🌗Pencils Protocol Privacy Policy

Issue date: 1 April 2023

Effective date: 1 April 2023

1. Introduction

The website(https://pencilsprotocol.io) (hereinafter referred to as the “Website”), is a platform operated by Pencils Protocol (hereinafter referred to as “we”, “us” or “Pencils Protocol”) to provide crypto-assets related services (hereinafter referred to as the “Services”). By continuing to access or use the Services provided by us, you confirm that you have carefully read and fully understood and consent to the policies and practices of our privacy policy (hereinafter referred to as the “Privacy Policy”). This Privacy Policy explains our policies and practices regarding the collection, use, and disclosure of data when you access and/or use our Services, the choices you have associated with that data, and how you can contact us about our privacy practices. We may update this Privacy Policy at any time by posting the amended version (including the effective date of the amended version) on our Website.

This Privacy Policy forms part of our Pencils Protocol General Terms and Conditions of Service (hereinafter referred to as the “Terms and Conditions”) and together with the Terms and Conditions govern your use of our Website. If you do not agree with this Privacy Policy or Our Terms and Conditions, please do not use the Website. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

At Pencils Protocol we respect the privacy of our visitors’, users’, and clients’ (also referred to as “you” or “your”) privacy. We do not rent, sell or trade the Personal Information we have collected about our visitors, users, and clients.

For purposes of this Privacy Policy, “Personal Information” is any information that identifies, relates to, or describes, directly or indirectly, an individual or household. This Privacy Policy applies to Personal Information we collect:

· When you access or use the Website.

· In email, text, and other electronic messages between you and us regarding the Website.

· Through mobile and desktop applications you download from the Website, which provide dedicated non-browser-based interaction between you and the Website.

· Offline or through any other means, including on any other website operated by us or any third party;

· From any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

2. Information We Collect About You and How We Collect It

We collect several types of information from and about visitors, users, and clients of our Website, including:

· Identifiers and contact information you provide, like your name and email address;

· Anonymous identifiers transmitted to the Website when you access our networks and computers, like IP address (from which we may infer general location information like country or region) and information about your internet connection, the equipment, devices, and browser settings used to access the Website;

· Anonymous information about website traffic and how users interact with the Website;

If you create an account with us or with one of the Services offered on the Website, we will collect the information you create or provide in association with your account (in addition to the information described above), which may include:

· Account log-in credentials for accessing any account you create with us;

· Identity verification information (such as KYC process information) you provide in connection with securing your account;

· Location information (such as country of residence), and social media links or other identifiers you provide as part of your account profile.

Other information we collect when you use or interact with the Website:

· Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, creating an account, or subscribing to a Service offered through the Website;

· Information you provide or that is generated by your use of the Website’s Services;

· Information you provide when communicating with us (records of correspondence, information you provide when reporting a problem).

3. How We Use and Disclose Your Information

We seek to limit our processing of Personal Information and other information we collect as appropriate for the performance of typical business and commercial purposes relation to the operation, maintenance and protection of the Website, and the provision of the Services provided therein. These purposes include:

· To present our Website and its contents to you;

· To provide you with information, products, or Services that you request from us, including the maintenance of any account or profile you create;

· To respond to your inquiries and other communications;

· To perform necessary and industry-appropriate auditing, security, and anti-fraud functions;

· To notify you about changes to our Website or any products or Services we offer or provide through it;

· To comply with legal requirements or to participate in the legal process, including compliance with lawfully issued and appropriate requests from law enforcement, courts, our advisors, attorneys, or others;

· As necessary or appropriate to protect us, you, or others;

· In any other way we may describe when you provide the information;

· For any other purpose with your consent.

Please be informed that, according to the applicable laws, if we take technical measures or other necessary measures for processing Personal Information, that could make the information receiver unable to identify any specific person and cannot retrieve it again, or we may conduct research, statistical analysis or to the collected information in a de-identified manner, to improve the content and layout of this Website, to provide product or Service support to business decisions, and to improve our products and Services (including using anonymous information for machine learning or algorithm model training), such processed information can be used without prior notice to you or obtaining your consent.

