Privacy Policy

EFFECTIVE DATE: May 12, 2024

FLock Technology Holdings (“FLock,” “Company,” “we,” “our” and/or “us”) has implemented this privacy policy because your privacy is important to us. This privacy policy (the “Policy”) describes the type of information that we gather from users of FLock services (the “Services”), and how we collect, use, and disclose information from users of our Service (“Users,” “you,” and/or “your”). By using our Service, you agree to the collection, use, disclosure, and procedures this Policy describes. By using the Services, you consent to the terms of the Policy and to our processing of Personal Information in the manner and for the purposes set forth herein. If you do not agree with the Policy, please do not use the Services. Beyond the Policy, your use of our Service is also subject to our Terms of Use.

We occasionally collect Personal Information from Users. “Personal Information” means any information that can, alone or associated with other information, be used to identify an individual, for instance by reference of a name, a username, an email address, an IP address, a photograph or others.

We reserve the right, at our sole discretion, to change the Policy at any time, which change will be effective five (5) days following posting the revision to the Policy on the Company website (the “Website”). Your continued use of the Services five (5) days following such posting means you accept those changes.

1. INFORMATION WE COLLECT

The Company collects the following information, some of which might be Personal Information.

(a) Information you provide directly

The Company collects information directly provided by Users as part of using the Services, such as:

• Information and payment information provided as part of linking your wallet address to the Website: wallet address, email address, username, and other optional information such as an avatar, your interests, or usernames to your third-party social networks;

• Other information and materials that you decide to post on the Website (e.g., the discussion forum, or other); and

• Contact information and the time, date, and content of your message and any attachments between you and the Company, as part of your communication with the Company when using the Services or applying for a job with us.

At any time during your use of the Services, you may decide to share some information or content publicly or privately.

If you decide to share your information or content publicly, and if you decide to include Personal Information, you understand that anyone may view this information.

If you decide to keep your information private and control the access to it, you understand that only the users that you authorize will view this information. The Company also reserves the right to access this information with your consent, or without your consent only for the purposes of pursuing legitimate interests such as maintaining security on its Services or complying with any legal or regulatory obligations. Where required by applicable law, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so.

(b) Information we collect from third parties

We may collect information from third parties that help us deliver the Services or process information. See “9. LIST OF THIRD-PARTY SERVICE PROVIDERS” for details.

(c) Information we automatically collect from your use of the Services

The Company automatically records information from your use of the Services such as:

• Information about your Use of the Services, your session (date and location) and your IP address;

• Information from cookies, especially your login information and your preferences; and

• Information about your device: type, model, version, operating system and browser.

(d) Cookies

We use cookies only for the purposes of delivering, updating, monitoring, improving the Services, and maintaining security on our Services by detecting, preventing and responding to any type of threats or incidents.

We may collect information through those cookies. If you do not wish to accept these cookies and you decide to disable them, you will not be able to access and use the Services.

2. USE OF INFORMATION

(a) Purposes of the use of information

The Company may use information from Users for the following purposes:

• to deliver the Services, which may include the creation of your account, the display of your profile or your content, or if applicable the upgrading of your account to a paid account;

• to operate and improve the Services by providing you with more effective customer service, making the Services easier to use by eliminating the need for you to enter the same information repeatedly; performing research and analysis aimed at improving the Services, or other products and technologies of the Company; automatically updating the Services; diagnosing or fixing problems with the Services;

• to conduct analysis or research on the Services or any topics related to it, for business operations or scientific purposes;

• to communicate with you, especially through the sending of welcome emails, information on technical service issues, security announcements, information of new services available, legal notices, response to your requests, or any other information that we think might interest or be relevant to you;

• to ensure and maintain security on our Services or Website, which may include detecting, preventing, investigating or otherwise addressing fraud or security issues;

• to protect against harm to the rights, property or safety of the Company, our Users, yourself or the public;

• to enforce any applicable terms of service or agreement, including investigations of potential violations thereof; and

• to comply with any applicable law, regulation, legal process or governmental requests.

(b) Grounds for the use of information

Pursuant to applicable data protection laws, and especially the European Union’s General Data Protection Regulation (EU) 2016/679 (the “GDPR”), the Company remains under an obligation to notify the Users about the legal basis on which their Personal Information is processed.

(c) Consent

By creating an account on the Website and by using the Services, you consent to disclose information, some of which might be personal, and to our processing of such Personal Information in the manner and for the purposes set forth in this Policy.

(d) Agreement

If you or your organization enter into an agreement with us, either by simply using the Services and abiding by the terms and conditions available on the Website, or by executing another separate agreement, you also consent to our processing of your Personal Information as pursuant the obligations of such an agreement.

(e) Legitimate Interests

Apart from the above cases, the Company will use the information collected from you to pursue legitimate interests such as legal or regulatory compliance, security control, business operations, scientific research, or any other interest reasonably held as legitimate.

