Privacy Policy

Effective as of August 29, 2024 This Privacy Policy describes how DFlow Inc. (“DFlow,” “we”, “us” or “our”) handles personal information that we collect through our digital properties that link to this Privacy Policy, including our website, mobile application, as well as through social media, our marketing activities, and other activities described in this Privacy Policy (collectively, the “Service”).

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Personal Information We Collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes: • Contact data, such as your first and last name, email address, professional title, and phone number. • Profile data, such as the username and password that you may set to establish an online account on the Service, crypto wallet address, and any other information that you add to your account profile. • Communications that we exchange with you, including when you contact us through the Service, social media, or otherwise. • Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order flow bids, sales offers and purchase history. • Blockchain data, such as crypto wallet accounts and associated details. • Financial data, such as your virtual currency or wallet accounts, stored value accounts, and associated details. • Investment data, such as royalties, fees, sales prices, and digital asset data. • Marketing data, such as your preferences for receiving our marketing communications and any information you provide when you engage with them. • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection. THIRD-PARTY SOURCES. We may combine personal information we receive from you with personal information we obtain from other sources, such as: • Public sources, such as public blockchains such as Solana, social media platforms, and other publicly available sources. • Data providers, such as information services and data licensors that provide demographic and other information. • Marketing partners, such as joint marketing partners. • Third-party services, such as web3 authentication services, that you use to log into, or otherwise link to, your Service account. This data may include your wallet address and other information associated with your account on that third-party service that is made available to us based on your account settings on that service. AUTOMATIC DATA COLLECTION. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as: • Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area. • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them. • Location data when you authorize the Service to access your device’s location. o Communication interaction data, such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails. COOKIES AND OTHER TECHNOLOGIES. Some of the automatic collection described above is facilitated by the following technologies: • Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers’ place. • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications. • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email address was accessed or opened, or that certain content was viewed or clicked. • Software development kits, or SDK, is third-party computer code that we may incorporate into our mobile applications that may be used for a variety of purposes, including to provide us with analytics regarding the use of our mobile applications, to integrate with social media, or add features or functionality to our app. • Chat technologies, such as those provided by Intercom that to operate the chat features that you can use to communicate with us through the Service. Intercom and other third parties may access and use information about webpages visited on our website, your IP address, your general geographic information (e.g., city, state), and other personal information you share through online chats for the purposes described in this Privacy Policy. You can learn more about Intercom at https://www.intercom.com/legal/privacy.

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How We Use Your Personal Information

We may use your personal information for the following purposes or as otherwise described at the time of collection: SERVICE DELIVERY. We may use your personal information to: • provide, operate and improve the Service and our business; • establish and maintain your user profile on the Service; • personalizing the service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service; • communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages; • understand your needs and interests, and personalize your experience with the Service and our communications; and • provide support for the Service, and respond to your requests, questions and feedback. RESEARCH AND DEVELOPMENT. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business. MARKETING AND ADVERTISING. We and our service providers and our third-party advertising partners may collect and use your personal information for direct marketing purposes. • Direct marketing. We may send you DFlow-related marketing communications about our products, services or promotions that may be of interest to you. You may opt-out of our marketing communications as described in the Opt-out of marketing section below. • Interest-based advertising. We and our third-party advertising partners may use cookies and similar technologies to collect information about your interaction with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. SERVICE IMPROVEMENT AND ANALYTICS. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services. COMPLIANCE AND PROTECTION. We may use your personal information to: • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities; • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); • audit our internal processes for compliance with legal and contractual requirements or our internal policies; • enforce the terms and conditions that govern the Service; and • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft. WITH YOUR CONSENT. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law. COOKIES AND OTHER TECHNOLOGIES. In addition to the other uses included in this section, we may use the Cookies and other technologies described above for the following purposes: • Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site. • Functionality. To enhance the performance and functionality of our services. • Advertising. To help our third-party advertising partners collect information about how you use the Service and other online services over time, which they use to show you ads on other online services they believe will interest you and measure how the ads perform. • Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en. RETENTION. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

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How We Share Your Personal Information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection. AFFILIATES. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy. SERVICE PROVIDERS. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, online chat functionality providers, customer support, email delivery, marketing, consumer research and website analytics). THIRD PARTIES DESIGNATED BY YOU. We may share your personal information with third parties where you have instructed us or provided your consent to do so. CRYPTOCURRENCY PLATFORMS. Any information collected necessary to process a digital asset order (such as your wallet address) is collected and processed directly by your chosen cryptocurrency platform. Please review the privacy policies for the relevant cryptocurrency platform to learn how they may use your payment information. LINKED THIRD-PARTY SERVICES. If you log into the Service with, or otherwise link your Service account to, a third-party service such as Dynamic, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service. To learn more about how Dynamic handles your personal information, please refer to their privacy policy located at https://www.dynamic.xyz/privacy-policy. ADVERTISING PARTNERS. Third-party advertising companies for the interest-based advertising purposes described above. BUSINESS AND MARKETING PARTNERS. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you. PROFESSIONAL ADVISORS. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us. AUTHORITIES AND OTHERS. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above. BUSINESS TRANSFEREES. Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, DFlow or our affiliates (including, in connection with a bankruptcy or similar proceedings).

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Your Choices

ACCESS OR UPDATE YOUR INFORMATION. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account. OPT-OUT OF MARKETING COMMUNICATIONS. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. COOKIES. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. DO NOT TRACK. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track.” To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com. DECLINING TO PROVIDE INFORMATION. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services. DELETE YOUR CONTENT OR CLOSE YOUR ACCOUNT. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us. ADVERTISING CHOICES. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools: • Browser settings. Changing your internet web browser settings to block third-party cookies. • Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies. • Platform settings. Certain platforms offer opt-out features that let you opt-out of use of your information for interest-based advertising. For example, you may be able to exercise that option for Google and Facebook, respectively, at the following websites: o Google: https://adssettings.google.com/ o Facebook: https://www.facebook.com/about/ads • Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs: o Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp o Digital Advertising Alliance: optout.aboutads.info. o AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance. You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes. We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above. OTHER SITES AND SERVICES The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use. SECURITY We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information. INTERNATIONAL DATA TRANSFER We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country. CHILDREN The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information. CHANGES TO THIS PRIVACY POLICY We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

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How to Contact Us

Email: hello@dflow.net