Privacy PolicyLast Updated: September 6, 2023.

This is the privacy policy ("Privacy Policy") for any application or web service owned or operated (collectively the "Platform") provided by PORTKEY PTE. LTD., company registration number 202311738C, with its registered office address at 10 ANSON ROAD, #12-08, INTERNATIONAL PLAZA, SINGAPORE (079903)("our", "we", or "Portkey"). Portkey is committed to protecting and respecting your privacy.1. INTRODUCTIONThis Privacy Policy is designed to help you understand how we collect, use, process, and share your personal information, and to help you understand and exercise your privacy rights. This Privacy Policy also constitutes a part of Portkey Terms of Service (the "Terms"). The terms used in this Privacy Policy shall have the same meanings as in the Terms except as otherwise provided herein.When you supply any personal data to us we have legal obligations towards you in the way we use that data. We must collect the information fairly and explain to you how we will use it. It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice that we may provide at or around the time that we collect or process personal data about you so that you are fully aware of how and why we are using that data.This Privacy Policy supplements other notices and legal documents including the Terms of Service ("Terms") and is not intended to override or replace them.If, for any reason, you do not agree to the Terms of this Privacy Policy, please stop using the Platform.Changes to our Privacy Policy: We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.Please note that: the Platform is not intended for use by nor directed at anyone under the age of 18 and we do not knowingly collect data relating to children. If you believe we have collected personal information about your child, you may contact us at support@portkey.finance and request that we remove information about them.2. PERSONAL INFORMATION WE COLLECT The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below. We may collect personal information automatically when you use our Services. A. Personal Information YOU PROVIDE TO US DIRECTLYWe may collect personal information that you provide to us.• We may collect personal information when you connect to our Digital Wallet, such as your wallet address, your wallet balance, your past or future transactions, and your interactions with the Blockchain.• Identity information, such as your first name, last name, username or similar identifier, title, date of birth and gender;• Contact information, such as your postal address, email address and telephone number;• Profile information, such as your username and password, interests, preferences, feedback and survey responses;• Feedback and correspondence, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with Service, receive customer support or otherwise correspond with us;• Financial information, such as your credit card or other payment card details;• Transactions. We may collect personal information and details associated with purchases you make using our Services, including information about what you purchased, from whom, the amount you paid, the cryptocurrency you used, and other information about the transaction.• Your Communications with Us. We may collect personal information, such as your email address, phone number, or mailing address, if we ask for it, and only when you provide this information to us, in the course of any request you make to us about our Services, register for our subscriptions, loyalty programs, participate in request customer or technical support, or otherwise communicate with us.• Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.• Images. Such as screenshots, profile photos, or any photos you share or upload autonomously while you use our services.• Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., Images, messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered "public," unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.• Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.• Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.• Technical information, such as your Ethereum wallet address, application programming interface (API)-key and network information regarding transactions. B. Personal Information Collected AutomaticallyWe may collect personal information automatically when you use our Services.• Automatic Collection of Personal Information. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services. • Cookie Policy (and Other Technologies). We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, and other technologies ("Technologies") to automatically collect information through your use of our Services. Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience. Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.• Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;• Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);• Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed; See "Your Privacy Choices and Rights" below to understand your choices regarding these Technologies.• We may also collect information about how you use the Platform through Google Play's Android Advertising ID technology and Apple iOS's Advertising Identifier. This is used only by us and our trusted third party service providers (see "Service Providers" below) for advertising and user analytics. The advertising identifier will only be connected to personally identifiable information where you have provided us with your explicit consent. We will respect your user selections for this technology and will not use the data in any way which you have asked us not to. We are committed to abiding by Google and Apple's terms of use and you may contact us (at support@portkey.finance), Google or Apple directly if you have any questions regarding our use of this technology.• Social Media Platforms. Our Services may contain social media buttons, such as Discord, which might include widgets such as the "share this" button or other interactive mini programs). These features may collect personal information such as your IP address and which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it. C. Personal Information Collected from Other SourcesThird-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services and organizations, such as the public Blockchain. For example, if you access our Services through a third-party application, or use our Services to access a third-party service, protocol, an app store, a third-party login service, or a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings.Updating your informationIf you want to update the information you have previously given to us, you can contact us at support@portkey.finance.3. HOW AND WHY WE USE/SHARE YOUR INFORMATIONWe use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below. A. Provide Our ServicesWe use your information to fulfill our contract with you and provide you with our Services, such as:• Managing your experience on our Services;• Providing access to certain areas, functionalities, and features of our Services;• Understanding your interaction with our Services through publicly available Blockchain information you share;• Answering requests for customer or technical support;• Communicating with you about your account, activities on our Services, and policy changes;• Applications if you apply for a job we post on our Services; and• Allowing you to register for events or promotions. B. Administrative PurposesWe use your information for various administrative purposes, such as:• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;• Measuring interest and engagement in our Services; • Short-term, transient use, such as contextual customization of ads;• Improving, upgrading, or enhancing our Services;• Developing new products and services;• Ensuring internal quality control and safety;• Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;• Debugging to identify and repair errors with our Services;• Auditing relating to interactions, transactions, and other compliance activities;• Sharing personal information with third parties as needed to provide the Services;• Enforcing our agreements and policies; and• Carrying out activities that are required to comply with our legal obligations. C. Marketing and Advertising our Products and ServicesWe may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.If you have any questions about our marketing practices, you may contact us at any time as set forth in "Contact Us" below. D. With Your Consent We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent. E. Other PurposesWe also use your personal information for other purposes as requested by you or as permitted by applicable law.