PRIVACY POLICY

IMPERVIOUS INC.
atbitcoin.com

Last Updated: May 7, 2025

1. INTRODUCTION

Impervious Inc. ("Company," "we," "us," or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website (atbitcoin.com) and services related to decentralized identities on the Spaces Protocol (collectively, the "Services").

We understand the unique privacy considerations that come with blockchain technology and decentralized identity services. This policy is designed to provide transparency about our practices while acknowledging the inherent features of blockchain technology, including its immutable nature.

Please read this Privacy Policy carefully. By accessing or using our Services, you agree to this Privacy Policy. If you do not agree with our policies and practices, please do not use our Services.

2. INFORMATION WE COLLECT

2.1 Information You Provide to Us

We may collect the following types of information when you register for or use our Services:

• Account Information: Name, email address, phone number, and other contact details necessary for account creation and management.
• Payment Information: Credit card details, cryptocurrency wallet addresses, and transaction information necessary for processing payments.
• Identity Verification Information: Information required to verify your identity in compliance with applicable laws and regulations.
• Communications: Information you provide when you contact us for customer support or other inquiries.

2.2 Information Generated Through Use of Our Services

• Transaction Data: When you register a Subspace through our Services, transaction details may be recorded on the Bitcoin blockchain. This information is necessary for the functioning of the Spaces Protocol.
• Usage Data: Information about how you interact with our Services, including access times, pages viewed, links clicked, and other actions taken while using our Services.
• Device Information: Information about the device you use to access our Services, including IP address, browser type, operating system, and device identifiers.

2.3 Information Stored on the Blockchain

It is important to understand that any information recorded on the Bitcoin blockchain as part of the Spaces Protocol is:

• Public: The blockchain is a public, distributed ledger that can be viewed by anyone.
• Immutable: Once information is recorded on the blockchain, it cannot be deleted or modified.
• Distributed: The blockchain is stored across multiple nodes worldwide and is not controlled by a single entity.

We recommend that you do not include sensitive personal information in blockchain transactions.

3. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

3.1 To Provide and Maintain Our Services

• To operate, maintain, and improve our Services
• To process transactions and manage your account
• To enable the registration and management of Subspaces within the @bitcoin Space
• To provide customer support and respond to your inquiries

3.2 For Legal and Operational Purposes

• To comply with legal obligations and regulatory requirements
• To enforce our Terms of Service and other agreements
• To detect, investigate, and prevent fraudulent transactions and other illegal activities
• To protect the rights, property, or safety of our users, our company, or others

3.3 For Communication and Marketing

• To communicate with you about your account and our Services
• To provide updates about service changes, features, or offers
• To deliver relevant content and recommendations

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason compatible with the original purpose.

4. HOW WE SHARE YOUR INFORMATION

4.1 Service Providers

We may share your information with third-party service providers who perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing. These service providers have access to your information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

4.2 Blockchain Records

Information recorded on the Bitcoin blockchain as part of the Spaces Protocol is inherently public and accessible to anyone. This may include transaction details related to Subspace registrations and transfers.

4.3 Business Transfers

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our website of any change in ownership or uses of your personal information.

4.4 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

5. DATA SECURITY

We implement appropriate technical and organizational measures to protect the security of your personal information. However, please be aware that no method of electronic storage or transmission over the internet is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

For information stored on the blockchain, security is provided by the blockchain's cryptographic protocols and distributed nature. However, you are responsible for maintaining the security of your private keys and digital wallet.

6. YOUR PRIVACY RIGHTS

Depending on your location, you may have certain rights regarding your personal information. These may include:

6.1 Access and Portability

You may have the right to access and receive a copy of the personal information we hold about you.

6.2 Correction

You may have the right to request correction of your personal information if it is inaccurate or incomplete.

6.3 Deletion

You may have the right to request deletion of your personal information in certain circumstances. However, due to the nature of blockchain technology, information recorded on the blockchain cannot be deleted. We will explain the implications when you exercise this right.

6.4 Restriction and Objection

You may have the right to restrict or object to the processing of your personal information in certain circumstances.

6.5 Withdrawal of Consent

Where we rely on your consent to process your personal information, you have the right to withdraw your consent at any time.

To exercise any of these rights, please contact us using the contact information provided below.

7. BLOCKCHAIN-SPECIFIC PRIVACY CONSIDERATIONS

7.1 Immutability and the Right to Be Forgotten

Due to the immutable nature of blockchain technology, information recorded on the Bitcoin blockchain as part of the Spaces Protocol cannot be deleted or modified. This includes transaction records related to Subspace registrations.

To address this limitation while respecting privacy rights:

• We minimize the personal data recorded on the blockchain
• We use cryptographic techniques to protect sensitive information
• We store most personal information off-chain in secure, compliant systems where deletion is possible

7.2 Pseudonymity vs. Anonymity

The Spaces Protocol provides a degree of pseudonymity, meaning your real-world identity is not directly linked to your blockchain transactions unless you choose to make that connection. However, blockchain analysis techniques could potentially link transactions to real-world identities under certain circumstances.

7.3 Cross-Border Data Transfers

Due to the distributed nature of blockchain technology, information recorded on the blockchain may be stored on nodes located worldwide. By using our Services, you acknowledge and consent to the transfer of information to countries which may have different data protection rules than your country.

8. CHILDREN'S PRIVACY

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us so that we can delete such information.

9. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Last Updated" date at the top of this Privacy Policy. We encourage you to review this Privacy Policy frequently to stay informed about how we are protecting your information.

10. CONTACT US

If you have any questions about this Privacy Policy or our privacy practices, please contact us at:

Impervious Inc.
24A Trolley Square #1378 Wilmington, DE 19806-3334 United States Email: privacy@impervious.com Phone: 215-326-9299

11. JURISDICTION-SPECIFIC PROVISIONS

11.1 European Economic Area (EEA) and United Kingdom

If you are located in the EEA or the UK, the following additional information applies:

• Legal Basis for Processing: We process your personal information based on the following legal bases:
• Performance of a contract when we provide you with our Services
• Compliance with legal obligations
• Our legitimate interests, which do not override your fundamental rights and freedoms

• Your consent, where applicable

• International Transfers: When we transfer your personal information outside the EEA or UK, we ensure appropriate safeguards are in place.

• Data Protection Officer: You can contact our Data Protection Officer at dpo@impervious.com.

• Supervisory Authority: You have the right to lodge a complaint with a supervisory authority in the EEA or UK.

11.2 California Residents

If you are a California resident, you have certain rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including:

• The right to know what personal information we collect, use, disclose, and sell
• The right to delete certain personal information
• The right to opt-out of the sale of personal information
• The right to non-discrimination for exercising your privacy rights

To exercise these rights, please contact us using the contact information provided above.

11.3 Other Jurisdictions

We are committed to complying with applicable privacy laws in all jurisdictions where we operate. If you have questions about jurisdiction-specific privacy rights, please contact us.

By using our Services, you acknowledge that you have read and understood this Privacy Policy.