1. Introduction

Welcome to the Opyn, Inc. (“Opyn”) Privacy Policy (the “Privacy Policy”). This Privacy Policy explains how we collect and use any information you submit when using the Interface, as defined within the Opyn User Terms of Service (“User Terms”). This Privacy Policy should be read in conjunction with the User Terms and is integrated into the User Terms. All capitalized proper nouns not defined in this Privacy Policy will have the same definitions and meanings as defined by the User Terms. Please review the Privacy Policy periodically as we may revise it from time to time. If you do not agree with or accept our Privacy Policy in its entirety, you must not access or use the Interface. If you use the Interface following a change to the terms of this Privacy Policy you agree to accept the revised policies. Please do not submit any information to us if you reside in a Restricted Territory or if you or your organization is a Restricted Person or US Person.

2. Information Collected

At Opyn, we may collect the following information from you when you access or use the Interface:

• Digital Wallet address, transaction history, and other associated information.
• Interactions with the Interface including but not limited to usage data and preferences.
• Online identifiers like computer and browser information, operating system, data usage, data transferred, geo location, and IP address.
• Information provided by third parties or publicly accessible databases which we may combine with other information collected.

3. Use of Your Information

Where applicable, we will use any information collected as directed by you and in accordance with the User Terms. Further, we may use your information in the following ways:

• To provide any services offered by the Interface, to process transactions, and to maintain, develop, and operate the Interface.
• To enforce the Privacy Policy or User Terms; to comply with applicable laws; to respond to third party, legal, and governmental inquiries; and to investigate any illegal or fraudulent activity.
• To enhance or improve our users’ experiences.
• To send and receive information to you via selected communication methods as set forth within the User Terms or where requested by you.
• To notify you of additional Opyn services and updates.
• To assist in maintaining the functionality, safety, and security of the Interface.
• To share your information with third party contractors hired by us to perform functions and provide services to us such as infrastructure providers, Blockchain Technology providers, marketing providers, and other vendors we use to make available the Interface.
• To release to governmental entities, authorities, or legal claimants as required.

4. Analytics

Third party analytics tools collect or use information about your use of the Interface, which helps us improve the user experience. We want to process as little personal information as possible when you use the Interface. We use Amplitude, a user analytics platform, in order to track how users interact with the interface in order to establish, implement, and evaluate how to improve the user experience. Amplitude uses cookies to help analyze how users use the site. For more information on the Amplitude cookie and how to disable it, go to section 6.2 “Cookies the Interface Uses.”

5. Sanctions and Risk Management

We use Chainalysis, a third party blockchain intelligence service provider to detect, prevent, and mitigate financial crime and other illicit or harmful activities on the Interface. Chainalysis combines on-chain data and real-world investigations to identify financial crime and other high-risk activities. Opyn applies an industry-wide standard of risk categories (e.g., sanctions, ransomware, child exploitation, stolen funds). Addresses that fall into a risk category are blocked from accessing the Squeeth App. User wallet addresses connecting to the Squeeth app will be cross-checked using a Chainalysis API with designated risk categories. Your address is shared with Chainalysis, but no metadata or IP addresses are shared. Users are not identified in this risk-assessment process. We do not retain the information we collect any longer than necessary for these purposes.

Sentry is used to record blocked address events that occur through the Chainalysis API.

6. Cookies

When you first come to the Interface, you may receive a notification that cookies are present. By clicking or tapping “Accept,” you agree to the use of these cookies as described here. By tapping “Decline,” you refuse to accept cookies from the Interface. If you refuse cookies, you might not be able to use other cookie-dependent features of the Interface. To manage specific Cookie settings, review this Privacy Policy for further information.

6.1 What is a Cookie

A cookie is a small string of text that a website (or online service) stores on a user’s browser. It saves data on your browser about your visit to our site or other sites. It often includes a unique identifier (e.g., cookie #123).

• “First-party cookies” are cookies set by us (or on our behalf) on our site.
• “Third-party cookies” are cookies set by other companies whose functionality is embedded into a site (e.g., google.com).
• “Session cookies” are temporary cookies stored on your device while you visit the Interface. They expire when you close your browser.
• “Persistent cookies” are stored on your browser for a period of time after you leave the Interface. Persistent cookies expire on a set expiration date or when they are deleted manually.

6.2 Cookies the Interface Uses

Amplitude: We use a third-party, persistent session SDK javascript cookie from Amplitude, AMP_###, to analyze how users use the interface. Third party analytics tools collect or use information about your use of the Interface, which helps us improve the user experience. The information generated by the cookie about your use of the website will be transmitted to and stored by Amplitude on servers in the European Economic Area. We do not track IP addresses through Amplitude. Amplitude will use this information on behalf of the Interface for the purpose of evaluating your use of the Interface, compiling reports on Interface activity and providing other services relating to Interface activity and internet usage. The IP-address that your browser conveys within the scope of Amplitude will not be associated with any other data held by Amplitude.

