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PRIVACY POLICY

Last updated: May 20, 2024

This privacy notice for PP ('we', 'us', or 'our') describes how and why we might collect, store, use, and/or share ('process') your information when you use our services ('Services'), such as when you:

- Visit our website at https://pp.one, or any of our websites and mobile applications that link to this privacy notice (including, but not limited to, swap.pp.one and other domain names at any level (subdomains) to the main domain "pp.one" (the "Site"));

- Engage with us in other related ways, including investments, transactions, swaps, sales, marketing, or events.

We restrict access to our Platform (and to any Product/Service) and never collect personal information from individuals located in, resident of, staying in, taxed in, having citizenship of, or using a crypto wallet or IP address in the following countries:

  • United States of America and its territories (American Samoa, Guam, Puerto Rico, the Northern Mariana Islands, and the U.S. Virgin Islands),
  • Canada,
  • New Zealand,
  • European Economic Area (EEA) countries (European Union and its Member States, including Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden Plus the three European Free Trade Association (EFTA) countries – Iceland, Liechtenstein, and Norway),
  • Crypto restricted countries (Afghanistan, Algeria, Bangladesh, Bolivia, China, Costa Rica, Ecuador, Iran, Kuwait, Morocco, Nepal, Nigeria, Oman, Qatar, Saudi Arabia),
  • Prohibited Countries (Myanmar (Burma), Côte D'Ivoire (Ivory Coast), Cuba, Crimea and Sevastopol, the so-called Donetsk People's Republic, Democratic Republic of the Congo, Iraq, Libya, the so-called Luhansk People's Republic, Mali, Nicaragua, Democratic People's Republic of Korea (North Korea), Somalia, Sudan, Syria, Yemen, Zimbabwe) and other countries whose access is restricted by these Legal Terms.

The collection of information from individuals in the above mentioned countries is handled exclusively by third parties (like Google which is responsible for handling, keeping and protecting it), which automatically occurs during your transition to or visit of our website, following our links on the internet or third-party messengers, or using search engines.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice. You can find more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the Products and features you use.

Learn more about the personal information you disclose to us.

Do we process any sensitive personal information? We may process sensitive personal information when necessary, with your consent or as otherwise permitted by applicable law. Learn more about the sensitive information we process. Do we receive any information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other external sources.

Learn more about the information collected from other sources.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We only process your information when we have a valid legal basis to do so. Learn more about how we process your information.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

Learn more about how we keep your information safe.

What are your rights? Depending on your geographical location, the applicable privacy law may grant you certain rights regarding your personal information.

Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by visiting http://www.pp.one/data-request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the privacy notice in full.

TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE PROCESS YOUR INFORMATION?
  3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
  4. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
  5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
  7. HOW LONG DO WE KEEP YOUR INFORMATION?
  8. HOW DO WE KEEP YOUR INFORMATION SAFE?
  9. WHAT ARE YOUR PRIVACY RIGHTS?
  10. CONTROLS FOR DO-NOT-TRACK FEATURES
  11. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
  12. DO WE MAKE UPDATES TO THIS NOTICE?
  13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

1. WHAT INFORMATION DO WE COLLECT?

Personal Information You Disclose to Us:

In short, we collect personal information that you voluntarily provide to us when registering on the Services, expressing an interest in obtaining information about us or our products and services, participating in activities on the Services, or otherwise contacting us.

Personal Information Provided by You Voluntarily Using the Platform:

The personal information we collect depends on the context of your interactions with us, the Services, the choices you make, and the products and features you use. It may include:

  • Identification and contact data such as your email address, name, and other personal data you provide when communicating with us.
  • Data related to your use of the Platform, such as wallet addresses (public blockchain addresses), transaction, and balance information (blockchain data)..

We do not have access to, nor will we ever ask for, your private keys or wallet seed. Never trust anyone or any application that requests your private keys or wallet seed.

  • Personal data required to comply with anti-money laundering (AML), know-your-client (KYC), and know-your-business (KYB) verification requirements (in limited circumstances, e.g., when registering and completing the Resolver Verification Process).

In some instances, providing your personal data is necessary to access certain products available via our Platform or the information you request. We will inform you when the communication of your personal data is necessary.

All personal information that you provide must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information Automatically Collected:

In short: Certain information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

Like many businesses, we collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: pp.one/privacy-policy.

The automatically collected information includes:

  • Log and Usage Data: Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services, which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, Internet Service Provider (ISP), the date and time of your visit, referring/exit pages, and possibly the number of clicks, among other data. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
  • Location Data: We collect location data, which can be precise or imprecise, depending on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information by refusing access to the information or by disabling your Location setting on your device. However, opting out may affect your ability to use certain aspects of the Services.

