🍪Mobile Privacy Policy

Snickerdoodle Labs, Inc.

1. General

We know that your privacy is important to you, and we work hard to earn and keep your trust. Snickerdoodle Labs, Inc. (collectively with its subsidiaries, “Snickerdoodle Labs,” “Company,” “we,” “us,” and “our”) respects your privacy and is committed to protecting your privacy through our compliance with this Privacy Policy (the “Policy”).

This Policy describes:

• The types of information we collect from you or that you may provide when you download our data wallet browser plugin, mobile application, desktop application, or digital platform (collectively, our “Platform”).

• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect on this Platform or in emails and other electronic messages between you and this Platform, and information gathered when you interact with our advertising on third-party websites if such advertisements include links to this Policy.

This Policy does not apply to information collected by us offline or through any other means, including on any other website operated by Snickerdoodle Labs or any third party, or information collected by any third party through any application or content (including advertising) that may link to or be accessible from the Platform (for further information, see below, “Third-party Websites”).

Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not use our Platform. By using our Platform, you agree to the terms of this Policy. This Policy may change from time to time (see below, “Changes to this Policy”). Your continued use of our Platform after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

2. Platform Terms of Use; Other Agreements

This Policy should be read in conjunction with any applicable Terms of Use, into which this Policy is incorporated by reference.

3. What We Collect and How We Collect It

When downloading or using the Platform, you are in control of your Personal Information. Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household or device (“Personal Information”). Although the Platform does not enable Snickerdoodle Labs to collect, process, or share your Personal Information, the Platform enables you to store Personal Information and account linkages like email within the Platform. Any Personal Information will be stored on your own device or encrypted and stored through a cloud-based provider. Your Platform account produces its own encryption keys, so even if Personal Information is stored in Google cloud, neither Google nor Snickerdoodle Labs can access it without your consent and disclosure of your key.

In order to download and use the Platform, you may be required to create an account with Snickerdoodle Labs. The Personal Information Snickerdoodle Labs may request in creating your account include, but may not be limited to, first and last name, email address, gender, age, and contact information.

The information that you provide in each case will vary. In some cases, you may be able to provide Personal Information via email or free text boxes, such as contacting Snickerdoodle Labs to request further information. When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal data, unless required for our services.

4. Account Creation & Automated Information Collection

After adopting the Platform, the Platform will proceed to wallet integration. From this integration, Snickerdoodle Labs organizes existing public data from public blockchains that may be associated with your wallet. This includes, but is not limited to, crypto-assets portfolio, average transaction size, average gas fees, preferred protocols, non-fungible token interest categories, and more.

5. Use of Your Information: YOU Are in Control

Whether it is off-chain data collected during enrollment, or on-chain data aggregated during wallet integration, we provide the data infrastructure that allows you to trade your data for rewards. Before you choose to accept a reward, you will be informed of what data specifically will be needed in exchange for the reward. No transfer can take place without your consent. Keep in mind, businesses and enterprises can view insights from this data through high-level, anonymized dashboards that prevent triangulation of specific individuals.

To the extent Snickerdoodle Labs has access to your information, the information we gather and that you provide is collected to provide you information and the services you request, in addition to various other purposes, including, but not limited to:

• providing the information, products and services you request;

• security, credit or fraud prevention purposes;

• providing you with effective customer service;

• providing you with a personalized experience when you use this Platform;

• contacting you with information and notices related to your use of this Platform;

• inviting you to participate in surveys and providing feedback to us (in accordance with any privacy preferences you have expressed to us);

• better understanding your needs and interests;

• improving the content, functionality and usability of this Platform;

• improving our products and services; and

• any other purpose identified in an applicable privacy notice, click-through agreement or other agreement between you and us.

Duration. The length of time Snickerdoodle Labs intends to retain any Personal Information stored on its systems, including sensitive information is: for as long as reasonably necessary to carry out Snickerdoodle Labs’ intended business purpose for such information, unless you revoke your consent.

