Points Protocol Privacy Policy

Last updated: July 21, 2025

Points Protocol Foundation Limited ("we," "our," "us," or the "Company") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, process, and protect information when you access or use Points Protocol and our related websites, platforms, software, technologies, features, and other online products and services (collectively, the "Services").

BY USING OUR SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY AND AGREE TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR INFORMATION AS DESCRIBED HEREIN.

1. Information We Collect

1.1 Information You Provide Directly

We may collect information that you provide directly to us, including:

Account Information: When you create an account or interact with our Services, we may collect information such as your username, email address, and other contact details
Transaction Information: Details about your interactions with Points Protocol, including transaction history, wallet addresses, and protocol usage patterns
Communications: Information you provide when you contact us for support, feedback, or other inquiries
User-Generated Content: Any content, feedback, or information you submit through our Services

1.2 Information Collected Automatically

When you use our Services, we automatically collect certain information, including:

Usage Data: Information about how you interact with our Services, including pages visited, features used, time spent, and click patterns
Device Information: Information about your device, browser, operating system, IP address, and other technical identifiers
Network Information: Details about your network connection, including blockchain network data and wallet connection information
Log Data: Server logs that include information such as access times, pages viewed, and system activity

1.3 Blockchain Data

Given the nature of blockchain technology:

Public Blockchain Information: Transactions on public blockchains are publicly visible and cannot be deleted or modified
Wallet Addresses: We may associate your wallet address with your use of our Services
On-Chain Activity: Your interactions with Points Protocol smart contracts are recorded on the blockchain

1.4 Information from Third Parties

We may collect information from third-party sources, including:

Blockchain Analytics: Information from blockchain analysis services
Identity Verification Services: Data from KYC/AML service providers
Integration Partners: Information from wallet providers and other integrated services

2. How We Use Your Information

We use the collected information for the following purposes:

2.1 Service Provision

Operating and maintaining Points Protocol
Processing transactions and protocol interactions
Providing customer support and responding to inquiries
Personalizing your experience with our Services

2.2 Security and Compliance

Detecting, preventing, and addressing fraud, abuse, and security issues
Complying with legal obligations and regulatory requirements
Conducting identity verification and AML/KYC procedures
Monitoring compliance with our Terms of Use

2.3 Communications

Sending important updates about our Services
Providing notifications about your account or transactions
Sharing information about new features or changes to our Services
Responding to your questions and support requests

2.4 Analytics and Improvement

Analyzing usage patterns to improve our Services
Conducting research and development
Generating aggregate statistics and insights
Optimizing protocol performance and user experience

We may share your information in the following circumstances:

3.1 Service Providers

We may share information with trusted third-party service providers who assist us in operating our Services, including:

Cloud hosting and infrastructure providers
Analytics and monitoring services
Identity verification and compliance services
Customer support platforms

3.2 Legal Requirements

We may disclose information when required by law or to:

Comply with legal processes, court orders, or governmental requests
Enforce our Terms of Use or other agreements
Protect our rights, property, or safety, or that of others
Prevent or investigate fraud, security breaches, or illegal activities

3.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.

We may share your information when you have given us explicit consent to do so.

4. Data Security

We implement appropriate technical and organizational measures to protect your information, including:

Encryption: Data transmission and storage encryption using industry-standard protocols
Access Controls: Restricted access to personal information on a need-to-know basis
Security Monitoring: Continuous monitoring for security threats and vulnerabilities
Incident Response: Procedures for responding to data breaches and security incidents

However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

5. Data Retention

We retain your information for as long as necessary to:

Provide our Services and fulfill the purposes outlined in this Privacy Policy
Comply with legal obligations and regulatory requirements
Resolve disputes and enforce our agreements
Maintain security and prevent fraud

Blockchain transactions are permanent and cannot be deleted.

6. Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your personal information:

6.1 Access and Portability

Request access to your personal information
Obtain a copy of your data in a portable format

6.2 Correction and Updates

Correct inaccurate or incomplete information
Update your account information

6.3 Deletion

Request deletion of your personal information (subject to legal and operational limitations)
Note: Blockchain data cannot be deleted

Withdraw consent where processing is based on consent
Opt out of non-essential communications

To exercise these rights, please contact us using the information provided in Section 11.

7. Cookies and Tracking Technologies

We use cookies and similar technologies to:

Remember your preferences and settings
Analyze usage patterns and improve our Services
Provide security features and prevent fraud
Deliver relevant content and advertisements

You can manage cookie preferences through your browser settings, but disabling cookies may affect the functionality of our Services.

8. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place for such transfers in accordance with applicable data protection laws.

9. Third-Party Links and Services

Our Services may contain links to third-party websites or integrate with third-party services. This Privacy Policy does not apply to such third parties, and we are not responsible for their privacy practices. We encourage you to review their privacy policies.

10. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child, we will take steps to delete such information.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make changes, we will:

Post the updated policy on our website
Update the "Last updated" date
Notify you of material changes through our Services or other appropriate means

Your continued use of our Services after any changes constitutes acceptance of the updated Privacy Policy.