We are VGX Foundation, C/O Harneys Fiduciary (Cayman) Limited,
4th Floor Harbour Place, 103 South Church Street, PO Box 10240, Grand Cayman KY1-1002 Cayman Islands. We are referred to in this notice as “SafeMoon”, “VGX Foundation” “we” or “us”.

• the VGX Wallet mobile application (the “App”);

• the websites owned or operated by us, including without limitation vgxfoundation.com, www.safemoon.com, swap.safemoon.com, wallettracker.safemoon.com, (collectively, the “Properties”); and

• our other products and services,

(together, the “VGX Foundation Products and Services”).
We may update this notice from time to time, so please check back in on a regular basis. Your continued use of SafeMoon Products and Services indicates your acceptance of the modified Privacy and Cookie Notice.

To the extent data is associated with an identified or identifiable natural person and is protected as personal data or similar designation under applicable data protection or privacy law, it is referred to in this notice as "personal data" and/or “personal information”.

Please note that the VGX Products and Services may link to or mention websites, applications or services that are not operated by us, and you should refer to the privacy policies on those third-party websites, applications or services to understand how your personal data is being used.

• Ask us to send a copy of your personal data to you or someone else
• Ask us to restrict, stop processing, or delete your personal data
• Object to our processing of your personal data
• Object to use of your personal data for direct marketing purposes
• Ask us to correct inaccuracies in your personal data

If we rely on consent to process data, or send direct marketing, you can withdraw consent by email to the address below.

If you have any questions concerning this notice, including how you can exercise your rights, please contact us at: legal@vgxfoundation.com

If we can’t resolve your issue, you can also get in touch with the local data protection or consumer protection authority in your country (as applicable for your jurisdiction). For instance, if you live in the UK, you can get in touch with the Information Commissioner’s Office: https://ico.org.uk/concerns.

If you live in a country or jurisdiction other than the UK, you can submit a complaint to the supervisory authority or (if applicable) consumer protection authority in your country or jurisdiction.

Services and Products Data

Information that we collect about you to provide VGX Products and Services to you, including:

• Name and/or username, public blockchain addresses, and any additional information (such as a profile picture or avatar) you provide when using VGX Products and Services (e.g. when creating a wallet on the App)

• Information provided when making transactions via VGX Products and Services (including without limitation, if relevant, the fiat and VGX account balances)

• Information relating to previous transactions made via VGX Products and Services (including without limitation information relating to transactions via the App such as "transactionHash", "blockHash", "blockNumber", "status", "type", "nonce", "transactionIndex", "from", "to", "amount", "tokenSymbol", "createdAt" and "gasUsed")

• If required for your use of any VGX Products and Services, information for the purpose of verifying your identity in order to effectuate transactions and to prevent fraud or misuse, such as photo ID, date of birth, name, email, address and/or phone number, and other information as may be required by our Know Your Customer (KYC), Know Your Business (KYB), Anti Money Laundering (AML) and related service providers

• Firebase Cloud Messaging (FCM) tokens

• Information relating to your device, such as user agent string, timestamp, IP address, device identifier

• Any other personal data you provide to us in order for us to provide VGX Products and Services to you (including information you send us as part of your enquiries)

• Information that we collect about you to fulfil your purchase of products or merchandise we may sell to you from time to time, such as: name, email address, telephone number, b, delivery address, information relating to your orders (e.g. products purchased), payment information, and any order- related correspondence between us and you.

We process this information: (a) to respond to your enquiries; (b) to provide VGX Products and Services to you; (c) to manage risk, prevent fraud, misuse and/or unlawful acts in relation to use of the VGX Products and Services, and (d) to understand how you use the VGX Products and Services to improve them.

Legal basis for this processing

• (a) and (b): Entering or performing contracts with you, fulfilling your orders, and complying with legal obligations.

• (c) Our legitimate interests of managing risk and protecting the VGX Products and Services from fraud, misuse, or unlawful acts.

• (d): Our legitimate interests of improving the VGX Products and Services.

More information

You may be required to provide us with certain information for us to provide certain VGX Products and Services to you.

Sources

We collect this personal data from you.

Recipients

We use a variety of service providers to assist us in providing VGX Products and Services. A representative, non-exhaustive list of such service providers is as follows:

We use Chainalysis for transaction monitoring to detect and prevent fraud, misuse and/or unlawful acts in relation to use of the VGX Products and Services. You can view Chainalysis’s privacy notice here: https://www.chainalysis.com/privacy-policy/.

