Privacy Policy

Overview

As a matter of policy, Akemona, Inc. does not disclose consumer or customer non-public information to unrelated third parties except in controlled circumstances permitted by applicable law, including, where applicable, Regulation S-P.

Akemona, Inc. and its affiliates (collectively, “Akemona,” “we,” “us,” or “our”) operate internationally, including through the akemona.com website and the Akemona mobile application (collectively, the “Service”). Akemona is committed to collecting and using information about visitors to our websites in accordance with applicable privacy and data protection laws.

Akemona provides technology services through the Service. This Privacy Policy applies solely to information collected through the Service.

This Privacy Policy is intended to:

• describe how Akemona collects and processes Personal Data through the Service and other data you may provide through the Service; and
• outline Akemona’s privacy and transparency practices under applicable law, including, where applicable, Regulation S-P, the California Consumer Privacy Act (“CCPA”), and the General Data Protection Regulation (“GDPR”).

We respect your privacy and understand the importance of how information you provide is used, stored, and shared. Accordingly, the use of Personal Data collected through our Service is limited to the purposes stated in this Privacy Policy.

This Privacy Policy explains:

• what personally identifiable information is collected from you through the Service, how it is used, and with whom it may be shared;
• your access to and control over your personally identifiable information, including how you may correct inaccuracies;
• your right, where applicable, to opt out of certain uses or sharing of your personal information and the circumstances in which we share information to provide the Service, execute transactions you request, comply with law, and operate our business;
• circumstances in which we may be unable to honor a deletion request due to legal, regulatory, security, fraud-prevention, and recordkeeping requirements;
• the security procedures in place to protect your information; and
• our use of cookies and similar technologies.

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service, as well as the choices you have associated with that data. We do not sell your personal information. We may share your personal information with third parties, such as cloud service providers, identity verification vendors, payment processors, banks, escrow companies, analytics providers, and regulatory or law enforcement authorities where required, to execute business operations, comply with law, and support other purposes consistent with this Privacy Policy.

By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy. Unless otherwise defined in this Privacy Policy, capitalized terms have the meanings set forth below.

Definitions

Service

The “Service” means the https://akemona.com website and the Akemona mobile application operated by Akemona, Inc.

Personal Data

“Personal Data” means data about a living individual who can be identified from that data, either alone or together with other information in our possession or likely to come into our possession.

Usage Data

“Usage Data” means data collected automatically, whether generated by use of the Service or from the Service infrastructure itself, such as the duration of a page visit.

Cookies

“Cookies” are small files stored on your device, whether a computer or mobile device.

Data Controller

For purposes of this Privacy Policy and applicable data protection law, Akemona is the data controller of your Personal Data. You may contact us at privacypolicy@akemona.com.

Data Processors or Service Providers

These are persons or entities that process data on behalf of the Data Controller. We may use various Service Providers to process your data more effectively.

Data Subject or User

A “Data Subject” or “User” is any living individual who uses our Service and is the subject of Personal Data.

Information Collection and Use

We collect different types of information for various purposes to provide and improve our Service. We collect personally identifiable information when you use the Akemona website, sign up, engage with features of the Service, or send us an inquiry. Akemona may share this personal information with its business partners and third parties for purposes consistent with this Privacy Policy.

Personal Data Collected

While using our Service, we may ask you to provide certain personally identifiable information that can be used to contact or identify you. Such information may include:

• first and last name;
• date of birth;
• Social Security number;
• phone number;
• address, state, province, ZIP or postal code, and city;
• cookies and Usage Data;
• email address;
• public address of your digital wallet;
• IP address; and
• marketing communication preferences.

In compliance with the Akemona Public Communications Policy, we may use your Personal Data to contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you. You may opt out of receiving any or all such communications by following the unsubscribe link or other instructions provided in the applicable email.

Tracking and Cookies Data

We use cookies and similar tracking technologies to track activity on our Service and store certain information.

A cookie is a piece of data stored on a site visitor’s device to help us improve access to our site. Cookies may also identify repeat visitors. For example, when we use a cookie to identify you, you may not need to re-enter a password more than once, which saves time while using our site.

Cookies can also help us track and understand user interests to enhance the experience on our site. The use of cookies is not inherently linked to personally identifiable information on our site, though cookies may include an anonymous unique identifier. We may also use other tracking technologies, such as beacons, tags, and embedded scripts, to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use portions of our Service.

Examples of cookies we use include Session Cookies, Preference Cookies, and Security Cookies.

Usage Data

We may also collect information that your browser sends whenever you visit our Service or access the Service through a mobile device. This Usage Data may include your IP address, browser type and version, pages visited, the time and date of your visit, time spent on pages, unique device identifiers, and other diagnostic data. When accessed through a mobile device, this may also include device type, unique device ID, mobile operating system, mobile browser type, and other diagnostic data.

Location Data

We may use and store information about your location if you give us permission to do so. We use this information to provide features of our Service and to improve and customize our Service. You may enable or disable location services at any time through your device settings.

Use of Data

Akemona, Inc. uses collected data for various purposes, including to:

• provide and maintain the Service;
• notify you about changes to the Service;
• allow you to participate in interactive features when you choose to do so;
• provide customer support;
• gather analysis and improve the Service;
• monitor usage of the Service;
• detect, prevent, and address technical issues;
• protect against unauthorized access to customer information;
• identify potential malicious activity; and
• provide you with news, special offers, and information about goods, services, and events similar to those you have already purchased or inquired about, unless you have opted out.