Information Collected from Other Sources:

In short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

To enhance our ability to provide relevant marketing, offers, and services to you and to update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g., Facebook, Twitter, Instagram, or Telegram), depending on your privacy settings, we receive personal information about you such as your name, email address, and gender. The specific personal information we collect from your social media account depends on your social media account's privacy settings.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, ensure security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent.

Detailed Processing Activities:

  • To Facilitate Account Creation and Authentication: We may process your information to help you create and log into your account, as well as to maintain your account.
  • To Deliver and Facilitate Delivery of Services: We process your information to provide you with the requested services.
  • To Respond to Inquiries and Offer Support: We may use your information to respond to your inquiries and resolve any issues you might have with the services provided.
  • To Send Administrative Information: We process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
  • To Fulfill and Manage Your Transactions: We process your information to fulfill and manage your investments, transactions, and exchanges made through the Services.
  • To Request Feedback: We may use your information to request feedback and to contact you about your use of our Services.
  • To Send Marketing and Promotional Communications: We process the personal information you provide for our marketing purposes, if this aligns with your marketing preferences. You can opt out of our marketing emails at any time (see "WHAT ARE YOUR PRIVACY RIGHTS?" below for more information).
  • To Deliver Targeted Advertising: We process your information to develop and display personalized content and advertising tailored to your interests, location, and more. For more details, see our Cookie Notice at pp.one/privacy-policy.
  • To Post Testimonials: We post testimonials on our Services that may contain personal information.
  • To Protect Our Services: We may process your information as part of our efforts to keep our Services safe and secure, including monitoring for and preventing fraud.
  • To Evaluate and Improve Our Services, Products, Marketing, and Your Experience: We process your information to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, Products, marketing, and your experience.
  • To Identify Usage Trends: We analyze how you use our Services to better understand their usage and improve them.
  • To Determine the Effectiveness of Our Marketing and Promotional Campaigns: We process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
  • To Comply with Legal Obligations: We process your information to comply with legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers: We may share your data with third-party vendors, service providers, contractors, product engineering providers, and technical maintenance vendors or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do so. They will also not share your personal information with any organization apart from us. They also commit to protecting the data they hold on our behalf and retaining it for the period we instruct. The categories of third parties we may share personal information with are as follows:

  • Ad Networks
  • Finance & Accounting Tools
  • Government Entities (competent courts, public authorities, government agencies, and law enforcement agencies to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement) and private parties, including but not limited to in response to subpoenas, search warrants, or court orders
  • Blockchain networks
  • Payment Processors, smart contracts developers, and providers
  • Sales & Marketing Tools, Affiliate Marketing Programs
  • Testing Tools
  • User Account Registration & Authentication Services, AML compliance and screening service providers to comply with AML laws and regulations and ensure a safe environment within the Platform
  • Website Hosting Service Providers
  • Business partners to assist such partners' investigations including into known cybersecurity breaches or cyber-hacks, or in the case of a serious crime that is likely to affect users of our Platform
  • Communication & Collaboration Tools
  • Data Analytics Services, third parties which may collect your personal data on our Platform via cookies, web beacons, and similar tracking technologies, subject to your prior consent
  • Data Storage Service Providers

We also may need to share your personal information in the following situations:

Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

Business Partners: We may share your information with our business partners to offer you certain Products, Services, or promotions.

4. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES AND THIRD-PARTY SERVICES?

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with our Services. We also use cookies and similar tracking technologies to automatically collect data from and store information on your device when you use, access, or otherwise interact with our Platform.

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantees regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link toward a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice.

We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

We may use Google Analytics to analyze user behavior on the Platform. For more information on how Google Analytics processes your personal data, please refer to the Google Analytics Privacy & Terms.

Please note that we are not responsible for (i) your use of Ethereum or any other blockchain and (ii) the use of your personal data as processed in these decentralized and permissionless blockchain networks. Your private key, which you utilize to access your Ethereum or other blockchain funds and initiate transactions, is stored only on your own device.

You should also be aware that due to the inherent transparency of the blockchain networks, transactions that you approve when using the Platform may be publicly accessible. This includes, but is not limited to, your public sending address, the public address of the receiver, the amount sent or received, and any other data a user has chosen to include in a given transaction.

Transactions and addresses available on blockchain may reveal personal data about the user's identity, and personal data can potentially be correlated now or in the future by any party who chooses to do so, including law enforcement.

We encourage you to review how privacy and transparency on the blockchain network work.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information. We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Cookies and similar tracking technologies, such as "Flash" cookies, "local storage," etc., (referred to as "cookies") are text files that can be stored on your devices when you visit an online service such as an application or a website. Cookies are used to store information on the user's device so that it can be accessed later.

