Privacy Policy

The Portal collects the following categories of information:

We use the information we collect for the following purposes:

• Rewards Program administration: to record and calculate Points, maintain Leaderboard rankings, determine Rewards eligibility, allocate and distribute Rewards, and administer Rewards Periods;

• Eligibility and compliance verification: to verify that participants satisfy the eligibility requirements set out in the Rewards Program Terms and Conditions, including sanctions screening and jurisdictional restrictions;

• Fraud prevention and abuse detection: to identify and prevent manipulation of the Rewards Program, including multi-wallet abuse, automated activity, and other prohibited conduct;

• Portal operation and security: to operate, maintain, and secure the Portal, monitor for threats and abuse, and investigate incidents;

• Analytics and improvement: to analyse usage patterns, improve Portal functionality and user experience, and develop new features; and

• Legal compliance: to comply with applicable laws, regulations, and legal obligations, and to respond to lawful requests from governmental authorities.

We process personal information on the following lawful bases:

• Contractual necessity: processing of wallet address data and Rewards Program Data is necessary to administer the Rewards Program and perform our obligations under the Rewards Program Terms and Conditions;

• Legitimate interests: processing of Technical and Usage Data for Portal security, fraud prevention, and analytics is based on our legitimate interest in operating and improving the Portal and protecting the integrity of the Rewards Program; and

• Legal obligation: processing necessary to comply with applicable laws and regulations, including sanctions screening and responses to lawful governmental requests.

We do not rely on consent as a lawful basis for processing in connection with Portal operation or Rewards Program administration, as participation is voluntary and the processing described above is necessary to deliver the Rewards Program or is based on legitimate interests. Where we process information based on legitimate interests, we have assessed that those interests are not overridden by your privacy rights, given the pseudonymous nature of the data processed and the limited scope of the Portal's activities.

A significant portion of the data underlying the Rewards Program is on-chain data recorded permanently and immutably on the Somnia Network public blockchain. This includes wallet addresses, prediction activity, Points-relevant transaction data, and timestamps. This data is publicly accessible to anyone and is not under our control or custody.

Wallet addresses are pseudonymous, not anonymous. You should be aware that:

• all wallet addresses you use in connection with the Rewards Program, and all on-chain activity associated with those addresses, are visible on the public blockchain;

• transaction amounts, frequencies, and patterns are publicly observable;

• blockchain analysis techniques, transaction pattern analysis, IP address correlation, and other methods may be used by third parties to link your wallet address to your real-world identity;

• once a wallet address is linked to your identity, all historical and future on-chain activity from that address may be attributed to you; and

• we cannot provide anonymity guarantees or prevent third-party blockchain analysis.

We have no control over blockchain analysis conducted by third parties, including analytics companies, regulators, or researchers. We cannot delete or modify on-chain data. Requesting deletion of information we hold at the Portal level will not affect your on-chain transaction history.

We do not sell or share your personal information with third parties for their own marketing purposes. We may share information in the following circumstances:

Your wallet address and Points balance are displayed publicly on the Portal Leaderboard. By participating in the Rewards Program, you acknowledge and accept that your wallet address and Points ranking will be publicly visible. If you do not wish your wallet address to be publicly displayed, you should not participate in the Rewards Program.

We retain information collected through the Portal for the following periods, subject to extension where required for legal, compliance, or legitimate business purposes:

• Wallet address and Rewards Program Data: for the duration of the relevant Rewards Period and for a period of 3 years following conclusion of that Rewards Period, to support audit, compliance, and dispute resolution purposes;

• Technical and Usage Data (including IP address logs): 12 months from the date of collection; and

• Communications data: 3 years from the date of the last communication.

Retention periods may be extended where reasonably necessary to: comply with applicable legal or regulatory obligations; investigate and address fraud, abuse, or security incidents; enforce the Rewards Program Terms and Conditions; or resolve disputes. On-chain data is retained permanently on the public blockchain and is outside our control.

Depending on your jurisdiction, you may have certain rights regarding personal information we hold about you. These may include the right to: access the personal information we hold about you; request correction of inaccurate information; request deletion of information we hold, subject to legal retention obligations and legitimate business interests; object to or request restriction of certain processing activities; and lodge a complaint with a competent data protection authority.

To exercise any of these rights, please contact us. We will respond to legitimate requests within a reasonable timeframe and generally within 30 calendar days. We may need to verify your identity or wallet address before processing a request.

Please note that:

• we cannot delete or modify on-chain data, which is permanently recorded on the public blockchain and outside our control;

• deletion of Portal-level data will not affect your on-chain activity history or your ability to interact with Venues directly; and

• certain information may be retained despite a deletion request where retention is required by applicable law or necessary for the legitimate purposes described in this Policy.

We do not collect or process sensitive personal information (as defined under applicable data protection laws), government-issued identification documents, financial account information, or biometric data. The Portal operates on a wallet-only, non-custodial basis and does not require identity verification.

We do not knowingly sell or share personal information, including personal information relating to individuals under the age of 18.

California residents may have additional rights under the California Consumer Privacy Act (CCPA), as amended.

The Portal uses cookies and similar tracking technologies to support its operation and to collect Technical and Usage Data. The following types of cookies may be used:

• Essential cookies: necessary for the Portal to function, including session management and security. These cannot be disabled without affecting Portal operation.

• Analytics cookies: used to understand how users interact with the Portal, including which pages are visited and how long sessions last. This data is used in aggregated, anonymized form to improve the Portal.

• Performance cookies: used to monitor Portal performance and identify errors.

You can control cookies through your browser settings. Most browsers allow you to view, block, or delete cookies. Please note that disabling certain cookies may affect the functionality of the Portal. We do not currently respond to "Do Not Track" signals from browsers, as no universally accepted standard exists for interpreting such signals.

Information collected through the Portal may be transferred to and processed in countries other than your country of residence. By accessing the Portal, you acknowledge that your information may be transferred to and processed in jurisdictions that may have different data protection rules than your own.

On-chain data is distributed across a global network of blockchain nodes operating in multiple jurisdictions. We have no control over the geographic location of blockchain nodes or the processing of on-chain data by those nodes.

Where we engage service providers who may access your information from other jurisdictions, we take steps to ensure that appropriate protections are in place consistent with applicable data protection requirements.

We maintain technical and organisational measures designed to protect information held in connection with the Portal against unauthorised access, disclosure, alteration, and destruction. However, no security measure is entirely infallible, and we cannot guarantee the absolute security of information transmitted over the internet or stored in our systems. You are responsible for maintaining the security and confidentiality of your wallet credentials. We will have no liability for any loss resulting from unauthorised access to your wallet or private keys.

The Portal may contain links to, or display information about, Venues and other third-party websites or services. This Policy does not apply to any Venue or third-party service. Each Venue and third-party service is subject to its own privacy policy and terms, which you should review before accessing or using it. We are not responsible for the privacy practices or content of any Venue or third-party service.

We may update or modify this Policy at any time. Any revised version will be published on the Portal with an updated effective date. Your continued access to or use of the Portal following the posting of a revised Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically. If you do not agree with any changes, you must discontinue use of the Portal.

For any questions, concerns, or requests relating to this Policy or the processing of your information in connection with the Portal or the Rewards Program, please contact us.