Lygos Privacy Policy

1. Introduction

Welcome to Lygos. This Privacy Policy explains how Lygos Labs Inc. ("Lygos," "we," "us," or "our") collects, uses, shares, and protects information about you when you use our website at [lygos.finance] (the "Site"), our Lygos Wallet mobile application ("App"), and our related platform and services (collectively, the "Services").

Your privacy and the security of your information are of paramount importance to us. We are committed to being transparent about our data practices. By using our Services, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect

We collect information to provide and improve our Services. The types of information we collect can be broken down into three categories:

(a) Information You Provide to Us:

• Account & Waitlist Information: When you request early access, join our waitlist, or create an account, we may collect information such as your name, company or entity name, and email address.
• Loan Application Information: To facilitate loan requests on the platform, we may collect information you provide, such as indicative borrow size, desired duration, and custody setup.
• Communications: If you contact us directly for support or other inquiries, we may collect your name, email address, and the contents of your communications.

(b) Information We Collect Automatically:

• Log and Usage Data: Like most online services, we automatically collect information when you use our Services, including your Internet Protocol (IP) address, browser type, operating system, pages visited, and the dates/times of your requests.
• Device Information: When you use our App, we may collect information about your mobile device, including its unique device identifier, operating system, and mobile network information.
• Cookies and Similar Technologies: We use cookies to operate and administer our Site and to gather usage data. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.

(c) Information from Public Blockchains:

• Blockchain Data: Our Services interact with public blockchains, such as the Bitcoin and Ethereum networks. When you use our Services, we may collect and process publicly available blockchain data, including your public wallet addresses and transaction hashes for loans you participate in. This information is necessary for the Services to function (e.g., to monitor loan status and repayments). We do not collect or have access to your private keys.

3. How We Use Your Information

We use the information we collect for various purposes, including:

• To Provide and Maintain our Services: To operate our platform, facilitate connections between Borrowers and Lenders, and allow you to interact with Discreet Log Contracts (DLCs).
• To Communicate With You: To respond to your comments and questions, provide customer support, and send you technical notices, updates, and security alerts.
• For Research and Development: To understand how our users interact with the Services so we can improve them and develop new features.
• For Safety, Security, and Compliance: To protect our platform and users from fraud, to enforce our Terms of Service, and to comply with our legal obligations.
• For Marketing: To send you marketing communications that we believe may be of interest to you, in accordance with your preferences. You may opt out of receiving these communications at any time.

4. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

• With Other Platform Users: For a loan to be facilitated, certain information, such as your public wallet addresses for funding and repayment, must be shared with the other party (Borrower or Lender) in the loan agreement.
• With Service Providers: We may share your information with third-party vendors and service providers who perform services on our behalf, such as cloud hosting (e.g., Google Cloud Platform), data analytics, and email delivery.
• For Legal Reasons: We may disclose your information if we believe it is required by any applicable law, regulation, legal process, or governmental request.
• In Connection with a Business Transfer: 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.
• With Your Consent: We may share your information for other purposes with your explicit consent.

5. Data Security

We implement reasonable administrative, technical, and physical security measures to protect your information from loss, theft, misuse, and unauthorized access. However, please be aware that no security measures are perfect or impenetrable, and we cannot guarantee the absolute security of your information.

6. Data Retention

We will retain your personal information for as long as is necessary for the purposes set out in this Privacy Policy, and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

7. Your Data Protection Rights

Depending on your location, you may have certain rights regarding your personal information, including the right to:

• Access, update, or delete the information we have on you.
• Object to our processing of your personal information.
• Request that we restrict the processing of your personal information.
• Request a copy of your personal information in a portable format.

To exercise these rights, please contact us at privacy@lygos.finance.

8. Children's Privacy

Our Services are not intended for use by anyone under the age of 18. We do not knowingly collect personally identifiable information from children. If you become aware that a child has provided us with personal information, please contact us.

9. Links to Other Websites

Our Services may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We have no control over and assume no responsibility for the content or privacy practices of any third-party sites or services.

10. Additional Privacy Disclosures

Residents of the European Economic Area

If you are a resident of the European Economic Area ("EEA"), you have certain rights and protections under the law regarding the processing of your personal data. Any reference to Personal Information in this Privacy Policy should be understood as referring to "personal data", defined under the General Data Protection Regulation ("GDPR") as "any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person".

Legal Basis for Processing

If you are a resident of the EEA, when we process your personal data we will only do so in the following situations:

• with your consent;
• to perform the Services you have requested from us or, upon your request, to take the steps necessary to provide you with such Services; or
• in the furtherance of our legitimate interests in maintaining business relationships and communicating with you as a business contact, about our activities and Services and providing, securing and improving our Services.

You have consented to the processing of your personal data for one or more specific purposes. We consider that our legitimate interests are in compliance with the GDPR and your legal rights and freedoms. You have the right to object to any of this processing and, if you want to, please contact us at the contact details indicated below.

Data Subject Requests

If you are a resident of the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you can contact us as indicated below. Please note that the limitation or deletion of your personal data may mean we will be unable to provide our Services. You also have the right to receive your personal data in a machine-readable format and have the data transferred to another party responsible for data processing.

Questions or Complaints

If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

Residents of California

California Civil Code Section § 1798.83 permits users who are California residents to request certain information, including the categories of personal information disclosed to third parties for their marketing purposes and the names and addresses of those third parties, regarding our disclosure of personal information to third parties for their direct marketing purposes, if any. If you are a California resident and you have questions about our practices with respect to sharing information with third parties and affiliates for their direct marketing purposes, please contact us at the address set out in Section 11 below.

11. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date at the top. You are advised to review this Privacy Policy periodically for any changes.

12. Contact Us

If you have any questions about this Privacy Policy, please contact us at privacy@lygos.finance.