PRIVACY POLICY

Privacy at a Glance

• What we collect. Identity and verification data, transaction and blockchain activity data, device and usage data, and communications with us. See Personal information we collect for the full list.
• How we use it. To operate the Service, verify your identity, comply with financial crime and sanctions obligations, and, with your permission, send you marketing materials.
• Who we share it with. Our affiliated entities, regulated service providers (including identity verification, card program, and payment partners), professional advisers, and authorities where required by law. We may share your identity verification (KYC) information with regulated partners that provide services through Plasma One so they can meet their own legal obligations without asking you to verify again. We do not sell your data to data brokers or advertisers.
• Your rights. You can access, correct, delete, or export your data, and object to certain uses. European and UK users have additional rights under GDPR and UK GDPR. Contact support@plasma.org to exercise any right.
• Our promise. We will never sell your personal data.

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

• Contact data, such as your first and last name, salutation, email address, mailing address, and phone number.
• Demographic data, such as your city, state, country of residence, postal code, and age.
• Profile data, such as the username and password that you may set to establish an online account on the Service, avatar, date of birth, redemption code, biographical details, profile photograph or picture, interests, preferences, and any other information that you add to your account profile.
• Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Transactional data, such as information relating to or needed to complete your transactions on or through the Service, including transaction numbers and transaction history.
• Blockchain activity data, such as information relating to or needed to complete your cryptocurrency transactions on or through the Service (including wallet address, transaction number, transaction sender and recipient, transaction amount, and transaction history), as well as information relating to other on-chain activity associated with your account or wallet, such as applications you have interacted with on the blockchain. Note that blockchain wallet addresses, while pseudonymous, may be combined with other data to identify you. Transactions recorded on public blockchains are permanent and accessible to anyone.
• Financial data, such as your digital currency or wallet account balance and other associated information.
• Payment card data, including masked card number (last four digits) and expiry date associated with your Plasma virtual card. Solely for the purpose of displaying virtual card details within the Plasma One app, we temporarily receive your full primary account number (PAN) from our card-program partner. We do not store your full PAN.
• Government-issued identification number data, such as national identification number (e.g., Social Security Number, tax identification number, passport number), state or local identification number (e.g., driver’s license or state ID number), and an image of the relevant identification card.
• Identity verification and anti-money laundering (AML) data, which we collect when you proceed with identity verification or any anti-money laundering or know-your-customer (KYC) requirement, including your full name, country of residency, email address, government-issued identification, date of birth, and a photograph or image of you.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Biometric Data. In connection with verifying your identity, we utilize a service provider that collects and uses biometric information, including facial data, from your driver’s license and / or passport photo to match against your live image. No other use of your facial data. Plasma does not directly store or share this biometric data with any third party. Instead, this biometric information is held by the service provider pursuant to its privacy policy, which can be found here: https://sumsub.com/privacy-notice-service/.

Sumsub stores face data on its secure infrastructure in accordance with its privacy notice. Sumsub retains face data for the period necessary to fulfill its identity verification obligations and comply with applicable legal requirements. Specifically:

• For residents of Illinois, face data is retained for a maximum of three (3) years from the date of collection.
• For residents of Texas, face data is retained until the purpose for collection has been satisfied or up to one (1) year after the purpose expires, whichever occurs first.
• For all other users, face data is retained for the duration required by applicable anti-money laundering regulations (typically up to five years after the end of the business relationship), after which it is deleted.

If you apply for the AED Services in the United Arab Emirates, facial verification for that application is performed through UAE PASS rather than through this service provider. For more information, see the "Notice to UAE users" section below.

Third-party sources. We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

• Public sources, such as government agencies, public records, public blockchains, and other publicly available sources.
• Private sources, such as data providers, social media platforms and data licensors.
• Marketing partners, such as joint marketing partners and event co-sponsors.
• Service providers that provide services on our behalf or help us operate the Service or our business.
• Business transaction partners. We may receive personal information in connection with an actual or prospective business transaction in which Plasma is the acquirer or successor — for example, from an entity we acquire, or a party involved in a transaction such as a merger, acquisition, sale of assets, or similar transaction, including in the context of an insolvency, bankruptcy, or receivership.
• Third-party linked services, such as third-party cryptocurrency platforms or wallets, that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer 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, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, content you viewed or otherwise engaged with, how long you spent on a page or screen, the website you visited before browsing to the Service, 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 emails or clicked links within them.
• Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

For more information concerning our automatic collection of data, please see the Tracking & other technologies section below and our Cookie Policy.

