Introduction

MetaPouch Technologies. (“MetaPouch” or “We”) values your privacy and is dedicated to safeguarding it in accordance with this policy. This document outlines:

• The kinds of information we may collect or you may provide when you access or use the MetaPouch website, metapouch.io (the “Website”).

• The types of information we may collect or that you may provide when you download, install, register with, access, or use the MetaPouch SuperApp (the “App”).

• Our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy pertains exclusively to information collected through the Website and the App (collectively referred to as the “Services”), as well as in email, text, and other electronic communications sent through or in connection with the Services.

This policy DOES NOT apply to information:

• Collected offline or on any other MetaPouch apps or websites, including websites accessible through the Services.

• Provided to or collected by any third party (refer to Third-Party Information Collection). Websites and apps operated by these third parties may have their privacy policies, which we encourage you to review before providing information on or through them.

Children

The Services are not intended for children as defined under applicable law, and we do not knowingly collect personal information from children. If we discover that we have collected or received personal information from a child, we will promptly delete that information. If you suspect we might have any information from or about a child, please contact us at legal@metapouch.io.

Information We Collect and How We Collect It

We collect information from and about users of our Services:

• Directly from you when you provide it to us.

• Automatically when you use the Services.

Information You Provide to Us

When you download, register with, or use the Services, we may request information by which you may be personally identified, such as name, postal address, email address, telephone number, or any other identifier that can contact you online or offline (“personal information”).

This information includes:

• Information filled in forms on the Services. This may include details provided when applying to become a partner, creating a secure account, logging in, inviting friends to join MetaPouch, or appointing an asset guardian. It may encompass your email address, company name, website URL, telephone number, country, FaceID, touch ID, pin code, name, MetaPouch Web3 identity, social media handles, photo, contacts, language, security questions and answers, bio, contact information belonging to your contacts and asset guardians, information related to the kind of support you are seeking, and information related to your goals with MetaPouch.

• Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.

• Details of transactions you perform through the App and the fulfillment of your orders. This information may include your wallet info, wallet address, contact names, photos, nicknames, email addresses, and telephone numbers, balance, recent transactions, transaction ID, notes, QR Code, credit card number, expiration date, CVV, billing name, and billing address.

• Your search queries on the Services.

Automatic Information Collection and Tracking

When you download, access, and use the Services, technology may be employed to automatically collect:

• Usage Details. When you access and use the Services, certain details of your access to and use of the Services, including traffic data, location data, logs, and other communication data, as well as the resources you access and use on or through the Services, may be automatically collected.

• Device Information. Information about your mobile device and internet connection, such as the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number, may be collected.

• Stored Information and Files. The App may access metadata and other information associated with other files stored on your device. This may include personal contacts, address book information, photos, audio, videos, and local cache.

• Location Information. The App collects real-time information about the location of your device. We do not directly read geo-location data for auto-enabling Second-factor authentication. We depend on IP Address location.

  Example: If the user signs in with abc@gmail.com from two different IPs in a short span of time and the two IPs are geographically located in two different locations, second-factor authentication is auto-enabled.

  If you prefer we do not collect this information, please refrain from using the Services or downloading the App. You can also opt out of certain information collection at any time using your device settings. For more information, refer to Your Choices About Our Collection, Use, and Disclosure of Your Information.

We may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking). For details on how you can opt out of behavioral tracking on or through the Services and how we respond to browser signals and other mechanisms for consumer choice about behavioral tracking, refer to Your Choices About Our Collection, Use, and Disclosure of Your Information.

Information Collection and Tracking Technologies

The technologies we use for automatic information collection may include:

• Cookies (or mobile cookies). A cookie is a small file placed on your computer or smartphone. You may be able to refuse cookies by adjusting the appropriate setting on your browser or smartphone. However, choosing this setting may render certain parts of our Services inaccessible.

• Web Beacons. Pages of the Services and our emails may contain small electronic files known as web beacons (clear gifs, pixel tags, and single-pixel gifs) that permit MetaPouch, for instance, to count users who have visited those pages or opened an email, and for other related app statistics (e.g., recording the popularity of certain content and verifying system and server integrity).

• Device Fingerprinting. Device fingerprints enable us to uniquely identify your device or browser.

Third-Party Information Collection

When you use the Services or their content, certain third parties may utilize automatic information collection technologies to gather information about you or your device. These third parties may include:

• Advertisers, ad networks, and ad servers.

• Analytics companies.

• Your mobile device manufacturer.

• Your mobile service provider.

• Financial services companies.

• Web3 wallets.

• Automated messaging platforms.

These third parties may employ tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal information, or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. This information may be used to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or their usage. If you have questions about an advertisement or other targeted content, contact the responsible provider directly. For information on how to opt out of receiving targeted advertising from many providers, see Your Choices About Our Collection, Use, and Disclosure of Your Information.

How We Use Your Information

We use information collected about you or provided by you, including personal information, to:

• Provide you with the Services and their contents, and any other information, products, or services you request from us.

• Verify your identity.

• Send you notices about your account.

• Understand how users interact with our Services and gauge user interest.

• Enhance our Services and tailor and optimize your experience.

