the privacy of the users (“you” and “your” or “Users”, as relevant) who explore and use Nal Pay, Nal Protocol, Nal Interface and Website located at nal.network (the “Site”), and Nal Testnet (collectively, the “Services”, defined in the NAL Terms of Service).

This Privacy Policy describes how we collect, use, and disclose your information when you use our Services, which include the services offered on our Site. Please note that we do not control websites, applications, or services operated by third parties, and we are not responsible for their actions. We encourage you to review the privacy policies of the other websites, decentralized applications, and services you use to access or interact with our Services.

OUR COLLECTION OF YOUR INFORMATION

Sometimes we collect your information automatically when you interact with our services, and sometimes we collect your information directly from individuals. At times, we may collect information about an individual from other sources and third parties, even before our first direct interaction.

WHAT INFORMATION WE COLLECT

We may collect the following information individuals provide in connection with our services:

1. Information you provide

• Your public wallet address

• Your basic information, including name, email, social media handles, businessname and other information you provide to us (“Basic User Information”)

2. Information collected automatically

• Browser and Device Information

• IP address/derived location information

• Other device characteristics or identifiers (e.g. plugins, the network you connect to)

3. Information we obtain from third parties

• Information from Analytics Providers: We receive information about your website usage and interactions from third party analytics providers. This includes browser fingerprint, device information, and IP address.

• Error Tracking Data: We utilize information from third party service providers to provide automated error monitoring, reporting, alerting and diagnostic capture for Service and Site errors to allow Usersto build more effectively.

OUR USE OF YOUR INFORMATION

We use the information we collect to:

• Manage our organization and its day-to-day operations;

• Communicate with individuals, including via email and social media;

• Market our services to individuals, including through in-person events, social media, email, and other online venues, based on individual interests and interactions with us;

• Administer, provide, maintain, improve, and personalize our products and services, including by recognizing an individual and remembering their information when they return to our services;

• Facilitate transactions and individual benefits and services, including customer support, contests, sweepstakes, and promotions;

• Identify and analyze how individuals use our services;

• Monitor and analyze trends, usage, and activities in connection with our services;

• Improve and customize our services to address the needs and interests of our user base and other individuals we interact with;

• Improve or support the Service;

• Test, enhance, update, and monitor the services, or diagnose or fix technology problems;

• Help maintain the safety, security, and integrity of our property and services, technology assets, and business;

• Defend, protect, or enforce our rights or applicable contracts and agreements;

• Detect, prevent, investigate, or provide notice of malicious, deceptive, fraudulent, unlawful or criminal activity;

• Facilitate business transactions and reorganizations impacting the structure of our business; and

• Comply with legal obligations.

OUR DISCLOSURE OF YOUR INFORMATION

We disclose the information we collect to:

• Identity Verification Providers: Where we engage a third-party identity verification provider to help us verify the identity of a specific individual with whom we are interacting, we will typically provide the third-party identity verification provider sufficient information to facilitate the identity verification service.

• Event, Promotion and Other Business Partners: Just as we may receive information from our event, promotion and other business partners, we may share information with them in connection with the relevant event, promotion or service we are offering.

• Data Analytics Providers: We may share information with our data analytics providers to facilitate the analytics services they are providing us.

• Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as web hosting, shipping and delivery, payment processing, fraud prevention, customer service, contests, sweepstakes, promotions, and marketing and advertising services. Depending on the function the provider serves, the service provider may process information on our behalf or have access to information while performing functions on our behalf.

• Business Transaction or Reorganization: We may take part in or be involved with a business transaction, such as a merger, acquisition, joint venture, or financing or sale or other transfer of company assets. We may disclose yourinformation to a third party during negotiation of, in connection with or as an asset in such a business transaction. Your information may also be disclosed in the event of insolvency, bankruptcy, or receivership.

• Legal Obligations and Rights: We may disclose information to third parties, such as legal advisors and law enforcement:

  1. in connection with the establishment, exercise, or defense of legal claims;

  2. to comply with laws or to respond to lawful requests and legal process;

  3. to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;

  4. to detect, suppress, or prevent fraud;

  5. to protect the health and safety of us and others; or

  6. as otherwise required by applicable law.