Tracking & other technologies

Cookies and other technologies. Some of the automatic collection described above is facilitated by cookies and other similar technologies. For more information, see our Cookie Policy. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.

Mobile applications. In the Plasma One mobile applications, we and our service providers use software development kits, device identifiers and similar technologies to operate and secure the applications, remember your preferences, measure usage and detect fraud. You can manage app tracking permissions through your device settings.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

• provide the Service and operate our business;
• enable security features of the Service;
• establish and maintain your user profile on the Service;
• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages; and
• provide support for the Service, and respond to your requests, questions and feedback.

Service personalization, which may include using your personal information to:

• understand your needs and interests;
• personalize your experience with the Service and our Service-related communications; and
• remember your selections and preferences as you navigate webpages.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services. For example, we may use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.

Marketing. We and our service providers may collect and use your personal information for marketing purposes. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of communications section below.

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
• protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and
• verify your identity and conduct anti-money laundering (AML), counter-terrorist financing, sanctions, and know-your-customer (KYC) checks in order to comply with our legal and regulatory obligations, including by contacting you to request additional information, KYC status, or documentation needed to complete those checks, and share the results of those checks with regulated partners that provide services through Plasma One so that they can satisfy their own obligations without repeating them.
• Plasma uses LLM-assisted tooling as part of its compliance review and risk operations. Certain personal information you provide may be processed by an LLM as part of that review. The review is human-in-the-loop: final compliance decisions are made or confirmed by a human reviewer. Plasma does not train any model on user content. This processing supports compliance, fraud prevention, sanctions screening, and risk-management functions, and is not used for service personalization or marketing.

Data sharing in the context of corporate events. We may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information below.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Further uses. In some cases, we may use your personal information for further uses, in which case we will ask for your consent to use of your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

Retention

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In particular, and without limitation: (a) we retain identity verification, KYC, and AML data (including government-issued identification numbers and images of identification documents) for the duration of our relationship with you and for five (5) years after that relationship ends, or for such longer period as required by applicable law (up to ten (10) years in certain jurisdictions); (b) we retain transactional data, blockchain activity data, and financial data for five (5) years following the relevant transaction or the end of our relationship with you, in order to comply with anti-money laundering, counter-terrorist financing, tax, and accounting obligations; (c) we retain marketing data until you opt out of receiving marketing communications or following 24 months of inactivity, whichever occurs first; and (d) we retain communications data for up to 3 years from the date of the relevant communication, unless a longer period is necessary to establish or defend legal claims.

When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

How we share your personal information

We may share your personal information with the following parties (or as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection).

Corporate affiliates. Our corporate subsidiaries and affiliates.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research, AI and LLM service providers supporting compliance and risk operations, and website analytics). We require service providers that process personal information on our behalf to be bound by written terms that obligate them to handle personal information only as instructed by us and consistent with applicable law.

Regulated service partners. Third parties that provide regulated services through or alongside Plasma One, such as bank transfers and virtual accounts, fiat on- and off-ramps, card issuance and program management, stablecoin conversion and yield products. When you use one of those services we share with the partner the information it needs to provide the service and to meet its own legal obligations, including your identity verification (KYC) and anti-money laundering data, verification results and supporting documents, so that the partner can rely on our checks rather than asking you to verify again. Each partner processes that information under its own privacy policy, which is presented to you when you first use its service.

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so. For example, entities conducting know-your-customer, identity verification or other anti-money laundering checks.

Partners. Third parties with whom we partner, including parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.

Third-party linked services. If you log into the Service with, or otherwise link your Service account to, an external cryptocurrency platform, wallet, or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in or financings of Plasma, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Plasma as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Other users and the public. Due to the nature of blockchain technologies, any data posted to or otherwise interacting with the Plasma blockchain or other public blockchains will be visible to other users of the Service and the public. Information about your interactions and/or transactions will be provided to the applicable blockchain network and may be accessible to third parties due to the blockchain protocol’s nature. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information. It may be possible for someone to identify you through your pseudonymous, public wallet address using external information sources, and any transaction you enter or otherwise interact with the Plasma blockchain could possibly be used to identify you or information about you.

Your choices

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Cookies and other technologies. For more information about cookies and similar technologies employed by the Service and how to manage your preferences, see our Cookie Policy.

Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Third-party linked services. If you choose to connect to or otherwise link with the Service through your account on a third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

For California residents. California residents may send us requests to legal@plasma.org for information regarding third parties to whom we have disclosed certain personal information (as defined under California’s “Shine the Light” law, Cal. Civ. Code Section 1798.83) during the preceding calendar year for those third parties’ own direct marketing purposes and the categories of personal information disclosed. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

Delete your content or close your account. You may be able to delete certain content through your account. If you wish to request to close your account, please contact us via appropriate support channels in Plasma One. Please note that due to the nature of blockchain technologies, neither you nor Plasma may be able to delete transactions or other data that are already on the blockchain. In addition, if you close your account, we are required by law to retain certain personal information (including identity verification, AML, and transaction records) for a period of time after closure, as described in the Retention section above and, for European users, the ‘Retention’ section of the Notice to European Users below.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

For example, when assets are transferred to a non-custodial wallet or a third-party decentralized protocol, Plasma has no control over and is not responsible for the processing of any data associated with those transactions by that protocol or by other participants on the blockchain.

Security

We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the Cayman Islands and operate through affiliates in the United Kingdom, the United States, and the United Arab Emirates. We also may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

For transfers of personal information out of the European Economic Area or the United Kingdom to recipients in third countries, Plasma relies on appropriate safeguards, including (as applicable) the European Commission’s Standard Contractual Clauses and the United Kingdom International Data Transfer Addendum issued by the Information Commissioner under section 119A of the UK Data Protection Act 2018. These mechanisms are implemented through the Plasma Intra-Group Data Processing and Transfer Agreement and through written contracts with our external service providers. You may request a copy of the relevant safeguards by contacting us.

Users in Europe should also read the information provided about transfers of personal information to recipients outside Europe contained in the ‘Notice to European users’ below.

Users in the United Arab Emirates who use the AED Services should read the ‘Notice to UAE users’ below, which explains that AED account data held for Ruya stays in the UAE and how other transfers out of the UAE are made under the UAE Personal Data Protection Law.

Children

The Service is not intended for use by anyone under the age of eighteen (18) or, where higher under the laws of your jurisdiction, the local age of majority. Identity verification (KYC) conducted by SumSub will verify your age and may decline applications that do not satisfy this requirement. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy constitutes your acknowledgment that the modified Privacy Policy applies to your interactions with the Service and our business. Depending on the kind of change we make to this Privacy Policy, we might notify you of the change or request your consent to it.

How to contact us

If you have questions about our practices or if you would like to exercise any privacy-related right that may be available to you depending upon applicable law, please contact us.

• Email: support@plasma.org
• In-App support is available in Plasma One

Notice to European users

General

Where this Notice to European users applies. The information provided in this ‘Notice to European users’ section applies only to individuals located in the European Economic Area (EEA) or United Kingdom (UK) (i.e., “Europe” as defined at the top of this Privacy Policy).

Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” as defined in the “GDPR” (i.e., the General Data Protection Regulation 2016/679 (“EU GDPR”)) and the EU GDPR as it forms part of the laws of the United Kingdom (“UK GDPR”). Under the GDPR, “personal data” means information about individuals from which they are either directly identified or can be identified. The personal information that we collect from and about you is described in greater detail in the section “Personal information we collect” that is set out above.

Controllers. Plasma and Plasma Labs UK Ltd. are joint controllers of your personal information within the meaning of Article 26 GDPR and Article 26 UK GDPR. This means both entities jointly determine the purposes and means of processing your personal data in connection with the Service, irrespective of where you are located. Plasma Labs UK Ltd. is the contact point for data subjects and handles requests to exercise your rights. Plasma is responsible for providing the information in this Privacy Policy, for security of processing, and for notifying personal data breaches. Each controller is responsible for the lawfulness of the processing it carries out. You may exercise your rights against either controller.

EU representative. For users located in the European Economic Area, Plasma’s representative under Article 27 GDPR is Data Protection Representative Limited (trading as DataRep), incorporated in Ireland with company registration number 616588, whose registered office is at The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland (email: digitalrequest@datarep.com; telephone: +353 (1) 919 8899). You may contact DataRep in connection with the processing of your personal information by Plasma; however, you may also continue to use the contact details set out in ‘How to contact us’ for the most direct response.

UK representative. Plasma Labs UK Ltd. is established in the United Kingdom and acts as joint controller (together with Plasma) within the meaning of Article 26 UK GDPR (see "Controllers" above). Because Plasma Labs UK Ltd. is itself established in the United Kingdom, the requirement to appoint a separate UK representative under Article 27 UK GDPR does not apply to Plasma's processing activities covered by this Privacy Policy. Plasma Labs UK Ltd. is the designated contact point for data subjects under the joint controllers' Article 26(2) arrangement and may be reached at legal@plasma.org or via the contact details in the "How to contact us" section above.

