This Privacy Policy (this “Policy”) describes how Monad Foundation and its affiliates (“Monad Foundation”, “us” or “we”) may collect, use and disclose personal information in connection with your access to and/or use of our websites (including https://www.monad.xyz and https://www.monad.foundation), mobile applications, and any related services, sales, marketing or events (collectively, the “Services”). For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Services.  

Your access to or use of the Services is subject to this Policy as well as our [Terms of Service] and any documents and additional terms or policies that expressly incorporate the Terms of Use (collectively, the “Terms”). Please read this Policy and the Terms carefully to ensure you understand them.  If you do not agree to this Policy, please do not use, access or download any of the Services.

We may update this Policy from time to time. If we make any changes, we will change the Last Updated date at the top of this Policy. We encourage you to periodically review the Policy for the latest information on our privacy practices. Any modifications to this Policy will be effective upon our posting of the updated Policy. In all cases, your continued use of the Services following the posting of any updated Policy indicates your acceptance of the updated Policy.

1. Personal Information We Collect

When you access or use the Services, we may collect certain categories of information about you from a variety of sources.

Personal Information You Give Us

We may collect the following personal information you provide directly to us in connection with the Services:

• Your Communications with Us.  We may collect personal information, such as email address, digital wallet address (“Wallet”) or online handle (for example, Discord) when you request information about our Services, register for our newsletter, request customer or technical support, or otherwise communicate with us.  

• Account Creation.  We may collect personal information when you create an account.  

• Interactions through social media and other third-party platforms. If you interact with us through any third-party platforms, such as our pages on Github or Discord, or through any of our pages or feeds on social media sites or platforms, such as LinkedIn or Twitter/X, we may collect information such as your name, username, contact information such as email address, location, and publicly-posted data such as your social media activity.  

• Sweepstakes or Contests.  We may collect personal information you provide for any sweepstakes or contests that we offer.  In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.  

• Conferences, Trade Shows, and Other Events.  We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.  

• Ecosystem Development.  We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

• Job Applications.  We may post job openings and opportunities on our Services.  If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us.  

Other data may include transaction data or history (such as your public blockchain transaction history and other information associated with a linked address or Wallet and token holdings). Should you contact us, we will collect the content of the communications we have with you and any personal data contained within, including the email address you used to contact us.

Information Collected Automatically

We also automatically collect certain information about your interaction with the Services (“Usage Data”). To do this, we may use cookies, web beacons/clear gifs and other tracking technologies ("Tracking Technologies"). Usage Data comprises of: ​

• Device information (e.g., unique device identifier, device type, IP address, operating system) ​

• Location information (e.g., approximate geolocation) ​

• Other information regarding your interaction with the Services (e.g., log data, date and time stamps, clickstream data)

We use Usage Data to tailor features and content to you and to run analytics and better understand user interaction with the Services. 

Information Collected from Third Parties

Third-Party Services and Sources.  We may obtain personal information about you from other sources, including through third-party services and organizations.  For example, if you access our Services through a third-party application, such a third-party login service or a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings.  

Blockchain Information.  We may obtain personal information about you through our analysis of blockchain information.  

2. Legal Basis for Processing

We may process personal information about you to:

• Provide, maintain, support and improve the Services and respond to inquiries related to the same;

• Allow you to personalize and improve your experience on with the Services; 

• Send you technical notices about the Services, including sending announcements, updates, security alerts, and support and administrative messages;

• Communicate with you about products, services, and events offered by us and others and provide news and information that we think will interest you (see the “Your Choices and Your Rights” section below for information about how to opt out of these communications at any time); 

• Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;

• Comply with our legal and regulatory obligations;

• Prevent, detect and investigate fraudulent, abusive or harmful activities;

• Analyze usage trends to permit access to the Services or provide the Services;

• Authenticate and verify individual identities, including requests to exercise your rights under this Privacy Policy;

• Debug to identify and repair errors with our Services;

• Enforce the Terms, this Policy and/or other applicable agreements, terms or policies; and

• Take certain actions that you have asked us to, and where relevant or necessary, obtain the necessary consents for us to take those actions.

You agree and acknowledge that 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. How We Share Information

In certain circumstances, we will share your information with third parties with your consent, as necessary, or as otherwise required or permitted by law. Specifically, we share your personal data:

• With service providers and vendors: We may share your personal data with third parties to process on our behalf. Such third parties include blockchain analysis service providers, know-your-customer and screening service providers, developers, content delivery service providers, and data analytics service providers. These service providers assist us with many different functions and tasks, including determining your eligibility with respect to participation in certain of the Services.

• When you request us to share certain information with third parties, with consent or to perform on a contract with you: With your permission, we may share your personal data with relevant third parties.

• With professional advisors, in our legitimate interests or as required by law: As necessary, we will share your personal data with professional advisors such as auditors, law firms, cybersecurity specialists, data analysis organizations, and/or consulting or accounting firms.

• For legal and security reasons and to protect our services and business, in our legitimate interests or as required by law: We will share your personal data with regulators, law enforcement agencies, public authorities, or any other relevant organizations: (i) in response to a legal obligation; (ii) if we have determined that it is necessary to share your personal data to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries; (iii) to protect the interests of, and ensure the safety and security, of us, our users, a third party, or the public; (iv) to exercise or defend legal claims; and (v) to enforce our terms and conditions, other applicable terms of service, or other agreements.

• With our affiliates, in our legitimate interests: We may share your personal data with our subsidiaries.

• In connection with an asset sale or purchase, merger, bankruptcy, or other business transaction or re-organization, in our legitimate interests: We may share your personal data with relevant third parties as necessary while negotiating or in relation to a change of corporate control such as a restructuring, merger, or sale of our assets.