As you navigate through and interact with the Platform, different types of cookies may be placed on your device, and we may ask for your consent to use those cookies. These cookies may be placed directly by us or by third parties. The data we collect automatically includes statistical and performance information arising from your use of the Platform. This type of data will only be used by us in an aggregated or anonymized manner.

Except for cookies that are necessary for the proper functioning of the Platform, you are free to refuse the deposit of cookies on your device at any time. If you do not want cookies to be placed or read on your device and choose this option when presented to you, a refusal cookie will be stored on your device so that we can keep track of your choice. If you delete this cookie, we will no longer be able to know that you have refused the use of cookies. Similarly, when you consent to accept cookies, a consent cookie is placed on your device.

You can choose to disable cookies through your individual browser options. The settings for each browser are different.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (such as your Facebook or Twitter logins). When you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes described in this privacy notice or otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than thirty-six (36) months past the termination of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it. If deletion or anonymization is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. Therefore, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security measures and improperly collect, access, steal, or modify your information.

Although we will do our best to protect your personal information, the transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account and the information we collect at any time. In accordance with applicable personal data protection regulations, you have the following rights: access, rectification, deletion, objection, restriction of processing, and data portability of your personal data.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent by contacting us using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

However, please note that withdrawing your consent will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

ACCOUNT INFORMATION

If you would like to review or change the information in your account or terminate your account, you can: log in to your account settings and update your user account. Alternatively, you can request information we keep by sending a request to [email protected].

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.

Cookies and Similar Technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services. For further information, please see our Cookie Notice: pp.one/privacy policy.

If you have questions or comments about your privacy rights, you may email us at [email protected]. Please note that some of these rights are subject to specific conditions set out in the applicable personal data protection regulation. Therefore, if your particular situation does not meet these conditions, we will unfortunately not be able to respond to your request. In this case, we will inform you of the reasons for our refusal.

Right of access: You may request access to your personal data at any time. If you exercise your right of access, we will provide you with a copy of the personal data we hold about you as well as information relating to its processing.

Right of rectification: You have the right to ask us to rectify or complete any personal data in our possession that you consider to be inaccurate or incomplete.

Right to erasure / to be forgotten: You can ask us to delete your personal data if, for example, it is no longer necessary for the processing we carry out. We will use our best efforts to comply with your request. Please note, however, that we may have to retain some or all of your personal data if we are required to do so by applicable law or if the personal data is necessary for the establishment, exercise, or defense of our rights.

Right to restriction of processing: You may also request that we restrict the processing of your Personal Data on grounds relating to your particular situation. For example, if you dispute the accuracy of your personal data or object to the processing of your personal data, you may also request that we do not process your personal data for the time necessary to verify and investigate your claims.

In such cases, we will temporarily refrain from processing your personal data until necessary verifications have been made or until we comply with your requests.

Right to data portability: You may request portability of the personal data you have provided us with. At your request, we will provide you with your personal data in a readable and structured format, so you can easily re-use it.

The portability of your personal data applies only to personal data that you have provided to us or that result from your activity on the Platform, under the condition that the disclosure of your personal data does not infringe the rights of third parties. If we are unable to comply with your request, we will inform you of the reasons for our refusal.

Right to object: You may object at any time, on grounds relating to your particular situation, if we use your personal data. We will then stop processing of your personal data unless there are overriding legitimate grounds for continuing to process your personal data (for example, if your personal data is necessary for the establishment, exercise, or defense of our rights or the rights of third parties in court proceedings). If we are unable to comply with your request to object, we will inform you of the reasons for our refusal. You can also object at any time to our processing of your personal data for marketing purposes.

Right to withdraw consent: You have the right to withdraw consent at any time for processing of your personal data based on consent. Withdrawing your consent prevents us from processing your personal data but does not affect the lawfulness of the processing carried out before the withdrawal.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (DNT) feature or setting that you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

11. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in. You may also be granted specific rights regarding our processing of your personal data depending on the law applicable in the country you are residing in. You may contact us if you have any questions in that regard.

Also, keep in mind that many blockchains are open to forensic analysis, which can lead to deanonymization and the unintentional revelation of personal data, particularly when blockchain data is combined with other data. Because blockchains are decentralized or third-party networks that are not controlled or operated by us, we are not able to erase, modify, or alter your personal data from such networks.

12. DO WE MAKE UPDATES TO THIS PRIVACY POLICY NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws. We periodically review this Policy to ensure it is compliant and up to date with applicable data protection regulations. We will post updates on this page accordingly. When changes are made, we will update the “Last updated” date at the top of this Policy.

Therefore, we encourage you to review this Policy regularly. Any modifications will take effect when posted or on the date specified as the effective date (if any). Your continued access to and use of the Platform indicates your acknowledgment and acceptance of the updated Privacy Policy.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at [email protected].

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