This performance cookie will be stored for up to 1 year.

In order to opt-out of the Amplitude cookie click HERE.

6.3 Disabling Cookies Through Your Browser

Most browsers automatically accept cookies, but this is typically something you can adjust. Information for each browser can be found in the links below:

• Safari on desktop and Safari Mobile (iPhone and iPads): Note that, by default, Safari is engineered to protect you from being tracked from site to site unless you disable Intelligent Tracking Prevention (ITP).
• Firefox: By default, Firefox protects you from cross-site tracking so long as you have not disabled Enhanced Tracking Protection (ETP). There is therefore less need to manage cookies to protect your privacy.
• Chrome
• Microsoft Edge: Enabling tracking prevention with Edge will protect you from being tracked between sites, such that there will be less of a need to manage your cookies in order to protect your privacy.
• Samsung Internet Browser. Note that Samsung Internet Browser includes “Smart Watch” protection that works to help protect you from being tracked across sites.
• Brave: Brave has several mechanisms to keep you from being tracked online, but you can change your privacy settings if you wish to have greater control over its decisions.

For more information about other browsers, please refer to this “All About Cookies” guide.

To reset your device identifier, follow Google instructions and Apple instructions.

7. Governmental Entities

We may combine any information collected with information made available in third party databases and public sources. We may use such information to address claims, to respond to governmental inquires or requests, or to investigate issues. Further, such information may be shared with governmental entities including criminal, civil, and, regulatory agencies. Please be aware that we may keep copies of your information subject to our internal retention policies for the purposes of abiding by Applicable Laws or to prevent fraud or injury to a third party.

8. Accessing and Editing Your Information

To access your Personal Data and information about how Opyn collects and uses your personal data, obtain a machine-readable, portable copy of your file, or to delete your personal data, please email us at [email protected]. Your ethereum wallet address is required as we cannot otherwise identify any associated data with your activity to execute your request.

To delete your order/transactional information. You may request to have this information deleted from Opyn’s personal records, which will restrict your access to the information. However, the information will be archived and kept on file for 10 years to comply with legal and contractual requirements.

Please note, however, that ethereum-based transactions by their very nature as a transaction on the Ethereum blockchain are publicly available transactions that cannot be deleted from public record as they are recorded on the ethereum blockchain. For more information on how transactions are recorded on Ethereum see the Ethereum Foundation’s website HERE.

If you have any questions regarding any information collected please contact us at [email protected]. #### 9. Opt Out of Commercial, Non-Commercial Communications and Do Not Track

If you decide to provide us with your contact information, you agree that we may send you communications via emails or other methods. However, you may choose to unsubscribe from certain communications by notifying Opyn that you no longer wish to receive these communications, we will endeavour to honor such requests promptly. If you wish to opt out of certain communications or information collection, please contact us at [email protected].

10. Third Party Websites and Links

When accessing a third party site through our Interface, you acknowledge that you are aware that these third party websites are not screened for privacy or security issues by us, and you release us from any liability for the conduct of these third party websites. Please be aware that this Privacy Policy, and any other policies in place, in addition to any amendments, do not create rights enforceable by third parties. Opyn bears no responsibility for the information collected or used by any third party website. You must review their policies to understand how their information collection practices work.

11. Security Measures

We make reasonable attempts to protect your information by using physical and electronic safeguards such as encryption. However, as the Interface relies on Blockchain Technology and electronic infrastructure that we have no control over, we can make no guarantees as to the security or privacy of your information submitted. For this reason, we recommend that you use anti-virus software, firewalls, and other precautions to protect yourself from security and privacy threats.

12. Age Compliance

We do not collect or process any information for any persons under the age of majority in your jurisdiction (“Minors”). Please do not submit information to us if you are under the age of majority in your applicable jurisdiction. In the event that we have inadvertently collected any information from a Minor please contact us immediately.

13. International Transfer

Your information may be transferred to – and maintained on – computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. Information that is submitted to Opyn will be collected, processed, stored, disclosed, and disposed of in accordance with applicable United States’ law and this policy. In addition, such information may be stored on servers located outside your resident jurisdiction. United States’ law may not provide the degree of protection for information that is available in other countries.

14. Merger and Acquisition

In the event that Opyn is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be transferred as part of that transaction. Please be aware that once the information is transferred your privacy rights may change.

15. Amendments

Like our User Terms, we may amend this Privacy Policy from time to time. When we amend this Privacy Policy, we will modify the date listed on this Privacy Policy or we may contact you. You must agree to the amendments as a condition of your continued use of our Interface. If you do not agree, you must immediately cease using our Interface.

16. Contact

If you have any questions regarding our Privacy Policy please contact us at [email protected].