Privacy Policy

This Privacy Policy, as amended or otherwise changed from time to time (this
“Privacy Policy” or “Policy”), explains the manner in which Set Power Free DAO
LLC, ( “SPF”, “we“, “us“, or “our“), SPF collects, uses, maintains, discloses and
protects personal information collected by or provided to us through our website
www.setpowerfree.com (the “Website” or “Site”) applications, brands, services
and products (collectively, “Services”). Whenever you access or use the Services,
you accept the terms and conditions of this Privacy Policy. If you do not agree
with or you are not comfortable with any aspect of this Privacy Policy, you should
immediately discontinue access or use of the Services.

This Policy does not apply to websites, software, or applications run by third
parties that SPF may link to, reference, or otherwise contract with, so please
reference the respective third-party privacy policy for information on how they
collect and use your information.

If you have any questions or concerns about this Policy, or our practices with
regards to your personal information, please contact us at
privacy@setpowerfree.com

Privacy Policy Updates and Changes

We may revise this Policy at any time for any reason, including but not limited to:
to reflect changes in law, changes in our personal information collection,
protection, and use practices, changes in the features available through the
Services, or address any advances in technology. If any changes are made to this
Privacy Policy, the changes will be effective upon posting to the Site. You should
review this Policy each time you visit the Site or use our Services to inform
yourself of any revisions. Your continued use of the Site will constitute your
acceptance of the Policy as revised. Capitalized terms not defined herein shall
have the meanings ascribed to them in SPF’s Terms and Conditions.

Pertinent Definitions

“Personal Data” means data that SPF may collect from you or that you may
voluntarily provide to SPF that may identify, relate to, describe, references, is
reasonably capable of being associated with, or could be reasonably linked,
directly or indirectly with you, your household, or your device(s) used to access
the Services, including, for example, your name, address, User ID, telephone
number, e-mail address, any blockchain addresses, as well as any other nonpublic
information about you that is associated with or linked to any of the
foregoing data.

“Anonymous Data” means data from which your identity is not readily
ascertainable, and that is not associated with or linked to your Personal Data;
Anonymous Data does not, by itself, permit the identification of individual
persons.

Lawful Basis for Processing

We only collect and process Personal Data about you where we have lawful
bases to do so. Lawful bases include consent where you have SPF consent,
contract, and legitimate interests.

Personal Data We May Collect

• We may collect Personal Data from you, such as your first and last
name, e-mail and mailing addresses, including country or region of
residence, User ID, date of birth, government-issued identification,
and password when you register for an account on the Services
(“Account”), report a problem with the Services, or otherwise use the
Services.
• We may also collect other Personal Data provided by third-party
identity verification services or via social networking websites.
If you tell us where you are (e.g., by allowing your mobile device or
computer to send us your location), we may store that information.
• We may collect your Personal Data, such as your User ID and it may
be used to track you across devices and connect you to alternative
datasets that we have, including but not limited to, discord data, and
your SPF app.
• If you provide us feedback or contact us via e-mail, message, chat or
similar functionality, we will collect your name and e-mail address, as
well as any other content included in the communication, in order to
send you a reply.
• Transactional information when you request information or purchase
a product or service from us.
• We also collect other types of Personal Data that you provide to us
voluntarily when seeking support services, such as email,
information submitted via online form, video conferencing service
information, other contact information, or other information provided
to support services staff.
• We may collect other data, including but not limited to, referral URLs,
your location, blockchain analytics information related to blockchain
addresses you provide.

Some information is collected automatically by our servers:

• Our servers (which may be hosted by a third-party service provider)
collect information from you, including your browser type, operating
system, Internet Protocol (“IP”) address (a number that is
automatically assigned to your computer when you use the Internet,
which may vary from session to session), domain name, and/or a
date/time stamp for your visit.
• As is true of most websites, we gather certain information
automatically and store it in log files. This information includes IP
addresses, browser type, Internet service provider (“ISP”),
referring/exit pages, operating system, date/time stamp, and
clickstream data.
• Like many online services, we use cookies to collect information.
“Cookies” are small pieces of information that a website sends to
your computer’s hard drive while you are viewing the Site. We also
use “cookies” from time to time to help personalize your online
experience with us. We will process Personal Data collected through
cookies in accordance with this Privacy Policy. If you have set your
browser to alert you before accepting cookies, you should receive an
alert message with each cookie. You may refuse cookies by turning
them off in your browser, however, you should be aware that our site,
like most other popular sites, may not work well with cookies
disabled.
• We retain information on your behalf, such as transactional data and
other session data linked to your Account.

