ICY LABS PRIVACY POLICY

Last Revised: November 15, 2021

Your privacy matters to us, so please do take the time to get to know and familiarize yourself with our policies and practices. Please understand that we reserve the right to change any of our policies and practices at any time, but you can always find the latest version of this Policy here on this page. Your continued use of our Platform after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

This Policy describes:

• The types of information we collect from you or that you may provide when you visit our website at https://icy.tools/ or utilize any related tools, mobile applications, web applications, decentralized applications, smart contracts, or Application Programming Interfaces (“APIs”) located at any of Icy Labs’ websites, including without limitation, successor website(s) or application(s) thereto (collectively, the “Platform”).


• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not use our Platform. By using our Platform, you agree to the terms of this Policy.

As used herein, “Personal Information” means information that identifies or is reasonably capable of identifying an individual, directly or indirectly, and information that is capable of being associated with an identified or reasonably identifiable individual.

1. Personal Information We Collect from You.We (or our Affiliates) may collect the following categories of Personal Information directly from you:
• Identification Information, such as name, email, phone number, postal address, Wallet address, social media information, and any information that may be legally required, including information required for Know Your Customer (“KYC”) verification purposes such as your social security number;
• Commercial Activity, such as public blockchain data; and
• Correspondence, such as information you provide to us in correspondence, including account opening, customer support, messages, text boxes, other user content, or the like.
• Payment information, such as credit or debit card numbers, bank account numbers, wire transfer information, and information connected to digital payment processing @qi/web-icy-tools/services such as Apple Pay or PayPal.



Icy Labs does not currently store or process credit or debit card information on our systems. Instead, all credit or debit card information is stored and processed by a trusted third-party PCI-DSS compliant processor.

2. Personal Information That May Be Collected Automatically. We (or our Affiliates) may collect the following categories of Personal Information automatically through your use of our @qi/web-icy-tools/services:
• Online Identifiers, such as IP address, domain name;
• Device Information, such as hardware, operating system, browser, device name, language preferences;
• Usage Data, such as system activity, internal and external information related to Icy Labs pages that you visit, clickstream information; and
• Geolocation Data, such as information about your device's location.

Automatic collection of Personal Information may involve the use of Cookies, described in greater detail below. Icy Labs does not currently store Online Identifiers, Device Information, or Geolocation Data on our systems; however, please be aware that third-parties with which we might interact, such as vendors or payment processors, might store such information.

3. Personal Information We Collect from Third Parties.We may collect and/or verify the following categories of Personal Information about you from third parties:


• Identification Information, such as name, email, phone number, postal address.
• Transaction Information, such as public blockchain data (Bitcoin, Ether, and other digital assets are not truly anonymous. We, and any others who can match your public digital asset address to other Personal Information about you, may be able to identify you from a blockchain transaction because, in some circumstances, Personal Information published on a blockchain (such as your digital asset address and IP address) can be correlated with Personal Information that we and others may have. Furthermore, by using data analysis techniques on a given blockchain, it may be possible to identify other Personal Information about you); and
• Additional Information, at our discretion to comply with legal obligations.


4. Accuracy and Retention of Personal Information

We take reasonable and practicable steps to ensure that your Personal Information held by us is (i) accurate with regard to the purposes for which it is to be used, and (ii) not kept longer than is necessary for the fulfillment of the purpose for which it is to be used.

We collect Personal Information about you in an attempt to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve our Services. We may use your Personal Information to:

1. Provide you with our Services. We use your Personal Information to provide you with our Services pursuant to the terms of our Terms.
2. Comply with legal and regulatory requirements. We process your Personal Information as required by applicable laws and regulations.
3. Detect and prevent fraud. We process your Personal Information to detect and prevent fraud, which is especially important given the irreversible nature of cryptocurrency transactions.
4. Protect the security and integrity of our Services. We use your Personal Information, including information about your device and your activity on Icy Labs to maintain the security of your account and the Icy Labs platform.
5. Provide you with customer support. We process your Personal Information when you contact our support team with questions about or issues with your account.
6. Market our products. We may contact you with information about our Services. We will only do so with your permission, which can be revoked at any time.
7. Other business purposes. We may use your Personal Information for additional purposes if disclosed to you before we collect your Personal Information or if we obtain your consent.