We may also use other service providers from time to time to assist us with the provision of VGX Products and Services, which may include providing marketing and advertising services, order fulfillment, providing mailing or email services, tax and accounting services, fraud prevention, web hosting, or other services.

Marketing Data

Information that we collect to make suggestions and recommendations to you about: (i) news and updates relating to us, our partners or the VGX Products and Services; (ii) content, and products and services that may interest you; and (iii) other promotional activity and events we think may be of interest, including:

• Email address

• Other information collected and clearly identifiable to you at the point of your signing up to our marketing communications

Legal basis for this processing

If required by law, we rely upon your consent for us to undertake this data processing activity. You can revoke your consent at any time by letting us know, including by emailing us.

In some instances (such as with some of our existing customers) the law may permit us to process your personal data to send marketing communications on the basis of our legitimate interests, being our legitimate business interests in marketing our activities and promoting the success of our business and the VGX Products and Services. If the information is not of interest for you, you can opt-out at any time by letting us know, including by emailing us.

Sources

We collect this personal data from you.

Recipients

We may use service providers from time to time to assist us with marketing and communication relating to the VGX Products and Services, which may include providing promotional and advertising services, providing mailing or email services, and similar services.

Waiting List Data

Information that we collect about you when you sign-up to being notified of when a new service or product is available, or to joining a waiting list for a new product or service:

• Full name

• Email address

• Country of residence

• Any personal data you provide to us in response to questions that we ask you in relation to the new product or service, the sign-up process, or VGX

We process this information: (a) to enable you to register your interest in the new product or service and receive updates on the new product or service; and (b) to collect your feedback on the new product or service, and VGX Products and Services in general.

Legal basis for this processing

• (a): Your consent

• (b): Our legitimate interest of improving our services and products

Sources

We collect this personal data from you.

Recipients

We may use service providers from time to time to assist us with marketing and communication relating to new products and services you have asked to be notified about, which may include providing promotional and advertising services, providing mailing or email services, and similar services.

Survey Data

Information that we collect about you when you respond to our surveys:

• Full name

• Email address

• Any personal data you provide to us in response to questions in our surveys

We process this information to understand your thoughts on VGX Products and Services.

Legal basis for this processing

Our legitimate interests of improving our products and services.

Sources

We collect this personal data from you.

Recipients

We may use service providers from time to time to assist us with providing surveys and analysing and understanding survey results.

Technical Data

Information that we collect about the device on which you are using the VGX Products and Services to tailor the delivery of the relevant SafeMoon Products and Services, including:

• Device type

• Geolocation data

We process this information: (a) to improve the delivery of the VGX Products and Services and to customize your experience to your preferences (e.g., if you have selected “dark mode”); (b) to understand how you use the SafeMoon Products and Services to improve them; and (c) to distinguish between bot and human traffic.

Legal basis for this processing

• (a) and (b): Our legitimate interests of understanding website usage and improving the SafeMoon Products and Services.

Sources

We use Google’s services to collect this personal data from you when you use the VGX Products and Services.

Recipients

Google in the USA collects and processes this information on our behalf.

Enquiry Data

Information that we collect to enable us to collect, record and properly respond to your submissions, enquiries and support requests in relation to the VGX Products and Services and our marketing materials:

• Name

• Email address

• Any personal data you provide to us in your submissions, enquiries and support requests

We process this information: (a) to support our efforts to provide you with the best experience when using the VGX Products and Services; (b) to improve the quality of the VGX Products and Services, and provide a better experience to you; and (c) to identify and correct any bugs in the VGX Products and Services.

Legal basis for this processing

Our legitimate interests of improving the VGX Products and Services.

Sources

We collect this personal data from you.

Recipients

N/A

Data From Job Applicants and Employees

(a) We collect information relating to employment and independent contractor candidates, including name, address, email address, telephone number, resume information, notes on meetings and interviews, references, interviewer impressions and other industry standard data, as well as data made publicly available or available to us on social networks. Interviews with candidates may be recorded in cases where the candidate provides consent.

(b) We collect information related to our employees and independent contractors, such as name, address, email address, telephone number, and other information that is customary or necessary to administer the employment or engagement relationship.

If the candidate, employee or independent contractor resides in a jurisdiction in which we are required to provide a separate applicant, employee or independent contractor privacy notice, our collection and use of the personal information is also governed by such separately-provided privacy notice. In such a case, such separately-provided privacy notice shall prevail in the event of any conflict between the terms of such notice and the terms of this notice.

