Privacy Policy

Laurium Corp ("we", "our", "us") is committed to protecting and respecting your privacy. We are a company established in Delaware, and for the purpose of applicable data protection laws, we are the data controller. Our representative in the European Economic Area and the UK is DataRep.

This Privacy Policy sets out the basis on which we will process any personal data or usage information we collect from you, or that you provide to us, in connection with your use of the pod.network website (our "Website") and any content, block explorers, tools, documentation, features, and functionality offered on or through the Website or other interfaces through which you interact with the pod network protocol (together, the "Services").

Please read this Privacy Policy carefully so that you understand your rights in relation to your personal data, and how we will collect, use, and process your personal data. This Privacy Policy supplements any other privacy-related notices and policies we may provide to you from time to time, and is not intended to override them. If you do not agree with this Privacy Policy in general or any part of it, you should not access the Website, use our Services, or otherwise provide your information to us.

Our Website and Services are not intended for children, and we do not knowingly collect data relating to children. Children must not use the Services, except where their parent or guardian has provided consent, if this option is available in your location.

We change our Privacy Policy from time to time. Updates to our Privacy Policy will apply only to information collected after the date of the change. We will note on our Website when our Privacy Policy has been updated. Please check the Website regularly for notices of changes to our Privacy Policy.

THE INFORMATION WE COLLECT

Information you give to us

You may provide some or all of the following personal data to us by interacting with the Services:

• Contact details to join the waitlist, including your email address
• Wallet details, through which you access the Services
• Social media account details, if you choose to access the Services via third-party social media platforms such as X
• Information for sanctions checks
• Information you provide to us about your experience with trading, i.e., whether you are a "Beginner", "Intermediate", "Advanced", or "Professional"
• Referral Codes, if you received a referral link to access the Services
• Transaction data, including deposit amounts, transaction hashes, and deposit status
• Any other information you choose to include in communications with us, for example, when sending a message to us via email or on our Website

This information is required to enable us to fulfill our contract with you. If you do not provide this information, we will not be able to provide you with our Services.

Information we collect automatically

When you visit our Website and use our Services we automatically collect the information sent to us by your computer, mobile phone, or other device. This information includes: (i) your IP address; (ii) device information including, but not limited to, name and type of operating system and browser used, and (iii) data about your use of the Services collected via cookies and analytics tools.

Information we collect from third parties

We may obtain information about you from outside sources, including information that we collect directly from third parties and information from third parties that you choose to share with us. Such information includes information we receive when you choose to link any third-party platform or wallet to your account.

HOW WE USE YOUR INFORMATION

We process your personal data in order to perform our contract with you, such as:

• provide you with our Services, other content, and Website functionality;
• register and maintain your account with us

We obtain your consent to process your personal data for the following reasons:

• sign you up for our newsletters or alerts;
• personalise our services for you; and
• if you opted into marketing, to communicate with you about products, services, marketing, promotions, events, and other news and information we think will be of interest to you.

In order to be responsive to you, to provide effective services to you, and to maintain our business relationship, as a matter of our legitimate interests, we will use your personal data to:

• administer the Website and Services, and for internal operations, in order to conduct troubleshooting, data analysis, testing, research, statistical and survey analysis;
• maintain the safety and security of our users, the Website, our Services, and business;
• send you announcements in relation to security, privacy, or administrative-related communications (these communications are not marketing-oriented, and we do not rely on consent, so you may not opt out);
• personalize our Website and our Services to ensure content is presented in the most effective manner for you and your device; and
• improve and develop our products.

In addition, we will use some or all of the above information to comply with any applicable legal obligations, to enforce any applicable terms and conditions and/ or terms of service, and to protect or defend the Services, our rights, the rights of our users, or others.

COOKIES

We use cookies and other similar technologies to collect information about your browsing activities over time and across different websites following your use of our Services. Cookies allow us to recognize and count the number of users and to see how users move around our website when they are using it. This helps us to improve our Services and the way our website works. You can find more information about cookies and how to manage them here.

For more information, please refer to our Cookies Policy.

