BLOCKS, DAO LLC PRIVACY POLICY

Welcome to BLOCKS, DAO LLC (“BLOCKS”, “we,” “us” or “our”). We know you take your privacy seriously, and we respect your privacy and are committed to protecting it through compliance with this privacy policy (“Privacy Policy”). Please take the time to read, review and familiarize yourself with this Privacy Policy, which describes the types of information BLOCKS, as a data controller, may collect from you or that you may provide and our practices for collecting, using, maintaining, protecting and disclosing that information.

BLOCKS Terms of Use (the “Terms”), along with this Privacy Policy, govern your access to and use of the Services and applies to all of the websites and mobile applications that we own and operate.

Capitalized terms not otherwise defined in this Privacy Policy have the same meaning as used in the Terms. For the avoidance of doubt, the use of the term “BLOCKS” in this Privacy Policy includes BLOCKS.

Acceptance of Privacy Policy

You acknowledge and agree that by visiting, using or accessing the Services in any manner, you accept the practices and policies outlined in this Privacy Policy, and you consent to the procedures we employ to collect, use, and share your information as outlined in this Privacy Policy. If you do not consent to any of the terms or procedures described in this Privacy Policy, you should NOT accessor use any of the Services.

Updates & Changes to Privacy Policy

BLOCKS reserves the right to, in its sole discretion, change, amend or modify the Privacy Policy at anytime to reflect changes in our data and information practices. If we modify or update this Privacy Policy, we will post changes and updates on this Site so that you will always be aware of what information we collect, use and disclose. Even if you do not receive a notification regarding any updates to the Privacy Policy, the amended terms of the Privacy Policy will govern your use of the Services. You are responsible for reviewing and understanding the Privacy Policy and any modifications to it. Accessing or using the Services in any way following a change to the Privacy Policy indicates your acceptance and consent to the amended policy. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected. The date of the last update of the Privacy Policy is indicated at the top of this Privacy

What Does This Privacy Policy Cover?

“Personal Information” is all data or information that BLOCKS gathers when you register for a BLOCKS Account or when you access or use the Services, which can be used to (i) identify you, either directly or indirectly, or (ii) contact you. This Privacy Policy covers our treatment of all Personal Information, including that which you voluntarily submit to us and/or are required to submit pursuant to applicable law, that which is automatically generated and that which we obtain from our partners or other third parties.

This Privacy Policy does not cover the practices of companies we do not own or control, or people that we do not manage.

What Information Does BLOCKS Collect?

Information You Provide to Us:

We receive and store any Personal Information you knowingly provide to us—either voluntarily or as required by law.

For example, we may collect the following Personal Information when you register for a BLOCKS Account and as you access or use our Services:

• full legal name,
• address,
• email address,
• mobile phone number,
• proof of identity (e.g., driver’s license, passport, or government-issued identity card),
• Social Security Number, Tax Identification Number, or other comparable government-issued identification number,
• date of birth,
• home address,
• bank account details and/or credit card numbers, and
• other personal, commercial and/or taxpayer or government identification information (e.g., any information we, in our sole discretion, deem necessary to comply with our legal obligations under various anti-money laundering (“AML”) laws).

Information Collected Automatically

We receive and record certain types of information automatically, such as whenever you interact with or access the Services. For example, we automatically receive and record information from your browser, including your IP address, your geographic location, device type and unique device identification numbers, and technical data collected through cookies (as discussed below), pixel tags and other similar technologies that identify your browser.

“Cookies” are small data files placed on your browser, computer or other devices when you visit certain websites, which are intended to recognize your device when you return to our website or related websites. We use cookies to help us recognize you as a user, collect information about your use of BLOCKS, and collect information about your computer or other devices. Cookies enable us to better customize our Services and Content for you.

Cookies we place on your browser or device are called “first party cookies.” Cookies set by our partners or other third parties are called “third party cookies.” Cookies set by third parties can recognize your device when you visit the BLOCKS website, as well as certain other websites or mobile applications.

Cookies can either be “session cookies” or“ persistent cookies.” Session cookies are temporary: they stay on your device only while you are visiting our website or accessing our Services. “Persistent cookies” stay on your browsing device until they expire or are deleted.

We—and our affiliates and/ or service providers—use the following types of cookies:

• Essential Cookies: Essential cookies allow you to navigate and use certain features of our Services. For example, certain essential cookies enable you to access secure areas of our Services. Without these cookies, some Services may be unavailable to you.
• Functional Cookies: Functional cookies allow us to record your choices and settings regarding our Services. These cookies help us personalize our content for you, greet you by name, and remember your preferences.
• Performance/Analytics Cookies: Performance/analytical cookies allow us to understand how you use our Services and website. For example, these cookies register information about the number of visitors to the website, the most frequently-viewed pages on our website and the length of time users view particular pages on our site.
• Advertisement Cookies:   Advertising cookies allow us and third parties serve relevant ads to you more effectively and help us collect aggregated audit data, research, and performance reporting for advertisers. They also enable us to understand and improve the delivery of ads to you and know when certain ads have been shown to you. Your web browser may request advertisements directly from ad network servers, these networks can view, edit, or set their own cookies, just as if you had requested a web page from their website. Although we do not use cookies to create a profile of your browsing behavior on third-party sites, we do use aggregate data from third parties to show you relevant, interest-based advertising. We do not provide any personal information that we collect to advertisers.
• Social Media Cookies: Third-party cookies from social media sites (such as Facebook, Twitter, etc) let us track social network users when they visit our Website, use our Services or share content, by using a tagging mechanism provided by those social networks. These cookies are also used for event tracking and remarketing purposes. Any data collected with these tags will be used in accordance with our and social networks’ privacy policies. We will not collect or share any personally identifiable information from the user.

