1. Information We Collect a. Information You Provide Account details (name, email address, password) Profile information (if applicable) Preferences for notifications and alerts b. Information Collected Automatically IP address, browser type, device type, operating system Log data (pages visited, features used, timestamps) Cookies and similar tracking technologies for performance and analytics c. Blockchain & Wallet Data Public wallet addresses you connect or import (via Zapper API or other integrations) Transaction data from blockchain explorers or third-party APIs (e.g., CoinGecko, Zapper) Note: We do not request or store your private keys. 2. How We Use Your Information We process your data for the following purposes: To provide and improve our services (portfolio tracking, analytics, alerts) To send transactional communications (account updates, security notices) To send marketing communications if you have given explicit consent To comply with legal and regulatory obligations To prevent, detect, and investigate fraud or misuse 3. Legal Basis for Processing (GDPR) Performance of a contract — delivering requested services Consent — marketing communications, optional features Legitimate interests — security, analytics, and platform improvement Legal obligation — compliance with applicable laws 4. Data Sharing We do not sell your personal data. We may share data with: Service providers (hosting, analytics, email delivery) Third-party API providers (CoinGecko, Zapper) to retrieve market and transaction data Legal authorities when required by law or to protect our rights 5. International Data Transfers Data may be processed in countries outside your jurisdiction. We ensure appropriate safeguards (e.g., EU Standard Contractual Clauses) for cross-border data transfers. 6. Data Retention We retain personal data only as long as necessary to provide services, fulfill legal obligations, or resolve disputes. You can request deletion of your account data at any time. 7. Your Rights (GDPR & CCPA) Depending on your location, you may have rights to: Access, correct, or delete your data Withdraw consent for marketing Receive a copy of your data (data portability) Object to processing based on legitimate interests To exercise these rights, contact info@blockturtle.com. 8. Cookies We use cookies to: Maintain session security Improve user experience Analyze usage patterns You can manage cookie settings via your browser. 9. Security We implement appropriate technical and organizational measures to protect your data. However, no online system is completely secure, and we cannot guarantee absolute security. 10. Changes to This Policy We may update this Privacy Policy from time to time. Continued use of our services after updates means you accept the changes. 11. Contact For privacy inquiries: info@blockturtle.com BlockTurtle Email Consent Policy Last Updated: August 2, 2025 This Email Consent Policy explains how BlockTurtle handles your email preferences and consent. 1. What You Consent To By opting in to our email communications, you agree that BlockTurtle may send: Newsletters — platform updates, feature announcements Educational content — guides, crypto insights Promotional offers — discounts, special access to premium features 2. Transactional vs. Marketing Emails Transactional emails — sent as part of service delivery (e.g., account verification, security alerts, requested alerts). These do not require separate consent. Marketing emails — require your explicit opt-in consent. You will not receive these unless you check the relevant consent box during signup or in your account settings. 3. How We Obtain Consent Consent is collected via an unticked checkbox during signup or subscription We use a timestamped record of your consent to comply with GDPR/CAN-SPAM requirements We may use a double opt-in process for added verification 4. Unsubscribing You can unsubscribe from marketing emails at any time by clicking the "unsubscribe" link in the footer Transactional emails cannot be unsubscribed from as they are essential to service use 5. Data Use Your email address will be used solely for the purposes stated when you provided consent. It will not be sold or shared with unaffiliated third parties for marketing purposes. 6. Compliance We comply with: GDPR — consent must be informed, specific, and freely given CAN-SPAM Act — all marketing emails include our business contact information and an easy unsubscribe method 7. Contact Email preferences or consent questions: info@blockturtle.com