HOW THE COMPANY SHARES YOUR INFORMATION

We do not use or share your personal data with others except as described in this Privacy Policy. In certain circumstances, we will share your information with third parties with your consent, as necessary, or as otherwise required or permitted by law. Specifically, we share your personal data:

• With service providers and vendors, in our legitimate interests to operate a successful business. Such third parties include: (i) data analytics vendors; (ii) security vendors; and (iii) website hosting vendors. These service providers assist us with many different functions and tasks, such as providing data storage and disaster recovery services and communicating with you.
• When you request us to share certain information with third parties, with consent or to perform a contract with you. With your permission, we will disclose your personal data to relevant third parties, such as wallet providers or crypto platforms.
• With professional advisors, in our legitimate interests to operate a successful business, or as required by law. As necessary, we will share your personal data with professional advisors such as auditors, law firms, or accounting firms.
• For legal and security reasons and to protect our services and business, in our legitimate interests to operate a successful business or as required by law. We will share your personal data with KYC/KYB providers, service providers that conduct blockchain analytics and wallet screening, regulators, law enforcement agencies, public authorities, or any other relevant organisations: (i) in response to a legal obligation; (ii) if we have determined that it is necessary to share your personal data to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries; (iii) to protect the interests of, and ensure the safety and security, of us, our users, a third party or the public; (iv) to exercise or defend legal claims; and (v) to enforce our terms and conditions, other applicable terms of service, or other agreements.
• With our affiliates, in our legitimate interests to operate a successful business. We may share your personal data with companies within our corporate family.
• In connection with an asset sale or purchase, a share sale, purchase or merger, bankruptcy, or other business transaction or re-organisation, in our legitimate interests to operate a successful business. We will share your personal data with a prospective buyer, seller, new owner, or other relevant third party as necessary while negotiating or in relation to a change of corporate control such as a restructuring, merger, or sale of our assets.

WHERE WE STORE YOUR INFORMATION

The personal data that we collect from you will be transferred to, and stored at/processed outside the EEA and UK, including in the United States. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy.

Transfers of data outside the EEA or the UK will be governed by the European Commission's standard contractual clauses for the transfer of personal data to third countries (specifically, module one (controller to controller transfer) and/or module two (controller to processor transfer), as relevant) or the UK Information Commissioner's international data transfer addendum to the EU standard contractual clauses, as relevant, unless the data transfer is to a country that has been determined by the European Commission or the relevant UK authorities, as applicable, to provide an adequate level of protection for individuals' rights and freedoms for their information (as set out here in respect of transfers from the EEA, and here in respect of transfers from the UK). Please contact us at the details set out in Section 10 should you wish to examine a copy of the EU standard contractual clauses or UK international data transfer addendum.

HOW LONG DO WE STORE YOUR PERSONAL DATA

We will retain and use your personal data for the period necessary to comply with our legal obligations (including in relation to any legal, regulatory, tax, accounting, or reporting requirements), resolve disputes, and enforce our terms and conditions, other applicable terms of service, and our policies. If you stop using our Services or if you delete your account with us, we may store your information in an aggregated and anonymised format; we may use this information indefinitely without further notice to you.

SECURITY

Although we do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the Website or over the internet; any transmission is at your own risk.

YOUR RIGHTS

If you are located in the EEA or the UK, you may have certain rights in relation to your personal data, subject to applicable law:

• Access: You have the right to access personal data we hold about you, how we use it, and who we share it with.
• Portability: You have the right to receive a copy of the personal data we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
• Correction: You have the right to correct any of your personal data we hold that is inaccurate.
• Erasure: In certain circumstances, you have the right to delete the personal data we hold about you.
• Restriction of processing to storage only: You have the right to require us to stop processing the personal data we hold about you, other than for storage purposes, in certain circumstances.
• Objection: You have the right to object to our processing of your personal data, including for marketing purposes.
• Withdrawal of consent: Where we rely on consent to process your personal data, you have the right to withdraw this consent at any time by contacting us.

Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. For example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interests or where we are required by law to retain your personal data.

To exercise any of these rights, or if you wish to delete your personal data from our systems, please contact us at privacy@pod.network. If you're based in the EU/EEA, UK or Switzerland, and wish to contact us via our GDPR Representative, DataRep, you may do so at datarequest@datarep.com or www.datarep.com/data-request. If you think we have infringed data protection laws, you have the right to lodge a complaint with us, and we will investigate your complaint and respond to you in a timely manner. You also have the right to lodge a complaint with the data protection supervisory authority in the country in which you are based or where you think we have infringed data protection laws.

THIRD PARTY LINKS

Our Website may contain links to other online platforms, plug-ins or other applications operated by third parties. We do not control such other sites or applications, and are not responsible for their content, their privacy policies, or their use of your information. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms, may also be viewable by other users of the Website and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on the Website. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of personal data by third parties. Any information submitted by you directly to these third parties is subject to that third party's privacy policy.

CONTACT

We welcome your questions, comments, and concerns about this Privacy Policy or your personal data. Please send us any feedback to privacy@pod.network.

LANGUAGE

Except as otherwise prescribed by applicable law, in the event of any inconsistency between the English language version and any other language version of this Privacy Policy, the English language version will prevail.