PRIVACY POLICY Last Revised: October 20, 2024 This Privacy Policy (“Privacy Policy”) explains how Skip Protocol, Inc. (“we,” “our,” or “us”) collects, uses and discloses information that we obtain about visitors (“you” and “your”) who access and use the skip.build website, together with all sub-domains, and any other websites that may be offered by us from time to time (the “Website”), the “Skip:Go” front-end user interface hosted by Skip at go.skip.build (the “Interface”), and any other web applications or software that may be offered by Skip from time to time (collectively, the “Services”). By visiting the Website, Interface or using any other Services, you acknowledge and agree to this Privacy Policy and that your data (including Personal Information, as defined below) will be handled by us in accordance with this Privacy Policy. The Services may contain feeds or links to third-party websites, applications or services, such as user interfaces for decentralized exchanges, bridges or any other types of websites, applications or services. If you visit third-party websites, applications or services, any information collected is governed by the terms and conditions and privacy policies of such third-parties. This Privacy Policy does not apply to information collected through third-party websites, applications or services that you may access through the Services. We are not responsible for the content of third-party websites, and your use of such third-party websites is at your own risk. This Privacy Policy applies globally. If you are a resident of the European Economic Area (“EEA”) or the United Kingdom (“UK”), please review the “Notice to Residents of the EEA and the UK” section below for important information about how we collect and use your Personal Information and your rights under the General Data Protection Regulation (“GDPR”) and the UK General Data Protection Regulation (“UK GDPR”). Please review this Privacy Policy carefully. If you have any questions, please reach out via the “Contact Us” information provided below. Personal Information That We Collect We, and third parties working on our behalf, collect and process the Personal Information that you directly provide to us through the Services. We may also collect and process Personal Information that is provided to us from other sources. “Personal Information” includes any information that, alone or in combination with other information, can be used to identify you, such as a personal identifier (e.g., name, phone number or email address), an identification number, online identifiers or inferences about your preferences. Personal Information does not include information that is de-identified or aggregated such that it cannot be used to identify individuals. Personal Information also includes “personal data,” as such term is defined under the GDPR or the UK GDPR. We may collect the following Personal Information: name, email address, social media handles, digital wallet addresses, publicly available blockchain data and usage data about devices you use to access the Services, such as device manufacturer, operating system, browser information, domain name, location and internet protocol (“IP”) address (collectively, “Automatically Collected Information”). We may also collect other information, which may be publicly available, or that we may acquire through third-party sources. Personal Information Used and Disclosed to Third Parties We, or third parties on our behalf may, use the Personal Information, including Automatically Collected Information, that we have about you to enforce our Terms of Service and this Privacy Policy, to provide the Services, communicate with you regarding your requests, analyze Services usage, for marketing and advertising purposes, to operate our referral or incentive program, to detect fraud or misuse to comply with our legal or regulatory obligations, with your consent or otherwise for valid business purposes, to help us improve your experience with the Services, to enforce eligibility requirements and record IP addresses, browser types, internet service provider and usage metrics. We may sell or share your personal information, as such term is defined under data privacy laws, to third parties for advertising and marketing purposes, including to provide advertising relevant to you.  
We may also share your Personal Information in the following circumstances:
  • Designated Service Providers. We may share your Personal Information with companies that we contract with in order to provide the Services (“Service Providers”). For example, Service Providers may: (i) provide products or services to you on our behalf; (ii) create or maintain our networks, systems, databases or analytics; (iii) provide other general support; (iv) respond to inquiries; (v) provide marketing services and advertising relevant to you; (vi) monitor and analyze the use and functionality of our Services; and (vii) other relevant internal business operations and purposes. Information disclosed to third parties may include aggregated and/or de-identified information derived from your Personal Information. We may disclose Automatically Collected Information obtained from your use of the Services to our Service Providers.
  • Affiliates. We may share your Personal Information with companies under common ownership and control of us, including our subsidiaries and affiliates.