6. How We Disclose Your Information

We do not sell or lease your Personal Information to any third party. We may disclose your Personal Information to a third party for a business purpose. When we disclose your Personal Information, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for the purposes set forth in the contract.

As described above, you are in control of your information sharing. To the extent we have access to your Personal Information, we may disclose your Personal Information for a business purpose to the following categories of third parties:

• Our affiliates; and

• Third party vendors who provide services that enhance our Platform, products and services to you (such as vendors for credit card processing, advertising and marketing and customer support).

Except as described in this Policy, we will not share your information with third parties without your notice and consent, unless it is under one of the following circumstances:

• Legal Reasons.

• We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, subpoena, or court order where possible;

• To respond to duly authorized information requests from law enforcement or other governmental authorities;

• To enforce our agreements, policies, or the Terms of Use;

• To investigate and prevent security threats, fraud, or other malicious activity; or

• To respond to an emergency that we believe in good faith requires us to disclose such information to assist in preventing the death or serious bodily injury of any person or Snickerdoodle Labs employee.

• Sale of Business or Merger. There are circumstances where Snickerdoodle Labs may decide to buy, sell, or reorganize its business in selected countries. In such circumstances, Snickerdoodle Labs will ensure your information is used in accordance with this Policy.

7. Accuracy and Access to Your Personal Information

We strive to maintain and process your information accurately. We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements. We employ technologies designed to help us maintain information accuracy on input and processing.

To view and change anyPersonal Information that you have provided to us, contact us directly for assistance.

8. Information of Minors

We do not intentionally seek to gather information from individuals under the age of thirteen (13). We do not target the Platform to minors, and would not expect them to be engaging with our Platform or services. We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet. If we are aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems.

9. Third-party Websites

This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates. Because this Policy is not enforced on third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or website and providing any information.

10. Your Rights Under State Law

California

• Shine the Light law. Pursuant to California Civil Code Section 1798.83, we will not disclose or share your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent.

• Do Not Track Signals. Other than as disclosed in this Policy, the Platform does not track users over time and across third-party websites to provide targeted advertising. Therefore, the Platform does not operate any differently when it receives Do Not Track (“DNT”) signals from your internet web browser.

• WE DO NOT SELL OR SHARE YOUR PERSONAL INFORMATION. If we ever decide to “sell” or “share” Personal Information, as those terms are defined under the California Consumer Privacy Act of 2018, we will update you via this Policy and include a link entitled “Do Not Sell or Share My Personal Information,” to provide you with an opportunity to opt out of the selling or sharing of your Personal Information.

Your Consumer Rights

Some state laws in the United States provide consumers with additional rights with respect to their personal information (also known as “personal data”), as those terms are defined under those applicable state laws. Such state laws may include, but are not limited to, the California Consumer Privacy Act of 2018 (the “CCPA”) as amended by the California Privacy Rights Act, the Colorado Privacy Act (“CPA”) and the Virginia Consumer Data Protection Act (“VCDPA”). Any personal information we collect is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, our services. If you reside in a state that provides additional rights with respect to your personal information, you may exercise each of your rights as identified below, subject to our verification of your identity. Please understand, by virtue of our Platform and our services, Snickerdoodle Labs does not intend to collect any Personal Information. However, in the event that you do provide us with Personal Information, these consumer rights may be applicable.

1. Access. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

2. Correction. You can correct what personal data our Platform database currently contains by accessing your account directly, or by contacting us to request that we correct or rectify any personal data that you have provided to us.

3. Limit Use and Disclosure of Sensitive Personal Information. If we collect any sensitive personal information, you have the right to request that we limit the use of the sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.

4. Portability. Upon request and when possible, we can provide you with copies of your Personal Information. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy

5. Deletion. You have the right to request that we delete any of your Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. Where applicable, we will ensure such changes are shared with trusted third parties.

