DAPPUNK – PRIVACY & COOKIES POLICY

(September 2026)

We're a global revolution with Users spread across the globe, therefore our Privacy Policy & Cookies Policy (simply referred to as the Privacy Policy for convenience) is borderless and applies to you wherever you may be based. That being said, certain provisions have specific jurisdictional applications, and we have specified where this is the case within this policy.

This Privacy Policy outlines how dappunk ("we", "our", or "us") collects, uses, discloses, stores, and manages personal information.

dappunk may, subject to the provisions of this paragraph, amend the Privacy Policy at its sole discretion at any time. The most recent version of the Privacy Policy will be available on dappunk's Website/Platform. It is your responsibility to periodically check the Privacy Policy and you further agree to be bound by any such amendments to this agreement upon such notification. Your continued use of the Platform constitutes agreement to any amended terms, with the latest version applying at the material time.

1. Personal Data

When you visit our Website or interact with our services, we may (if provided) collect personal information including your name, date of birth, email address, phone number, address, and other social media accounts.

The Personal Data we collect from Users includes, without limitation:

  • Full name
  • Date of birth
  • Email address
  • Gender
  • Residence address
  • Zip code
  • Nationality
  • Passport or National ID number
  • Telephone number

2. Financial Data

When you use our Platform we may request certain financial information such as your payment details and wallet address. This is so that you may make purchases using our payment gateway, or so your account can be credited if you are a Content Creator.

The Financial Data we collect from Users includes, without limitation:

  • Credit/Debit card details
  • Wallet address
  • Source of wealth
  • Occupation
  • Bank account details, including institution name, branch, account name, bank identifier
  • Bank account number or IBAN

3. Identity Verification (KYC)

To comply with applicable anti-money laundering (AML) and counter-terrorist financing regulations, and to protect the security of our platform and its users, we apply Know Your Customer ("KYC") procedures to certain transactions.

When KYC is triggered: Where a user requests to withdraw funds from their platform balance and the withdrawal amount, whether as a single transaction or cumulatively over a defined period, meets or exceeds the threshold(s) we set from time to time, we will require that user to complete an identity verification process before the withdrawal is processed.

How we contact you: If your withdrawal triggers this requirement, we will contact you directly through a support ticket inside of the dappunk app.

Information we collect: As part of this process, we may ask you to provide:

  • Government-issued identification (such as a passport, national ID card, or driver's license)
  • Proof of address (such as a recent utility bill or bank statement)
  • Selfie or liveness verification
  • Additional documentation required to confirm your identity or the source of funds

How we protect this data: Any Personal Data and documents you submit for KYC purposes are encrypted both in transit and at rest, and are accessible only to authorized personnel and, where applicable, our verified identity-verification service providers. We do not sell this data, and it is used solely for verification, compliance, and fraud-prevention purposes.

Retention: We retain KYC data for as long as required to meet our legal and regulatory obligations, after which it is securely deleted or anonymized in accordance with our data retention schedule.

Consequences of non-completion: If requested verification is not completed, or if the information provided cannot be verified, we may delay, limit, or decline the withdrawal request, and may restrict further use of the affected account until the requirement is satisfied.

4. Usage Data

We may collect information on how you use and access the Website such as your IP address, browser type, operating system, device information, data set, geolocation, pages visited, time spent on the Platform, and other diagnostic and key performance indicators to help improve our service. With the exception of the IP address; the other usage data cannot be used to identify you.

The Usage Data we collect from Users includes, without limitation:

  • IP address
  • Login information
  • Browser type and version
  • Time zone setting
  • Platform
  • Operating system
  • Transaction history
  • Pages accessed and links clicked

5. Data Use

dappunk collects and uses your personal information for a range of purposes including:

  • To provide and maintain our services
  • To notify you about changes and updates to our services
  • To be able to provide customer service
  • To personalise your experience and improve our service
  • To process transactions
  • For marketing and promotional purposes

In addition, dappunk may share your personal information:

  • with third-party service providers
  • when required to do so by law or court order
  • to protect our legal rights, prevent fraud, or maintain security

6. Data Storage and Transfer

Your data may be stored, maintained, and/or transferred to computer servers located outside your country, where the jurisdictional data protection laws may differ to those from your home jurisdiction. By providing your information to dappunk, you consent to the storage, maintenance and/or transfer of your personal information to our servers, wherever they may be located.

We maintain physical, technical, administrative, and procedural safeguards in connection with the collection, storage, processing, use, transfer and disclosure of the User's Personal Data. We use firewall barriers, encryption techniques, and authentication procedures to maintain the security of User's online sessions. We take all measures to protect your Personal Data, taking into account the nature of the Personal Data and the processing, and the threats posed. We are constantly working to improve on these safeguards to help keep your Personal Data secure. For more information, you can contact us using the Contact Information provided below.

