Privacy policy.

35 TO FIRST PRIVACY POLICY

1. Privacy Policy

This Privacy Policy explains 35 To First LLC (“we”, “us”, “our”) practices, including your choices,

regarding the collection, use, and disclosure of certain information, including your personal

information in connection with the 35 to First website: 35to1st.com (“Site”) and related services

(“Services”).

2. Contacting Us

If you have general questions about your account or how to contact customer service for

assistance, please email us at support@35to1st.com. For questions specifically about this

contact our Data Protection Officer/Privacy Office by email at support@35to1st.com.

The data controller of your personal information is 35 to First. Please note that if you contact us

to assist you, for your safety and ours we may need to authenticate your identity before fulfilling

your request.

3. Collection of Information

We receive and store information about you such as:

• Information you provide to us: We collect information you provide to us which includes:

o your name, email address, address or postal code, payment method(s), telephone

number, country of residence, gender, date of birth, usernames, passwords, and

other identifiers you might use. We collect this information in a number of ways,

including when you enter it while using our service, interact with our customer

service, or participate in surveys or marketing promotions;

o verification information necessary to verify your account or identity;

o information when you choose to provide ratings, preferences, account settings

(including preferences set in the "Account" section of our website), or participate

in consumer surveys, or otherwise provide information to us through our service or

elsewhere; and

o information related to your digital wallet. You will need a digital wallet and

associated wallet address to access certain aspects of the Site.

• Information we collect automatically: We may collect information about you and your

use of our service, your interactions with us and our advertising, as well as information

regarding your network, network devices, and your computer or other capable devices you

might use to access our service (such as mobile devices). This information includes:

o your activity on the Site, such as NFT selections, NFTs you have viewed, ads

viewed (if applicable) and search queries;

o your interactions with our emails and texts, and with our messages through push

and online messaging channels;

o details of your interactions with our customer service, such as the date, time and

reason for contacting us, transcripts of any chat conversations, and if you call us,

your phone number and call recordings;

o device IDs or other unique identifiers, including for your network devices (such as

your router) and digital wallet, and devices that are 35 to First capable on your

network;

o resettable device identifiers (also known as advertising identifiers), such as those

on mobile devices, tablets, and computers that include such identifiers;

o device and software characteristics (such as type and configuration), connection

information including type (wifi, cellular), statistics on page views, referring source

(for example, referral URLs), IP address (which can be used to tell us your general

location, such as your city, state/province, and postal code), browser and standard

web server log information;

o information collected via the use of cookies, web beacons and other technologies,

including ad information (such as information on the availability and delivery of ads,

the site URL, as well as the date and time);

o information about your social media engagement including your interactions with

our accounts and social media pages in third party communities, forums, and

social media sites; and

o location information, including precise or approximate location information

provided by a mobile or other device interacting with one of our sites, platforms,

applications, or physical properties.

• Information from third-party companies: We also obtain information from other

sources. We protect this information according to the practices described in this Privacy

Policy, plus any additional restrictions imposed by the source of the information. These

sources vary over time, but could include:

o service providers and other sources/companies that offer their product and/or

services to us or to you, for use in conjunction with our Service, or whose products

and/or Services may be linked from our Site;

o service providers that help us determine a location based on your IP address in

order to customize our service and for other uses consistent with this Privacy

Policy;

o security service providers that provide us with information to secure our systems,

prevent fraud and help us protect the security of 35 to First accounts;

o payment service providers that provide us with payment or balance information, or

updates to that information, based on their relationship with you;

o advertisers that run ad campaigns on 35 to First (“Advertisers”) that might provide

us with: identifiers (for example, cookies or resettable identifiers); and information

about your interests, including demographic information and your activities online

(such as websites visited, apps used and ads viewed);

o vendors who provide communication and identity verification services to us and

which you choose to use; and

o other vendors who provide us information necessary to run our business or enforce

our Terms of Service.

• Public Information: We collect data from activity and information that is publicly visible

and/or accessible on blockchains or other public sources. This may include, for example,

blockchain wallet addresses and information regarding purchases, sales, or transfers of

NFTs, which may then be associated with other date you have provided to us.

4. Use of Information

We may use information for the purposes described in this Privacy Policy, or as otherwise

disclosed at the time of collection. Please note that while information may be processed for more

than one purpose, not all of the purposes or processing activities below will necessarily apply in

every case. Our particular use of your information will depend on how you engage with us,

including the permissions you give us and other controls you exercise regarding our processing

of your information.

We use information to provide, analyze, administer, enhance and personalize our services and

marketing efforts, to provide, analyze, administer, and enhance the Services, to process your

registration, your purchases/sales and your payments, and to communicate with you on these

and other topics. For example, we use such information to:

• provide, operate and maintain the Services;

• improve and analyze the Services;

• determine your general geographic location (such as your city, state/province, and postal

code);

• analyze, improve and personalize your use and experience on the Site;

• comply with legal obligations, cooperate with investigations by law enforcement or other

authorities of suspended violations of law, and or/to protect our legal rights;

• secure our systems, prevent fraud and help us protect the security of 35 to First accounts;

• prevent, detect and investigate potentially prohibited or illegal activities, including fraud,

and to enforce our terms;

• analyze and understand our audience, improve our service (including our user interface

experiences and service performance) and optimize content, recommendation algorithms

and delivery;

• communicate with you concerning our service so that we can send you news about 35 to

First, details about new features and content available on the Site, special offers,

promotional announcements, consumer surveys, and to assist you with operational

requests such as password reset requests. These communications may be by various

methods, such as email, push notifications, text message, online messaging channels,

and matched identifier communications.

5. Disclosure of Information

We disclose your information for certain purposes and to third parties, as described below:

• 35 to First Affiliates: We share your information among the 35 to First affiliated

companies as needed for: providing you with access to the Services; providing customer

support; making decisions about service improvements; content development; and for

other purposes described in the Use of Information section of this Privacy Policy

(“Affiliates”). In any case, we require our Affiliates to honor this Privacy Policy.

• Service Providers: We use other companies, agents or contractors ("Service Providers")

to perform services on our behalf or to assist us with the provision of services to you. For

example, we engage Service Providers to provide marketing, advertising,

communications, security, infrastructure and IT services, to customize, personalize and

optimize our service, to provide bank account or balance information, to process credit

card transactions or other payment methods, to provide customer service, to analyze and

enhance information (including information about users' interactions with our service), and

to process and administer consumer surveys. We do not authorize them to use or disclose

your personal information except in connection with providing their services (which

includes maintaining and improving their services).

• Corporate Restructuring. In our legitimate interests to run an effective business, we may

share some or all of your information and information about you in connection with or

during negotiation of any merger, financing, acquisition, or dissolution transaction or

proceeding involving a sale, transfer, or divestiture of all or a portion of our business or

assets. In the event of an insolvency, bankruptcy, or receivership, your information and

information about you may also be transferred as a business asset. If another company

acquires our company, business, or assets, that company will possess the information

collected by us and will assume the rights and obligations regarding your information and

information about you as described in this Privacy Policy.

• Protection of 35 to First and others: 35 to First and its Service Providers may disclose

and otherwise use your personal and other information where we or they reasonably

believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal

process, or governmental request, (b) enforce applicable terms of use, including

investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal

or suspected illegal activities (including payment fraud), security or technical issues, or (d)

protect against harm to the rights, property or safety of 35 to First, its users or the public,

as required or permitted by law.

• Public Activity. In order to provide our Services in accordance with our contract with you,

we may display or share information relating to your public activity on this Site.

• Other Disclosures. We may also disclose your information and information about you: (i)

to fulfill the purpose for which you provide it, including to provide you with our Service and

new features or facilitate the use of login integrations in accordance with our contract with

you; (ii) with our professional advisors in our legitimate interests; (iii) for any other purpose

disclosed by us when you provide it; or (iv) with your consent

6. Third Party Websites and Wallets.

The Site may contain links to third-party websites. We have no control over and cannot be

responsible for any third-party website (or their content) which you may be redirected to. This

to use certain aspects of the Services, you must use a digital wallet which allows you to engage

in transactions. Your interactions with any third-party digital wallet provider are governed by such

provider’s terms of service and privacy policy, and not ours.

7. Your Choices

We provide you the ability to make certain choices regarding the use of information on our

Services, including the following:

• Email and Text Messages. Subsequent to creating an account and receiving the

Services, you may periodically receive emails or text messages (as indicated by you) from

us regarding the Services. If you no longer want to receive certain communications from

us via email or text message, you may indicate a preference to stop receiving these

communications by following the unsubscribe instructions provided in the communication.

Please note that you cannot unsubscribe from service-related correspondence from us,

such as messages relating to your account transactions.

• Cookies. We and our Service Providers use cookies and other technologies (such as web

beacons), as well as resettable device identifiers, for various reasons. If you decide at any

time that you no longer wish to accept cookies from our Service, you can change your

browser settings to stop accepting cookies or to prompt you before accepting a cookie

from the websites you visit.

For more information about cookies set through the Site, as well as other types of online tracking

(including the collection of information by third parties about your online activities over time and

across third-party websites or online services for online behavioral advertising), and to exercise

choices regarding them, click here. Exercising choice over cookies is specific to that web browser

or device.

8. Your Information and Rights

You can request access to your personal information or correct or update out-of-date or

inaccurate personal information we hold about you. You may also request that we delete personal

information that we hold about you.

When you visit the "Account" portion of our website, you have the ability to access and update a

broad range of information about your account, including your contact information, your payment

information, and other related information about your account (such as the content you have

viewed and rated). You must sign in to access the "Account" section.

For other requests, or if you have any other questions regarding our privacy practices, please

wishing to exercise their data protection rights in accordance with applicable data protection laws.

Please also see the "Your Choices" section of this Privacy Policy for additional choices regarding

your information.

We may reject requests that are unreasonable or not required by law, including those that would

be extremely impractical, could require disproportionate technical effort, or could expose us to

operational risks such as enabling fraud.

9. Retention of Information.

We may retain information as required or permitted by applicable laws and regulations, including

to honor your choices, for our billing or records purposes and to fulfill the purposes described in

this Privacy Policy. Specifically, we retain information for our legitimate interests and essential

business purposes, such as operating, maintaining and improving our services; complying with

our legal obligations; and exercising our legal rights and remedies, including enforcing our terms

of use. Our retention of information is based on many factors such as your relationship with 35 to

First; the nature of the information; compliance with our legal obligations; defending or resolving

actual or anticipated legal claims. We take reasonable measures to destroy or de-identify personal

information in a secure manner when it is no longer required.

10. Security

We use reasonable administrative, logical, physical and managerial measures to safeguard your

personal information against loss, theft and unauthorized access, use and modification. These

measures are designed to provide a level of security appropriate to the risks of processing your

personal information. Unfortunately, no measures can be guaranteed to provide 100% security.

Accordingly, we cannot guarantee the security of your personal information. Furthermore, you are

responsible for the security of your digital wallet, and we encourage you to take steps to ensure

it is and remains secure. If you discover an issue related to your wallet, please contact your wallet

provider.

11. Children

You must be at least 18 years of age or older to create a 35 to First account. Minors may only use

the service with the involvement, supervision, and approval of a parent or legal guardian.

12. Changes to This Privacy Policy

We will update this Privacy Policy from time to time in response to changing legal, regulatory or

operational requirements. We will provide notice of any such changes (including when they will

take effect) in accordance with applicable law. Your continued use of the Services after any such

updates take effect will constitute acknowledgement and (as applicable) acceptance of those

changes. If you do not wish to acknowledge or accept any updates to this Privacy Policy, you may

cancel your 35 to First account. To see when this Privacy Policy was last updated, please see the

"Last Updated" section below.

13. US State (including California Consumer Privacy Act (CCPA)) Privacy Notice

This Privacy Notice applies to consumers who reside in states that have adopted consumer

privacy laws and supplements the Privacy Policy, to the extent applicable. Because of differences

in certain state laws, this supplement is broken into two sections: (i) California (CCPA) Specific

Notices, applicable to California residents only, and (ii) a California (CCPA) and other State

Specific Sections that may apply to residents of one or more states with consumer privacy laws

requiring such information. Such states as of the date of this Privacy Notice are California,

Colorado, Connecticut, Utah, and Virginia (collectively “US State Privacy Laws”).

If you are a California consumer, please see our California Consumer Privacy Act (CCPA) Privacy

Notice by clicking here.

If you a resident of another state with a U.S. State Privacy Law, please see our State Specific

Disclosure Section by clicking here.

14. UK, EU & EMEA Resident’s Rights

If you are an EU or UK resident, you may have certain additional privacy rights. To exercise these

rights, or to contact our Data Protection officer in Europe, please submit a request by navigating

to the Individual Rights Request Portal in Europe. In some cases, you may also have the right to

present claims before the competent authority, by complying with local law procedures as

applicable.

Last Updated: 12/11/2025

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