We will never sell, share, rent, or trade your Personal Information with third parties for their commercial purposes. Further, we will not share your Personal Information with third-parties, except as described below:

1. 1. Service Providers. We may share your Personal Information with third-party service providers for business or commercial purposes, including fraud detection and prevention, security threat detection, payment processing, customer support, data analytics, Information Technology, advertising and marketing, network infrastructure, storage, transaction monitoring. We share your Personal Information with these service providers only so that they can provide us with the @qi/web-icy-tools/services, and we prohibit our service providers from using or disclosing your Personal Information for any other purpose.
2. 2. Law Enforcement. We may be compelled to share your Personal Information with law enforcement, government officials, and regulators.
3. 3. Corporate Transactions. We may disclose Personal Information in the event of a proposed or consummated merger, acquisition, reorganization, asset sale, or similar corporate transaction, or in the event of a bankruptcy or dissolution.
4. 4. Professional Advisors. We may share your Personal Information with our professional advisors, including legal, accounting, or other consulting @qi/web-icy-tools/services for purposes of audits or to comply with our legal obligations.
5. 5. Consent. We may share your Personal Information with your consent.

If we decide to modify the purpose for which your Personal Information is collected and used, we will amend this Policy.

Subject to applicable laws and regulations, we may from time to time send direct marketing materials promoting @qi/web-icy-tools/services, products, facilities, or activities to you using information collected from or about you. You may also opt-out of such communications by following the directions provided in any marketing communication. It is our policy to not provide your Personal Information for those third parties’ direct marketing purposes without your consent.

No security is foolproof, and the Internet is an insecure medium. We cannot guarantee absolute security, but we work hard to protect Icy Labs and you from unauthorized access to or unauthorized alteration, disclosure, or destruction of Personal Information we collect and store. Measures we take include encryption of the Icy Labs website communications with SSL; periodic review of our Personal Information collection, storage, and processing practices; and restricted access to your Personal Information on a need-to-know basis for our employees, contractors and agents who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

1. Lawful Bases for Processing. We process personal data subject to GDPR on one or more of the following legal bases:
• Legal Obligation: to conduct anti-fraud and to fulfill our retention and other legal obligations;
• Contractual Obligation: to satisfy our obligations to you under our Terms, including to provide you with our Services and customer support @qi/web-icy-tools/services, and to optimize and enhance Icy Labs;
• Legitimate Interest: to monitor the usage of Icy Labs, conduct automated and manual security checks of our Services, to protect our rights; and
• Consent: to market Icy Labs and our Services. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before consent is withdrawn.


2. European Privacy Rights. European residents have the following rights under GDPR, subject to certain exceptions provided under the law, with respect to their personal data:
• Rights to Access and Rectification. You may submit a request that Icy Labs disclose the personal data that we process about you and correct any inaccurate personal data.
• Right to Erasure. You may submit a request that Icy Labs delete the personal data that we have about you.
• Right to Restriction of Processing. You have the right to restrict or object to our processing of your personal data under certain circumstances.
• Right to Data Portability. You have the right to receive the personal data you have provided to us in an electronic format and to transmit that personal data to another data controller.

To submit a request to exercise these rights, please contact us using the methods described at the end of this Policy. When handling requests to exercise European privacy rights, we check the identity of the requesting party to ensure that he or she is the person legally entitled to make such request. While we maintain a policy to respond to these requests free of charge, should your request be repetitive or unduly onerous, we reserve the right to charge you a reasonable fee for compliance with your request.

Icy Labs operates with many of our systems based in the United States. As a result, we may transfer personal data from Europe to third countries outside of Europe, including the United States, under the following conditions:

• Contractual Obligation. Where transfers are necessary to satisfy our obligation to you under our Terms, including to provide you with our Services and customer support @qi/web-icy-tools/services, and to optimize and enhance Icy Labs; and
• Consent: where you have consented to the transfer of your personal data to a third country.

Where transfers to a third country are based on your consent, you may withdraw your consent at any time. Please understand, however, that our @qi/web-icy-tools/services may not be available if we are unable to transfer personal data to third countries.

When we transfer personal data to third countries, we endeavor to ensure adequate safeguards are implemented, for example through the use of standard contractual clauses or Privacy Shield certification.

Based on California law, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To submit a request to exercise these rights, please contact us using the methods described at the end of this Privacy Policy. When handling requests to exercise CCPA privacy rights, we check the identity of the requesting party to ensure that he or she is the person legally entitled to make such request. While we maintain a policy to respond to these requests free of charge, should your request be repetitive or unduly onerous, we reserve the right to charge you a reasonable fee for compliance with your request