How We Use Your Information

We will only use your Personal Data in ways that you provide us your consent or
when the law allows. Please note that we may process your Personal Data
without your knowledge or consent where this is required or permitted by law.

In general, Personal Data you submit to us is used either to respond to requests
that you make, or to aid us in serving you better. We use your Personal Data in
the following ways:

• facilitate the creation of and secure your Account on the network;
• identify you and perform identity verification through a service
provider;
• provide improved administration of our websites and Services;
• improve the quality of experience when you interact with our
websites, products, and Services;
• send you a welcome e-mail to verify ownership of the e-mail address
provided when your Account is created;
• send you administrative e-mail notifications, such as Account
activity, transaction processing, security or support and maintenance
advisories;
• identify, prevent, and report potentially suspicious, fraudulent, or
illegal activities;
• notify you about important changes to our Terms and Conditions or
Privacy Policy; and respond to your inquiries or other requests.
• make our Site and Services more useful to you.

 All data collected automatically will be used to administer or improve our Services as follows:

• We use IP addresses to make our website and Services more useful
to you, and to perform identity verification.
• We use information from log files to analyze trends, administer the
Services, track users’ movements around the Services, gather
demographic information about our user base as a whole, and better
tailor our Services to our users’ needs. Except as noted in this
Privacy Policy, we do not link this automatically collected data to
Personal Data.
• We may use both session Cookies (which expire once you close your
web browser) and persistent Cookies (which stay on your computer
until you delete them) to provide you with a more personal and
interactive experience with our Services. This type of information is
collected to make the Services more useful to you and to tailor the
experience with us to meet your special interests and needs.
• We also use third-party web analytics tools that help us understand
how users engage with our Site. This information is used to compile
reports and to help us improve our Site. You can opt-out of such
third-party analytic tools without affecting how you visit our Site by
contacting us at privacy@setpowerfree.com .
• We may create Anonymous Data records from Personal Data by
excluding information (such as your name) that makes the data
personally identifiable to you. We use this Anonymous Data to
analyze request and usage patterns so that we may enhance the
content and navigation of our Services. We reserve the right to use
Anonymous Data and aggregated and other de-identified information
for any purpose and disclose Anonymous Data to third parties in our
sole discretion.

SPF does not sell Personal Data to any third party.

Retention of Personal Data

Unless the law specifies a different retention period, we will only keep your
Personal Data for the time strictly necessary to carry out the operations for which
said Data has been collected by us. In general this means we will retain your
Personal Data for as long as you have an active Account with us.

Personal Data destruction procedures and methods

In principle, we destroy the Personal Data without delay after the purpose of
collection and use of Personal Data is achieved. However, this is not the case
when preservation is required according to laws and regulations.
The destruction procedure and method are as follows:
• Personal Data printed on paper: shredded with a shredder or
incinerate
• Personal Data stored in electronic file format: Deleted using a
technical method that cannot reproduce the record.

Marketing

We strive to provide you with choices regarding certain Personal Data uses,
particularly around marketing and advertising. We have established the following
Personal Data control mechanisms:

We may use your Personal Data to form a view on what Services we think may be
of interest to you. You will receive marketing communications from us if (i) you
have requested information from us; or (ii) use our Services, in each case, you
have chosen to opt-in and not opted out of receiving marketing communications.
We will get your express opt-in consent before we share your Personal Data with
any company outside of SPF for marketing purposes.

You acknowledge by providing your personal information in connection with
receiving services from SPF, that you have an established business relationship
with SPF. As such, you provide SPF with express consent to contact you using
your personal information for all matters relative to your services with SPF. This
may include the use of autodialed or pre-recorded telephonic communications
for operational communication, which may include the verification of your
personal information, the collection of a debt, or any other necessary
communication or confirmation in connection with any element of your ongoing
service with SPF. You further acknowledge that this established business
relationship may extend beyond the standard eighteen months from the last
transaction standard. You understand that services with SPF may not have such
a transaction within eighteen months, but that the relationship will still be
considered as ongoing due to the specific nature of SPF services. The
established business relationship, which is created upon the initiation of
services, and the providing of personal information to SPF shall continue for five
years following the providing or updating of any personal information in
connection with your services with SPF. With respect to sales and marketing
from SPF specifically, you understand that the same existing business
relationship standard applies.

