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PRIVACY POLICY

Last Updated: February 11, 2026

Alamas Labs, Inc., a Delaware corporation (including all affiliates, collectively referred to as "AL", "we", "us" or "our") operates Farao (as defined in the Terms of Use).

This privacy policy ("Privacy Policy") applies to all Personal Data (defined below) collected through Farao and cookies used, as well as marketing campaigns, product feedback forms, surveys, events, and sales.

We collect and use your Personal Data in accordance with this Privacy Policy and in compliance with applicable data protection legislation, including but not limited to the EU General Data Protection Regulation ((EU) 2016/679) ("GDPR"), EU Privacy and Electronic Communications Directive (2002/58/EC), and the California Consumer Privacy Act (Cal. Civ. Code § 1798.100 et seq.).

Personal Data

"Personal Data" or "Personal Information" refers to any personally identifiable information that can be used to identify or contact you, which may include, but is not limited to:

  • Phone number used to register for or log into a Farao account
  • Usage metadata

Overview of How We Collect Your Personal Data

To create and administer your Farao account

Categories of Personal Data: Your phone number, your email, your Google account, your social media handle, your wallet ID; your device data, such as your computer's or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 5G), and general location information such as city, state or geographic area when you access Farao.

Legal basis: Performance of contract, you enter into a contract with us when accepting our Terms of Use for the service.

Retention period: For as long as the account is active; deletion within a reasonable period of time after closure to comply with legal or contractual obligations.

To allow you to fund your account with an external crypto wallet

Categories of Personal Data: Your wallet ID, where a wallet is linked to your Farao account, certain interaction data (e.g. trading volume, usage metrics) may be associated with your account information.

Legal basis: Performance of contract, you enter into a contract with us when accepting our Terms of Use for the service.

Retention period: Blockchain-related data (e.g., cryptocurrency wallet addresses or transaction records) may be permanently recorded on-chain and cannot be deleted.

To operate our points and referral system

Categories of Personal Data: Your account identification data, your social media handles.

Legal basis: Performance of contract. Retention period: For as long as the account is active.

To calculate and display engagement metrics

Categories of Personal Data: Your account identification data, wallet ID, your online activity data, such as trading volume, pages or screens you viewed on Farao, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.

Legal basis: Performance of contract. Retention period: For as long as the account is active.

To answer your contact request or respond to feedback

Categories of Personal Data: Feedback or correspondence, such as information you provide when you contact us with questions, feedback, product reviews, or otherwise correspond with us online.

Legal basis: Our legitimate interest to answer your correspondences. Retention period: The time needed to answer you and no longer than 3 years after the last contact with you.

For marketing and advertising purposes

Categories of Personal Data: Your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.

Legal basis: Your consent if you are an individual and our legitimate interest to promote our services and product if you are a professional. Retention period: Until you withdraw your consent or opt out.

To conduct surveys

Categories of Personal Data: Your identification and contact details and your answers to surveys.

Legal basis: Our legitimate interest to conduct surveys to improve our services and product. Retention period: Up to 3 years after your answer to the survey.

Analytics and product improvement

Categories of Personal Data: Usage logs, interaction data.

Legal basis: Our legitimate commercial interest to improve our Products and develop Products. Retention period: Up to 12 months; anonymized thereafter. Anonymous data is no longer personal data, no retention period applies.

Analytics through third-party tools

We use third party analytics tools to understand how users interact with the App and to improve functionality and performance. No cookies are used. We do not use analytics for advertising or cross-app tracking.

Categories of Personal Data: Device information, usage events, and diagnostic data generated by the App.

Legal basis: Our legitimate commercial interest to improve our Products and develop Products. Retention period: Up to 12 months; anonymized thereafter.

Fraud prevention, security, enforcement

For compliance, fraud prevention, and safety including to (a) protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Products; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

Categories of Personal Data: Device/browser data, wallet data. IP addresses may be evaluated, together with other data, in case of attacks on the network infrastructure or other unauthorized use or misuse of the Products, for the purpose of intelligence and protection, and if appropriate, used in criminal proceedings for identification and civil and criminal proceedings against the relevant users.

Legal basis: Our legitimate interest to protect our Products against fraud, abuse, and misuse as well as to comply with a legal obligation or as otherwise required by applicable law. Retention period: As long as necessary for fraud detection and enforcement; typically, up to 5 years.