We take appropriate steps to ensure data privacy and security through various hardware and software methodologies. However, we cannot guarantee the security of any information that is disclosed online.

Except as described in this Policy, we will not disclose any of your information and we shall only share information in the following circumstances:

a. We may share your Personal Data if required by law or good-faith that such actions are necessary to comply with the applicable laws and regulations state laws, or in a need of a litigation process, judicial or other government warrant or to cooperate with applicable law enforcements or regulatory authorities.

b. We may share your Personal Data with affiliates, selected third parties, including business suppliers, distributors and subcontractors, and/or outsourced service providers when it is necessary for the delivery of our services. These third parties may have access to or process information about you as part of providing services for us. Please note that the aforementioned third parties only collect, use and disclose your information in the ways indicated by us in order to provide adequate services. We are not liable or responsible for the Privacy and Cookies Policies of these third parties. We recommend that you review the Privacy and Cookies Policy of any third-party services you interact with to understand their use of cookies and data collection practices.

c. We may share your Personal Data with our service providers under contracts to operate the business. For instances:

  • Cloud storage
  • Payment process
  • Transaction monitoring
  • Network infrastructure
  • Security
  • Customer support
  • Marketing
  • Data analytics

We may share your Personal Data with any financial institutions which we partner with, to process payments you have authorized.

7. Data Retention

We may retain your data through third parties subject to their privacy policies, as long as you continue to use our Services, have an account with us, or for as long as it is necessary to fulfil the purposes outlined in this Privacy Policy. We retain Personal Data for as long as it is needed for the purposes for which we collected it.

We retain data for as long as you have an active dappunk account. Some information can be deleted from the Platform on request, however, unless prohibited by law, we may retain either the original or an accurate copy of all data and information received from its Users in an easily accessible format for a period of five (5) years subsequent to the termination of your association with our Platform.

We do not store, sell, share, rent, or lease any Credit/Debit Card details or Personally Identifiable Information to any third party. We do not pass any Debit/Credit Card details to third parties. You can ask to close your account by contacting us, and we will delete your data on request. Once deleted, we will not have any information available to us through/by the third parties.

We may, however, retain your data for an additional period as it is permitted or required under applicable laws, for legal, tax, or regulatory reasons, or for legitimate and lawful business purposes.

We take reasonable measures to ensure that all Personal Data is destroyed or permanently deleted if it is no longer required for the purpose of providing services on our Platform for which it was processed. In certain circumstances, if required by law and/or law enforcement agencies, we may not destroy any personal records or Personal Data even though the prescribed period for retention shall have elapsed.

Furthermore, information or data collected via technical means such as cookies, web page counters, and other analytics tools is kept for a period of up to one (1) year from the expiry of the termination of our association with the User.

8. EU Data Protection Rights

We are obliged and bound by the General Data Protection Regulation (GDPR), which is drafted and passed by the European Union to regulate and protect the data of EU citizens (thereby any EU Users).

If, as a User, you are located in the European Economic Area (EEA), you will have the rights described below:

a. You may request access to and receive information about the Personal Data we maintain about you, update and correct inaccuracies in your Personal Data, restrict or object to the processing of your Personal Data, have the information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Data to another company.

b. You may withdraw any consent you previously provided to us regarding the processing of your Personal Data, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdraw your consent.

c. If you are located in the EEA, we will comply with applicable GDPR law when transferring your Personal Data outside of the EEA.

9. Protected Rights Under the GDPR

Under certain circumstances, according to applicable laws and regulations, you have rights under data protection laws in relation to your Personal Data as detailed below:

a. Request Access: This enables you to receive copies of your Personal Data we hold about you and to check that we are lawfully processing it, known as "data subject access request", this enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

b. Request Erasure: This enables you to request us to delete or remove your Personal Data where there is no good reason for us to continue to process it. Nonetheless, there may be circumstances where we may be legally entitled to retain your Personal Data in accordance with the terms of this Policy.

c. Request to Restrict Processing: This enables you to restrict the processing of your Personal Data, which is processed based on our legitimate interests. In the event of such an objection, we will no longer process your Personal Data, unless we demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defence of legal claims. Be aware that restricting your data processing can lead to limited access to our Platform.

d. Request to Object Processing: You have the right to object to the processing of your Personal Data where we are relying on a legitimate interest 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.

e. Request to Transfer: Under your request, we will provide you your Personal Data in a structured, commonly used, machine-readable format. This right only applies to automated information that you initially provided, consent for us to use or where we used the information to perform a contract with you.

f. Right to Data Rectification: This gives you the authority to request the correction of your Personal Data that we process or hold. This right ensures that Personal Data is accurate, up-to-date, and complete. If you discover that your Personal Data is incorrect, incomplete, or outdated, you can exercise this right by submitting a formal request to us. We are then obligated to rectify the erroneous data without undue delay, considering the purposes of the processing. This right supports the accuracy and fairness of data processing and contributes to the overall integrity and reliability of the Personal Data collected and processed by us.

