Privacy and Cookie Policy

28 August 2026

nGRND (“nGRND”, “We”) are committed to protecting and respecting your privacy. We do not sell the personally identifiable information of our users.

We will only process your personal data where permitted by applicable data protection laws, including the British Virgin Islands Data Protection Act, 2021, regarding the Protection of Personal Data, the European and UK General Data Protection Regulation and any analogous law that may apply to you. Together with our Terms of Use, this Privacy Policy describes what type of personal data we collect from you, or that you provide to us, will be processed by us and the legal basis we operate under to collect such information. Please read the following carefully to understand our views and practices regarding your personal data and how we guard and process it.

2. Information We May Collect from You

We may request and collect from you, and you hereby consent to our collection and processing of the following data about you:

Data We May Request From You:

• Name
• e-mail address
• Phone number
• Telegram Username or ID
• Jurisdiction
• Address
• Information you choose to provide via campaigns, giveaways, forums or support requests
• KYC/KYB/AML may be required to be performed either directly through the Platform or through a third-party provider. You may be required to provide all necessary information to perform these services.

We will automatically collect information from and about you, and you hereby consent to our collection and processing of the following data about you through the platform, which may include but is not limited to:

• Account data
• Token balances
• Upgrades and / or purchases
• Leaderboard position
• Referral data
• Reward eligibility
• Claim history
• Login data
• Activity data
• Security and anti-bot data
• Technical logs / error logs
• Browser information
• IP addresses

Transactional information we may collect, and you hereby consent to our collection and processing of the transactional information about you through the platform, which can include, but is not limited to:

• Public wallet addresses
• Public blockchain transactions
• Transaction hashes
• Claim transactions
• Purchase or conversion records connected to your wallet(s)
• Token balances only where visible publicly or are needed for the platform

nGRND may collect and process, either directly or through a third-party provider, KYC, KYB and AML data, and you hereby consent to provide and to our collection of documents which may include, but are not limited to:

• Date of birth
• Nationality
• Citizenship
• Country of residence
• Copy of your government issued identification
• Selfie or liveness check
• Proof of address
• Source of funds
• Source of wealth
• Sanctions screening
• PEP screening
• Adverse media checks
• Company documents
• Director information
• Ultimate beneficial ownership information

Device, Security and Anti-Fraud Data

nGRND may collect and process the following Device, Security and Anti-Fraud Data and Information and you hereby consent to the collection of such information:

• Device information
• Device identifiers
• Security and anti-fraud data
• Browser information
• Operating system information
• IP address
• Approximate geo-location
• Language settings
• Time zone
• Session IDs
• Cookie IDs
• Analytics IDs
• API request metadata
• Suspicious activity indicators
• Bot/fraud risk scores
• Security logs

nGRND may collect and process the following wallet and blockchain data and you hereby consent to the collection of such information:

• Wallet connection events
• Wallet signature proofs
• Connected wallet addresses
• Network/chain IDs
• Token contract addresses
• Blockchain transactions
• Transaction hashes
• Claim status
• Vesting
• Airdrop eligibility
• Reward eligibility
• Gas/fee data
• Any launchpad or exchange-related records where applicable

3. Purposes of Collection

• To provide you with our products and services, which may include but are not limited to: administering token claims; airdrops; vesting; rewards; leaderboard systems; referrals; purchases; conversions; fraud and bot prevention; AML/sanctions checks; dispute handling; audit/accounting; platform security; technical support; regulatory compliance; enforcement of the Terms and Conditions
• To notify you about changes to our products or services
• To authenticate your access to our products or services
• To provide you with information about any other products and services we may offer that are similar to those that you have already enquired about
• To make suggestions and recommendations to you about goods or services that may be of interest to you
• We use information that we observe about you from your interactions with our Site, our email communications to you and/or with Services to send you marketing communications
• To communicate with you where you have consented to receive such marketing communications, or where we have a lawful right to do so
• To carry out our obligations arising from any contracts entered into between you (or your employer) and us and to provide you with the information, products and services that you (or your employer) request from us
• To monitor Site traffic and volume
• To track usage statistics on our Site
• For Data Processing, which may include technical information, including the Internet protocol (IP) address used to connect your computer to the Internet; your login information, browser type and version, time zone setting, browser plug-in types and versions, operating systems and platform
• To assist in keeping our site safe and secure
• Information regarding your personal or professional interests, demographics, experiences with our products and contact preferences
• For customer analysis. We analyse your contact details with other personal information that we observe about you from your interactions with our Site, our email communications to you and/or with our Services such as the Services you have viewed. Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Site, or from your mobile
• To process any job application
• Education and employment history

4. Legal Basis

• Performance of contract, legitimate interest in providing our products and services to you
• Consent
• Legitimate interest to develop our products/services and grow our business
• Performance of contract
• Legitimate interest; necessary for compliance with our legal obligations
• Legitimate interest, necessary for the purpose of protecting our systems and for detecting and preventing fraud
• Consent: necessary for compliance with our legal obligations
• Legitimate interest for the purpose of administration of our business
• Consent: where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other clients

5. Information from Other Sources

We may receive information about you from other sources, such as conference organisers and marketing companies. Where we process this information, the legal basis for the processing will be consent. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

6. Marketing

From time to time, we may send you information regarding that which we perceive may be of interest to you or your business. If at any time you prefer not to receive further communications from us in any or all forms (except in connection with information, products or services that you specifically request) you will have the ability to opt-out from such communications by means of a link provided in e-mails that are sent to you by us.