• Otherwise with Consent or Direction: We may disclose theinformation about an individual to certain other third parties or publicly with the individual’s consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our services.

COOKIES AND RELATED TECHNOLOGIES

We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, similar technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect your information and use or disclose your information for the purposes described in the sections above. For example, our services use Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to collect and view reports about the traffic on our website. Individuals can obtain more information on the use of Google Analytics by visiting Google’s privacy policy here and individuals can view Google’s currently available opt-out options here.

CHOICE RELATING TO THE USE OF COOKIES ON OUR PLATFORM SERVICES

If an individual would prefer not accepting cookies, most browsers will allow the individual to: (i) change the individual’s browser settings to notify the individual when the individual receives a cookie, which lets the individual choose whether or not to accept it; (ii) disable existing cookies; or (iii) set the individual’s browser to automatically reject cookies. Please note that doing so may negatively impact the individual’s experience using our website, as some features and offerings may not work properly or at all. Depending on the individual’s device and operating system, the individual may not be able to delete or block all cookies. In addition, if the individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser on each device the individual actively uses. The individual may also set their email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether they have accessed our email and performed certain functions with it.

CHILDREN’S PERSONAL INFORMATION

Our services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If an individual is under the age of 13, they should not use our services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.

LINKS TO THIRD-PARTY WEBSITE OR SERVICES

Our services may include links to third-party websites, plug-ins, and applications. Except where we post, link to, or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

INFORMATION FOR CALIFORNIA RESIDENTS

In addition to the information and rights described in this Privacy Policy, residents of California have additional rights and access to specific information under the California Consumer Privacy Act (“CCPA”) concerning their personal information. This section of the Privacy Policy applies to you if you are a California resident (referred to as a “Consumer” as defined by the CCPA). If you are not a Consumer, this section does not apply to you, and you should not rely on it.

1. Information Collection and Usage

The following is a summary of the personal information (as defined by the CCPA) we

collect and use in connection with our Services for commercial and business purposes.

For more details, please refer to the relevant sections of this Privacy Policy.

Categories of Personal Information we may collect and use for commercial and business purposes:

• Contact and account registration information: When you register for an account or get in touch with us, you may provide us with your name, email address, physical address, phone number, account username and password, electronic signature, and other relevant details.

• Financial or payment information: We collect information related to the payment methods you provide, billing details, and information about the products or services you purchase.

• Transaction information: When you use our Services for transactions, we may collect the names and email addresses of transaction participants, subject lines, the history of actions taken within a transaction (e.g., reviews, signatures, enabling features), and personal information of individuals involved or their devices, such as names, email addresses, IP addresses, and authentication methods.

• Customer service information: We gather information regarding your customer service interactions with us, including any questions or messages you send us directly through online forms, email, phone, or mail.

• Information about your web browser, mobile device, or internet connection: When you access our Services online, we may automatically collect your IP address, device identifiers, device attributes (including cookie IDs and mobile advertising IDs), data on how you interact with our online Services (usage data), location information (such as city, state, country, and ZIP code associated with your IP address or derived through Wi-Fi triangulation), and, with your permission based on your mobile device settings, precise geolocation information obtained from GPS functionality on your mobile device.

Commercial and Business Purposes for Using Collected Personal Information:

• Providing requested products and services to you and processing payments.

• Creating and managing your account, and maintaining our relationship with you (e.g., communication, providing requested information).

• Sending you transaction records, including those related to purchases or other events.

• Marketing features, products, or special events via email or phone, and sending you marketing communications about third-party products and services we believe may interest you.

• Conducting sweepstakes, contests, and refer-a-friend programs.

• Selecting and delivering tailored content and advertising, and supporting marketing and advertising efforts for our Services.

• Generating and analyzing data about our users and their usage of our Services.

• Testing changes and developing new features and products for our Services.

• Addressing issues you may encounter with our Services, including providing support and resolving disputes.