  • Legal or Regulatory Obligations. We may disclose your Personal Information if we believe that such disclosure is necessary to satisfy our legal or regulatory obligations. This may include: (i) to comply with the law or in response to a subpoena, court order, government request or other legal process; (ii) to produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations or other legal or administrative proceedings; (iii) to protect the interests, rights, safety or property of us, or any of our subsidiaries, affiliates, employees or users of the Services; (iv) to monitor compliance with and enforce the Terms of Service; (v) to operate the systems that are designed to allow the Services to function properly; (vi) for internal research purposes or managing the use of our copyrighted materials; or (vii) if we reasonably believe that a disclosure is necessary.
  • Business Transactions. In the event that we go through a business transition, such as a merger, acquisition by another company, reorganization or sale of a portion of its assets, some or all of your Personal Information may be transferred in connection with the proposed transaction.
  • Consent. With your consent or at your direction, such as sharing with your representatives or third parties.
Cookies and Other Data Collection Technologies We utilize cookies and other data collection technologies on our Services. A cookie is a small text file placed on your computer that helps us understand how you and our other visitors use the Services, to enhance the user experience through different features and functionality and to analyze and compile usage data. Personal Information collected by cookies may include your device’s IP address, browser type, operating system, computer platform, web pages viewed and/or the date and time of your visit. For example, we may use cookies to remember your preferences or settings. We may also use Software Development Kits (“SDKs”) on the Services for services related to on-ramping and maintenance of crypto wallets. SDKs are a collection of tools or libraries that we may use to add functionality to the Services. Most browsers include tools to manage or disable cookies. You can visit the help function on most browsers to modify how your browser handles cookies. However, if you disable cookies, some features of the Services may not function properly. Cookies can be categorized by how long they remain on your device. All cookies have expiration dates in them that determine how long they stay in your browser. There are two broad categories of duration: Session Cookies. Session cookies are temporary cookies that exist only during an online session and are not stored on your computer or mobile device. Persistent Cookies. Persistent cookies are those placed on your computer or mobile device for a pre-determined length of time when you visit our Website, Interface or otherwise access the Services. Persistent cookies remain on your device until deleted manually or automatically. To assist us with the various uses and purposes described in this Privacy Policy, your Personal Information, including information collected by cookies or similar data collection technologies, may be aggregated, analyzed or linked to other information we have about you (including information from other online and offline sources). For example, we may use Service Providers to collect information about your use of the Services, such as pages viewed via the Website, to provide us reports about your use of the Services. Global Privacy Control. The Global Privacy Control (“GPC”) is a method for individuals to opt-out of the sale or sharing of their personal information, as such term is described under applicable data protection laws, via a user-enabled privacy control that is available on certain internet browsers. Our systems are not configured to detect or respond to the GPC. You can learn more about the GPC here. “Do Not Track” Signals. Some web browsers have “Do Not Track” or similar features that allow you to tell each website you visit that you do not want your activities on that website tracked. Currently, the Services do not respond to “Do Not Track” signals and will continue to collect information about you even if your browser’s “Do Not Track” functionality is activated. Please note that your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of cookie information. Notice to Residents of the EEA and the UK If you are a resident of the EEA or the UK, you have the rights under the GDPR or the UK GDPR. We are required to comply with the GDPR, the UK GDPR and applicable local laws with respect to certain Personal Information we collect. If you are a resident of the EEA or the UK, the GDPR and the UK GDPR provides you with certain rights and choices regarding your Personal Information and how you can exercise those rights. Please note that we do not collect Special Categories of Personal Information, as such term is defined under the GDPR and the UK GDPR. Legal Bases for Processing Your Personal Information. We collect and process Personal Information for the following legal bases:
  • We process your Personal Information with your valid, explicit consent.
  • We process your Personal Information when necessary to perform our agreements with you.
  • We process your Personal Information in pursuit of our legitimate interests. Examples of these legitimate interests include operation and improvement of the Services, personalization of content on the Services and made available via the Services, and protection from fraud or security threats.
  • We process your Personal Information when necessary to ensure compliance with a legal obligation to which we are subject.
  • We process your Personal Information to protection an individual’s vital interests.