7. Cookies

Our sites may use cookies to distinguish you from other users of a site. This helps us to provide you with a good experience when you browse our sites and also allows us to improve our sites.

Cookies are small text files which a website may put on your computer or mobile device when you first visit a site or page. We may use cookies on our sites to improve their performance and enhance your user experience.

If you do not want to receive cookies, you may choose to opt-out by changing your browser settings. Most browsers allow you to turn off cookies. Switching off cookies may restrict your use of a site and/or delay or adversely affect the way in which it operates.

Listed below are the cookies that may be used on the Site, along with their source and supposed usage:

First Party Cookies: Cookies that are set by the website and can only be used by the website.

• To persist user session so they stay logged in on the website (session only)
• To store currently logged in user details to pre-fill form data
• To authorise the interface with nGRND servers
• To save user’s account preferences

Third Party Cookies and Platform Data

Cookies that are not set by the website owner and are primarily used for analytical data of that service or feature.

Google

• To track current active users
• To get visits based on geolocation
• To get most visited pages and duration of user session per visit
• To get devices commonly used to access the site
• To get traffic based on time of day
• To know how users get referred to the website

8. Third Party Platform Data

Third Party Platform Data that we may receive may include, but is not limited to:

• Telegram data
• Discord data
• Other social media platforms
• Payment or purchase confirmation data from Telegram, TON, GRAM and other platforms
• Data relating to Campaigns / giveaways conducted on other platforms
• Analytics

9. Disclosure Of Your Information

We may share your information with selected third parties, which may include but is not limited to:

• Third party service providers, for example, our recruitment applicant tracking system provider, wallet providers, blockchain nodes, blockchain indexers, blockchain explorers, exchanges, launchpads, email/CRM tools, hosting providers, cloud providers, regulators, analytics providers, professional advisors including lawyers, bankers, auditors and insurers who provide consultancy, KYC/AML providers, banking or payment processors, legal, insurance and accounting services
• Analytics and search engine providers that assist us in the improvement and optimisation of our sites
• Any party which acquires nGRND or substantially all of its assets, in which case personal data held by it about its customers will be one of the transferred assets
• Third parties to whom we outsource certain services which may include, without limitation, document processing and translation services, confidential waste disposal, IT systems or software providers, IT Support service providers, document and information storage providers
• Third party service providers to assist us with client insight analytics, such as Google Analytics
• Third party service providers that provide social media services, such as Discord, X, Gleam and Google
• Any other party used for campaigns, giveaways, payments, analytics, claims or support
• Any other party as required by law, or in order to enforce or apply our terms of use and other agreements or to protect the rights, property, or safety of nGRND, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction
• Government or regulators
• Professional indemnity or other relevant insurers
• Regulators/tax authorities/corporate registries

Additionally, any User that participates in any event that may or may not include awarded giveaways and/or prizes through the Platform must agree to have their social media handle(s), the item value and details published, where applicable, at nGRND’s sole discretion. In the event nGRND would like to publish additional details about an event, giveaway and/or prize, such details will be published once written approval has been obtained. All events are void where prohibited by law.

10. Where We Store Your Personal Data

The data that we collect from you may be transferred to, stored and processed in any destination where nGRND or its affiliates, subsidiaries or facilities used by third party service providers have a presence. We will only transfer your data to countries that adequately ensure an adequate level of data protection or where we have mandated compliance with such standards through contractual means.

In the event where we have given you (or where you have chosen) a password which enables you to access certain parts of a site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We will implement appropriate technical and organisational measures to protect your data, taking into account the nature, scope, context and purpose of the processing and the risks involved in processing. Unfortunately, the transmission of information via the internet is not completely secure. Although we will seek to protect your personal data, we cannot guarantee the security of your data transmitted to a site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

11. How Long Will We Store Your Personal Data

The personal data that we collect from you will be stored only for so long as is necessary to fulfil the purpose for which the data was collected, or to comply with applicable legal, tax or regulatory requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

12. We will NEVER ask you for any of the following information

• Seed phrases
• Private keys
• Wallet passwords
• Exchange passwords
• Bank login details
• Personal account passwords
• Secret recovery phrases

13. Your Rights

You have the following rights, subject to the provisions of relevant privacy laws:

• to access your data in accordance with then applicable privacy and subject access laws
• to request that inaccurate data be rectified
• to request that your personal data be erased
• to restrict the processing of your data
• to transfer your data between controllers
• to object to processing of personal data

Should you wish to exercise any of your rights under BVI or other privacy laws please contact nGRND at the address detailed below.

Changes To Our Privacy Policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

14. Contact

Questions, comments and requests regarding this privacy policy should be sent to Data Protection Officer, nGRND Inc., Suite 5, Oleander Building, Port Purcell, Tortola, VG1110, British Virgin Islands.

Date: 28 August 2026

© 2026. nGRND Gold Protocol Inc. All rights reserved. No part of this document may be reproduced, distributed, or transmitted in any form or by any means, including photocopying, recording, or other electronic or mechanical methods, without the prior written permission of nGRND Gold Protocol Inc.