If you choose to prevent or limit your device’s acceptance of cookies on your browser or device, you may not be able to use or access all of our Services. If you do not consent to the placing of cookies on your device, do not access or use our Services.

We may also collect information from publicly available sources. We do not link information obtained from Cookies to other personal information.

Our emails may contain a "web beacon" (or "tracking pixel") to tell us whether our emails are opened and verify any clicks through to links or advertisements within the email. We may use this information for purposes including determining which of our emails are more interesting to users and to query whether users who do not open our emails wish to continue receiving them. The pixel will be deleted when you delete thee mail. If you do not wish the pixel to be downloaded to your device, you should read the email in plain text view or with images disabled.

We work closely with third parties who may provide certain Personal Information to us, such as:

Information Collected from Other Sources

We work closely with third parties who may provide certain Personal Information to us, such as:
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• basic personal information (e.g., name and address) from the banks you use to transfer money, public databases, credit bureaus or our business partners;
• other personal, commercial and/or identification information (e.g., information we, in our sole discretion, deem necessary to comply with our legal obligations under various AML laws) from business partners who may use a combination of government records and other publicly available information to verify your identity and
• your financial information (e.g., your bank account details) from the banks you use to transfer money to us.

Credit reference agencies do not provide us with any personal information about you but may be used to corroborate the information you have provided to us.
‍

How Does BLOCKS Use My Personal Information?

BLOCKS primarily uses Personal Information to customize, develop, operate, and improve our Services, including by implementing preferences requested by our users.

We also use Personal Information gathered from our users to:

•  Verify your identity and allow you to activate a BLOCKS Account;
•  Protect us and our proprietary materials, including the Content;
• Enhance security for our users, including by monitoring and verifying user identity as well as combatting malware, viruses or other security risks;
• Comply with applicable laws requiring us to collect certain Personal Information, including AML laws;
•  Contact you and allow other users to contact you;
• Analyze your use of the Services, including to personalize content based on your usage patterns; and
•  and for other legitimate business purposes.

In certain cases, we may share some Personal Information with third parties, but only as described below. We will disclose any information we collect, use or receive if required or permitted by law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account, and personal data will likely be among the assets transferred.

Why Is BLOCKS Permitted to Process My Personal Data?

BLOCKS primarily uses Personal Information to customize, develop, operate, and improve our Services, including by implementing preferences requested by our users.

We rely on the following bases to process your Personal Information:

Consent: We may use your Personal Information as described in this Privacy Policy subject to your consent. To withdraw your consent, please contact us [email protected]. Please also see the section below regarding your rights and choices.

Performance of a contract: We may need to collect and use your Personal Information to enter into an agreement with you or to perform an agreement that you have with us. When we process Personal Information on behalf of third parties, we do so in performance of agreements with such third parties.

Legitimate Interests: We may use your Personal Information for our legitimate interests to provide our Services and to improve our Services and the Content. We process information on behalf of third parties who have legitimate interests in operating their businesses. We may use technical information as described in this Privacy Policy and use Personal Information for our marketing purposes consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable law.

When and With Whom Does BLOCKS Share My Personal Information?

BLOCKS may share your Personal Information with third parties who have a legitimate purpose for accessing it. We will never sell, rent or otherwise profit from your Personal Information.

We will share your Personal Information in the following circumstances:

Service Providers: We employ other companies and people to assist with parts of our business operations and perform tasks on our behalf. Where necessary, we will share your Personal Information with these service providers in order to deliver the Services to you. For example, we may provide your Personal Information to identity verification services to perform KYC and AML checks and to prevent fraud; to the custodian who provides services for and access to thee- Wallet; to bill collection, marketing, and technology services; or to financial institutions or payment processing companies to receive and process your payment information or credit card transactions.

Unless we tell you differently, our service providers do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.

Change of Control/Transfer of Assets: If we engage in any potential business transaction, including selling our assets, we may disclose your Personal Information in an anonymized form in connection with the evaluation of such transactions. In the event of a merger, acquisition, or other corporate combination, or if we go out of business or enter bankruptcy, we may transferor sell Personal Information to a third party. We will provide notice to you prior to any transfer of your data to another company or person through a change of control or other corporate combination.

