We collect “Non-Personal Information” and “Personal Information.” Non-Personal Information includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks. Personal Information includes your email, first and last name, company name, company address, contact information and other information that is needed for the operation of the mass[Wallets] service as presented on the website, which you submit to us through the registration process at the Site.

To activate the Service you do not need to submit any Personal Information other than your email address. To use the Service thereafter, you do need to submit further Personal Information which may include information that can be used to identify you, such as your email address, first and last name, company name, company address, contact details, account credentials, and any other information you submit to us through the registration process or while using the Service that is needed for the operation of mass[Wallets]. However, in an effort to improve the quality of the Service, we track information provided to us by your browser or by our software application when you view or use the Service, such as the website you came from (known as the “referring URL”), the type of browser you use, the device from which you connected to the Service, the time and date of access, and other information that does not personally identify you. We track this information using cookies, or small text files which include an anonymous unique identifier. Cookies are sent to a user’s browser from our servers and are stored on the user’s computer hard drive. Sending a cookie to a user’s browser enables us to collect Non-Personal information about that user and keep a record of the user’s preferences when utilizing our services, both on an individual and aggregate basis. For example, the Company may use cookies to collect the following information:

• Pages and features you visit or use
• Time spent on the Site or Service
• Referring and exit pages
• Browser type, device type, and operating system
• Approximate location derived from IP address
• Error logs and performance data

Note that public blockchain data is inherently public and the Company does not control it.

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The Company may use both persistent and session cookies; persistent cookies remain on your computer after you close your session and until you delete them, while session cookies expire when you close your browser. For example, we store a persistent cookie to track pages visited, features used, time spent, referring URLs, device/browser type, approximate location (if collected), error logs, performance data.

In addition to the information provided automatically by your browser when you visit the Site, to become a subscriber to the Service you will need to create a personal profile. You can create a profile by registering with the Service and entering your email address, and creating a user name and a password. By registering, you are authorizing us to collect, store and use your email address in accordance with this Privacy Policy.

The Site and the Service are not directed to anyone under the age of 13. The Site does not knowingly collect or solicit information from anyone under the age of 13, or allow anyone under the age of 13 to sign up for the Service. In the event that we learn that we have gathered personal information from anyone under the age of 13 without the consent of a parent or guardian, we will delete that information as soon as possible. If you believe we have collected such information, please contact us at support@masswallets.xyz.

The wallets created through the Service are non-custodial. This means we do not hold, control, or have access to your private keys. You (or the company you represent) remain solely responsible for the security of private keys and any assets associated with the wallets.

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Any transactions or data recorded on public blockchains are publicly visible by design and are outside our control once they are broadcast to the network. Wallet addresses and on-chain activity are generally not considered Personal Information under this Privacy Policy once they exist on a public blockchain. However, any off-chain information we store that is linked to a wallet address (for example, account details associated with a particular wallet) is treated as Personal Information and is covered by this Privacy Policy.

We process Personal Information only when we have a valid legal basis to do so. This may include: (a) performance of a contract with you (or steps necessary to enter into a contract); (b) our legitimate interests in operating, improving, and securing the Service, provided those interests are not overridden by your rights; (c) compliance with legal obligations; or (d) your consent, where we specifically ask for it.

We do not sell your Personal Information. We also do not share your Personal Information for cross-context behavioral advertising. We only share Personal Information with third parties as described in this Privacy Policy (primarily with service providers who assist us in operating the Service, or when required by law). We do share Personal Information with vendors who are performing services for the Company, such as the servers for our email communications who are provided access to user’s email address for purposes of sending emails from us. Those vendors use your Personal Information only at our direction and in accordance with our Privacy Policy.

The Service functions as a user-interface orchestration layer and integrates with multiple external providers. This includes the separate mass[Currency] protocol and related services offered by independent companies. When you use features that interact with mass[Currency] or other external providers, certain information (such as wallet-related metadata or technical identifiers) may be shared with or processed by those third parties in accordance with their own terms and privacy policies. We encourage you to review the privacy practices of any third-party services you interact with through the Service.

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We also share Personal Information with service providers who help us operate the Site and Service (for example, hosting providers, email delivery services, analytics providers, and customer support tools). These providers are only authorized to process Personal Information as necessary to perform services on our behalf and are required to protect it.

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In general, the Personal Information you provide to us is used to help us communicate with you. For example, we use Personal Information to contact users in response to questions, solicit feedback from users, provide technical support, and inform users about promotional offers.

We may share Personal Information with outside parties if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable legal process or enforceable governmental request; to enforce applicable Terms of Service, including investigation of potential violations; address fraud, security or technical concerns; or to protect against harm to the rights, property, or safety of our users or the public as required or permitted by law.

In general, we use Non-Personal Information to help us improve the Service and customize the user experience. We also aggregate Non-Personal Information in order to track trends and analyze use patterns on the Site. This Privacy Policy does not limit in any way our use or disclosure of Non-Personal Information and we reserve the right to use and disclose such Non-Personal Information to our partners, advertisers and other third parties at our discretion.

In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our assets may continue to process your Personal Information as set forth in this Privacy Policy. If our information practices change at any time in the future, we will post the policy changes to the Site so that you may opt out of the new information practices. We suggest that you check the Site periodically if you are concerned about how your information is used.

We implement technical and organizational security measures designed to protect your Personal Information from unauthorized access, loss, misuse, or alteration. These measures include encryption in transit, access controls, and secure infrastructure practices. Your account is protected by the password you create, and we encourage you to use a strong, unique password and to log out after each session.

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Because the Service involves non-custodial wallets, you remain solely responsible for protecting your private keys and any recovery information. No method of electronic transmission or storage is completely secure. While we strive to protect your information, we cannot guarantee absolute security. These measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using our Service, you acknowledge that you understand and agree to assume these risks.

Depending on your location, you may have certain rights regarding your Personal Information. These may include the right to:

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• Access the Personal Information we hold about you
• Request correction of inaccurate or incomplete Personal Information
• Request deletion of your Personal Information
• Request restriction of processing of your Personal Information
• Object to processing of your Personal Information
• Receive a copy of your Personal Information in a portable format
• Withdraw consent where we rely on consent as the legal basis for processing
• Opt out of marketing communications at any time

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California residents may also have additional rights under the California Consumer Privacy Act (CCPA/CPRA), including the right to know what Personal Information we collect, the right to delete, the right to correct, the right to opt out of the “sale” or “sharing” of Personal Information, and the right to non-discrimination for exercising these rights. We do not sell or share your Personal Information for cross-context behavioral advertising.

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To exercise any of these rights, please contact us at support@masswallets.xyz. We will respond to verifiable requests within the timeframes required by applicable law. We may need to verify your identity before fulfilling certain requests.

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You may also opt out of promotional emails by following the unsubscribe instructions in those emails or by contacting us at support@masswallets.xyz. Even if you opt out of marketing messages, we may still send you important administrative or service-related communications.

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As part of the Service, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Site and the Service. Therefore, this Privacy Policy does not apply to your use of a third party website accessed by selecting a link on our Site or via our Service. To the extent that you access or use the Service through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.

The Company reserves the right to change this policy and our Terms of Service at any time. We will notify you of significant changes to our Privacy Policy by sending a notice to the primary email address specified in your account or by placing a prominent notice on our site. Significant changes will go into effect 30 days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check the Site and this privacy page for updates.

If you have any questions regarding this Privacy Policy or the practices of this Site, please contact us by sending an email to support@masswallets.xyz.