4. Location of Personal Information

Please be aware that personal information we collect may be transferred to, processed, stored, and used in the Cayman Islands and other jurisdictions.

Data protection laws in the Cayman Islands and other jurisdictions where we have affiliates may be different from those of your country of residence. Your use of the Services 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 Cayman Islands and other jurisdictions as set out in this Policy.

Your personal information may be transferred to and stored or processed in countries outside the jurisdiction in which you live and reside, including outside the European Economic Area (“EEA”) and United Kingdom (“UK”), and including to the U.S., in order to provide the Services. Your personal information is also processed by staff operating outside the UK/EEA who work for us or for third-party service providers or partners. We will take steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy. When we transfer your personal information to third parties located outside the EEA/UK, we seek to put in place appropriate safeguards to ensure that this transfer occurs in accordance with applicable laws. These measures include seeking entry into the standard contractual clauses (“SCCs”) approved by the European Commission (for transfers outside the EEA) and/or an international data transfer agreement/addendum to the SCCs approved by the UK Information Commissioner’s Office (“ICO”) (for transfers outside the UK), unless the data transfer is to a country that has been determined by the European Commission or the relevant UK authorities, as applicable, to provide an adequate level of protection for individuals’ rights and freedoms for their personal data.

5. Your Choices and Your Rights

You may have choices about the collection and use of information about you. You can choose not to provide certain information, but then you might not be able to use the Services.

• Communications. If you do not want to receive messages / communications from us related to the Monad ecosystem, the Services (or part of the Services) or marketing, please adjust your communication preferences / opt-out / unsubscribe at any stage by contacting wpp@monad.foundation.

• Browser and Devices. Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including any portal features and general functionality, to work incorrectly.

Under applicable data protection laws, you may have certain rights in relation to your personal data. These rights may include the following:

• Access to your personal data that we hold, information on how we use it, and who we share it with;

• Request the correction of inaccurate or incomplete personal data we hold about you, which we may verify as necessary before making changes;

• Deletion or removal of your personal data, in certain circumstances;

• Objection to the processing of your personal data, in certain circumstances;

• Restriction of the processing of your personal data, to stop us from processing the personal data we hold about you other than for storage purposes, in certain circumstances;

• Portability of your personal data; we will endeavor to provide you, or a third party, with a copy of the personal data that we hold about you and transfer it to a third party in a structured, commonly used, machine-readable format;

• Withdrawal of consent, where we rely on consent to process personal data; this will not affect the processing of personal data carried out before consent is withdrawn or on legal bases other than consent.

You may submit a written request concerning the processing of your personal data to wpp@monad.foundation. Please note that, prior to any response to such request, we will require you to verify your identity. In addition, we may have valid legal reasons to refuse your request and will inform you if that is the case.

Note that these rights apply only in certain circumstances and all of these rights may be limited by law. Such limitations may apply, for example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interests, or where we are required by law to retain your personal data.

To the extent required under applicable data protection laws, we will be responsive to your request without undue delay and where required under applicable data protection laws, at least within one month (though this may be extended by a further two months in certain circumstances).

6. Social Networks and Other Third Party Websites and Links

We may provide links to websites or other online platforms operated by third parties, including third-party social networking platforms, such as Twitter, Discord, or Medium, operated by third parties (such platforms are “Social Networks”). If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of these sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share or post on Social Networks, may also be accessible or viewable by other users of the Services and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services. 

7. Third Party Wallet Extensions

Certain transactions conducted via our Services may require you to connect a Wallet to the Services. By using such Wallet to conduct such transactions via the Services, you agree that your interactions with such third party Wallets are governed by the privacy policy for the applicable Wallet. We expressly disclaim any and all liability for actions arising from your use of third party Wallets, including but without limitation, to actions relating to the use and/or disclosure of personal information by such third party Wallets.

8. Children’s Personal Information

The Services are intended for general users who are 18 years of age or older, and are in no way directed at children.  We do not knowingly collect personal information from children.  If you believe such information has been collected in error, please email wpp@monad.foundation to notify us of this.  

9. Retention of Information

We retain information collected in accordance with this Policy only for so long as you use the Services or as long as it is necessary to fulfill the relevant purposes described in this Policy, unless a longer retention period is required or permitted by law such as for tax, accounting, fraud prevention, investigative, and dispute resolution purposes, or to establish or defend a legal claim or other legal requirements. In some instances, we may anonymize personal information about you such that it can no longer be used to identify you, in which case we can use such information indefinitely without further notice to you.

10. Periodic Reviews and Updates to Policy

This Policy takes into account the requirements of the Cayman Islands Data Protection Act 2021 and general Privacy Principles. Individuals located in the European Union (“EU”) and the United Kingdom (“UK”) may have rights under the EU General Data Protection Regulation 2016/679 and the UK General Data Protection Regulation, respectively (collectively, the “GDPR”). Please note that you can file a claim with the data protection supervisory authority in the EEA country in which you live or work or where you think we have infringed data protection laws, or with the UK Information Commissioner’s Office, as applicable to you. Other applicable global privacy and data-protection laws may provide you rights with respect your personal data and other information.

We may review and update this Policy from time to time. Updates to our Policy will apply only to information collected after the date of the change. If we make material changes to the Policy, we will note on our Website that the Policy has been updated and update the Last Updated date at the top of this Policy.

11. Contact Us

Monad Foundation is the controller of the personal information we process under this Policy.

Should you have any questions or complaints about our privacy or data-protection practices, your personal data, or this Policy, please email us at wpp@monad.foundation.