DATAGRAM DATA PROTECTION AND PRIVACY POLICY

Last Updated: June 9, 2025

This Data Protection and Privacy Policy (“Privacy Policy”) outlines how Datagram Group Ltd., a company incorporated in the British Virgin Islands (“BVI”) (“Datagram”, “we”, “us”, or “our”), collects, uses, protects, and discloses your personal information through our websites (including https://datagram.network and any subdomains), software, node operations, testnet campaigns, and

services (collectively, the “Services”).

By accessing or using our Services, you acknowledge that you have read, understood, and agreed to this Privacy Policy. If you do not agree with any part of this Privacy Policy, please refrain from using our Services.

1. INTRODUCTION

1.1 This Privacy Policy sets out how Datagram collects and processes Personal Data, the rights of individuals (“Data Subjects”), and the safeguards in place to ensure that your data is protected.

1.2 This Policy takes into account the Data Protection Act, 2021 (BVI) and general data privacy principles, and also considers provisions relevant under EU and UK GDPR, where applicable.

2. DEFINITIONS

2.1 Personal Data means any information relating to an identified or identifiable natural person.

2.2 Processing means any operation performed on Personal Data, including collection, storage, use, sharing, or deletion.

2.3 Controller means Datagram Group Ltd., which determines the purposes and means of Processing Personal Data.

2.4 Processor means a third-party service provider processing data on our behalf.

2.5 Data Subject means the individual to whom the Personal Data relates.

3. PRINCIPLES

We commit to the following principles when processing Personal Data:

• Lawfulness, fairness, and transparency
• Purpose limitation
• Data minimization
• Accuracy
• Storage limitation
• Integrity and confidentiality
• Accountability and compliance

4. HOW WE COLLECT PERSONAL DATA

We may collect data in the following ways:

• When you sign up for node operations or participate in our testnet
• When you connect a wallet to interact with our Services
• When you fill in forms, surveys, bug reports, or send us feedback
• Through cookies and usage logs from your interaction with our websites
• From third-party services integrated into our platform
• From public blockchain data tied to your wallet

5. TYPES OF DATA COLLECTED

We may collect the following categories of Personal Data:

• Name, email, social handles (e.g., Twitter, Discord, Telegram)
• Wallet address and on-chain identifiers
• Node registration and uptime data
• Participation logs from testnet campaigns
• Browser, IP address, and device metadata
• Usage statistics, preferences, and communication history
• Geolocation and connection data (to ensure network security and performance)

6. PURPOSES OF PROCESSING

We use Personal Data to:

• Register and manage node operations and participation in testnets
• Enable eligibility tracking for airdrops and rewards
• Analyze uptime, resource contributions, and performance of nodes
• Improve and maintain the security and integrity of our infrastructure
• Communicate with participants, partners, and users
• Comply with legal obligations and resolve disputes
• Monitor misuse, abuse, or unauthorized activity

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7. LEGAL BASIS FOR PROCESSING

We process your data based on the following legal bases:

• Consent — you have voluntarily provided your data
• Contractual necessity — needed to perform obligations to you
• Legal compliance — required by applicable BVI or other laws
• Legitimate interests — ensuring integrity, performance, and growth of our Services

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8. CHILDREN’S DATA

Our Services are not intended for individuals under 18 years of age. We do not knowingly collect data from minors. If we discover we have, we will promptly delete such data.

9. YOUR RIGHTS

Subject to applicable laws, you may have the right to:

• Access your Personal Data
• Request correction or deletion
• Object to or restrict certain processing
• Withdraw consent at any time
• Lodge a complaint with your data protection authority

Requests can be sent to: info@datagram.network

10. DATA SHARING

We may disclose Personal Data to:

• Cloud and hosting providers
• Analytics tools (e.g., Google Analytics)
• Partners (e.g., validators, exchanges, KYC providers)
• Service providers helping us with infrastructure, marketing, or communication
• Regulators and legal authorities when required by law
• Affiliates or successors in corporate transactions

We do not sell your Personal Data.

11. CROSS-BORDER TRANSFERS

Your data may be stored or processed in jurisdictions outside the BVI. Where applicable, we ensure appropriate safeguards are in place, including data protection agreements and standard contractual clauses.

12. SECURITY MEASURES

We use technical and organizational safeguards to protect Personal Data, including:

• Access controls and encryption
• Network monitoring and logging
• Role-based access to sensitive infrastructure
• Regular audits and vulnerability checks

No system is entirely secure, and we cannot guarantee absolute protection. In case of a breach, we will notify affected users as required by law.

13. COOKIES AND TRACKING

We use cookies and similar technologies to:

• Authenticate users
• Track uptime and node activity
• Analyze site traffic and usage patterns

You can disable cookies in your browser settings, though some features may become limited.

14. THIRD-PARTY LINKS AND WALLETS

Datagram may link to or integrate with third-party services (e.g., wallets, Gitbook, Discord, analytics platforms). We are not responsible for their privacy practices. Please review their privacy policies separately.

15. RETENTION

We retain Personal Data:

• As long as needed for its processing purpose (e.g., testnet rewards)
• As required by law
• Until the user requests deletion (unless legal grounds to retain exist)

Data may be de-identified and retained for research or analytical purposes.

16. UPDATES TO THIS POLICY

We may update this Privacy Policy from time to time. Material changes will be notified via our website or official communication channels. Continued use of our Services after updates constitutes acceptance.

17. CONTACT

If you have any questions about this Privacy Policy or your data rights, please contact:

info@datagram.network

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