Privacy Policy

Effective date: June 26, 2026

We at GiveSentiment know you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy. By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.

Remember that your use of GiveSentiment's Services is at all times subject to the Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

What does this Privacy Policy cover?

This Privacy Policy covers our treatment of personally identifiable information ("Personal Information") that we gather when you are accessing or using our Services, but not to the practices of companies we don't own or control, or people that we don't manage. We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with our Services, including to personalize, provide, and improve our services, to allow you to set up a user account and profile, to contact you and allow other users to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some Personal Information with third parties, but only as described below.

As noted in the Terms of Use, we do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact us at info@givesentiment.com.

Will GiveSentiment ever change this Privacy Policy?

We're constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on the Services, by sending you an email if we have one for you. Please note that if you've opted not to receive legal notice emails from us (or you haven't provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

What Information does GiveSentiment Collect?

Information You Provide to Us:

We receive and store any information you knowingly provide to us. For example, through the registration process and/or through your account settings, we may collect Personal Information such as your name, email address, phone number, blockchain wallet address and third-party account credentials (for example, your log-in credentials for ThirdWeb Wallet or other third party sites). If you provide your third-party account credentials to us or otherwise sign in to the Services through a third party site or service, you understand some content and/or information in those accounts ("Third Party Account Information") may be transmitted into your account with us, and that Third Party Account Information transmitted to our Services is covered by this Privacy Policy; for example, when you sign into the Services using MetaMask, we will receive your wallet address. Certain information may be required to register with us or to take advantage of some of our features. For example, as outlined in the "Compliance with Biometric Privacy Laws" section below, we may collect biometric data, such as facial geometry or other unique biological patterns, solely for the purpose of user authentication and verifying that you are a human and not a bot. This collection is voluntary but may be necessary to access certain features of our Services. We do not use biometric data for any other purpose, and we do not sell or share this data with third parties.

We may communicate with you if you've provided us the means to do so. For example, if you've given us your email address, we may send you promotional email offers on behalf of other businesses, or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our services. If you do not want to receive communications from us, please indicate your preference by sending us an email at info@givesentiment.com.

Information Collected Automatically

Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, "cookie" information, the type of browser and/or device you're using to access our Services, and the page or feature you requested. "Cookies" are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device's acceptance of cookies, but this may prevent you from taking advantage of some of our features. Our advertising partners may also transmit cookies to your browser or device, when you click on ads that appear on the Services. Also, if you click on a link to a third party website or service, such third party may also transmit cookies to you. Again, this Privacy Policy does not cover the use of cookies by any third parties, and we aren't responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor "Do Not Track" requests you have set using your browser or device.

We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services - for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible. For more information, please visit our Cookie Policy here [insert link to Cookie Policy]

Will GiveSentiment share any of the Personal Information it receives?

Surveys on our platform may request Personal Information, demographic information, and/or other information which might be used to identify you by combining it with other information. The specific information requested will be clearly specified on a survey-by-survey basis in each survey's terms and conditions. Your participation in any survey is entirely voluntary and at your sole discretion. You may decline to participate in any survey without penalty including without limitation those which request Personal Information; but obviously you will not receive Rewards for surveys you do not participate in. Note that this limitation in your access to the Services is directly related to the nature of our business model and the value derived from data sales. Your choice not to participate in a particular survey will not affect your access to the rest of our Services. Survey Creators are instructed to request only information that is necessary for the stated purpose of the survey. We have no control over the policies and practices of Data Licensors as to privacy or anything else, so if you choose to take part in any transaction with a Data Licensor, please review the licensing terms associated with that particular survey and all such Licensor's business or websites policies. Data Licensors may combine the survey responses and associated information they purchase with other data sources, which could potentially result in the creation of personal information or allow for re-identification. GIVESENTIMENT IS NOT RESPONSIBLE FOR, AND EXPRESSLY DISCLAIMS ANY LIABILITY ARISING FROM, SUCH DATA COMBINATION PRACTICES BY DATA LICENSORS OR ANY SUBSEQUENT USE OR PROCESSING OF THE DATA ONCE IT HAS BEEN SOLD AND TRANSFERRED TO THEM.

By participating in a survey, you consent to the collection and sale of the provided Personal Information to the specified Data Licensor(s) under the terms outlined. The Personal Information you provide may be sold to these parties for purposes such as market research, product development, or as otherwise specified in the survey terms. You can choose which surveys to participate in based on your comfort level with the Personal Information requested and its intended use and/or based upon your views of the Data Licensor. You can access, correct, or request deletion of your survey responses and the associated Personal Information through your account settings, but please note that any Data Licensor that has already purchased the survey response set and any associated Personal Information will have acquired it and any dispute or request for deletion must be resolved by contacting them directly.

We may also share your Personal Information with third parties as described below:

Information that's been de-identified. We may de-identify your Personal Information so that you are not identified as an individual and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual.

Advertisers: We allow advertisers and/or merchant partners ("Advertisers") to choose the demographic information of users who will see their advertisements and/or promotional offers and you agree that we may provide any of the information we have collected from you in non-personally identifiable form to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers. For example, we might use the fact you are located in San Francisco to show you ads or offers for San Francisco businesses, but we will not tell such businesses who you are. Or, we might allow Advertisers to display their ads to users with similar usage patterns to yours, but we will not disclose usage information to Advertisers except in aggregate form, and not in a manner that would identify you personally. Note that if an advertiser asks us to show an ad to a certain audience or audience segment and you respond to that ad, the advertiser may conclude that you fit the description of the audience they were trying to reach.

We may deliver a file to you through the Services (known as a "web beacon") from an ad network. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network's servers, these companies can view, edit, or set their own cookies, just as if you had requested a web page from their site. You may be able to opt-out of web beacon tracking conducted by third parties through our Services by adjusting the Do Not Track settings on your browser; please note that we don't control whether or how these third parties comply with Do Not Track requests.

Affiliated Businesses: In certain situations, businesses or third party websites we're affiliated with may sell or provide products or services to you through or in connection with the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. One such service may include the ability for you to automatically transmit Third Party Account Information to your Services profile or to automatically transmit information in your Services profile to your third party account; for example, transferring your Sentiment data to Stripe in order to receive rewards. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business' or websites' policies.

Our Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we may use a payment processing company to process and transmit your rewards. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. Note that an "agent" may also be considered a "partner" in certain circumstances and may be subject to the terms of the "Information that's been de-identified" section above in that regard.

User Profiles and Submissions: Certain user profile information, including your name, location, blockchain wallet address and any video or image content that such user has uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address your request for our services. Your account privacy settings may allow you to limit the other users who can see the Personal Information in your user profile and/or what information in your user profile is visible to others. Please remember that any content you upload to your public user profile, along with any Personal Information or content that you voluntarily disclose online in a manner other users can view (on discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by anyone. Your username may also be displayed to other users if and when you send messages or comments or upload images or videos through the Services and other users can contact you through messages and comments. Additionally, if you sign into the Services through a third party social networking site or service, your list of "friends" from that site or service may be automatically imported to the Services, and such "friends," if they are also registered users of the Services, may be able to access certain non-public information you have entered in your Services user profile. Again, we do not control the policies and practices of any other third party site or service.

Business Transfers: We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.

Protection of Company and Others: We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law or court order; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of GiveSentiment, our employees, our users, or others. