Privacy Policy

This Privacy Policy ("Privacy Policy") explains how Elementa Protocol ("Elementa," "we," "us," or "our") collects, uses, stores, protects, and discloses information in connection with the Elementa ecosystem, including the Elementa Wallet application, website, desktop applications, mobile applications, software, APIs, interfaces, and related services (collectively, the "Services").

This Privacy Policy applies to information processed through the Services and explains your rights and choices regarding your personal information.

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy.

If you do not agree with this Privacy Policy, you should not access or use the Services.

Elementa respects the privacy and security of its users.

We are committed to:

• collecting only information reasonably necessary for legitimate purposes;
• using personal information in accordance with applicable law;
• implementing reasonable technical and organizational safeguards;
• limiting access to personal information to authorized personnel and service providers;
• being transparent about how information is collected and used;
• protecting information against unauthorized access, loss, misuse, alteration, and disclosure; and
• respecting applicable privacy rights.

We do not sell your personal information for money.

We do not intentionally collect information that is not reasonably necessary for operating, securing, improving, supporting, or legally complying with the Services.

However, no internet-based service, software system, digital storage system, or transmission method can be guaranteed to be completely secure.

Accordingly, while we use reasonable safeguards to protect your information, we cannot guarantee absolute security.

Elementa provides non-custodial wallet software.

This means that Elementa does not generally take custody or control of your Digital Assets or private cryptographic keys.

Your blockchain transactions may be publicly visible on the applicable blockchain network.

A blockchain address may be publicly associated with transaction history and other blockchain data.

Although blockchain addresses may not directly contain your legal name, blockchain data may potentially be linked with other information in certain circumstances.

You should therefore carefully consider what information you connect, submit, or associate with your Wallet.

The non-custodial nature of the Wallet does not mean that Elementa collects no information.

Depending on how you use the Services, Elementa may process information such as account information, device information, technical information, wallet addresses, transaction-related information, support communications, analytics data, and information received from third-party providers.

The information we collect depends on how you use the Services. We may collect the following categories of information.

Elementa may integrate with third-party service providers. These may include:

• authentication providers;
• blockchain infrastructure providers;
• RPC providers;
• on-ramp providers;
• off-ramp providers;
• KYC providers;
• payment processors;
• analytics providers;
• application performance providers;
• cloud infrastructure providers;
• customer support platforms;
• security providers; and
• other technology providers.

Third-party providers may independently collect information from you. Their processing of personal information may be governed by their own privacy policies and terms. You should review the privacy policies of third-party services before using them.

We may use information for the following purposes.

Where applicable privacy laws require a legal basis for processing personal information, we may process information based on one or more of the following:

• Consent — Where you have provided consent.
• Contractual Necessity — Where processing is necessary to provide requested Services or perform an agreement with you.
• Legal Obligation — Where processing is required to comply with applicable law.
• Legitimate Interests — Where processing is reasonably necessary for legitimate business purposes, including: security; fraud prevention; service improvement; technical operations; business administration; protecting legal rights; and preventing misuse.
• Protection of Vital Interests — Where necessary to protect the vital interests of an individual or another person, where legally permitted.

The applicable legal basis depends on the specific processing activity and applicable law.

We may share information in the following circumstances.

Elementa takes reasonable technical and organizational measures designed to protect personal information. Depending on the nature of the information and the risks involved, safeguards may include:

• encryption in transit;
• encryption at rest where appropriate;
• access controls;
• authentication controls;
• least-privilege access;
• security monitoring;
• logging;
• infrastructure security;
• vulnerability management;
• backup controls;
• incident response procedures; and
• internal security practices.

Access to personal information is limited to personnel and service providers who require access for legitimate purposes.

However, no security system is completely secure. We cannot guarantee that:

• unauthorized access will never occur;
• data transmission will always be secure;
• the Services will never be attacked;
• information will never be lost; or
• a security incident will never occur.

You are also responsible for protecting your own credentials and devices. You should:

• use strong passwords;
• protect authentication credentials;
• enable available security features;
• avoid sharing account access;
• keep devices updated;
• avoid suspicious links;
• protect recovery credentials; and
• immediately report suspected unauthorized activity.

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including:

• providing the Services;
• maintaining business records;
• fulfilling legal obligations;
• resolving disputes;
• enforcing agreements;
• preventing fraud;
• maintaining security; and
• protecting legal rights.

Retention periods may vary depending on:

• the type of information;
• the purpose of processing;
• legal requirements;
• regulatory requirements;
• security considerations; and
• operational requirements.

Some information may be retained for longer periods where required by law. Information permanently recorded on public blockchains may not be capable of deletion by Elementa.

Elementa and its service providers may process information in countries other than the country where you reside. Those countries may have privacy laws that differ from the laws of your country.

Where applicable law requires safeguards for international transfers, we will seek to implement appropriate safeguards.

By using the Services, you acknowledge that information may be processed internationally, subject to applicable law.

Depending on your jurisdiction, you may have rights regarding your personal information. These rights may include the right to:

• request access to personal information;
• request correction of inaccurate information;
• request deletion of information;
• request restriction of processing;
• object to certain processing;
• request data portability;
• withdraw consent where processing is based on consent; and
• lodge a complaint with a relevant data protection authority.