• Managing the Services platform, including support systems and security.

• Preventing, investigating, and responding to fraud, unauthorized access or use of our Services, violations of terms and policies, or other inappropriate activities.

• Complying with legal obligations and applicable retention periods.

• Establishing, exercising, or defending our rights in legal claims.

2. The Right to Opt Out of Personal Information Sales

Consumers have the right to opt out of the “sales” of their personal information as defined by the CCPA. According to the CCPA, with certain exceptions, a “sale” occurs when a business sells, rents, releases, discloses, disseminates, makes available, transfers, or otherwise communicates orally, in writing, or electronically, a consumer’s personal information to another business or a third party in exchange for monetary or other valuable consideration.

As explained in more detail in other part of this Privacy Policy, we share personal information with other companies. Consumers can submit requests to opt out of such sharing using the following methods:

• Adjusting cookie settings and selecting the option to opt out of respective cookie activities.

• Clicking the “unsubscribe” link at the bottom of any Project marketing communication.

3. The Right to Access

Consumers have the right to request specific details about the personal information we have collected about them within the past 12 months. This includes the right to request:

• The specific pieces of personal information and categories of personal information we collected about them.

• The categories of personal information we sold or disclosed for business purposes and the categories of third parties to whom we sold or disclosed that information for a business purpose.

• The categories of sources from which we collected personal information.

4. The Right to Deletion

Consumers have the right to request the deletion of personal information we have collected from them. However, the CCPA allows us to retain information in certain circumstances (e.g., legal obligations, specific exceptions outlined by the CCPA).

5. How to Exercise Access and Deletion Rights

Consumers can submit requests for accessing or deleting their personal information by accessing and reviewing personal information associated with your account by contacting us via support@nal.network.

For security purposes, we will verify your identity before fulfilling your request. If you have an account with us, we may verify your identity by having you log in. If you don’t have an account, we may need to contact you or request additional information (such as your name, email address, or telephone number) to verify your identity.

Once your identity is verified, we will respond to your request to the extent permitted by law. If we’re unable to verify your identity, we may ask for more information or deny your request. If we can’t fulfill your request completely, we will provide you with further details explaining why.

Please note that certain personal information may be exempt from these requests under applicable law. Additionally, we require certain types of personal information to provide our products and services. If you request deletion of such information, you may no longer be able to access or use our products and services.

6. The Right to Nondiscrimination

Consumers have the right to be free from discrimination for exercising their CCPA rights.

We will not deny, charge different prices for, or provide a different level of quality of goods or services with respect to Consumers who choose to exercise their CCPA rights.

7. Authorized Agents

If you designate an agent to make CCPA requests on your behalf, we will verify both your identity and your agent’s authorization to act on your behalf. We may request a signed written authorization or a copy of a power of attorney to verify the agent’s authority.

8. “Shine the Light”

If you are a California resident, you have the right to request a list of third parties that received your personal information for direct marketing purposes in the previous year. This list will include the types of personal information shared. We provide this list at no cost. To request this information, please contact us via the Site.

ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE

If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data, and this section applies to you.

1. Legal Basis for Processing

When we process your personal data, we will do so in reliance on the following lawful bases:

• To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products and services you requested).

• When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).

• To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of communications).

• When we have your consent to do so (e.g., when you opt in to receive communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.

2. Data Retention

We store other personal data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

3. Data Subject Requests

Subject to certain limitations, you have the right to request access to the personal data we hold about you and to receive your data in a portable format, the right to ask that your personal data be corrected or erased, and the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, please contact us at support@nal.network.

4. Questions or Complaints

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en

For individuals in the UK: https://ico.org.uk/global/contact-us/

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

UPDATES TO THIS PRIVACY POLICY

We will update this Privacy Policy from time to time. When we make changes to this Privacy Policy we will change the date at the beginning of this Privacy Policy. If we make material changes to this Privacy Policy, we will notify individuals by email to their registered email address, by prominent posting on our services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

CONTACT US

If you have any questions or requests in connection with this Privacy Policy or other privacy-related matters, please send an email to support@nal.network.