You can ask us or third parties to stop sending you marketing messages at any
time by following the opt-out links on any marketing message sent to you or by
contacting us. However, where you opt out of receiving marketing messages, this
will not apply to Personal Data provided to us as a result of your use of our
Service, a product/service experience or other transactions.

How we Share your Information – Personal Data shared with third parties

We disclose your Personal Data as described below and as described elsewhere
in this Privacy Policy.

• It may be necessary to disclose your Personal Data to comply with
any legal obligation, to defend or investigate any illegal or suspected
violations of SPF’s Terms and Conditions, to enforce our Terms and
Conditions and this Privacy Policy, or to protect the rights, safety,
and security of SPF, our users, or the public.
• We may share your Personal Data with third-party service providers
to provide you with the Services; to conduct quality assurance
testing; to facilitate creation of accounts; to provide technical
support; and to verify your identity. These third-party service
providers are required not to use your Personal Data other than to
provide the services requested by you.
• We may share some or all of your Personal Data with third parties
(e.g., the purchaser or new owner) in connection with or during
negotiation of any merger, financing, acquisition or dissolution
transaction or proceeding involving sale, transfer, divestiture, or
disclosure of all or a portion of our business or assets. In the event
of an insolvency, bankruptcy, or receivership, Personal Data may also
be transferred as a business asset. If another company acquires SPF
assets, that company will possess the Personal Data collected by
SPF and will assume the rights and obligations regarding your
Personal Data as described in this Privacy Policy.
• We may disclose your Personal Data to affiliated/partner brands, and
you specifically consent to the same.

Our Services may contain links to other third-party websites which are regulated
by their own privacy policies. SPF is not responsible for the privacy policies of
these third-party websites even if they were accessed using the links from our
Services.

Other than as stated in this Privacy Policy, SPF does not disclose any of your
Personal Data to third parties unless required to do so by law enforcement, court
order, or in compliance with legal reporting obligations.

Transfers outside of the EEA

Your Personal Data may be transferred to, processed, and stored in countries
other than the country in which you are a resident, including the United States,
European Union, the UK, and other region. We may share your Personal Data with
our partners and third party companies that assist in providing SPF Services
which are based in various locations globally.

If you are based in the European Union, this may involve transferring your data
outside the European Economic Area (EEA). In addition, many of our external
third parties are also based outside of the EEA so their processing of your
Personal Data will involve a transfer of data outside the EEA. We may transfer
personal data from EEA to third countries outside of EEA, under the following
conditions:

• Contractual Obligation: Where transfers are necessary to satisfy our
obligation to you under our EULA, including to provide you with our
services and customer support services, and to optimize SPF; and
• Consent: where you have consented to the transfer of your Personal
Data to a third country.

Whenever we transfer your Personal Data out of the EEA, we ensure a similar
degree of protection is afforded to it by ensuring at least one of the following
safeguards is implemented:

• We will only transfer your Personal Data to countries that have been
deemed to provide an adequate level of protection for personal data
by the European Commission. For further details, see European
Commission: Adequacy of the protection of personal data in non-EU
countries.
• We may use specific contracts approved by the European
Commission which SPF Personal Data the same protection it has in
Europe. For further details, see European Commission: Model
contracts for the transfer of personal data to third countries.
• In respect of transfers to entities in the US, we may transfer Personal
Data to them if they are part of the Privacy Shield which requires
them to provide similar protection to personal data shared between
Europe and the US. For further details, see European Commission:
EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism
used by us when transferring your Personal Data out of the EEA. If you wish to be
informed about what Personal Data we hold and want it removed from our
systems or to exercise any of your rights granted under your country of
residence, please contact us at privacy@setpowerfree.com

Updating Information

You can update your personal or account information by contacting our support
team at privacy@setpowerfree.com

We will retain your information for as long as your Account is not closed or as
needed to provide you access to your Account. If you wish to close your Account,
open a ticket in our support center. We will retain and use your information as
necessary to comply with our legal obligations, resolve disputes, and enforce our
Terms and Conditions.

