Privacy Policy

This Privacy Policy ("Policy") describes how Bonkus Labs, LLC and its affiliates ("we", "us", or "our") may collect, process, use, store, and disclose personal information as data controller, and your rights and choices regarding this information when using the circus.trade website and interface (the "Interface"). For the purposes of this Policy, "personal information" is any information related to an identified or identifiable natural person.

Please read this Policy carefully. You can contact us with questions using the details in the "Contact Us" section below.

This Policy applies to personal information collected through the Interface. If you do not agree with the terms of this Policy, do not access or use the Interface, or any other aspect of our business.

When you interact with the Interface, we may collect certain categories of information about you, including personal information from a variety of sources.

Information you provide to us

Data may include: (i) any digital-asset, smart-contract, or protocol address ("Wallet") information; and (ii) geolocation data. You provide this data to us when you connect your Wallet to the Interface.

Other data may include transaction data or history (such as your public blockchain transaction history and other information associated with a linked address or Wallet and token holdings). Should you contact us, we will collect the content of the communications we have with you and any personal data contained within, including the email address you used to contact us.

Information we collect automatically

When you visit certain pages or screens on the Interface, our servers save each access in a log file. The following data may be collected: (i) the date and time of access; (ii) the country from which the website is accessed; (iii) the operating system of your computer and the browser you are using (provider, version, and language); and (iv) the transmission protocol used (e.g., HTTP).

Finally, we may use web beacons/clear gifs, geolocation and tracking technologies, and other applications when you visit the Interface, including technologies collecting certain information about your access to, use of, connection to, or interaction with the Interface ("Usage Data") that may be integrated with third-party service providers.

In our legitimate interests to provide effective services to you, we may also use this data to create aggregated, anonymized, or de-identified data.

Certain features of the Interface may require you to connect a compatible third-party digital Wallet. By using such Wallet, you agree that your access to, use of, connection to, and/or interactions with such third-party Wallets are governed by the policy for the applicable Wallet, and you agree that you are using the Wallet in accordance with the terms and conditions of the applicable third-party provider of such Wallet.

Wallets are not maintained or supported by, or associated or affiliated with, us. We expressly disclaim any and all liability for actions arising from your use of third-party Wallets, including but without limitation, actions relating to the use and/or disclosure of personal information by such third-party Wallets.

We generally process the information we collect when we need to do so to perform our contract with you. For example, the processing of this data is carried out for the purpose of enabling your access to, use of, connection to, and interaction with the Interface, including: (i) to facilitate your connection to the Interface; and (ii) to identify if you are likely to be a Restricted Person, as defined in our Interface Terms. Each case with respect to any of (i) or (ii) is in order for us to perform our contract with you and in our legitimate interests to provide access to the Interface to you.

With your consent, we may use any data collected, including Usage Data, to tailor features and content to you and to ensure content is presented in the most effective manner for you and your device. We may also use and run analytics to better understand your user experience with respect to the Interface.

We may also process this data in our legitimate interests to assist system security and stability for provision of the Interface, to conduct troubleshooting, data analytics, testing, and research, and to enable optimization and internal statistical analysis with respect to the Interface, as well as to maintain the safety and security of our users, the Interface, and to improve and develop the Interface.

In addition to the foregoing, we may use any of your information to comply with any applicable legal obligations, to enforce any applicable terms of use, and to protect or defend the Interface, our rights, and the rights of our users or others.

We use cookies to enhance your experience when accessing and using the Interface. The cookies we use are strictly necessary cookies, which help ensure compliance with our Interface Terms, and are otherwise integral to our ability to provide the best user experience and to help us understand general usage patterns. These cookies are not used for marketing purposes. By continuing to use the Interface, you consent to the placement of these cookies.