Akemona will never ask you for your private keys or passwords. Protecting your private keys and passwords is your responsibility.

Except as necessary to fulfill your request and operate the Service, we do not share your information with third parties outside our organization except as described in this Privacy Policy. Operating the Service may involve third-party login providers, cloud hosting, analytics, customer support, payment processing, escrow services where applicable, identity verification, legal and regulatory compliance, security, fraud prevention, and the development and improvement of our products, services, content, and advertising.

To comply with applicable legal and compliance requirements, information you provide may be validated against sanctions, anti-money laundering, or fraud-prevention databases, where applicable.

Transactions you execute on a public blockchain through the Service may be publicly visible using your public address. We may require the public address of your digital wallet to provide certain Service features.

Unless you ask us not to, we may contact you by email in the future to tell you about our products or services or changes to this Privacy Policy.

Your Access to and Control Over Personal Information

By changing your preferences on the Akemona website, you may be able to:

• see what data we have about you, if any;
• correct data we have about you; and
• express concerns about our use of your data.

We may be unable to honor requests to delete certain data because we must retain certain records for legal, regulatory, security, fraud-prevention, and recordkeeping purposes, including records relating to transactions and compliance activity. You may also opt out of future contact from us at any time.

Requests to Opt Out and Delete Personal Data

We do not share your personal information with third parties for their direct marketing. We may send newsletters, information about website upgrades, and information about new products by email. You can opt out of these communications by clicking the unsubscribe link at the bottom of the applicable communication.

We may be unable to comply with certain requests to delete personal data due to legal, regulatory, security, fraud-prevention, dispute-resolution, and business-operations-related restrictions, including where we must retain records of transactions and related compliance activity.

Refusal to Provide Necessary Personal Data

We require Personal Data to provide contracted products and services, further a professional relationship or collaboration, and comply with applicable law or regulation. If you fail to provide requested information, we may be unable to provide products or services to you or your organization or otherwise collaborate with you or your organization.

Security Procedures

Whenever we collect sensitive information, that information is encrypted and transmitted to us securely. You can confirm this by looking for a lock icon in the address bar and by checking that the webpage address begins with “https.”

While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need access to personally identifiable information to perform a specific job are granted such access. The computers and servers in which we store personally identifiable information are kept in a secure environment behind a firewall.

Legal Basis for Processing Personal Data Under the GDPR

If you are from the European Economic Area, our legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the context in which we collect it. Akemona may process Personal Data because we need to perform a contract with you, you have given us permission to do so, the processing is in our legitimate interests and not overridden by your rights, for payment processing purposes, or to comply with the law.

Retention of Data

Akemona, Inc. retains Personal Data only as long as necessary for the purposes set out in this Privacy Policy. We will retain and use certain Personal Data and related records for a minimum of six years, or such other period as required or permitted by applicable law, to comply with legal and compliance obligations, resolve disputes, and enforce our legal agreements and policies.

Usage Data is generally retained for a shorter period, except where it is used to strengthen security, improve functionality, or where we are legally required to retain it longer.

Transfer of Data

Your information, including Personal Data, may be transferred to and maintained on computers located outside your state, province, country, or other governmental jurisdiction, where data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. Akemona, Inc. will take all reasonably necessary steps to ensure that your data is treated securely and in accordance with this Privacy Policy and that no transfer of your Personal Data will occur unless adequate controls are in place.

Disclosure of Data

Business Transactions

If Akemona, Inc. is involved in a merger, acquisition, or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different privacy policy.

Disclosure to Law Enforcement

We may disclose Personal Data if required to do so by law or in response to valid requests by public authorities, such as a court or government agency.

Disclosure for Legal Reasons

Akemona, Inc. may disclose Personal Data in the good-faith belief that such action is necessary to comply with a legal obligation, protect and defend the rights or property of Akemona, Inc., prevent or investigate possible wrongdoing in connection with the Service, protect the personal safety of users or the public, or protect against legal liability.

Service Providers and Professional Advisers

We may employ third-party companies and individuals to facilitate our Service, perform Service-related functions, or assist us in analyzing how our Service is used. These third parties may have access to your Personal Data only to perform those tasks on our behalf and are obligated not to disclose or use it for any other purpose. These may include cloud platform providers, identity verification vendors where applicable, payment processing vendors, escrow service providers where applicable, customer support providers, auditors, lawyers, and other professional advisers. In addition, Akemona may use public blockchains such as Ethereum, which may allow third parties to view token balances and transactions associated with public wallet addresses.

Security of Data

We maintain reasonable and appropriate security measures, including technical and organizational measures, to protect against the loss, misuse, and alteration of Personal Information we receive about you. However, we cannot guarantee that information will never be accessed, disclosed, altered, or destroyed through a breach of physical, technical, or managerial safeguards. When you submit information to us, please be aware that your information is transmitted across the internet and that no method of transmission over the internet is completely secure.

California Online Privacy Protection Act and Do Not Track

We do not support Do Not Track (“DNT”). Do Not Track is a browser preference you can set to inform websites that you do not want to be tracked. You can enable or disable Do Not Track through the preferences or settings page of your web browser.