Privacy Policy

Rugpullfinder, Ltd - Privacy Policy - Last Revised: 27 Jun 2022

This Privacy Policy is designed to help you understand how Rugpullfinder, Ltd. (collectively with anysubsidiaries, called “Rug Pull Finder”, “we”, “us”, and “our”) collects, uses, and shares your personalinformation and to help you understand and exercise your privacy rights. This Policy should be read in conjunction with our Terms of Service (“Terms”) into which this Policy is incorporated by reference.

Your privacy matters to us, so please do take the time to get to know and familiarize yourself with our policies and practices. Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not use our Platform. By using our Platform, you agree to the terms of this Policy.

This Privacy Policy applies to personal information processed by us, through our websites, mobileapplications and any other services or interfaces owned or controlled by Rug Pull Finder that post a linkto this Privacy Policy (each a “Service” and together, the “Services”). For the avoidance of doubt, Rug PullFinder does not control the blockchain protocol (“Protocol”) on which non-fungible tokens (“NFTs”) aretradable or useable and cannot control activity and data on the Protocol, the validation of transactions onthe Protocol, or use of the Protocol.

We may revise this Privacy Policy from time to time at our sole discretion. If there are any material changesto this Privacy Policy, we will notify you as required by applicable You understand and agree that you willbe deemed to have accepted the updated Privacy Policy if you continue to use our Services after the newPrivacy Policy takes effect.

We collect Personal Information about you in an attempt to provide you with the best experience possible,protect you from risks related to improper use and fraud, and help us maintain and improve our Services. We collect information that you provide to us, information we obtain automatically when you use ourServices, and information from other sources such as third-party services and organizations, as described below.

Information You Provide to Us Directly

We may collect the following personal information that you provide to us:
- Account Creation. We may collection information when you create an account with us or our service providers, such as name and email address. We may also require that you provide additional identity and verification information
- Purchases, Wallet and Transaction Information. In order to engage in certain transactions or purchases on the Services, you may need to provide us or our third-party payment processors with your payment information and allow us to connect to your digital wallet by providing us with your public wallet address. We will never ask you or collect your private keys. We do not directly collect or store any payment card information entered through our Services or access your digital wallet, but we may receive from our third-party payment processing providers information associated with your payment card information (e.g., your billing details).
- Other Transactions. We may collect personal information and details associated with your activities on our Services.
- Your Communications with Us. We may collect personal information, such as email address, phone number or mailing address when you request information about our Services, register for our newsletter, apply for a job or otherwise communicate with us.
- Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., via the Rug Pull Finder community on Discord, messaging and chat features, and social media pages). Any personal information you provide on the public sections of these features will be considered “public, ”unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users.
- Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
- Sweepstakes, Giveaways or Contents. We may collect personal information you provide for any sweepstakes, giveaways, 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.

Information Collected Automatically

We may collect personal information automatically when you use our Services such as:
- Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet Protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), Internet service provider, and metadata about the content you provide. We may also automatically collect information regarding your use of our Services, such as pages you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you user our Services.
- Cookie Policy for Cookies and Other Technologies. We, as well as third parties that provide content or other functionality on our Services, may use cookies, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.
- Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
- Our uses of these Technologies fall into the following general categories:
o Analytics. We may use our Technologies and other third-party tools to process analytics information on our Services. These technologies allow us to process usage data to better understand how our Services are used, and to continually improve and personalize our Services. Some of our analytics partners include:
o Google Analytics. For more information about how Google uses your data (including for its own purposes, e.g., for profiling or linking it to their data), please visit Google Analytics’ Privacy Policy.
o Social Media Platforms. Our Services may contain social media buttons, such as Discord, Twitter, Instagram, LinkedIn, Youtube, and others, which might include widgets such as “share this” button or other interactive mini programs. These features may collect your IP address and which page you are visiting on our Services and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

Information Collected from Other Sources

- Third-party Sources. We may obtain 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 as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.
- Sharing Features. Our Services may offer various tools and functionalities that allow you to provide information about your friends; third parties may also use these services to upload information about you. Our Services may also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).

We collect Personal Information about you in an attempt to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve our Services.

We may use your Personal Information to:
- Provide Our Services We use your information to fulfill our contract with you and provide you with our Services and perform our contract with you, such as:
- Managing your information;
- Providing access to certain areas, functionalities, and features of our Services;
- Answering requests for customer or technical support;
- Communicating with you about your account, activities on our Services, and policy changes;
- Processing your financial information and other payment methods to facilitate purchases and transfers via the Services;
- Allowing you to register for sweepstakes, giveaways, or events.

