We at De.Fi know you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy.

This Privacy Policy covers our treatment of personally identifiable information (“Personal Information ”) that we gather when you are accessing or using our Services, but not to the practices of companies we don’t own or control, or people that we don’t manage. We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with our Services, including to personalize, provide, and improve our services, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some Personal Information with third parties, but only as described below.If you are under the age of majority in your jurisdiction of residence, you may use the Services only with the consent of or
under the supervision of your parent or legal guardian. Consistent with the requirements of the Children's Online Privacy Protection Act (COPPA), if we learn that we have received any information directly from a child under age 13 without first receiving his or her parent's verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use our Services and subsequently we will delete that information.

We're constantly trying to improve our Services and how we approach privacy matters, so we may need to change this Privacy Policy from time to time, but we will alert you to changes by requiring you to log in to our Services again and accept the new Privacy Policy and/or by some other means. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used.

Information You Provide to Us: We receive and store any information you knowingly provide to us. For example, this includes information you provide when you import your Wallet such as information regarding your transactional history on a Blockchain network, information you provide each time you wish to make a transfer of Virtual Currency through the Services, or usage information, such as information about how you use the Service and interact with us. It also includes contact information you elect to provide to us, such as your email address, feedback and correspondence, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with Service, receive customer support or otherwise correspond with us, and marketing information, such your preferences for receiving marketing communications and details about how you engage with them. You should understand that, because of the nature of most Blockchain networks, your entire transactional history conducted from your Wallet is provided to us or otherwise publicly accessible and is necessary to support your usage of the Services. Information Collected Automatically: Whenever you interact with our Services, we automatically receive and record
information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, “cookie” information, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be
able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features. If you click on a link to a third-party website or service, such third party may also transmit cookies to you. Again, this Privacy Policy does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor “Do Not Track” requests you have set using your browser or device.We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services - for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.Information Collected from Other Websites and Do Not Track Policy: Through cookies we place on your browser or device,
we may collect information about your online activity after you leave our Services. Just like any other usage information we collect, this information allows us to improve the Services and customize your online experience, and otherwise as described
in this Privacy Policy. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. When you turn on the Do Not Track function in your browser, we stop collecting the information from your browser that allows us to tailor advertisements and other content specifically to you that is based on your visits to our advertising partners’ websites. Specifically, we stop collecting information from the unique browser cookie that links your browser to visits to third party sites. Do Not Track signals are set on a browser-bybrowser basis, so you must set them on every browser you use if you do not wish to be tracked. Remember that this is just our Do Not Track policy, and we can’t and don’t make any promises about how third parties react when you set this signal on your browser.Information we will never collect: We will never ask you to share your private keys to your Wallet or other security information that could be used to access your Wallet without your explicit consent and action. Never trust anyone or any site that asks you to enter your private keys or similar security information.

We do not share or sell the personal information that you provide us with other organizations without
your express consent, except as described in this Privacy Policy. We may share your Personal Information
with third parties as described below:

• Affiliated Businesses: In certain situations, businesses or third-party websites we’re affiliated with may sell or provide products or services to you through or in connection with the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third-party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies.
• Our Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you or to us. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.
• Business Transfers: We may choose to buy or sell assets and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.
• Third Party Services: We may use third party services, such as Google Analytics, to grow our business, to improve and develop our Services, to monitor and analyze use of our Services, to aid our technical administration, to increase the functionality and user-friendliness of our Services, and to verify that users have the authorization needed for us to process their requests. These services may collect and retain some information about you, such as the IP address assigned to you on the date you use the Services, but not your name or other personally identifying information. We may combine the information generated through the use of these services with your Personal Information but never in a way that will identify you to any other user. Although these services may plant a persistent cookie on your web browser to identify you as a unique user the next time you use the Services, the cookie cannot be used by anyone but Google. These services’ ability to use and share information about your use of the Services is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. You may find additional information about Google Analytics at https://google.com/policies/privacy/partners/. You can opt out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout/.
• Protection of De.Fi and Others: We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law or court order; protect the rights, property, or safety of De.Fi, our employees, our users, or others.