To create anonymous data

Categories of Personal Data: All of the data processed, as mentioned above.

Legal basis: Our legitimate business interest to create anonymous data sets for research and business purposes. Retention period: Anonymous data is no longer personal data, no retention period applies.

To process your request to exercise your rights

Categories of Personal Data: Your identification and contact details. Where needed, we may request you to provide an ID.

Legal basis: Our legal obligation to manage your rights. Retention period: The time needed to answer you and no longer than 5 years after the last contact with you (legal prescription).

Cookies and Automatic Data Collection

We use essential cookies and similar technologies to enable the core functionality of Farao, such as maintaining user sessions and preferences. We also use analytics cookies to understand how users interact with Farao and to improve performance. Cookies are small pieces of data — usually text files — placed on your computer, tablet, phone or similar device when you use that device to access our services.

You can opt out of having your online activity and device data collected through these third-party services, including by:

  • Blocking cookies in your browser by following the instructions in your browser settings. For more information about cookies, including how to see the cookies on your device, manage them, and delete them, visit www.allaboutcookies.org.
  • Blocking or limiting the use of your advertising ID on your mobile device through the device settings.
  • Using privacy plug-ins or browsers. Certain browsers and browser extensions can be configured to block third-party cookies and trackers.
  • Using advertising industry opt-out tools on each device or browser where you use the services, available at http://optout.aboutads.info and http://optout.networkadvertising.org.

We may use plug-ins from social networks on Farao and/or maintain pages on social platforms, such as Telegram, Discord, and other third-party platforms. When you activate plug-ins by clicking on them, the operators of the respective social platforms may record that you are on Farao and may use this information. Additionally, when you visit or interact with Farao-related pages on those social media platforms, the platform provider's privacy policy will apply to your interactions and their collection, use and processing of your personal information. AL is not responsible for data collected by these individual social media platforms, and any processing of your personal data by social media platforms is solely their responsibility and occurs according to their privacy policies.

Sharing of Personal Information

With the exception of the provider(s) of AL, we do not make your Personal Data available to third parties unless you have expressly consented to it, if we are legally obligated to, or if this is necessary to enforce our rights concerning a contractual relationship. This is our legitimate interest in the processing of data in the sense of Art. 6 Par. 1 lit. f GDPR.

Service providers: We may share your Personal Information with third party companies and individuals that provide services on our behalf or help us operate Farao (such as customer support, hosting, data processors, analytics, email delivery, marketing, identity verification, and database management services).

Web3 projects and collaborators: We may share your Personal Information with web3 projects and collaborators as necessary to provide Farao.

Professional advisors: We may disclose your Personal Information to professional advisors, such as lawyers and auditors, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety: We may share your Personal information for compliance, fraud prevention, and safety purposes described above.

Financial transactions: If you conduct financial transactions by credit card or debit card through Farao, we may forward your credit/debit card information to the credit/debit card issuer and the credit/debit card acquirer. If you choose to use a credit/debit card, you may be asked to provide all the necessary information. The legal basis for passing on the data lies in the fulfillment of an agreement in the sense of Art. 6 Par. Lit. b GDPR.

Your Rights and Choices

Opt out of marketing communications: You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email. You may continue to receive service-related and other non-marketing emails.

Data protection rights: Depending on where you live, you may have the following rights, as provided under applicable law and subject to any limitations in such law:

  • To access the Personal information we hold about you (including, if applicable, to receive it in a structured and commonly used machine-readable format);
  • To request we correct any inaccurate Personal Data we hold about you;
  • To request we delete any Personal Information we hold about you;
  • To restrict the processing of Personal Data we hold about you;
  • To object to the processing of Personal Information we hold about you; and/or
  • To withdraw your consent to the processing of Personal Data we hold about you, when we have relied on consent as the legal basis to process your Personal Information.

Please note that, prior to any response to the exercise of such rights, we may require you to verify your identity. In addition, we may have valid legal reasons to refuse your request and will inform you if that is the case. For more information on your rights, please contact us using the details in the "How to contact us" section below.