These rights are not absolute. We may be required to retain certain information to:

• comply with legal obligations;
• prevent fraud;
• maintain security;
• establish or defend legal claims;
• comply with regulatory requirements; or
• fulfill other lawful purposes.

To exercise applicable privacy rights, contact us at info@elementaprotocol.com. We may need to verify your identity before processing a privacy request.

Where available, you may request deletion of your Elementa account.

Account deletion may not result in the deletion of all information. We may retain information where reasonably necessary or legally required for:

• legal compliance;
• fraud prevention;
• security;
• dispute resolution;
• recordkeeping;
• tax or accounting purposes;
• regulatory obligations; or
• the establishment, exercise, or defense of legal claims.

Information recorded on public blockchains cannot generally be deleted or modified by Elementa.

The Elementa website and certain Services may use cookies and similar technologies. These technologies may be used for:

• essential functionality;
• security;
• authentication;
• analytics;
• performance;
• preferences; and
• marketing, where applicable and legally permitted.

You may be able to control cookies through your browser settings. Disabling certain cookies may affect the functionality of the Services.

Elementa may use analytics and application monitoring tools to understand how users interact with the Services. These tools may collect information such as:

• device information;
• application events;
• usage patterns;
• crash information;
• technical information;
• IP address information;
• approximate location; and
• other analytics information.

Where third-party analytics providers are used, those providers may process information according to their own privacy policies. Elementa may use aggregated or de-identified information to understand trends and improve the Services.

The Services are not intended for individuals who are not legally permitted to use them under applicable law.

We do not knowingly collect personal information from children in violation of applicable law.

If you believe that a child has provided personal information to us inappropriately, contact us. If we learn that we have collected personal information from a child in circumstances where collection was not permitted, we will take reasonable steps to address the situation as required by applicable law.

The Services may contain links to third-party websites, applications, services, or platforms. Elementa is not responsible for the privacy practices of third parties.

Your use of third-party services is governed by their own terms and privacy policies. You should review those policies before providing information to third parties.

If Elementa becomes aware of a security incident involving personal information, we will assess the incident and take reasonable steps as required by applicable law. Depending on the circumstances, this may include:

• investigating the incident;
• containing the incident;
• taking corrective action;
• notifying relevant authorities;
• notifying affected users where legally required; and
• implementing measures to prevent recurrence.

We cannot guarantee that every security incident can be prevented.

You acknowledge that blockchain networks are generally decentralized and transparent. Transactions may reveal information such as:

• wallet addresses;
• transaction amounts;
• token types;
• timestamps;
• transaction history; and
• smart contract interactions.

Once information is recorded on a public blockchain, it may be permanently available to the public. Elementa cannot guarantee the anonymity or confidentiality of blockchain transactions. You should not assume that blockchain transactions are private.

Elementa's non-custodial architecture is intended to reduce the risk that Elementa itself can directly control or transfer user Digital Assets. However, non-custodial architecture does not eliminate all security risks.

Users remain responsible for:

• securing devices;
• securing credentials;
• protecting recovery mechanisms;
• reviewing transactions;
• verifying addresses; and
• protecting Wallet access.

Elementa is not responsible for losses resulting from the compromise or misuse of user credentials or access mechanisms, except to the extent liability cannot legally be excluded.

Elementa will not ordinarily require you to provide:

• private keys;
• seed phrases;
• recovery phrases;
• Wallet passwords; or
• other credentials capable of directly controlling your Digital Assets.

You should never send these credentials to:

• Elementa employees;
• customer support;
• third-party websites;
• individuals claiming to represent Elementa; or
• any other person unless you fully understand the security consequences.

If someone asks for your recovery phrase or private key while claiming to represent Elementa, treat the request as suspicious.

Communications with Elementa may be stored or retained for purposes including:

• customer support;
• quality assurance;
• security;
• dispute resolution;
• training and service improvement, where legally permitted; and
• legal compliance.

Do not include sensitive credentials in support communications.

We may update this Privacy Policy from time to time. When we make material changes, we may provide notice through:

• the Services;
• our website;
• email;
• application notifications; or
• other legally appropriate methods.

The "Last Updated" date at the beginning of this Privacy Policy indicates when it was most recently updated. Your continued use of the Services after the effective date of an updated Privacy Policy constitutes acceptance of the updated Privacy Policy to the extent permitted by law.

If you have questions, concerns, or requests regarding this Privacy Policy or the processing of your personal information, contact us at:

Elementa Protocol

Email: info@elementaprotocol.com

For privacy-related requests, please include sufficient information for us to understand and process your request.

By using the Elementa Services, you acknowledge and understand that:

• Elementa is a non-custodial software provider;
• Elementa does not generally custody or control your Digital Assets;
• blockchain transactions may be publicly visible and permanent;
• Elementa may process personal information necessary to provide, secure, improve, and legally operate the Services;
• third-party providers may independently process your information;
• KYC and on-ramp/off-ramp providers may process information under their own privacy policies;
• Elementa may disclose information where legally required or legally permitted;
• no internet or technology system can guarantee absolute security;
• you are responsible for protecting your own Wallet credentials and devices; and
• your privacy rights are protected in accordance with applicable law.

Elementa is committed to handling personal information responsibly, securely, and transparently. We will not sell your personal information for money, and we will use and disclose personal information only for legitimate business purposes, service provision, security, legal compliance, and other purposes described in this Privacy Policy or otherwise permitted by applicable law.

BY USING THE SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY.