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PRIVACY POLICY

> Last Updated: November, 2023

Puffer Foundation, a Cayman Islands foundation company (as "Puffer", "we",
"our", or "us"), currently provides services including, but not limited to, the
website located at https://puffer.fi, and any content, functionality, and
services offered on or through such website ("Services"). We take the protection
of your personal data very seriously. We collect and use your personal data in
accordance with this privacy policy and in compliance with the Cayman Islands
Data Protection Act (as amended) and, in respect of any EU data subjects, the EU
General Data Protection Regulation (together, the "Data Protection
Legislation"). This privacy policy ("Privacy Policy") provides you with
information about the collection and use of your personal data when using our
website.


INFORMATION OBTAINED WHEN YOU ACCESS OUR WEBSITE

When you access our website, we and our service providers may obtain or request
information about you, your computer or mobile device, and your interaction over
time with our website, as described below.

 * Personal information that is automatically collected. When you visit our
   website, we and our service providers may automatically log information about
   you, your computer or mobile device, and your interaction over time with our
   website, our communications and other online services, such as:
   
   * Device data, such as your computer’s or mobile device’s operating system
     type and version, manufacturer and model, browser type, screen resolution,
     RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP
     address, unique identifiers (including identifiers used for advertising
     purposes), language settings, mobile device carrier, radio/network
     information (e.g., WiFi, LTE, 4G), and general location information such as
     city, state or geographic area.
   
   * Online activity data, such as pages or screens you viewed, how long you
     spent on a page or screen, browsing history, navigation paths between pages
     or screens, information about your activity on a page or screen, access
     times, and duration of access, and whether you have opened our marketing
     emails or clicked links within them.

 * Personal information that you may be asked to provide. When you visit our
   website, you may be asked to provide the following information to us:
   
   * Contact and account information, such as your first and last name, email
     address, phone number, date of birth, photographic identification,
     government issued identification and other contact details.
   
   * Feedback or correspondence, such as information you provide when you
     contact us with questions, feedback, product reviews, or otherwise
     correspond with us online.
   
   * Usage information, such as information about how you use our website and
     interact with it, including information associated with any content you
     upload to our website or otherwise submit to us, and information you
     provide when you use any interactive features of our website.
   
   * Other information that we may collect which is not specifically listed
     here, but which we will use in accordance with this Privacy Policy or as
     otherwise disclosed at the time of collection.

 * Personal information that we obtain from third parties. When you visit our
   website, we may obtain information from the following sources:
   
   * Other sources. We may obtain your personal information from other third
     parties, such as marketing partners, publicly-available sources and data
     providers.


HOW WE USE YOUR PERSONAL INFORMATION

 * We may collect, store and use your personal data for purposes including the
   following. The processing is necessary for the performance of a contract,
   including:
   
   * administering or managing Puffer;
   * facilitating the continuation or termination of the contractual
     relationship between you and Puffer; and
   * administering and facilitating any transaction between you and Puffer.

 * The processing is necessary for compliance with applicable legal or
   regulatory obligations, including:
   
   * undertaking due diligence including anti-money laundering and
     counter-terrorist financing checks, including verifying identity and
     addresses (and, where applicable, in relation to beneficial owners);
   * sanctions screening and complying with applicable sanctions and embargo
     legislation;
   * complying with requests from regulatory, governmental, tax and law
     enforcement authorities;
   * surveillance and investigation activities;
   * carrying out audit checks, and instructing our auditors;
   * maintaining statutory registers; and preventing and detecting fraud.

 * In pursuance of our legitimate interests, or those of a third party to whom
   your personal data are disclosed, including:
   
   * complying with a legal, tax, accounting or regulatory obligation to which
     we or the third party are subject;
   * assessing and processing requests you make;
   * investigating any complaints, or pursuing or defending any claims,
     proceedings or disputes;
   * providing you with, and informing you about, products and services;
   * managing our risk and operations;
   * complying with audit requirements;
   * ensuring internal compliance with our policies and procedures;
   * protecting Puffer against fraud, breach of confidence or theft of
     proprietary materials;
   * seeking professional advice, including legal advice;
   * facilitating business asset transactions involving Puffer or related
     entities;
   * monitoring communications to/from us (where permitted by law); and
     protecting the security and integrity of our IT systems.

We will only process your personal data in pursuance of our legitimate interests
where we have considered that the processing is necessary and, on balance, our
legitimate interests are not overridden by your legitimate interests, rights or
freedoms.


SHARING YOUR PERSONAL DATA

 * Service providers. We may share your personal information with third party
   companies and individuals that provide services on our behalf or help us
   provide the Services (such as customer support, hosting, analytics, email
   delivery, marketing, identity verification, and database management
   services).

 * Web3 partners. We may share your personal information with our web3 partners
   as necessary to provide the Services.

 * Professional advisors. We may disclose your personal information to
   professional advisors, such as lawyers, bankers, auditors and insurers, where
   necessary in the course of the professional services that they render to us.

 * For compliance, fraud prevention and safety. We may share your personal
   information for the compliance, fraud prevention and safety purposes
   described above.

 * Business transfers. We may sell, transfer or otherwise share some or all of
   our business or assets, including your personal information, in connection
   with a business transaction (or potential business transaction) such as a
   corporate divestiture, merger, consolidation, acquisition, reorganization or
   sale of assets, or in the event of bankruptcy or dissolution.


SENDING YOUR PERSONAL DATA INTERNATIONALLY

Due to the international nature of our business, your personal data may be
transferred to jurisdictions that do not offer equivalent protection of personal
data as under the Data Protection Legislation. In such cases, we will process
personal data or procure that it be processed in accordance with the
requirements of the Data Protection Legislation.


‍RETENTION AND DELETION OF YOUR PERSONAL DATA

We will keep your personal data for as long as it is required by us. For
example, we may require it for our legitimate business purposes, to perform our
contractual obligations, or where law or regulation obliges us to. Some personal
data will be retained after your relationship with us ends. We expect to delete
your personal data (at the latest) once there is no longer any legal or
regulatory requirement or legitimate business purpose for retaining your
personal data.


AUTOMATED DECISION-MAKING

We will not take decisions producing legal effects concerning you, or otherwise
significantly affecting you, based solely on automated processing of your
personal data, unless we have considered the proposed processing in a particular
case and concluded in writing that it meets the applicable requirements under
the Data Protection Legislation.


YOUR RIGHTS

You have certain data protection rights, including the right to:

 * be informed about the purposes for which your personal data are processed;
 * access your personal data;
 * stop direct marketing;
 * restrict the processing of your personal data;
 * have incomplete or inaccurate personal data corrected;
 * ask us to stop processing your personal data;
 * be informed of a personal data breach (unless the breach is unlikely to be
   prejudicial to you);
 * complain to the Data Protection Ombudsman; and
 * require us to delete your personal data in some limited circumstances.


CHANGES

We reserve the right to change this policy from time to time by updating this
Data Privacy Policy on the website.


CONTACT US

We are committed to processing your personal data lawfully and to respecting
your data protection rights. Please contact us at contact@puffer.fi if you have
any questions about this notice or the personal data we hold about you marking
your communication "Data Protection Enquiry".