This Privacy Policy ("Policy") describes how UNREAL VENTURES LLC, operating under the Trust Vault brand ("Trust Vault", "we", "us", "our") collects and processes your personal data ("you", "your") through our websites (trustvault-app.com) and applications or other services (together with our websites and applications - our "Services"). By using our Services or interacting with us, you agree to the collection, storage, processing and transfer of your personal data as described in this Privacy Policy.

1. Our relationship with you

Your right to privacy and protection of personal data is important to us. Trust Vault is committed to best practices in privacy, and we will only collect data when strictly necessary to provide our Services.

By using Trust Vault Services, including visiting our website, using our application, interacting on social media or community forums, participating in our offline events, you acknowledge and accept the use, disclosure and procedures outlined in this Privacy Policy.

2. Collection and use of your personal data

"Personal data" is information that can identify a person or relates to an identifiable individual. Following privacy best practices, we strive to collect only the amount of personal data necessary to provide our Services to users.

When using our self-custody wallet

As a user of our wallet application, whether through the app or browser extension, you have the option to create or import wallet information that is stored locally on your device. We do not collect email addresses or any other categories of personal data for this purpose.

When visiting our website

When you use our website, read our blog, request customer support, participate in our community forum or campaigns, you may provide personal data. Note that we do not request your wallet information for these purposes. You can access our forum without creating an account, although you have the option to create a profile if you want to interact with other participants.

Recruitment and employment

If you apply for a position with us or become our employee, we collect and process your personal data for purposes including recruitment, onboarding, employment administration, compliance with legal obligations, and other employment-related activities.

Push notifications

We may send you additional push notifications through our app to provide alerts, updates, or news relevant to your interests. These notifications are sent based on your preferences, which you can manage or revoke at any time through the app's notification settings.

Biometric authentication (Face ID and fingerprint scanning)

We offer optional biometric authentication (such as Face ID or fingerprint recognition) as a secure and convenient method to access your wallet. If you choose to enable biometric authentication, your biometric data is processed directly on your device using the mobile operating system's built-in security features. Biometric authentication information is never transmitted to our servers or third parties.

Personal data collected automatically

In certain circumstances, we may collect personal data automatically from you when using our Services in accordance with applicable laws. This may include device data, logs, and usage data, which helps us improve your experience, provide customer support, improve the performance of our sites and Services, and protect your account by detecting unauthorized access and preventing fraud.

3. Use of cookies

We use cookies and similar tools to enhance user experience, provide our services, improve our marketing efforts, and understand how customers use our services so we can make improvements. Depending on applicable laws in the region where you are located, a cookie banner in your browser will inform you how to accept or decline cookies.

4. How and why we share your data

Information about our users is an important part of our business, and we are not in the business of selling our users' personal data to others. We may share personal data with our service providers or third parties in connection with Trust Vault activities, as certain Trust Vault features rely on various third-party products and services, such as web hosting processing, cloud storage, analytics, and improvement of website-related services and features.

We may also share personal data with the following parties or in the following circumstances:

• Business transfers: As our business develops, we may sell or buy other businesses or services. In such transactions, user information is usually one of the transferred business assets, but remains subject to promises made in any pre-existing Privacy Policy.
• Legal authorities: We may be required by law or court order to disclose certain information, which may cover personal data or any interaction we may have with relevant regulatory, law enforcement and/or other competent authorities.
• Protection of us and others: We will share personal data outside Trust Vault if we have reasonable grounds to believe that access, use, retention or disclosure of information is reasonably necessary to comply with any applicable law, regulation, legal process or enforceable government request.

5. International transfer of personal data

We maintain servers hosted by our trusted service providers, and your information may be processed on servers located outside your country of residence. Additionally, we may transfer your personal data to our affiliates, third-party partners, and service providers located in various countries worldwide.

In cases where we process your personal data on servers outside your country or transfer it to third countries or international organizations outside your country of residence, we implement appropriate technical, organizational, and contractual security measures to ensure protection of your personal data.

6. Data security

We recognize that information security is a critical component of data privacy. We are committed to ensuring protection of your information in accordance with applicable laws and our data privacy policies. While no data transmission, including transmission over the Internet or through any website, can be guaranteed as completely secure, we employ a range of commercially reasonable physical, technical, and procedural measures to protect personal data from unauthorized access, use, disclosure, alteration, or destruction.

If you are a user of our self-custody wallet, remember that your wallet information and private key are stored locally on your device and remain under your personal control. To protect wallet information, ensure that access controls and password are enabled on your device and wallet app. It is important to keep your password secret and not share it with anyone.

7. Data retention

We retain your personal data to ensure your continued use of our Services, for as long as required to fulfill the relevant purposes described in this Privacy Policy, or as may be required by law for tax and accounting purposes, or to resolve disputes and/or legal claims.

Note that even if you delete your wallet addresses from the Trust Vault mobile app, delete Trust Vault mobile apps from your device, or request deletion of your information, the right to delete/erase your personal data is not absolute in some circumstances. This is because blockchains are public decentralized networks, and blockchain technology generally does not allow data deletion.

8. What privacy rights do you have?

Under applicable law, as indicated below, you have a number of rights regarding your privacy and protection of your personal data. You have the right to request access to your personal data, correction and deletion, as well as request data portability.

• Right to access: You have the right to obtain a copy of the personal data we hold about you, as well as certain information related to its processing.
• Right to correction: You may request correction of inaccurate personal data and provide additional information to complete your records. You can also change your personal data in your account at any time.
• Request for deletion of your personal data: You may request deletion of your personal data, including cases where such personal data is no longer needed to achieve the purposes for which it was collected.
• Right to object: You may object to the processing of your personal data for reasons related to your situation. For example, you have the right to object when we rely on legitimate interest or when we process your data for direct marketing purposes.
• Right to restrict processing: In certain cases, you have the right to temporarily restrict our processing of your personal data, provided there are valid grounds for this.
• Right to withdraw or refuse consent: You have the right to withdraw your consent and require us to stop collecting, using and/or disclosing your personal data for any or all purposes listed above at any time.
• Right to portability: You may also request that we provide your information in a structured format so you can send it to another service provider.

Submitting a privacy request

To exercise your rights, you can submit a request by contacting us at support@trustvault-app.com. We will respond as quickly as possible. If we cannot respond within 10 business days, we will notify you in writing of the timeframe for our response.

9. Children

We are particularly sensitive to information about children. Our Services are not intended for children, and our users must be at least eighteen (18) years old to use our services. We do not knowingly request data from or market to persons under 18 years of age. By using the Services, you represent that you are at least 18 years old. If we become aware that we have collected personal data from a person under 18 years of age, we will deactivate the relevant account and take reasonable steps to promptly delete all such data from our records.

10. Terms of use, notices and changes

If you choose to use our Services, your use and any disputes about privacy are subject to this Privacy Policy and our Terms of Use. If you have any privacy concerns at Trust Vault, please contact us and we will do our best to resolve them.

We reserve the right to update and revise this Policy at any time. We will periodically review this Privacy Policy to ensure it complies with applicable laws and reflects changes in our business. If we revise this Privacy Policy, we will update the "Last updated" date at the beginning of this Policy and make every effort to notify you.

11. Privacy team contact information