10. Cookies Policy

Cookies are small text files that are placed on your device like computer, mobile or any other device by a Website, containing details of your browsing history ("Cookies"). Whenever you visit our Platform, the Website sends Cookies to the device you are using to access our Platform, and your device automatically stores the Cookie in a file located within your Website browser allowing us to recognize your device upon future access.

We use the following Cookies to operate our Platform, such as;

a. Session Cookies are temporary and expire once you close your browser. It stores information for the time, or session when you are on our Platform;

b. Persistent Cookies encompasses all Cookies that remain on your hard drive until you erase or your browser does it. It depends on the Cookie's expiration date. All persistent Cookies have an expiration date written into their code, but their duration can vary;

c. First-party-cookies are put on your device directly by our Platform you are visiting;

d. Third-Party Cookies are placed on your device, not by our Platform, but by a third party like an advertiser or an analytic system. Generally, the Third-Party Cookies consist of tracking Cookies used to identify online behavior, understand interests, and then customize advertising for the User on other Websites. Any information obtained from Third-Party Cookies is processed by the respective Collaborative Partners;

e. Google Analytics Cookies to measure our User's interactions with the Content on our Platform. These Cookies collect information about your interactions with our Platform, such as unique visits, repeat visits, session duration and Website activity;

f. Essential Cookies are known as strictly necessary Cookies for you to browse our Platform and use the features of it, such as accessing secure areas of our Platform. These Cookies are generally First-Party Session Cookies. These Cookies do not require consent from you. Essential Cookies help to make our Platform easy to use by providing basic functions such as page navigation, language selections, authorization and filling in forms. Our Platform will not function without these Cookies and they cannot be disabled. These Cookies do not reveal the User's identity or collect information. They are stored on the User's device until the browser is closed;

g. Functionality Cookies allow for our Platform to remember choices you have made in the past like what language you prefer, what region you would like or what the username and password are, so you can automatically log in. We use Cookies for navigation and to facilitate your access to and use of this site. These Cookies are necessary for transmission of communications on the network or to supply services whatever requested by you. Further they help us to know which pages are the most and least popular and see how visitors navigate;

h. Performance Cookies collect information about how you use our Platform, like which page you visited and which link you clicked on. None of this type of information can be used to identify you. The sole purpose of performance cookies is to improve our Platform functions. Analytics may collect information through log data, such as; (i) IP address, (ii) Type of browser and device, (iii) Operating system, (iv) Name of the Internet Service Provider, (v) Country information, (vi) Date and time of visit, (vii) Web page origin and exit; and/or

You reserve the right to decide whether to accept or reject Cookies from our Webpage. You can exercise your Cookie rights by setting your preferences in the Cookie Consent Manager. However, you will not be able to reject the Essential Cookies and still access the Webpage, as they are strictly necessary to provide you with our services. In the event you choose to reject certain Cookies, you may still use our Webpage though your access to some functionality and areas of our Platform may be restricted. You may also set or amend your web browser controls to accept or refuse Cookies.

We ensure to take certain physical and technical safeguards to protect your Personal Data that we collect and maintain. However, please note and be aware that there are no security measures which are accurate and perfect or impenetrable.

Under certain circumstances we do not guarantee that Personal Data of yours will not be accessed, disclosed, or amended or destroyed by breach of any of our physical and technical safeguards. If you choose to use our Platform from different jurisdictions/regions of the world with laws governing data collection, then please note that you are transferring your Personal Data outside of those jurisdictions/regions for storage and processing purposes.

11. Updates and Modifications

We reserve the right, at our sole discretion, to modify, amend, supplement or replace this Privacy Policy at any time and such update details shall be indicated at the top of this page.

Users are encouraged to frequently visit the legal documentation section of our Website to be updated about the changes on the Website. Modifications will be effective on the day they are posted.

Your continued access to the Platform means that you agree to the updated policies, and to abide by the updated version.

12. Contact

In the event of any comments, questions, inquiries or complaints regarding this Policy, the User has the right to submit questions and/or concerns at support@dappunk.com.