4. Third Party Sites and Services

The Website may contain links to third party websites and Services and may collaborate with third parties who provide related Services. For example, Pencils Protocol works with third-party vendors to facilitate users’ participation in those vendors’ token and NFT transactions. We do not endorse or control and are not responsible for the policies and practices of third parties and third-party websites. We make no representations, guarantees, or warranties about the security and privacy of your information on other sites.

This Privacy Policy does not apply to third-party websites, products, or Services, even if we provide links to them or they link to us, which shall be subject to the privacy policy otherwise explained to you by such third-party providers. We urge you to carefully read the privacy policy of any site or Service you access in order to understand its specific privacy and information usage practices.

5. Cookies

When you access our Website, we may place certain data saved on your devices accessing our products and/or Services (i.e. Cookies) in accordance with the market practice, which will be used to recognize you as a client, collect usage information to optimize our customized Services and improve your user experience. Such information may also be used to ensure compliance and account security as well as evaluation and improvement of our Services and marketing activities.

You may reject the use of cookies, but this will affect your use of certain or all of the functions on our Website.

6. Additional Terms

This Privacy Policy may be supplemented by additional terms, privacy statements or notices that explain how we or our partners may collect and process information (including Personal Information) in specific circumstances (“Additional Terms”). For example, if you participate in a specific Service offered in collaboration with a third-party partner, like the auction of a real-world asset, Additional Terms may be disclosed to you when you use that Service that govern your use of that Service.

7. Accessing, Correcting, Deleting or Updating Your Information

If you have an account with Pencils Protocol, you can review and make changes to your account information by logging into the Website and visiting your account profile page.

You may also send us an email at [e-mail] to request access to, correct, or delete any personal information that you have provided to us. We may request additional information in order to verify your identity and locate information relevant to your request. In some circumstances, we may be unable to delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

8. Data of or Relating to Children and Minors

Our Website is not intended for use by individuals who have not attained the age of majority. Persons under the age of majority in their place of residence are not eligible to use the Website, and we do not knowingly collect or store any Personal Information from such persons.

9. Consent to Processing and Transfer of Information

Please be aware that information about you, including but not limited to Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or otherwise to a governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you choose to use the Website, you hereby consent to such transfer, processing, and use.

10. Data Security and User Responsibility for Password Confidentiality

We maintain procedural, technical, and physical safeguards to help protect against loss, misuse or unauthorized access, disclosure, alteration, or destruction of Personal Information.

Despite of the security measures we have implemented and our commitment to safeguard your Personal Information in line with the market standard, we cannot guarantee the absolute security of the transmission of information via the Internet or the electronic storage of information.

If you are aware of any security vulnerabilities on our Website, or you believe that your interaction with us is no longer secure, we welcome any suggestion or report on any security vulnerability that you become aware of or would like to recommend to us.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. It is in your best interest to not share your password with anyone.

11. Updates to This Privacy Policy

We may update this Privacy Policy from time to time, which will be posted by us from time to time on this Website. If you do not agree to the revised content, you shall stop accessing the Website immediately. When an updated version of this Privacy Policy is published, your continued access to the Website shall be deemed as an explicit indication that you agree to the updated content, and you agree to abide by the updated Privacy Policy.

We will notify you by email to the primary email address specified in your account. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

12. How to Contact Us

If you have any questions or concern regarding this Privacy Policy or our processing of your Personal Information, please email us at: [e-mail]. This is our only valid and official channel to receive your feedback., Any communication made other than through this email might not be received by us timely or at all, and you shall be responsible for any loss, omission or delay caused thereby.

We will only communicate or announce notices to you through the official channel of the Website or by posting notice on this Website. We will not be responsible for your loss in relation to your reliance on or trust in any information received other than through the official channels as set out above.