Privacy Policy

This Privacy Policy explains how Freeport Markets, Inc., a Delaware corporation ("Freeport," "we," "us," or "our") collects, uses, shares, and protects information when you access or use the Freeport Markets mobile application (the "App") and our website at www.freeportmarkets.com (together, the "Services").

By using the Services, you acknowledge you have read and understood this Privacy Policy. If you do not agree, do not use the Services.

Key principle: We collect only the data reasonably necessary to operate, secure, and improve the Services. We do not sell your personal information and we do not use App diagnostics for advertising.

1. Scope and Important Notes

1.1 App vs. Website

• This Policy covers both the App and the website.
• The App may collect data for functionality, security, analytics, and performance monitoring.
• The website uses cookies and similar technologies as described in Section 11.

1.2 Third-Party Authentication Only

The Services use third-party authentication and do not offer username/password login managed by Freeport. You can only log in through Privy using supported methods such as Google OAuth or Apple Sign In. Authentication data is processed by those providers subject to their own policies and terms.

1.3 Non-Custodial / Wallet Notes (If Applicable)

If the Services allow you to connect a third-party wallet or interact with third-party protocols, those transactions occur on third-party networks or platforms. Freeport does not custody your assets through the Services unless expressly stated in a separate written agreement. Blockchain transactions may be publicly visible on applicable networks.

1.4 Third-Party Services

The Services may include links to or integrations with third-party services. Their privacy practices are governed by their own policies. We are not responsible for third-party privacy practices.

2. Information We Collect

We collect information in three main ways: (a) information you provide, (b) information collected automatically, and (c) information from cookies and similar technologies (website).

2.1 Information You Provide

We may collect:

• Contact Information: your email address (typically provided to us by the authentication provider) when you create an account, log in, or contact support.
• Communications: information you include in messages to us (e.g., support inquiries, feedback).

2.2 Information Collected Automatically (App and Website)

Depending on your device, your settings, and how you use the Services, we may collect:

• Usage Data: information about how you interact with the Services (e.g., screens viewed, buttons tapped, feature engagement patterns).
• Diagnostics Data: crash logs and performance metrics such as load times and responsiveness.
• Device and Technical Data: device type, operating system, App version, language settings, and technical identifiers.
• Log Data: IP address (or approximate location derived from IP), timestamps, and event logs used for security and debugging.

2.3 Data "Not Linked to Your Identity" (Apple App Store Disclosures)

Consistent with Apple disclosures, we may collect certain categories of data that are not linked to your personal identity, such as:

• Diagnostics Data
• Usage Data

2.4 Authentication and Identity Data (Privy, Google, Apple)

Because login is provided through Privy using Google OAuth and Apple Sign In, we may receive certain information from those providers to create and manage your account, such as:

• Email address
• Authentication tokens / session identifiers (technical data necessary to keep you logged in)
• Basic profile signals provided by the authentication method (for example, a stable user identifier)

Freeport does not receive your Google or Apple password. Your use of Privy, Google, and Apple authentication is governed by their respective terms and privacy policies.

2.5 Wallet and Account Infrastructure (Privy)

If the Services support wallet connectivity or embedded wallet infrastructure via Privy, certain information may be processed in connection with enabling that functionality, such as:

• Wallet address(es) you connect or create through the Services
• Account/session data necessary to provide wallet-related features

Freeport does not receive or store your private keys.

2.6 Blockchain Data

Transactions on public blockchain networks are publicly accessible. Freeport does not "collect" blockchain data from the blockchain as a database, but blockchain activity may be viewable by anyone and may be associated with wallet addresses you use with the Services.

3. How We Use Your Information

We use information to:

3.1 Provide, Maintain, and Secure the Services

• Create and manage your account
• Authenticate access and maintain sessions
• Provide user support and service communications
• Maintain security, prevent fraud, detect unauthorized access, and enforce protections

3.2 Improve Performance and User Experience

• Understand feature usage (in aggregated form where feasible)
• Diagnose bugs, crashes, and performance issues
• Optimize usability, reliability, and functionality

3.3 Compliance, Risk, and Enforcement

We may use information to comply with legal obligations and enforce our Terms, including to:

• Detect and prevent fraud, abuse, or prohibited activity
• Comply with applicable law and lawful requests
• Protect the rights, property, and safety of Freeport, our users, and others

Note on "KYC / compliance": Freeport does not directly conduct identity verification via separate KYC collection in the App. Authentication and identity signals are provided through third-party login providers (Privy, Google, Apple) and processed under their policies.

4. Legal Bases for Processing (EEA/UK and Similar Jurisdictions)

Where required by applicable law (including GDPR), we process personal information based on one or more of the following legal bases:

• Contract / Service Delivery: to provide the Services you request.
• Legitimate Interests: to secure, maintain, and improve the Services; prevent fraud; and support operations (balanced against your rights).
• Consent: for certain cookies and optional features (where required).
• Legal Obligation: to comply with applicable laws and lawful requests.

5. How We Share Information

We do not sell your personal information. We may share information only in limited circumstances:

5.1 Service Providers

We use the following categories of service providers to operate the Services, and may share limited information with them as necessary:

• Cloud Hosting and Infrastructure: Amazon Web Services (AWS) (including storage, compute, databases, monitoring, and security tooling used to run the Services).
• Authentication / Account and Wallet Infrastructure: Privy (to enable login, session management, and wallet-related functionality, where applicable).

We do not share your personal data with service providers for their own marketing purposes.

5.2 Authentication Providers (Google and Apple)

When you choose to log in via Google OAuth or Apple Sign In, those providers process data as part of authentication. Freeport receives limited information (such as your email address and a stable identifier) to operate your account, and those providers process data according to their own terms and privacy policies.

5.3 Legal, Safety, and Security

We may disclose information if we believe it is reasonably necessary to:

• Comply with law, regulation, subpoena, or court order
• Respond to lawful requests by public authorities
• Protect the security or integrity of the Services
• Prevent fraud, abuse, or illegal activity
• Protect the rights, property, or safety of Freeport, our users, or others

5.4 Business Transfers

If Freeport is involved in a merger, acquisition, reorganization, financing, or sale of assets, information may be transferred as part of that transaction, subject to standard confidentiality protections.

5.5 With Your Consent

We may share information when you explicitly consent.

6. Data Security

We use commercially reasonable and industry-standard safeguards designed to protect information, which may include:

• Encryption in transit (secure protocols)
• Access controls and authentication
• Monitoring and logging for security events
• Secure development and operational practices

No system is 100% secure. You are responsible for safeguarding your device, credentials, and email account.

7. Data Retention

We retain information only as long as reasonably necessary to provide the Services and for legitimate business and legal purposes.

Typical retention periods:

• Account information (e.g., email): retained while your account is active. If you request deletion, we will delete or de-identify account data unless we must retain certain information for legal, security, or dispute-resolution purposes.
• Support communications: retained for up to 24 months for quality and recordkeeping.
• Security logs and audit logs: typically retained for up to 12 months for security and incident investigation.
• Crash logs / diagnostics: typically retained for up to 180 days to identify and fix stability issues.
• Analytics / usage data: retained in aggregated or de-identified form where feasible and may be retained longer for long-term product analysis.

We may retain information longer where required by law, to enforce agreements, or to resolve disputes.

8. Your Rights and Choices

Depending on your location and applicable law, you may have rights to:

• Access the personal information we hold about you
• Correct inaccurate or incomplete information
• Delete certain personal information
• Object to or restrict certain processing
• Port your information to another service (where required)

8.1 Exercising Rights / Account Deletion

To request access, correction, or deletion of your account data, contact us at partners@freeportmarkets.com.

We may need to verify your identity and may deny or limit requests where permitted by law (for example, where retention is required for security, legal compliance, or dispute resolution).

8.2 Device Controls

You can also control certain collection by:

• Adjusting device privacy settings
• Limiting analytics permissions (where available)
• Updating notification settings

9. Children's Privacy

The Services are not intended for individuals under 18. We do not knowingly collect personal information from children. If you believe a child has provided us information, contact us at partners@freeportmarkets.com.

10. "Do Not Track" Signals

Some browsers offer a "Do Not Track" (DNT) setting. The Services may not respond to DNT signals in a uniform way because there is no consistent industry standard. We do not sell personal information and do not use App diagnostics for advertising.

11. Website Cookies and Similar Technologies

We use cookies and similar technologies on www.freeportmarkets.com to operate the website, improve performance, and understand usage.

11.1 What Are Cookies?

Cookies are small text files stored on your browser or device when you visit a website. They help websites recognize your device, remember preferences, and improve your experience.

11.2 Types of Cookies We Use

Necessary Cookies (Always Active)

• Enable core website functions (e.g., security and navigation)
• Required for basic functionality

Statistics / Performance Cookies (Consent Where Required)

• Provide aggregated insights (e.g., pages visited, time spent, referrers)
• Used to improve usability and performance

Preference Cookies (Consent Where Required)

• Remember choices like language or region (where applicable)

Marketing Cookies

• We do not use marketing cookies for targeted advertising at this time. If we enable marketing cookies in the future, we will update this Policy and provide consent controls where required by law.

11.3 How to Control Cookies

You can manage cookies through:

• Your browser settings (block/delete cookies)
• Opt-out features provided by certain analytics tools (where available)

Disabling cookies may affect website functionality.

12. International Users

If you access the Services from outside the United States, you understand that information may be processed and stored in the United States or other jurisdictions where we or our service providers operate, which may have different data protection laws than your location.

Where required, we use appropriate safeguards for cross-border transfers.

13. Changes to This Privacy Policy

We may update this Policy from time to time. We will post updates and revise the "Last Updated" date above. Material changes may also be communicated through in-app notices or other reasonable means. Your continued use of the Services after an update constitutes acceptance of the updated Policy.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, contact us at:

Email: partners@freeportmarkets.com