Your Rights With Respect To Personal Information. Subject to certain conditions, if you are a resident of the EEA or UK and have submitted Personal Information to us, you have the right to access, correct, delete, or object to or restrict the use of certain Personal Information covered by this Privacy Policy. You may also have the right to request the following: a copy of your Personal Information in a structured, commonly used and machine-readable format and/or request that we transmit that Personal Information to a third party where this is technically feasible, and that we refrain from processing Personal Information. To honor any requests, we will take steps (and may need to collect information from you) to verify your identity. You can also designate an authorized agent to make a request on your behalf. If you use an authorized agent, please include written permission that you have designated that agent to make the request or proof of the agent’s power of attorney. We may follow up with you to verify your identity before processing your authorized agent’s request. We will only use Personal Information provided in the verification process for identity verification purposes. Please note that if you exercise such rights, this may affect our ability to provide the Services to you. While we will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such requests or deny certain requests, to the extent allowed or required by applicable law. For inquiries about your Personal Information, please contact us through one of the methods listed in the “Contact Us” Section below. You have the right to lodge a complaint about the processing of your Personal Information with a supervisory authority. Withdrawal of Consent. Where you have given us valid, explicit consent to collect, use and process your Personal Information, we will rely on your valid, explicit consent. In instances in which we have based our processing of your Personal Information on your consent, you have the right to withdraw your consent. To withdraw such consent, please contact us through the methods listed below. Please note that when you withdraw consent, we might not be able to provide you with the Services. In certain situations, we may continue to process your Personal Information after you have withdrawn consent and requested that we delete your Personal Information, if we have a legal basis to do so. For example, we may retain certain information if we need to do so to comply with a legal obligation or if it is necessary to do so to pursue our legitimate interest in keeping the Services safe and secure. International Transfers of Personal Information. We are headquartered and operate in the United States. If you visit or use the Services, or contact us from outside the United States, please be advised that (i) any Personal Information you provide to us or that we automatically collect will be transferred to the United States; and (ii) by using or submitting Personal Information through the Services, you explicitly authorize the transfer to and subsequent processing in the United States, and other countries in which we operate, in accordance with this Privacy Policy. Please be advised that the United States and other countries may not offer the same privacy protections as the laws of the jurisdiction where you reside. Data Retention We retain Personal Information we collect as long as it is necessary and relevant to fulfill the purposes outlined in this Privacy Policy. Subject to applicable law, we may also retain Personal Information to resolve disputes, enforce any of our terms of service or engage in other actions permitted by applicable law. Children’s Privacy The Services are intended for users 18 years of age or older. You are not permitted to use the Services if you are younger than 18 years of age without parental or guardian consent. In accordance with applicable children’s data protection laws, we do not knowingly collect Personal Information from children under the age of 18. If we learn we have collected or received Personal Information from a child under 18 years of age without authorization, verification or parental consent, we will promptly delete that information. Security of Your Personal Information We maintain administrative, physical and technical safeguards designed to protect the Personal Information we collect and maintain. However, no data transmission over the internet is ever 100% secure. As a result, while we strive to protect your information, we cannot guarantee or warrant the security of any information you transmit via the Services. “Shine the Light” Law Under California Civil Code Section 1798.83, California residents are entitled to request and obtain from us once per calendar year information about when we share your Personal Information with third parties for those third parties’ own direct marketing purposes. To request this information, please contact us by email and indicate “California Shine the Light” in the subject line. In the past year, we have not shared Personal Information with third parties for those third parties’ own direct marketing purposes. Email Marketing We, or third parties on our behalf, may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email sent by us or on our behalf or by contacting us. Your option not to receive marketing material shall not preclude us from: corresponding with you, by email or otherwise, regarding your relationship with us; accessing your Personal Information for our internal business purposes; or disclosing your Personal Information as described in this Privacy Policy for purposes other than sending you marketing materials. Notification of Changes We reserve the right to update, modify or change this Privacy Policy from time to time. If we make a material change to the way we intend to use your Personal Information, we will notify you by updating this Privacy Policy and modifying the date updated at the beginning of this Privacy Policy. We encourage you to review the Privacy Policy whenever you access the Services to stay informed about our privacy practices. Contact Us We seek to resolve any issues that you have with our privacy practices. If you have questions or complaints regarding this Privacy Policy, please contact us at through email at: support@skip.money or by telephone at: +1 (646) 258-3405. Please include “Privacy” in the subject line of your inquiry.