As Required by Law: We reserve the right to access, read, preserve, anddisclose any Personal Information to comply with law or court order, includingto verify your identity, prevent and detect fraud and crime, conduct or cooratein investigations of fraud or other illegal activity, enforce or apply our Terms orprotect the rights, property, or safety of BLOCKS, our employees, ouruers, or others.

In Anonymized Form: BLOCKS may use your Personal Information to create aggregated and anonymized data about our Services or the user thereof and provide such information to our partners. In anonymizing your Personal Information or aggregating usage information, we will ensure you are not identifiable as an individual.

Affiliates: We may disclose information about you to our affiliates for the purpose of being able to offer you related or additional products and services. Any information relating to you that we provide to our affiliates will be treated by those affiliates in accordance with the terms of this Privacy Policy

Advertisers: We may display online advertisements and we may share aggregated and non-identifying information about our customers that we collect through the registration process or through online surveys and promotions with certain advertisers. We do not share personally identifiable information about individual customers with advertisers. In some instances, we may use this aggregated and non-identifying information to deliver tailored advertisements to the intended audience.

How Does BLOCKS Protect My Personal Information?

BLOCKS takes the security of your Personal Information seriously and has implemented reasonable and commercially viable administrative, physical and technical security measures to help ensure that Personal Information is not lost, abused, altered or open to unauthorized use and/or disclosure. We cannot guarantee that all transmission of data over the Internet or through a blockchain network is completely secure or error-free.

We cannot guarantee complete security of the Personal Information we hold in our records. For that reason, you acknowledge and agree that you are responsible for safeguarding, protecting—and preventing unauthorized access to—your Personal Information and your BLOCKS Account. You agree to protect the password for, and any other security information related to, your BLOCKS Account, to limit access to the computer(s) or device(s)you use to access the Services, and to sign out of your BLOCKS Account after you have completed accessing the Services. We will not be liable for privacy violations that arise from your errors or negligent use of the Services or for processes and networks that we do not control and for unauthorized access to information by those who have gained access through unlawful means.

If you suspect that your Personal Information or your BLOCKS Account has been compromised, immediately contact BLOCKS Customer Support at [email protected].

What Are My Rights & Choices Relating to My Personal Information?

It is your right not to disclose Personal Information to us. However, where you fail to provide Personal Information required by law or otherwise required to open a BLOCKS Account, we may not be able to register you to use or access the Services or may terminate your BLOCKS Account

You have the right, through your BLOCKS Account, to access and view certain Personal Information you provided to us, including your name and password, your email address, your transaction history and information relating to your use of the Services.

In addition, you have the right to determine whether we hold accurate and current Personal Information about you, to request a copy of the Personal Information we hold about you pursuant to applicable law, and to update your Personal Information. Note, however, that we may maintain a copy of the prior Personal Information in our records.

You have the right to request that we delete certain Personal Information about you or that we delete your BLOCKS Account by contacting BLOCKS Customer Support at [email protected]. Pursuant to applicable laws, including those relating to the BSA and AML, we may retain certain information about you even after you request that we delete your Personal Information or terminate your BLOCKS Account.

In certain circumstances, you have the right to receive the Personal Information you have provided to us in an electronic format and to request that we transmit that Personal Information to another data controller.

Disclosures for California Users

California Information-Sharing Disclosure : California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed. If you are a California resident and want such a list, please send us a written request by email to [email protected] with “California Privacy Rights” in the subject line.

California Right to Object : If you are a California resident, to the extent provided under California law, you may object in writing to the sale or other sharing of your personal information, and we will refrain from doing so with out an economic impact on you, except to the extent, if any, that our inability to make use of your data impacts the economic value of our business relationship.

California Do Not Track Disclosure : We do not currently recognize or respond to browser-initiated Do Not Track signals as there is no consistent industry standard for compliance. Depending on the browser you are using, you may be able to choose to block third party cookies or browse in a private browsing mode. The Services and the BLOCKS website are accessible even when private browsing is turned on. The information we collect is governed by this Privacy Policy.

How Long Does BLOCKSKeep My Personal Information?

We retain the Personal Information we collect for so long as reasonably necessary to fulfill the purposes for which the data was collected, to perform our contractual and legal obligations, and for any applicable statute of limitations periods.

Privacy of Minors

BLOCKS does not knowingly collect or solicit Personal Information from anyone under the age of 18. If you are under 18, do NOT attempt to access or use the Services and do NOT send any Personal Information to us. If we learn that we have collected Personal Information from a person under age 18, we will delete and/or destroy that information as quickly as reasonably possible and close any BLOCKS Account associated with it. If you know that a person under the age of 18 is using our Services or provided Personal Information to us, please contact BLOCKS Customer Support at [email protected].

Links to Other Sites

BLOCKS may include links to third party sites on the BLOCKS website or when you are accessing the Services. The inclusion of any link does not imply that we endorse the products and services offered at such linked site. These third-party sites have separate and independent privacy policies which we encourage you to review. We therefore have no responsibility or liability for the content and activities of these linked sites.

Contact BLOCKS

If you have any questions or concerns regarding this Privacy Policy or otherwise would like to contact BLOCKS, please send BLOCKS Customer Support an email at [email protected].