OneSafe Privacy Policy

Last Revised on [ March 27, 2024 ]

This Privacy Policy for Thresholdz Inc. (“Company”, “we”, “us” “our”) describes how we collect, use and disclose information about users of the Company’s websites (onesafe.io and thresholds.io) and any related services, tools and features (collectively, the “Services”). For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Services.

Please read this Privacy Policy carefully. By using, accessing or downloading any of the Services, you agree to the collection, use and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use, access or download any of the Services.

UPDATING THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date at the top of this Privacy Policy. If we make changes that materially impact our use of your information, we will use reasonable efforts to notify you, such as by emailing you at the last email address you provided us, and taking such other steps as required by applicable law. If you do not agree to any updates to this Privacy Policy, please do not access or continue to use the Services.

COMPANY’S COLLECTION AND USE OF INFORMATION

When you access or use the Services, we may collect and handle certain categories of information about you from a variety of sources. Some features of the Services may require you to directly enter certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit or that we may collect through our Services may include:

  • The following information about you: name, email address, mailing address and phone number. We collect these details to communicate with you.

  • The following account information: username. We collect information to maintain, authenticate and secure your account with us. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. If you believe your account has been compromised, please contact us immediately.

  • The following third-party wallet (“Wallet”) information: public wallet address. We collect third-party wallet information in order to create a profile and facilitate your use of the Services.

  • The following bank account information: routing and account numbers, transaction history, profile information and billing address. We collect bank account information to help facilitate transactions through the Services, to link your bank account to the Services and for certain know-your-business and other identity verification reviews.

  • Any information that you choose to include in communications with us, for example, when contacting us through the Services.

We also automatically collect certain information about your interaction with the Services (“Usage Data”). To do this, we may use cookies, web beacons/clear gifs and other geolocation tracking technologies*.* (“Tracking Technologies”). Usage Data may include:

  • Precise location

  • Device type, such as your phone, computer, or tablet

  • IP address

  • Browser type

  • Date and time stamps, such as the date and time you first accessed the Services

  • Operating system

  • Log data

  • Other information regarding your interaction with the Services, such as clickstream data and ad impressions

We use the information we collect automatically to improve our products and Services, to tailor the Services to you, to run analytics and better understand user interaction with the Services and to market to you.

We may obtain information about you from outside sources. Such information may include:

Information from third parties that you choose to share with us, for example:

When you choose to link any social media platforms to your account, such as Facebook or Twitter. This information is used to maintain your account and login information.

When you use the Services to connect to one of our third party partners, such as Maple Finance, TrueFi. This information is used to facilitate the Services and conduct know-your-business type reviews.

When you use our Services to interact with a third party Wallet provider, such as Fireblocks, MetaMask or WalletConnect). This information is used to facilitate the connection to your Wallet.

When you sign into our Services using passwordless authentication, such as Magic Link or OAuth. This information is used to facilitate your login to the Services.

When you choose to make a payment using one of our third party integrations, such as Plaid or Evolve Bank. This information is used to facilitate transactions through the Services.

Any information we receive from outside sources will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. See Section 5 below for more information.

In addition to the foregoing, we may use any of the above information to comply with any applicable legal obligations, to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

HOW THE COMPANY SHARES YOUR INFORMATION

In certain circumstances, the Company may share your information with third parties for legitimate purposes subject to this Privacy Policy. Such circumstances may include:

With vendors or other service providers, such as

Payment processors

Know-your-business service providers

Data analytics vendors

Cloud storage providers

IT service management vendors

Email marketing services vendors

Advertising and marketing service providers

Hosting service providers

Customer support service providers

With our affiliates or otherwise within our corporate group

With third parties for marketing purposes

With our third party partners (i.e., Evolve Bank, Maple Finance, TrueFi)

To comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries

For fraud prevention or identify verification purposes

In connection with an asset sale, merger, bankruptcy, or other business transaction

To enforce any applicable terms of service

To ensure the safety and security of the Company and/or its users

When you request us to share certain information with third parties, such as through your use of social media widgets or login integrations

With professional advisors, such as auditors, law firms, or accounting firms

COOKIES AND OTHER TRACKING TECHNOLOGIES

Do Not Track Signals

Your browser settings may also allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our website is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit [

http://www.allaboutdnt.com/.](http://www.allaboutdnt.com/)

Cookies and Other Tracking Technologies

Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including any portal features and general functionality, to work incorrectly.

To opt out of tracking by Google Analytics, click

here

.

If you have questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.

SOCIAL NETWORKS AND OTHER THIRD PARTY WEBSITES AND LINKS (INCLUDING WALLET EXTENSIONS)

We may provide links to websites or other online platforms, including third-party social networking platforms (such as Facebook, such platforms “Social Networks”), operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of these sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share or post on Social Networks, may also be accessible or viewable by other users of the Services and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services. Any information submitted by you directly to these third parties, by interacting with Social Networks or through the use of third-party wallets to conduct transactions on the Platform is subject to that third party’s privacy policy. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of personal information by third parties, including Social Networks, or arising from the use of third-party wallets.

SMS NOTIFICATIONS AND CONSENT

By opting into our SMS notifications service, you agree to receive text messages regarding updates, alerts, and reminders from OneSafe. Messages may vary in frequency depending on your interactions with us. You acknowledge that standard message and data rates may apply according to your mobile phone service provider.

Opting In: To subscribe to our SMS notifications, you explicitly agree to these terms and provide consent either through our website by entering your phone number and confirming your subscription or by texting a keyword to our designated number.

Your Privacy: We respect your privacy. Your phone number and subscription details will be used solely for delivering the requested SMS notifications and will not be shared with third parties for their marketing purposes without your explicit consent.

Opting Out: You can unsubscribe from our SMS notifications at any time by replying STOP to any message you receive from us or by following the unsubscribe instructions provided in the message. Upon receiving your request, we will send you one final message to confirm that you have been unsubscribed. After this, you will no longer receive SMS notifications from us.

CHILDREN’S PRIVACY

Children under the age of 13 are not permitted to use the Services, and we do not seek or knowingly collect any personal information about children under 13 years of age. If you are the parent or guardian of a child under 13 years of age who has provided us with personal information, you may contact us using the information below to request that it be deleted.

DATA SECURITY

We have implemented commercially reasonable measures designed to protect the confidentiality, integrity, and security of your information. Please be aware though that, despite our reasonable efforts, no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” Please further note that any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us.

CALIFORNIA PRIVACY RIGHTS

Sharing for Direct Marketing Purposes

California law permits users in California to request certain details about how their “personal information” (as defined in California Civil Code Section 1798.83) is shared with third parties for direct marketing purposes. We may from time to time elect to share certain “personal information” about you with third parties for those third parties’ direct marketing purposes. California users may, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. If this applies, you may obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year.

To make such a request, please contact us using the information listed below. Please note that we are only required to respond to one request per California resident each year.

INTERNATIONAL USERS

We are based in the United States. If you access the Services from outside the United States, we want to remind you that our handling of information about you will be subject to United States data privacy laws.

HOW TO CONTACT US

Should you have any questions about our privacy practices or this Privacy Policy, please email us at support@onesafe.io.

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