Administrative Purposes
We use your information for our legitimate interest, such as:
- Pursuing our legitimate interests such as direct marketing, research and development (includingmarketing research), network and information security, and fraud prevention
- Measuring interest and engagement with our Services;
- Improving, upgrading or enhancing our Services;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity,and prosecuting those responsible for that activity;
- Ensuring internal quality control and safety;
- Authenticating and verifying individual identities;
- Debugging to identify and repair errors with our Services:
- Auditing relating to interactions, transfers, and other compliance activities;
- Sharing information with third parties as needed to provide the Services;
- Enforcing our agreements and policies; and
- Other uses as required to comply with our legal and regulatory obligations.

Marketing our Products and Services
We may use personal information to tailor and provide you with content. We may provide you with these materials as permitted by applicable law. Some of the ways we may market to you include emailcampaigns.If you have any questions about our marketing practices or if you would like to opt out of the use of yourpersonal information for marketing purposes, you may contact us at any time as set forth in “Contact Us”below.

With Your Consent
We may use personal information for other purposes that are clearly disclosed to you at the time youprovide personal information or with your consent.

Other Purposes
We may use your information for other purposes as requested by you or as permitted by applicable law.De-identified and Aggregated Information. We may use personal information and other information aboutyou to create de-identified and/or aggregated information, such as de-identified demographicinformation, de-identified location information, information about the device from which you access ourServices, or other analyses we create.

We will never sell, share, rent, or trade your Personal Information with third parties for their commercial purposes. Further, we will not share your Personal Information with third parties, except as described below. Disclosures to Provide our Services

The categories of third parties with whom we may share your information are described below:
- Notice Regarding Use of Blockchain. Transactions involving our NFTs will be conducted on therelevant Protocol. Information about your transfers will be provided to the blockchain and maybe accessible to third parties due to the public nature of the blockchain. Because entries to the blockchain are, by their nature, public, and because it may be possible for someone to identify you through your pseudonymous, public wallet address using external sources of information, any transaction you enter onto the blockchain could possibly be used to identify you, or information about you.
- Other Users of the Services and Parties You Transact With. Some of your personal information may be visible to other users of the Services (e.g., information featured on generally accessibleparts of the contracts or on a user profile). In addition, to complete transfers via the Services, we will need to shar esome your personal information with the party that you are transacting with.
- Third Party Websites and Applications. You may choose to share personal information or interactwith third-party websites and/or third-party applications, including, but not limited to, third-party electronic wallet extensions. Once your personal information has been shared with a third-party website or a third-party application, it will also be subject to such third party’s privacy policy. We encourage you to closely reach each third-party website or third-party application privacy policy before sharing your personal information or otherwise interacting with them. Please note that wedo not control, and we are not responsible for the third-party website’s or the third-partyapplication’s processing of your personal information.
- Service Providers. We may share your personal information with our third-party service providerswho use that information to help us provide our Services. This includes service providers thatprovide us with IT support, hosting, customer service, and related services.
- Business Partners. We may share your personal information with business partners to provideyou with a product or service you have requested. We may also share your personal informationto business partners with whom we jointly offer products or services.
- Affiliates. We may share your personal information with members of our corporate family.- APIs/SDKs. We may use third-party application program interfaces (“APIs”) and softwaredevelopment kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.

Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assistwith an investigation or prosecution of suspected or actual illegal activity.

Disclosures in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy,receivership, purchase or sale of assets, or transition of service to another provider, your information maybe sold or transferred as part of such a transaction, as permitted by law and/or cpntract.Professional AdvisorsWe may share your Personal Information with our professional advisors, including legal, accounting, orother consulting services for purposes of audits or to comply with our legal obligations.

We may share your Personal Information with your consent.

Your Privacy Choices. The privacy choices you may have about your personal information are determinedby applicable law and are described below:
- Email Communications. If you receive unwanted email from us, you can use the unsubscribe linkfound at the bottom of the email to op out of receiving future emails. Note that you will continue to receive transfer-related emails regarding services you have requested. We may also send youcertain non-promotional communications regaerding us and our Services, and you will not be ableto opt out of those communications (e.g., comminciations regarding our Services or updates toour Terms or this Privacy Policy.
- “Do Not Track”. Do Not Track (“DNT” is a privacy preference that users can set in certain webbrowsers. Please note that we do not respond to or honor DNT signals or similar mechanismstransmitted by web browsers.
- Cookies. You may stop or restrict the placement of Technologies on your device or remove themby adjusting your preferences as your browser or device permits. However, if you adjust yourpreferences, our Services may not work properly. Please note that cookie-based opt-outs are noteffective on mobile applications

Your Privacy Rights. In accordance with applicable law, you may have the right to:
- Access Personal Information about you, including: (i) confirming whether we are processing yourpersonal information, (ii) obtaining access to or a copy of your personal information;, or (iii)receiving an electronic copy of personal information that you have provided to us, por asking usto send that information to another company (the right of data portability);
- Request Correction of your personal information where it is inaccurate or incomplete. In somecases, we may provide self-service tools that enable you to update your personal information;
- Request Deletion of your personal information;
- Request Restriction of or Object to our processing of your personal information, including wherethe process of your personal information is based on our legitimate interest or for direct marketing purposes; and
- Withdraw Your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness ofprocessing before the withdraw.If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

We take steps designed to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure. By using our Services or providing your personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relation to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by postinga notice on our Services, by mail or by sending an email to you.

