PRIVACY POLICY FOR FBYT

We may update this Privacy Policy from time to time to reflect changes in our data processing practices, regulatory requirements, or operational needs.

Where required, we will provide you with the opportunity to:

1. (a)
   Provide consent
2. (b)
   Object to processing
3. (c)
   Exercise your rights under applicable data protection laws

We will notify you of material changes through the Interface before they take effect.

By accessing or using the Interface, you represent and warrant that:

1. (a)
   You are at least eighteen (18) years of age
2. (b)
   You have the legal capacity to enter into binding agreements

If you are under 18, you may not use the Interface.

This Privacy Policy applies to all interactions with the Interface.

We may engage third-party service providers (“processors”) to support our operations. These may include:

1. (a)
   Technical maintenance providers
2. (b)
   Project and team management tools
3. (c)
   Communication service providers
4. (d)
   Analytics, statistics, performance, and marketing vendors

These processors may access and process Personal Data strictly in accordance with our instructions and for operational purposes only. We enter into a data processing agreement with each processor in accordance with Article 28 GDPR.

Types of Data Collected. To the maximum extent possible, we aim to minimize Personal Data collection.

1. (a)
   Automatically Collected Data

   1. (i)
      IP address
   2. (ii)
      Browser type and version
2. (b)
   Blockchain Data

   1. (i)
      Public wallet addresses
   2. (ii)
      Transaction history
   3. (iii)
      Token balances

   Wallet addresses may constitute Personal Data, in particular when associated with your IP address or other identifiers, and we treat them as such. We use public blockchain addresses to understand user interaction patterns in aggregate. We do not use this data to identify individual users.

3. (c)
   Log Files

   We follow standard procedures for log file usage. This may include:

   1. (i)
      IP addresses
   2. (ii)
      Browser type
4. (d)
   Communication Data

   Any information you voluntarily provide when contacting us.

5. (e)
   Rewards and Referral Data

   Your points balance, loyalty tier and referral activity.

How and Why We Use Personal Data. We process Personal Data only for the following purposes:

1. (a)
   Ensuring security and preventing fraud
2. (b)
   Identifying irregular or malicious activity
3. (c)
   Maintaining and improving performance
4. (d)
   Analyzing user behavior in aggregate
5. (e)
   Administering and operating the Interface, including the rewards and referral programmes
6. (f)
   Responding to user inquiries
7. (g)
   Complying with legal and regulatory obligations

Legal Basis for Processing. We may process Personal Data based on:

1. (a)
   Contract performance - to provide access to the Interface
2. (b)
   Legitimate interests - to secure and improve the Interface
3. (c)
   Legal obligations - to comply with applicable laws
4. (d)
   Consent - where required, including for non-essential cookies (see Section 5)

Blockchain Disclaimer. The Interface operates in connection with decentralized blockchain networks.

You acknowledge that:

1. (a)
   Blockchain transactions are public and immutable
2. (b)
   Data recorded on-chain cannot be deleted or modified
3. (c)
   FBYT does not control blockchain networks

We are not responsible for the processing of data on blockchain networks.

Disclosure of Personal Data. We may disclose Personal Data:

1. (a)
   To service providers and processors
2. (b)
   To Rockwell Technologies Ltd., where you activate automated trading, which processes your data as an independent controller under its own privacy notice
3. (c)
   To affiliates or related entities (if applicable)
4. (d)
   To comply with legal obligations or law enforcement requests
5. (e)
   In connection with mergers, restructuring, or corporate changes

We do not sell Personal Data.

Data Retention. We retain Personal Data only as long as necessary to:

1. (a)
   Fulfill the purposes outlined in this Policy
2. (b)
   Comply with legal requirements
3. (c)
   Resolve disputes and enforce agreements

Unless a longer period is required by law, IP addresses and log files are retained for no longer than 12 months, and communication data for no longer than 24 months after our last contact with you.

Aggregated and anonymized data may be retained for longer periods.

We may use cookies and similar technologies to collect information about:

1. (a)
   Device usage
2. (b)
   Browsing behavior
3. (c)
   Interaction patterns

This data helps us:

1. (a)
   Improve the Interface
2. (b)
   Enhance user experience
3. (c)
   Analyze performance

Strictly necessary cookies are used without consent. All other cookies, including analytics and marketing cookies, are placed only with your prior consent, which you may give or withdraw at any time through the cookie settings in the Interface. You can also manage cookies through your browser settings.

If you are located in the European Economic Area, you may have the following rights:

1. (a)
   Right to be informed
2. (b)
   Right of access
3. (c)
   Right to rectification
4. (d)
   Right to erasure (“right to be forgotten”)
5. (e)
   Right to restrict processing
6. (f)
   Right to data portability
7. (g)
   Right to object
8. (h)
   Right to withdraw consent
9. (i)
   Right to lodge a complaint with a supervisory authority

To exercise any of these rights, contact us at [email protected]. We will respond within one month of receiving your request, which may be extended where permitted by Article 12 GDPR. You may lodge a complaint with the supervisory authority of your country of residence.

The Interface is not directed to individuals under 18.

We do not knowingly collect Personal Data from minors.

Personal Data may be transferred to jurisdictions outside your country of residence.

Where required, we implement appropriate safeguards in accordance with applicable laws, such as an adequacy decision of the European Commission or the Standard Contractual Clauses adopted by it.

We implement technical and organizational measures to protect Personal Data, including:

1. (a)
   Encryption
2. (b)
   Access controls
3. (c)
   Secure infrastructure

However, no system can guarantee absolute security.