We endeavor to protect the privacy of the Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.

If you are a resident of the European Economic Area (“EEA”), you may have additional rights under the General Data Protection Regulation (the “GDPR” ) and other applicable law with respect to your Personal Data, as outlined below.For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. De.Fi will be the controller of your Personal Data processed in connection with the Services.If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at info@de.fi

We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.

• Information we collect directly from you:We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:
• Public key data for your Wallet and associated transactions on a Blockchain network
• E-Mail address
• Other information you may elect to submit in your communications with us while using our Services, such as your name in connection with providing feedback or user testimonials.

• Information we automatically collect when you use our Services: Some Personal Data is automatically collected when you use our Services, such as the following:
• IP address
• Device identifiers
• Web browser information
• Page view statistics
• Browsing history
• Usage information
• Transaction information (e.g. transaction amount, date and time such transaction occurred)
• Cookies and other tracking technologies
• Log data (e.g. access times, hardware and software information)

We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:

• Enable access to decentralized protocols and dapps using your Wallet through our Interface or App
• Communicate with you to process transactions to and from your Wallet
• Provide support and assistance for the Services
• Personalize website content and communications based on your preferences
• Comply with our contractual or legal obligations
• Respond to user inquiries
• Resolve disputes
• Protect against or deter fraudulent, illegal or harmful actions

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

• Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
• Public key data for your Wallet and associated transactions on a Blockchain network
• E-Mail address
• Legitimate Interest: We consider and balance any potential impacts on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by any adverse impact on you (unless we have your consent or are otherwise required or permitted to by law). We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
• IP address
• Device identifiers
• Web browser information
• Page view statistics
• Browsing history
• Usage information
• Transaction information (e.g. transaction amount, date and time such transaction occurred)
• Cookies and other tracking technologies
• Log data (e.g. access times, hardware and software information)
• Examples of these legitimate interests include:
• Operation and improvement of our business, products and Services
• Marketing of our products and Services
• Provision of customer support
• Protection from fraud or security threats
• Compliance with legal obligations
• Completion of corporate transactions
• Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
• Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy. These parties include:

• Payment processors
• Fraud prevention service providers
• Analytics service providers
• Staff augmentation and contract personnel
• Hosting service providers
• Co-location service providers

We also share Personal Data when we believe it is necessary to:

• Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
• Protect us, our business or our users, for example to prevent spam or other unwanted communications and investigate or protect against fraud
• Maintain the security of our products and Services

We also share information with third parties when you give us consent to do so.

Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.

We retain Personal Data about you for as long as necessary to provide you Services. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we may retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity, and, where possible, we refrain from collecting Personal Data. For example, De.Fi does not collect private key data associated with your Wallet, and we secure the Personal Data you provide in a controlled, secure environment and protected from unauthorized access. De.Fi regularly audits its system for any possible security vulnerabilities to safeguard Personal Data. De.Fi protects the security of your information during transmission by using Transport Layer Security (TSL/SSL), which encrypts all information that you input. However, your private key is the key to your Wallet. If you do share your private key or your Personal Data with others that enables them to access your private key, you remain responsible for all actions taken in the name of your Wallet. If you lose control of your private key, you may lose control over your Wallet or your Personal Data and may be subject to legally binding actions taken of your behalf

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email info@de.fi. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary, to verify your identity and the nature of your request.

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by visiting De.Fi’s Interface.
• Rectification: If you believe that any Personal Data, we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can correct some of this information directly by editing them on De.Fi’s Interface.
• Erasure: You can request that we erase some or all your Personal Data from our systems, provided that this will not erase any Personal Data you have submitted on a Blockchain network that isn’t controlled by us.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint: You have the right to lodge a complaint about De.Fi’s practices with respect to your Personal Data with the supervisory authority of your country or European Union Member State.

If you have any questions about this section or our data practices generally, please contact us using the following information:

• Email address for contact: info@de.fi

If you have any questions or concerns regarding our privacy policies, please send us a detailed
message to info@de.fi, and we will try to resolve your concerns.