• Automated Decision Making. We may engage in automated decision making, including profiling. For example, we may engage in automated decision making to detect fraud. Portkey Economy's processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as set forth in "Contact Us" below.• De-identified and Aggregated Information. We may use personal information to create deidentified and/or aggregated information, such as demographic information, information about the device from which you access our Services, or other analyses we create.4. HOW WE DISCLOSE YOUR PERSONAL INFORMATIONWe disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below. A. Disclosures to Provide our ServicesThe categories of third parties with whom we may share your personal information are described below.• Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of our Services. This includes service providers and vendors that provide us with IT support, hosting, payment processing, customer service, and related services.• Affiliates. We may share your personal information with our company affiliates for example: for our administrative purposes, IT management, or for them to provide services to you or support and supplement the Services we provide.• Other Users or Third Parties You Share or Interact With. As described above in "Personal Information We Collect," because our Services use information about you that you share to a public Blockchain, your use of our Services may be published to that public Blockchain, which is accessible to others, including those who may not use our Services. In addition, and in connection with a promotion or airdrop, we may allow you to share personal information or interact with others, and third parties (including individuals and third parties who do not use our Services and the general public).• Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as "interest-based advertising" or "personalized advertising".• APIs/SDKs. We may use third-party application program interfaces ("APIs") and software development kits ("SDKs") as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in "Contact Us" below. B. Disclosures to Protect Us or OthersWe may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others' rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity. C. Disclosure in the Event of Merger, Sale, or Other Asset TransfersIf we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract. 5. SECURITYPortkey takes the protection of your information very seriously. We have put in place appropriate physical, electronic and managerial security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, including use of secure servers, passwords and industry standard encryption for data both in transit and at rest (for data in transit we use up-to-date versions of SSL and for data at rest we use AES-256).Where we have given you a password that enables you to access certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.6. INTERNATIONAL DATA TRANSFERSAll information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.If we transfer personal information which originates in some regions where have been protected by Personal Data protection Laws and Regulations including, but not limited to Singapore, the United States, Canada, the European Economic Area, Switzerland, and/or the United Kingdom, to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the The Personal Data Protection Act (PDPA) released by Personal Data Protection Commission Singapore.7. YOUR PRIVACY CHOICES AND RIGHTSAs a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have as well as how you can exercise them.Right of Access• You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a "subject access request").• Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.• You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.Your Right to Rectification and Erasure• You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right.• You may also ask us to erase personal data that we control if you do not believe that we need to continue retaining it (you may have heard of this right described as the "right to be forgotten"). Although we will do everything to respect your request and personal data it may not always be possible to erase all of your personal data as there may be legal requirements to keep certain personal data or technical limitations to the data we can delete; for example, we are not able to satisfy requests to erase records and information recorded on the blockchain, including, but not limited to, your chosen user name, your transaction history and your account balance.• There may also be legitimate interests in keeping certain data including, amongst others, if the data is required for the Platform to function. If this is the case we will continue to process this data.• If erasure is not technically possible or we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you this and our reasoning at the time we respond to your request.• You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.Your Right to Restrict Processing• Where we process your personal data on the basis of a legitimate interest you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.• You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify that data's accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.• Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.• You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.Your Right to Portability• Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.• Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.Your Right to object to processing• You may object to processing of your personal data where we rely on legitimate interest for processing that personal data. We will comply with your request unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.Your Right to stop receiving communications• For details on your rights to ask us to stop sending you various kinds of communications, please contact us.Your Right to object to automated decision making and profiling• You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.Withdrawal of consent• Where we are relying on consent to process your personal data you may withdraw consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.Exercising your rights• When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).8. CHILDREN'S INFORMATION The Services are not directed to children under 13 in the United States, or those under the age of consent in their relevant jurisdiction, including Singapore, Canada, the European Union, and we do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in "Contact Us" below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it.9. OTHER PROVISIONS Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk. Supervisory Authority. If your personal information is subject to the applicable data protection laws of Singapore, Canada, the United States, Australia, Brazil, the European Economic Area, Switzerland, or the United Kingdom,, you have the right to lodge a complaint with the competent supervisory authority or attorney general if you believe our processing of your personal information violates applicable law.Personal DataProtection Commission SingaporePrivacy Office. U.S.DEPARTMENT of STATEOffice of the Privacy Commissioner of CanadaOffice of the Australian Information CommissionerAutoridade Nacionalde Proteçãode Dados (ANPD)EEA Data Protection Authorities (DPAs)Swiss Federal Data Protection and Information Commissioner (FDPIC)UK Information Commissioner's Office (ICO)10. CONTRACT DETAILSIf you have any queries regarding this Privacy Policy, if you wish to exercise any of your rights set out above or if you think that the Privacy Policy has not been followed, please contact us by emailing at support@portkey.finance.Portkey Team