We process this information for the purposes of fulfilling open job positions and recruiting job applicants and/or candidates, and administering the employment relationship.

Subject to applicable law, we may use this information for operational purposes to:

• Process job applications for employment.
• Contact the candidate or its recruiter about suitable job opportunities as they may arise.
• Contact references and/or perform background checks with a candidate’s authorization.
• Evaluate eligibility, skills and interest for potential matching with available positions at our company.
• Conduct internal analyses to understand the job applicants and to improve our recruitment process.

Comply with legal obligations (e.g., health and safety, anti-discrimination laws).

Manage candidates’ and employees’ relationship with us.

Legal basis for this processing

We normally collect or use personal information where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (e.g., to communicate with you, to evaluate your application, to manage our recruitment processes and administer employment relationship(s)), or where applicable, where we have obtained your consent to process for a specific purpose. In certain situations, we may have a legal obligation to collect or retain personal information (e.g., to comply with applicable employment laws and regulations) or need the personal information to protect your vital interests or those of another person.

Sources

We collect this information from you where you provide it to us. We also collect such information from other sources as follows:

• Third-party sources. For example, employment screening agencies, background check agencies, recruiting agencies, service providers, former employers and/or educational institutions, publicly available information on websites or social media (where relevant for recruitment purposes and allowed by applicable law), and from others where they are legally allowed to share your personal information with us.
• Individuals who refer you. For example, if a friend thinks you may be interested in a job at our company, he or she may give us your contact details and resume.

Recipients

• Service Providers. We may share information with service providers who assist us to administer our recruitment process and employment relationships, such as for talent acquisition and administration, technology services, background checks, where allowed by applicable law, employment history checks, payroll, etc.. We have contracts with our service providers that address the safeguarding and proper use of your personal information.
• Your employer or organization for reference checks.
• Government Authorities. We may share your personal information to comply with our legal obligations, regulations, or contracts, or to respond to a court order, administrative, or judicial process, such as a subpoena, government audit, or search warrant where we are legally compelled to do so.
• Corporate Transactions. Your personal information may be disclosed or transferred to relevant third parties in the event of, or as part of the due diligence for, any proposed or actual reorganization, sale, merger, consolidation, joint venture, assignment, transfer, or other disposition of all or part of our business, assets, or stock.

Consent. We may share your personal information in other ways if you have asked us to do so or have given consent.

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You can find out more about how Google uses data by clicking here.

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Data retention

Other than as set out above, we may disclose your personal data:

• Where required by law, government, competent authorities or the courts or to establish, exercise or defend our legal rights, and for the purposes of preventing crime and fraud (for example, we may share personal data with our professional advisors, service providers, investigators, or credit reference agencies).

• With members of our corporate group, suppliers and subcontractors, as necessary for the purposes set out in this notice.

• If involved in an investment, merger, acquisition, or sale of our organisation or assets, personal data we hold may be shared on the basis of the legitimate interests of us, our shareholders, customers and other parties to a transaction, unless those interests are outweighed by prejudicial impacts upon you.

You may have the right, depending on your jurisdiction, to request the following about the personal information we have collected about you during the past 12 months:

• The categories and specific pieces of personal information we have collected about you;

• The categories of sources from which we collected the personal information;

• The business or commercial purpose for which we collected the personal information;

• The categories of third parties with whom we shared the personal information;

• The categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose;

• The right to receive requested information in a readily-usable format if provided electronically; and

• The right to update or correct any personal information which is out of date or incorrect.

To make a request, see the “How do you contact us” section under the “Introduction” heading above.

You may also have the right to ask if we disclose your personal information to third parties for their direct marketing purposes (we do not). It also gives you the right to ask if we sell your personal information to third parties (we do not, and have not done so in the past), and if we did (which we don’t), you would have the right to opt out of such sales.

Additional information about the categories of information we collect and its usage and sharing are located under the sections entitled “Your Data and How We Use It”, “Cookies, Analytics and Similar Technologies”, and “Data Retention and Disclosure”, above.

If you live in a relevant jurisdiction and would like to send us a request to exercise one of your above rights, you may do so by contacting us as indicated in the “How do you contact us” section under the “Introduction” heading above.

To help protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with your request.

You may designate an authorized agent to make a request on your behalf as permitted under law, though before we process that request, we will require that you provide the authorized agent written permission to do so and verify your identity directly with us.

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.