Cookies

We collect web browser information in order to enhance your experience on our
Services and track how the Services are being used. Cookies are small data files
that are stored on your computer’s hard drive, and in addition to using cookies to
provide you with a better user experience, we use cookies to identify and prevent
fraudulent activity. The information collected can include, but is not limited to,
your IP address, referral URLs, the type of device you use, your operating system,
the type of browser you use, geographic location, and other session data.
Cookies are not permanent and will expire after a short time period of inactivity.
You may opt to deactivate your cookies, but it is important to note that you may
not be able to access or use some features of our Services. Please note that SPF
is not responsible and cannot be held liable for any loss resulting from your
decision or inability to use such features.

Do Not Track (“DNT”) is an optional browser setting that allows you to express
your preferences regarding tracking by advertisers and other third parties. At this
time, we do not respond to DNT signals.

Security of Information

We take the protection of your Personal Data seriously. We use industry-standard
data encryption technology and have implemented restrictions related to the
storage of and the ability to access your Personal Data. However, please note
that no transmission over the Internet or method of electronic storage can be
guaranteed to be 100% secure. Additionally, we aim to enforce internal
regulations and rectify issues as soon as they are discovered.

Legal Rights Concerning Your Information

Depending on your state or country of residence, under certain circumstances, you have rights under data protection laws in relation to your Personal Data which are set out in more detail below:

 

Request confirmation and access	This enables you to confirm whether or not we are processing your Personal Data and that you may access your Personal Data.
Request change or correction	This enables you to have any Personal Data we hold about you changed or corrected, though we may need to verify the accuracy of the new data you provide to us. If you need to add or change any information, you can log into your Account and make the change in your settings. If it doesn’t look like you can make the change on your own, please reach out to us at privacy@setpowerfree.com and we make work to correct any errors.
Request deletion	This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with applicable law. Please note: your right of deletion would not apply for various reasons including if we need to retain your Personal Data in order to comply with a legal obligation or to establish or defend a legal claim. Where we are unable to comply with your request of deletion, we will notify you at the time of your request.
Object to processing	You have the right to object to the processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing	This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to delete it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request to transfer	If you ask us, we will provide you or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdrawal of consent	This applies where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at privacy@setpowerfree.com

For California Customers please click here: https://oag.ca.gov/privacy/ccpa

Accessing your Information

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, depending on your state or country or residence, if your request is clearly unfounded, repetitive or excessive, we may refuse to act on your request or charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your rights to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

California Residents

If you are a California resident, you may have certain rights with respect to your
Personal Data, including the following:
• Right to know, whether we collect and save your Personal Data, the
source of the Personal Data we have about you, the categories and
purposes of use of your Personal Data, , whether it is being disclosed
or sold, and to whom it is being disclosed or sold;
• Right, subject to certain exceptions, to have your Personal Data
deleted from our possession or control;
• Right to opt-out from the sale of your Personal Data. As described in
the section above, we do not sell Personal Data and have not done
so in the past 12 months;
• Right to limit sensitive Personal Data use (e.g., information relating
to your government ID or geolocation) to specifically permitted
purposes; and
• Right to not be discriminated against for exercising your rights
• Right to correct inaccurate personal information that we may have
about you;
• Right to limit the use and disclosure of sensitive personal
information collected about you.

The California Consumer Privacy Act (CCPA), as amended by the California
Privacy Rights Act (CPRA) permits California residents who use our website to
request certain information regarding our disclosure of personal information to
third parties for their direct marketing purposes. To make such a request, or if
you have any questions or concerns about your California privacy rights, our
Privacy Policy, or our use of your personal information, please send an email
to privacy@setpowerfree.com.
For all California residents, any such inquiries shall be responded to within fortyfive
(45) days. We must verify your identity with respect to such
inquiries. Depending on the nature of the Personal Information at issue, we may
require additional measures or information from you as part of that verification.
For California residents under age 18 who have publicly posted content or
information, you may request and obtain removal of such content or information
pursuant to California Business and Professions Code Section 22581, provided
you are a registered user of any website where this Policy is posted. To make
such a request, please send an email with a detailed description of the specific
content or information to privacy@setpowerfree.com .