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Important: Part of Farao incorporates blockchain technology. A blockchain is a shared and synchronized digital database that is stored on multiple nodes. As, by design, data on a blockchain cannot be changed or deleted, your ability to exercise your data protection rights such as your right to erasure, or your rights to object or restrict processing with respect to onchain Personal Data may be affected.

International Data Transfers

By using Farao, you understand and acknowledge that we may transfer your Personal Information to service providers or other third parties who are located in countries which may not provide the same protections as the data protection laws where you are based. This includes service providers of AL and e-commerce providers such as payment solution providers to assist us in the processing of your online payments.

When we transfer your Personal Data to third parties abroad for the purposes of the data processing described in this Privacy Policy, unless we can rely on a derogation provided under data protection law, we will ensure that relevant safeguards are in place to afford adequate protection for your Personal Information and we will comply with applicable data protection laws, in particular if you reside in (i) the UK or the EEA by relying on a UK government adequacy regulation or adequacy decision by the European Commission, (ii) the United States, by relying on the California Consumer Privacy Act, or (iii) other jurisdictions, by relying on contractual protections for the transfer of your Personal Information.

Notice to California Residents

The California Consumer Privacy Act or "CCPA" (Cal. Civ. Code § 1798.100 et seq.) affords consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.

California Civil Code Section 1798.83 permits individual California residents to request certain information regarding our disclosure of certain categories of personal information to third parties for those third parties' direct marketing purposes. To make such a request, please contact us using the information in the "How to Contact Us" section below. This request may be made no more than once per calendar year.

If you are a California resident, you have certain additional rights with respect to your personal information pursuant to the CCPA. We are required to inform you of:

  • What categories of information we may collect about you, including during the preceding 12 months: See the section above "Overview of How We Collect Your Personal Data".
  • The purposes for which we may use your personal information, including during the preceding 12 months: See the sections above.
  • The purposes for which we may share your personal information, including during the preceding 12 months: See the section above "Sharing of Personal Information".
  • In the preceding 12 months, we have not sold any personal information of consumers.

You have the right to request to know: (i) the categories of personal information we have collected about you in the last 12 months; (ii) the specific pieces of personal information we have about you; (iii) the categories of sources from which that personal information was collected; (iv) the categories of your personal information that we sold or disclosed in the last 12 months; (v) the categories of third parties to whom your personal information was sold or disclosed in the last 12 months; and (vi) the purpose for collecting and selling your personal information.

These rights are subject to limitations as described in the CCPA. We may deny your request if we need to do so to comply with our legal rights or obligations. We will not discriminate against any consumer for exercising their CCPA rights.

You may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. To protect your information, we may need to verify your identity before processing your request, including by collecting additional information to verify your identity, such as government issued identification documents.

Other Sites, Applications and Services

Farao may contain links to other websites, mobile applications, blockchain protocols, blockchain applications, blockchain exchanges and other online and blockchain services (collectively, "Third Party Resources") operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included in Third Party Resources that are not associated with us. We do not control Third Party Resources, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your Personal Information. We encourage you to read the privacy policies of the Third-Party Resources you use.

Security Practices

We take precautions to protect your stored Personal Data against manipulation, partial or complete loss, and unauthorized access by third parties of Personal Information we maintain. Unfortunately, data transmission over the internet (including via blockchain) cannot be guaranteed as completely secure. Please note that any data transmission on the internet (including through blockchains) is generally not secure or may be accessed by third parties, and we accept no liability for data transmitted to us via the internet or through a blockchain.

Children

Farao is not intended for use by children under 18 years of age. If we learn that we have collected Personal Information through Farao from a child under 18 without the consent of the child's parent or guardian as required by law, we will delete it.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on Farao. We may also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through Farao.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on Farao (or as otherwise indicated at the time of posting).

How to Contact Us

If you have a concern about our privacy practices, including the way we handle your Personal Information, please contact us at: support@getfarao.com

We will endeavor to respond to your complaint as soon as possible.

You can also report it to your local data protection authority that is authorized to hear those concerns. Contact details for certain data protection authorities:

  • For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en
  • For individuals in the UK: https://ico.org.uk/global/contact-us/
  • For individuals in Switzerland: https://www.edoeb.admin.ch/en/contact-2
  • For individuals in California: https://cppa.ca.gov/about_us/contact.html

© 2026 Alamas Labs, Inc. All rights reserved.