6. Opt-out of Processing. You have the right to request that we do not sell your Personal Information, use your Personal Information for Targeted Advertising, or use your Personal Information for profiling. Where applicable, we will ensure such changes are shared with trusted third parties.

7. Non-Discrimination. If a data subject exercises his or her rights under applicable state law, including but not limited to the CCPA, CPA, and VCDPA, we shall not discriminate against that data subject by denying our goods or services, charging different prices or rates to similarly situated consumers, providing a different level or quality of our goods or services, or taking any other adverse action.

8. Exercising your rights. If you are a data subject that has rights under applicable state law, including but not limited to the CCPA, CPA, and VCDPA, who chooses to exercise the rights listed above, you can submit a request to our Data Protection Officer at [e-mail].

Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information. If an authorized agent makes a request on your behalf, we may require proof that you gave the agent permission to submit the request.

Responding to Your Request. Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the Personal Information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.

We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing.

In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

11. For Platform Users Outside of the United States

We do not warrant or represent that this Policy or the Platform’s use of your Personal Information complies with the laws of any particular jurisdiction. Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours. Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.

12. For Platform Users in the European Union (“EU”)

Under the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, or “GDPR”), individuals in the EU are afforded specific rights with respect to their Personal Information, or “personal data” as defined under the GDPR. For the purposes of this Policy, Snickerdoodle Labs operates as a data controller. Any personal data we collect from you is processed in the United States and under the terms of this Policy.

Any personal data we collect from you is processed in the legitimate interest of our business and providing our services to you as the lawful means of such processing. You may always withdraw your consent to our use of your personal data as described below. We will only retain your personal data for the time necessary to provide you the information and services to which you have consented, to comply with the law and in accordance with your rights below.

You can exercise any of the following rights, subject to verification of your identity, by notifying us as described below:

• Access. You may email us at [e-mail] to request a copy of the personal data our Platform databases currently contain.

• Automated Processing and Decision-Making. You may email us at [e-mail] to request that we stop using your personal data for automated processing, such as profiling. In your email, please explain how you wish us to restrict automated processing of your personal data. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data.

• Correction or Rectification. You can correct what personal data our Platform database currently contains by accessing your account directly, or by emailing us at [e-mail] to request that we correct or rectify any personal data that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause information to be incorrect. Where applicable, we will ensure such changes are shared with trusted third parties.

• Restrict Processing. When applicable, you may restrict the processing of your personal data by submitting a request via email to In your email, please explain how you wish us to restrict processing of your personal data. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.

• Object to Processing. When applicable, you have the right to object to the processing of your personal data by submitting a request via email to. When such objections are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.

• Portability. Upon request and when possible, we can provide you with copies of your personal data. You may submit a request via email to When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent. Where applicable, we will ensure such changes are shared with any trusted third parties.

• Withdraw Consent. At any time, you may withdraw your consent to our processing of your personal data through this Platform by notifying us via email at. Using the same email address associated with your Platform account, simply type the words “WITHDRAW CONSENT” in the subject line of your email. Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.

• Erasure. If you should wish to cease use of our Platform and have your personal data deleted from our Platform, then you may submit a request by emailing us at Upon receipt of such a request for erasure, we will confirm receipt and will confirm once your personal data has been deleted. Where applicable, we will ensure such changes are shared with trusted third parties.

• Submit Complaints or Questions. If you wish to raise a complaint on how we have handled your personal data, you can contact us as described below. If you reside in a European Union member state, you may also lodge a complaint with the supervisory authority in your country.

13. Safeguarding the Information We Collect

We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure. However, we can never promise 100% security. You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password. If you believe your credentials have been compromised, please change your password. Please also notify us of any actual or suspected unauthorized use.

14. Changes to this Policy

This Policy describes our current policies and practices with regard to the information we collect through this Platform. We are continually improving and adding to the features and functionality of this Platform along with the products and services we offer through this Platform. If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen).

15. How to Contact Us

We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information, please contact us by email at [e-mail].