Supervisory authority. Because no member of the Plasma Group is established in the EEA, the “one-stop-shop” mechanism under Article 56 GDPR does not apply. You may lodge a complaint with the competent supervisory authority in your country of habitual residence or place of work.

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

• Where we need to process your personal information in order to deliver the Service to you, or where you have asked us to take specific action which requires us to process your personal information (“Contractual Necessity”).
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
• Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
• Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see the ‘How we use your personal information’ section above and the description of associated data sharing relevant to such purposes set out in the ‘How we share your personal information’ section also above.

Retention

We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or otherwise for the ‘Compliance and protection’ purposes outlined above.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In particular, the following retention periods apply: (a) identity verification, KYC, and AML data (including government-issued identification numbers and images of identification documents) is retained for the duration of our relationship with you and for five (5) years after that relationship ends, as required by applicable anti-money laundering and counter-terrorist financing laws (including the UK Money Laundering Regulations 2017 and EU anti-money laundering legislation), or for such longer period as applicable law requires (up to ten (10) years in certain jurisdictions); (b) transactional data, blockchain activity data, and financial data is retained for five (5) years following the relevant transaction or the end of our relationship with you, in order to comply with anti-money laundering, counter-terrorist financing, tax, and accounting obligations; (c) marketing data is retained until you opt out of receiving marketing communications or following 24 months of inactivity, whichever occurs first; and (d) communications data is retained for up to 3 years from the date of the relevant communication, unless a longer period is necessary to establish or defend legal claims. Where we retain personal information solely to comply with a legal retention obligation, we restrict the processing of that information to compliance purposes only.

When we no longer require the personal information that we have collected about you, we will either delete or anonymize it 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. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Other information

No obligation to provide personal information. You do not have to provide personal information to us. However, where we need to process your personal information either to comply with applicable law or to deliver our Service to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our Service to you. We will notify you if this is the case at the time.

No sensitive information. We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership, or biometric or genetic characteristics other than as requested by us as part of the Service) on or through the Service, or otherwise to us. If you provide us with any such sensitive personal information when you use the Service, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Service.

Automated processing. We use automated processing, including SumSub's identity verification platform and internal compliance tooling, to assess KYC and AML obligations as required by applicable financial crime law.

Where automated processing produces a decision that restricts or closes your account, you have the right to request human review, express your point of view, and contest the outcome. Contact us to exercise this right.

Your additional rights

Because the Plasma blockchain and third-party blockchains on which the Services may operate are decentralized public ledgers, transaction data recorded on those ledgers cannot be deleted or modified by Plasma. Accordingly, your right of erasure does not extend to on-chain transaction data, and your right of rectification does not allow Plasma to alter on-chain transaction data. Plasma will honor your erasure request in respect of off-chain personal information subject to these technological limits and to Plasma's legal obligations to retain certain information (including AML/CFT record-keeping).

General. European data protection laws may give you certain rights regarding your personal information in certain circumstances. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

• Access. Provide you with information about our processing of your personal information and give you access to your personal information.
• Correct. Update or correct inaccuracies in your personal information.
• Delete. Delete your personal information where there is no good reason for us continuing to process it - you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Transfer. Transfer to you or a third party of your choice a machine-readable copy of your personal information which you have provided to us.
• Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
• Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.
• Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.

Exercising These Rights. You may submit these requests by contacting us. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month of receipt. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.

Your Right to Lodge a Complaint with your Supervisory Authority. Although we urge you to contact us first to find a solution for any concern you may have, in addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

• For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en
• For users in the UK – the contact information for the UK data protection regulator can be found here: https://ico.org.uk/make-a-complaint/
• For users in the United Arab Emirates – complaints may be made to the UAE Data Office, the federal data protection authority established under Federal Decree-Law No. 44 of 2021. Contact details for the UAE Data Office are published on the UAE Government portal at https://u.ae.

Data Processing outside Europe

We are incorporated in the Cayman Islands with affiliated entities and service providers in the U.S., the U.K., and other jurisdictions. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:

• Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time) or under specific adequacy frameworks approved by the European Commission or UK Government (as and where applicable) (from time to time).
• Transfers to territories without an adequacy decision.
• We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S.).
• However, in these cases:
• we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.

Notice to UAE users

General

Where this Notice to UAE users applies. This section applies when you apply for, activate or use the AED Services in Plasma One: an AED account with Ruya Community Islamic Bank LLC (“Ruya”) and/or AED-stablecoin conversion through Morpheus Software Technology FZE (“Morpheus”), as described in the Plasma One UAE/AED Services Addendum to our Terms of Service (the “Addendum”). The rest of this Privacy Policy continues to apply to your Plasma One account, app, wallet, security, support and compliance data. If this section describes AED Services processing differently from the rest of this Privacy Policy, this section controls that processing. Terms such as personal data, process, controller and processor have the meanings given in the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) (the “PDPL”). References to the PDPL apply to the extent that it governs the relevant processing. Ruya’s processing of banking and account information is subject to the legal requirements applicable to Ruya, as explained in its privacy notice. Capitalized terms not defined here have the meanings given in the Addendum.

This is Plasma’s notice. It is not Ruya’s or Morpheus’s privacy notice. Each partner’s own notice governs that partner’s processing, and you should read it before accepting that partner’s documents.

Who is involved and in what role

A party’s role depends on the purpose for which it processes personal data. The table below explains each party’s role when handling your personal data for the AED Services:

These terms describe the purposes for which each party processes information. The same information may be processed by more than one party for different purposes; sharing it does not remove the restrictions applicable to the recipient’s use of it.

Personal information processed for the AED Services

In addition to the categories described under “Personal information we collect” above, the AED Services involve:

• Emirates ID and residency data (Ruya Customer Data), such as Emirates ID number and expiry, passport and residence visa information, nationality, residency, tax identifiers, signature, the document images and attributes retrieved through UAE PASS, and the result of UAE PASS facial verification.
• AED banking data (Ruya Customer Data), such as your Ruya customer number, AED Account details and IBAN, account status, balance, transaction history, beneficiaries, holds, restrictions, service messages, statements, complaints and fraud or dispute information.
• Conversion data (Morpheus Data, with copies held as Plasma Data for your records), such as your Morpheus user identifier, rate and order information, fees, VAT, network costs, client-money transfer information, status, settlement and return data.

UAE PASS. UAE PASS, the UAE national digital identity operated by the Federal Authority for Identity, Citizenship, Customs and Port Security and the Telecommunications and Digital Government Regulatory Authority, supplies verified identity attributes and attested documents with your approval and performs facial verification of you within the UAE PASS app. When you approve a UAE PASS request, your documents and attributes are retrieved and transmitted to Ruya; Plasma checks that they are complete and intact, transmits them and the verification result, and does not keep them or receive a biometric template. UAE PASS’s own privacy terms apply to its processing. Ruya decides whether to approve your AED Account application.

Sharing for the AED Services

Between Plasma and Ruya. Plasma collects and transmits to Ruya the identity, contact, UAE PASS, verification, tax, employment, financial, account-purpose, expected-activity, source-of-funds and supporting-document data that Ruya needs to assess and service your AED Account. Ruya shares with Plasma your account identifiers, IBAN, application and account status, balance, transaction information, restrictions, service notices and fraud or dispute data so that the app can display your AED Account and support you. That sharing continues while you use the AED Services, to the extent necessary, for support, transaction monitoring and compliance checks, dispute resolution and fraud investigations, and regulatory requests and audits. Plasma uses Ruya Customer Data only to provide and support the AED Services on Ruya’s behalf and in accordance with Ruya’s documented instructions, and shares it with its service providers only as authorised by Ruya.

With Morpheus. After you have accepted the relevant Morpheus documents and provided the required data-sharing consent, Ruya creates your Morpheus profile using the identity and KYC information it has verified, under a reliance arrangement between Ruya and Morpheus. Plasma shares with Morpheus your wallet address and ownership evidence, your Ruya customer identifier and IBAN as payout details, and the data necessary to process or resolve the relevant conversion, transfer, return, complaint or investigation. Where this includes Ruya Customer Data, Plasma shares it on Ruya’s documented instructions. Morpheus shares with Plasma and Ruya your Morpheus user identifier, onboarding and compliance status, order and transfer status, rate and fee data, settlement confirmations, transaction hashes, return information and complaint data to the extent each recipient needs that information for its role in providing and supporting the AED Services or meeting applicable legal obligations. No information is sent to Morpheus until you have accepted the Morpheus documents and given the Morpheus consent.

Authorities. In addition to the authorities described under “How we share your personal information” above, data may be disclosed to the Central Bank of the UAE and VARA where required or permitted by law.

Where data is processed and international transfers

Ruya Customer Data stays in the UAE. Ruya Customer Data is processed within the UAE by Ruya and Plasma MENA FZE. Plasma will not transfer it, or make it accessible, outside the UAE except on Ruya’s documented instructions, with Ruya’s prior written authorisation and subject to applicable legal requirements.

Plasma Data. Plasma Data is processed in the locations described under “International data transfer” above. This paragraph applies to information processed by Plasma for its own purposes as a controller, rather than on Ruya’s behalf. Where the PDPL applies, any international transfer must satisfy its applicable requirements. Depending on the transfer, this may involve contractual safeguards meeting those requirements or another permitted basis, such as necessity for the performance of your contract or your express consent, subject to the conditions applicable to that basis. Where a transfer relies on your consent, we will provide information about the destination, recipient, purpose and relevant risks before asking for your consent. You may refuse or withdraw that consent, but a feature that depends on the transfer may then be unavailable if no other lawful transfer basis applies.

Retention, security and your rights

Retention. Application and KYC information transmitted to Ruya is securely deleted by Plasma after transmission, except to the extent retained on Ruya’s documented instructions for specified purposes and periods, or as required by applicable law. Plasma’s general retention periods described above do not apply to information held solely on Ruya’s behalf. Other Ruya Customer Data held by Plasma is returned to Ruya or securely deleted in accordance with Ruya’s documented instructions when the AED Services end for you or when Ruya requests it, except where the law requires Plasma to keep it. Any information retained is protected and used only for the purpose justifying its continued retention. Plasma retains Plasma Data for the periods described under “Retention” above. Ruya and Morpheus apply their own retention periods as described in their respective privacy notices.

Security incidents. If a security incident affects your personal data, you will be notified as required by applicable law, including information about the measures taken to address the incident. For incidents involving Ruya Customer Data, Ruya is responsible for notifying you, with Plasma providing assistance where needed.

Your rights. Depending on the law applicable to the processing, you may have rights to access, correct, erase or transfer your personal data, restrict or stop its processing, withdraw consent, and request human review of automated decisions. Where the PDPL applies, you may also obtain information about our processing without charge and object to processing for direct marketing, including related profiling. These rights are subject to applicable conditions and exceptions.

You may also complain to the authority competent to handle your complaint under the applicable law. For Ruya Customer Data, contact Ruya, as controller, using the contacts in Ruya’s privacy policy. For Plasma Data, contact us as described under “How to contact us” above. For Morpheus’s data, contact Morpheus using the contacts in its privacy notice. If you contact Plasma about processing for which Ruya or Morpheus is responsible, we will help direct your request to the appropriate party. We may request information reasonably necessary to verify your identity before responding to a request. A right may be limited where processing or retention is required by banking, AML/CFT, sanctions, tax or other applicable law.

Partner consents and withdrawing them

Before the relevant processing begins, you will be asked to provide the consents required for the service you select. These include a Ruya–Plasma data-sharing consent for the AED account service and a separate Morpheus consent before your information is disclosed to Morpheus for conversion onboarding or services. Where applicable, we will separately request your consent to an international transfer and offer an optional marketing choice. Each consent request is presented separately and is not selected by default. We keep a record of your consent. You may decline consent, but we will explain if this means that a particular service cannot be provided. Accepting this Privacy Policy does not by itself give any of those consents.

Withdrawing the Ruya and Plasma consent. You may withdraw your Ruya–Plasma data-sharing consent at any time using the procedure described in Ruya’s privacy notice. Following withdrawal, sharing that relies on that consent will cease. This may prevent you from accessing or using your AED Account through Plasma One. Withdrawal does not affect the lawfulness of processing carried out before withdrawal or processing that may lawfully continue without consent. Ruya’s account terms govern the effect on your underlying AED Account.

Withdrawing the Morpheus consent. You may withdraw your Morpheus data-sharing consent at any time through the app or using the procedure described in the Morpheus privacy notice. Plasma and Ruya will stop further disclosures to Morpheus that rely on that consent. You will no longer be able to initiate new conversions through Plasma One. Withdrawal does not automatically cancel a conversion already in progress; any such conversion will be handled in accordance with the applicable terms and law.

Other consents. If you withdraw consent on which an international transfer relies, and no other lawful basis for that transfer applies, the affected feature may become unavailable. Withdrawing optional marketing consent does not affect account access or service messages. You can withdraw these consents by contacting us using the details under “How to contact us” above.