Managing Cookies

• Browser Settings: Most browsers allow you to remove or reject cookies. See your browser's help documentation or visit www.allaboutcookies.org for guidance.
• Mobile Settings: Your device settings may allow you to limit advertising ID use for interest-based advertising.
• Privacy Plugins: Tools such as PrivacyBadger, Ghostery, or uBlock Origin can block third-party trackers. (We do not endorse or control such plugins.)
• Industry Opt-Out Tools: Digital Advertising Alliance, Network Advertising Initiative, Google Ad Settings.

Note that disabling certain cookies may impact the functionality of the Interface.

Under applicable data protection laws, you may have certain rights in relation to your personal information. These rights may include the following:

• Access to your personal information that we hold, including, how we use it, and who we share it with;
• Request the correction of inaccurate or incomplete personal information we hold about you, which we may verify as necessary before making changes;
• Deletion or removal of your personal information, in certain circumstances;
• Objection to the processing of your personal information, in certain circumstances;
• Restriction of the processing of your personal information, to stop us from processing the personal information we hold about you other than for storage purposes, in certain circumstances;
• Portability of your personal information; we will endeavor to provide you, or a third party, with a copy of the personal information that we hold about you and transfer it to a third party in a structured, commonly used, machine-readable format;
• Withdrawal of consent, where we rely on consent to process personal information; this will not affect the processing.

You may submit a written request concerning the processing of your personal data via the Interface or other designated support channels. Please note that, prior to any response to such request, we will require you to verify your identity. In addition, we may have valid legal reasons to refuse your request and will inform you if that is the case.

Note that these rights apply only in certain circumstances and all of these rights may be limited by law. Such limitations may apply, for example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interests, or where we are required by law to retain your personal data.

To the extent required under applicable data protection laws, we will be responsive to your request without undue delay and where required under applicable data protection laws, at least within one month (though this may be extended by a further two months in certain circumstances).

In certain circumstances, we may share your information with third parties with your consent, as necessary, or as otherwise required or permitted by law, including, but not limited to:

• service providers and vendors: we may share your personal data with third parties to process on our behalf. Such third parties could include blockchain analysis service providers, screening service providers, developers, content delivery service providers, and data analytics service providers. Such service providers may assist us with many different functions and tasks, including geo-blocking based on IP address (using IP data) and collecting anonymized device information for analytics purposes.
• professional advisors, in our legitimate interests or as required by law.
• for legal and security reasons and to protect our Interface, in our legitimate interests or as required by law.

Your personal information may be transferred to and stored or processed in countries outside the jurisdiction in which you live and reside, including to the United States of America, in order to protect the Interface. We will take steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy.

We will retain your personal information only for so long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting or reporting requirements, or as otherwise required by law. The length of time we retain your data will depend on the nature of the data and the purpose for which it was processed.

Be aware that despite our efforts to protect your personal data and other information, we cannot guarantee perfect security of your information transmitted through the Interface. In addition, note that any information you send to us electronically, may not be secure while in transit. Any transmission is at your own risk.

When you access, use, connect to, or interact with the Interface, we and any of our third-party service providers may receive and record personal information that you may have provided and your digital signature.

The Interface may contain links to third-party websites, applications, or online assets not owned or controlled by us. This Policy does not apply to those third-party properties. We encourage you to review the privacy policies of any third-party Interface you access. We assume no responsibility for their content, policies, or practices.

Individuals located in the European Union ("EU") and the United Kingdom ("UK") may have rights under the EU General Data Protection Regulation 2016/679 and the UK General Data Protection Regulation, respectively (collectively, the "GDPR"). Note that you can file a claim with the data protection supervisory authority in the EEA country in which you live or work or where you think we have infringed data protection laws, or with the UK Information Commissioner's Office, as applicable to you. Other applicable global privacy and data-protection laws may provide you rights with respect to your personal data and other information.

We may review and update this Policy from time to time. Updates to this Policy will apply only to information collected after the date of the change. If we make material changes, we will update the "Last updated" date at the top of this Policy.

Should you have any questions or complaints about our privacy or data-protection practices, your personal data, or this Policy, you may contact us via the Interface or other designated channels.