• Maintain the Services and troubleshoot problems.

• Conduct advertising and marketing activities.

• Prevent fraud.

• Fulfill our obligations and enforce our rights arising from any contracts entered into between you and us, including billing and collection.

• Notify you when App updates are available, and of changes to any products or services we offer or provide though it.

• In any other way we may describe when you provide the information.

• Fulfill any other purpose for which you provide it.

• For any other purpose with your consent.

The usage information we collect aids us in improving our Services and delivering a better and more personalized experience by enabling us to:

• Estimate our audience size and usage patterns.

• Store information about your preferences, allowing us to customize our Services according to your individual interests.

• Speed up your searches.

• Recognize you when you use the Services.

We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please see Your Choices About Our Collection, Use, and Disclosure of Your Information.

Disclosure of Your Information

We may disclose aggregated information about our users without restriction.

In addition, we may disclose personal information that we collect or you provide:

• To our subsidiaries and affiliates.

• To contractors, service providers, and other third parties we use to support our business, including: advertising networks, customer relationship management platforms, digital trading platforms, financial services companies (including Ramp; please note that through our use of Ramp, we may collect, use, and disclose your account balance, transaction history, bank account information, and other data or information that identifies or can be used to identify you), fraud protection providers, web3 wallets (including Magic), messaging applications and automated messaging platforms (including Customer.io), mobile application platforms, payment processors, social networks (including links to our Facebook, Instagram, LinkedIn, and Twitter pages), technology providers, video sharing platforms (including YouTube- for more information about YouTube’s collection of information, see Google’s privacy policy at: http://www.google.com/policies/privacy), and your bank.

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of MetaPouch’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by MetaPouch about our Services’ users is among the assets transferred.

• To fulfill the purpose for which you provide it.

• For any other purpose disclosed by us when you provide the information.

• With your consent.

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

• To enforce our rights arising from any contracts entered into between you and us, including our Terms and Conditions, and for billing and collection.

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of MetaPouch, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

Your Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to us. We do not respond to Do-Not-Track signals at this time; however, we have enabled mechanisms to provide you with the following control over your information:

• Tracking Technologies. You can set your browser or device to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Services may then be inaccessible or not function properly.

Third parties, including Google, may place and read cookies on your browser or device, or use web beacons to collect information in connection with ad serving on or through the Services. Our partners will collect personal information for personalization of ads and use cookies for personalized and non-personalized advertising and measurement. Ad serving may be based on users’ visits to our Services or other websites or apps, and your activity may be tracked over time and across websites or apps. For information about how Google collects, shares, and uses data, please visit: https://policies.google.com/technologies/partner-sites. You may opt out of personalized ads from Google by visiting the Google Ads Settings web page at: http://www.google.com/ads/preferences/. For more information, please visit Google’s privacy policy at: https://policies.google.com/privacy?hl=en&fg=1. -

• Promotion by MetaPouch. If you do not want us to use your information to promote our own or third parties’ products or services, you can opt-out by stating your request to legal@metapouch.io.

• Targeted Advertising. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads (including ads served using non-cookie technologies) from members of the NAI on the NAI’s website, available at: https://optout.networkadvertising.org/?c=1. You can also visit the Digital Advertising Alliance’s website, available at https://youradchoices.com/, to use its Consumer Choice Tools.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: legal@metapouch.io. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

Your Canadian Rights

MetaPouch and its data servers are located in India. Sending personal information outside of Canadian borders may increase the risk of disclosure of information because the laws in the destination country dealing with protection of information may not be as strict as in Canada. By agreeing to this Privacy Policy, you consent to allow your personal information to be transferred outside of Canada to MetaPouch and the parties noted in the Disclosure of Your Information section for processing in India in order that we may provide you with the services requested.

Subject to applicable law, you may have the right to access your personal information (including the right to access your personal information in an electronic format and the right to an account of the use that has been made or is being made of the personal information and the third parties to which it has been disclosed), or update or correct your personal information (including, where applicable, the right to obtain deletion of any personal information collected otherwise than according to law), at any time upon request. If you have provided your consent to the processing of your personal information, you have the right to fully or partly withdraw your consent. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose(s) to which you originally consented unless there is another legal ground for the processing. If you have any questions or complaints about this Privacy Policy or the handling of your personal information, if you wish to decline to have your personal information collected, used, or disclosed for the purposes set forth in this Privacy Policy or to withdraw your consent to our use of your personal information, or if you would like to request access to, deletion of, or update to any personal information we have on file, please contact: [insert privacy officer name and contact information]. Where applicable, you may also contact the privacy officer to obtain information about MetaPouch’s policies and practices with respect to service providers outside Canada.

Subject to applicable law, you may also direct complaints to the privacy commissioner of the jurisdiction in which you reside or other applicable supervisory authority.

Accessing and Correcting Your Personal Information

You can review and change your personal information by logging into the App and visiting your account profile page.

You may also send us an email at legal@metapouch.io to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. Please note that if you delete your account, your account and wallet will be deleted within thirty days.

We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated and an in-App alert the first time you use the Services after we make the change.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

MetaPouch Technologies

legal@metapouch.io