Privacy Policy

This privacy notice for Mass Labs (doing business as Mass Market) ("Company," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

• Visit our website at http://mass.market, our demo-shop, or any website of ours that links to this privacy notice
• Engage with us in other related ways ― including any sales, marketing, or events

Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@mass.market.

Summary of key points:

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? Some of the information may be considered 'sensitive' in certain jurisdictions, for example your ethnic origins, sexual orientation or religious beliefs. We do not process any sensitive information.

Do we receive any information from third parties? We do not collect any information from third parties.

How do you process my information? We process your information to provide, improve, and administer our Services, communicate with you, and to comply with law. We process your information only when we have a valid legal reason to do so.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties who provide services to us, for example providing hosting or privacy-aware usage analytics.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do I exercise my rights? The easiest way to exercise your rights is by contacting us at info@mass.market. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what Mass Labs does with any information we collect? Review the notice in full below.

TABLE OF CONTENTS

1. What information do we collect?
2. How do we process your information?
3. What legal bases do we rely on to process your personal information?
4. When and with whom do we share your personal information?
5. What is our stance on third party websites?
6. Do we use cookies and other tracking technologies?
7. Is your information transferred internationally?
8. How long do we keep your information?
9. How do we keep your information safe?
10. Do we collect information from minors?
11. What are your privacy rights?
12. Controls for Do-Not-Track features
13. Do United States residents have specific privacy rights?
14. Do residents of other regions have specific privacy rights?
15. Do we make updates to this notice?
16. How can you contact us about this notice?
17. How can you review, update or delete the data that we collect from you?

1. What information do we collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you use any of our website or participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Name
• Company name
• Email address
• Mailing address

Sensitive Information. We do not process any sensitive information.

Payment Data.We may collect data necessary to process your payment if you make purchases, such as your cryptocurrency wallet address that you paid from, cryptocurrency wallet address that you paid to, the chain and token used for payment, and amount of token transacted. All payment data is stored on the blockchain, which is a public ledger of transactions. Data identifying what was purchased or where it was delivered to is not stored on the blockchain.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as:

• IP address
• Device information (mobile or desktop)
• Operating system
• Browser type and version
• Pages visited and time spent on the website
• Referring URL
• Country and approximate location

Like many businesses, we also collect information through cookies and similar technologies. We use a privacy aware analytics service for this, which you can read more about in our Cookie Notice .

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

2. How do we process your information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To fulfil and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send you our newsletter and communications. We may process the personal information you give to us in order to send you our newsletter or project updates by email. You can opt out of our newsletter emails at any time. For more information, see "What are your privacy rights?" below).
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. What legal bases do we rely on to process your information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
  • Analyze how our services are used so we can improve them to engage and retain users
  • Understand how our users use our products and services so we can improve user experience
  • Support our marketing activities
  • Send users information about special offers and discounts on our products and services
  • Diagnose problems and/or prevent fraudulent activities
• •Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

In legal terms, we are generally the "data controller" under European data protection laws of the personal information described in this privacy notice, since we determine the means and/or purposes of the data processing we perform.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations

4. When and with whom do we share your personal information?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work.

We make every effort to self-host open-source tools where possible. Where we cannot, we have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The categories of self-hosted open source tools or third-party service providers that we may share personal information with are as follows:

• Cloud Computing Services
• Communication & Collaboration Tools
• Data Analytics Services
• Data Storage Service Providers
• Finance & Accounting Tools
• Order Fulfilment Service Providers
• Payment Processors
• Performance Monitoring Tools
• Sales & Marketing Tools
• Testing Tools
• User Account Registration & Authentication Services
• Website Hosting Service Providers

5. What is our stance on third party websites?

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.

The Services may link to third-party websites, online services or mobile applications that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

6. Do we use cookies and other tracking technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies to access or store information. We do not use any Google Analytics services. We use Matomo's privacy-aware tools for analysing and processing data as set out in section 2 above. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice .

7. Is your information transferred internationally?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in Europe. If you are accessing our Services from outside Europe, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "When and with whom do we share your information?" above), in other countries. Please be aware that any financial transactions you make using distributed ledger technologies are stored on multiple nodes located in multiple countries and regions around the world. If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

8. How long do we keep your information?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. How do we keep your information safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

10. Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@mass.market.

11. What are your privacy rights?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "How can you contact us about this notice?" below. We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "How can you contact us about this notice?" below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our newsletters and other promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "How can you contact us about this notice?" below. You will then be removed from the mailing lists — however, we may still communicate with you for fulfillment of requested services or other non-marketing purposes.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at info@mass.market.

12. Controls for Do-Not-Track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

13. Do United States residents have specific privacy rights?

In Short: Yes, if you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

We will use and retain the collected personal information as needed to provide the Services or for:

• Category A - 1 year
• Category B - 1 year
• Category D - 1 year
• Category G - 1 year
• Category I - 1 year

We may also collect other personal information outside of these categories instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests;
• Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

Learn more about how we use your personal information in section 2 above.

Learn more about how we share your personal information in sections 4 and 5 above.

More information about our data collection and sharing practices can be found in this privacy notice and our Cookie Notice .

You may contact us by email at info@mass.market.

If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Your rights with respect to your personal data

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ('profiling')

Depending on the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware and Maryland)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
• Right to review, understand, question and correct how personal data has been profilied (as permitted by applicable law, including the privacy law in Minnesota)
• Right to limit use and disclosure of sensitive data and personal data (as permitted by applicable law, including the privacy law in California).

How to exercise your rights

To exercise these rights, you can contact us by visiting info@mass.market, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate and authorised agent to make a request on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with applicable laws.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate. We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

California 'Shine The Light' Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

14. Do residents of other regions have specific privacy rights?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020. This Privacy Notice satisfies the notice requirements defined in both Privacy Acts.

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us using the contact details provided below.

If you believe we are unlawfully processing your personal informatio, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal inforamtion. You can make such a request by contacting us using the contact details provided below. If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator:

The Information Regulator (South Africa)

General enquiries: enquiries@inforegulator.org.za

Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za

15. Do we make updates to this notice?

In Short: Yes, we will update this notice as necessary – as new features and services are developed and to stay compliant with relevant laws.

We may update this privacy notice 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.

We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

16. How can you contact us about this notice?

If you have questions or comments about this notice, you may contact us by email at info@mass.market.

If you have any further questions or comments, you may also contact us by post at the following corporate address:

Fl.4 Willow House,
Cricket Square,
Grand Cayman KY1-9010

17. How can you review, update or delete the data that we collect from you?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please write to us at: info@mass.market.