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United Kingdom, the United State or other countries, which may havedata protection laws that are different from the laws where you live. We endeavor to safeguard yourinformation consistent with the requirements of applicable laws.

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enfoce ouragreements, and comply with applicable laws.

While customers who are located in the European Union (“EU”), European Economic Area (“EEA”) or theChannel Islands, or other locations subject to EU data protection law (collectively, “Europe”) are customers of our United Kingdom entity, we recognize and, to the extent applicable to us, adhere torelevant EU data protection laws. For purposes of this section, “personal data” has the meaning providedin the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
- Lawful Bases for Processing. We process personal data subject to GDPR on one or more of thefollowing legal bases:
- Legal Obligation: to conduct anti-fraud and to fulfill our retention and other legal obligations;
- Contractual Obligation: to satisfy our obligations to you under our Terms, including to provide youwith our Services and customer support services, and to optimize and enhance our Services;
- Legitimate Interest: to monitor the usage of our Services, conduct automated and manual securitychecks of our Services, to protect our rights; and
- Consent: to market Rug Pull Finder and our Services. You may withdraw your consent at any timewithout affecting the lawfulness of processing based on consent before consent is withdrawn.

European Privacy Rights. European residents have the following rights under GDPR, subject to certainexceptions provided under the law, with respect to their personal data:
- Rights to Access and Rectification. You may submit a request that Icy Labs disclose the personaldata that we process about you and correct any inaccurate personal data.
- Right to Erasure. You may submit a request that Icy Labs delete the personal data that we haveabout you.- Right to Restriction of Processing. You have the right to restrict or object to our processing of yourpersonal data under certain circumstances.
- Right to Data Portability. You have the right to receive the personal data you have provided to usin an electronic format and to transmit that personal data to another data controller.If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws. When handling requests to exercise European privacy rights, we check the identity of the requesting party to ensure that he or she is the person legally entitled to make such request. While we maintain a policy to respond to these requests free of charge, should your request be repetitive or unduly onerous, we reserve the right to charge you a reasonable fee for compliance with your request.

Collection and Transfer of Data Outside of EEA
Rug Pull Finder operates with many of our systems based in the United Kingdom and the United States. As a result, we may transfer personal data from Europe to third countries outside of Europe, including the United States, under the following conditions:
- Contractual Obligation. Where transfers are necessary to satisfy our obligation to you under ourTerms, including to provide you with our Services and customer support services, and to optimize and enhance our Services; and
- Consent: where you have consented to the transfer of your personal data to a third country.Where transfers to a third country are based on your consent, you may withdraw your consent at anytime. Please understand, however, that our services may not be available if we are unable to transferpersonal data to third countries. When we transfer personal data to third countries, we endeavor to ensure adequate safeguards areimplemented, for example through the use of standard contractual clauses or Privacy Shield certification.

While customers who are located in California, United States subject to California Consumer Privacy Actof 2018 (“CCPA”) are customers of our United Kingdom entity, we recognize and, to the extent applicableto us, adhere to relevant CCPA data protection laws. The CCPA provides California residents the right toknow what categories of personal information we collected about them and whether we disclosed thatpersonal information for a business purpose (e.g. to a service provider) in the preceding twelve months. The categories of sources from which we collect personal information and our business and commercialpurposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Information” above, respectively.
“Sales” of Personal Information under the CCPA. For purposes of the CCPA, Rug Pull Finder does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

Additional Privacy Rights for California Residents
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us forthe exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiableconsumer request related to your personal information. To designate an authorized agent, please contactus as set forth in “Contact Us” below.If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. When handling requests to exercise CCPA privacy rights, we check the identity of the requesting party toensure that he or she is the person legally entitled to make such request. While we maintain a policy torespond to these requests free of charge, should your request be repetitive or unduly onerous, we reservethe right to charge you a reasonable fee for compliance with your request

The Services are not directed to children under 16 (or other age as required by local law), and we do notknowingly collect personal information from children. If you are a parent or guardian and believe yourchild has provided us with personal information without your consent, you may contact us as set forth in“Contact Us” below. If we learn that a child has provided us with personal information in violation ofapplicable law, we will promptly take steps to delete such information, unless we have a legal obligationto maintain it.

The Services may contain links to other websites/applications and other websites/applications mayreference or link to our Services. These third-party services are not controlled by us. We encourage ourusers to read the privacy policies of each website and application with which they interact. We do notendorse, screen or approve, and are not responsible for, the privacy practice or content of such otherwebsites or applications. Providing personal information to third-party websites or applications is at yourown risk.

If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the rightto lodge a complaint with a supervisory authority if you believe our processing of your personalinformation violates applicable law.

15. CONTACT USIf you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as