Residents of other Colorado, Connecticut, Utah, and Virginia

We treat collected information of persons residing in any jurisdiction with the
upmost care and in accordance with applicable law.
Colorado – we adhere to the consumers’ privacy rights and company personal
data collection duties set forth in Colorado’s comprehensive data privacy law
known as the Colorado Privacy Act (CPA), or Colo. Rev. State. § 6-1-1301 et seq.,
which comports with the Colorado Consumer Protection Act.
Connecticut – we do and will abide by Connecticut’s primary data privacy law
known as Personal Data Privacy and online Monitoring, or 2022 S.B. 6 or Public
Act No. 22-15 effectual on July 1, 2023, which gives Connecticut residents the
right to request a copy of their personal data, correct any inaccuracies, and opt
out of personal data processing. Moreover, we comply with Conn. Gen. Stat. §
42-471, which mandates that we safeguard personal information from being
misused by third parties and erase it upon disposal.
Utah – we observe the requirements of Utah’s 2022 S.B 227, known as the Utah
Consumer Privacy Act (UCPA) effectual as of December 31, 2022, which gives
consumers the right to know:
– what type of data we collect about them;
– how their data is being used; and
– whether or not we intend to sell the data to third parties.
In further compliance with the UCPA, upon request, we will provide you access to
your data, permit you to delete your personal data, and allow you to opt out of
personal data collection.
Virginia – we fulfill the requirements of Virginia’s Consumer Data Protection Act
(2021 H.B. 2307/2021 S.B. 1392), which lays out how we control and process
data and mandates that, upon request, we will provide you access to your data,
permit you to delete your personal data, correct your data, as well as allow you to
opt out of personal data collection.
To make a request regarding your personal data, in accordance with any of the
laws of Colorado, Connecticut, Utah or Virginia, please send an email with a
detailed description of the specific content or information
to privacy@setpowerfree.com

Residents of Other U.S. States and Compliance with Federal Law

We reiterate that we treat collected information of persons residing in any
jurisdiction with the utmost care and in accordance. Thus, for purposes of
clarity, we pronounce our adherence to the following laws of these U.S. States:
• Arizona – Ariz. Rev. Stat. § 41-151.22
• Delaware – Del. Code § 1204C and Del. Code Tit. 6 § 205C
• Hawaii – 2021 H.B. 1253
• Maine – 35-A MRSA § 9301
• Minnesota – Minn. Stat. §§ 325M.01 to .09
• Missouri – Mo. Rev. Stat. §§ 182.815, 182.817
• Nevada – NRS §§ 205.498, 603A.300, 603A.340
• New York – Civ. Rts. Code § 52-C*2
• Oregon – ORS § 646.607
• Tennessee – Tenn. Code § 10-7-512
• Vermont – 9 V.S.A § 2446-2447
While the United States does not currently have a data privacy and protection law
enacted at the federal level, should such a law become enacted, we intend to
comply with all provisions that may be set forth therein.
To make a request regarding your personal data, in accordance with any of the
laws of any U.S. State, or to inquire about federal data privacy and protection
compliance, please send an email with a detailed description of the specific
content or information to privacy@setpowerfree.com

Children’s Privacy

Unfortunately, if you’re under 18, you cannot use our Services. We do not knowingly solicit or collect information from anyone under 18. If we become aware that a person under the age of 18 has provided us with Personal Data without verification and parental consent, please alert us at privacy@setpowerfree.com and we will work to delete it immediately.

Updates to this Privacy Policy

We may update this Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Policy frequently to be informed of how we are protecting your information.

Contact Us

If you have any queries or complaints about our collection, use or storage of your Personal Data, or if you wish to exercise any of your rights in relation to your personal information, please contact our Data Protection Officer (“DPO”) at privacy@setpowerfree.com . We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your Personal Data.

Based on the applicable laws of your country, you may have a right to request access to the Personal Data we collect from you, change, or delete the Personal Data. To request the review, update or removal of your Personal Data, please contact us at privacy@setpowerfree.com.