3. SHARING OF INFORMATION

The Company will not sell, rent or lease your Personal Information except as provided for by this Policy. The Company may also share other information as provided by this Policy.

(a) Affiliates

The Company may share User information and Personal Information collected by the Services with businesses that are part of the same group as the Company, or that become part of that group in the event of a change of control, merger, acquisition or sale (“Affiliates”).

(b) Third-party service providers

The Company may occasionally hire other companies to provide limited services on its behalf, such as providing customer support, hosting websites, processing transactions, or performing statistical analysis of its Services. Those companies will be permitted to obtain only the Personal Information they need to deliver the relevant service. They will be required to maintain the confidentiality of the information and are prohibited from using it for any other purpose. See “9. LIST OF THIRD-PARTY SERVICE PROVIDERS” for details.

(c) With your consent

At any time during your use of the Services, or upon explicit request from us, you may consent to the disclosure of your information.

(d) For security and safety purposes

In the event of any fraud, security threats or incidents, we reserve the right to disclose your information without your consent for the purposes of ensuring and maintaining security on our Website and for all of our Users, and detecting, preventing, investigating or otherwise addressing fraud or security issues.

Similarly, we reserve the right to disclose your information without your consent for the purpose of protecting against harm to the rights, property or safety of the Company, our Users, yourself or the public.

(e) For legal or regulatory purposes

We also reserve the right to disclose your information without your consent to comply with any applicable law, regulation, legal process or governmental requests.

(f) Anonymous Information

The Company may use Anonymous Information (as defined below) or disclose it to third-party service providers, to provide and improve the Services and other products or technologies of the Company. The Company may disclose Anonymous Information (with or without compensation) to third parties, including advertisers and partners, for purposes including, but not limited to, targeting advertisements. “Anonymous Information” means information which does not enable identification of an individual User, such as aggregated information about use of the Services.

4. YOUR RIGHTS

(a) Access your information

You may be entitled under data protection laws to access and review Personal Information the Company holds related to you.

You may access, modify or delete the Personal Information we collected by editing your profile or controlling the content that you share at any time.

If you have any other request, all such communications regarding access to Personal Information should be addressed to: [e-mail]. Such inquiries should be clearly marked as data protection queries and you should indicate if the request is time sensitive.

(b) Data retention

We retain your information for as long as necessary to deliver the Services, to comply with any applicable legal requirements, to maintain security and prevent incidents and, in general, to pursue our legitimate interests. We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required or permitted by law to keep this information for a longer period. When determining the specific retention period, we take into account various criteria, such as the type of Services provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the relevant statute of limitations.

You may decide to cancel your account and your content at any time by editing your profile. If you wish to request the erasure of all of your Personal Information that we process, you may do so by sending a written request to [e-mail].

Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so, as permitted under applicable data protection law.

5. DATA SECURITY

The security of your Personal Information is important to us. The Company follows generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect Personal Information. However, no method of transmission over the Internet, or method of electronic storage, is fully secure. Therefore, while the Company strives to use commercially acceptable means to protect Personal Information, the Company cannot guarantee its absolute security or confidentiality. If you have any questions about security, you can contact the Company at [e-mail].

In the event of an incident affecting your Personal Information, we will act promptly acceptable means to identify and address the incident, and to notify you.

Please be aware that certain Personal Information and other information provided by you in connection with your use of the Services may be stored on your device (even if that Information is not collected by the Company). You are solely responsible for maintaining the security of your device from unauthorized access. Similarly, you also remain responsible for maintaining the confidentiality of your wallet address and password or any other information that should reasonably be held confidential.

6. CHILDREN’S PRIVACY

The Services are neither directed to nor structured to attract children under the age of 13 years. Accordingly, the Company does not intend to collect Personal Information from anyone it knows to be under 13 years of age. The Company will direct potential users under 13 years of age not to use the Services.

If the Company learns that Personal Information of persons less than 13 years of age has been collected without verifiable parental consent, the Company will take the appropriate steps to delete this information.

To make such a request, please contact the Company at: [e-mail].

7. OPTION TO UNSUBSCIRBE

The Company may collect your email address in order to send information and respond to inquiries and/or other requests or questions.

The Company does not use false or misleading subjects or email addresses. The Company reasonably identifies advertisements and includes in its communications the physical address of its business location. The Company honors opt-out/unsubscribe requests. Users may follow the instructions at the bottom of an email from the Company in order to unsubscribe from correspondence.

8. CONTACT US

If you have any questions, comments, or concerns about this Policy, please email us at [e-mail].

9. LIST OF THIRD-PARTY SERVICE PROVIDERS

We may share your information with third-party service providers, and when we do, we ensure that they access your information in compliance with applicable data protection laws. The following list sets forth our current third-party service providers as of the effective date displayed at the top of this Policy:

• Apple

• Alchamy

• AWS

• Datadog

• Google

• Grafana Cloud

• Notion

• Sentry

• Slack

• Supabase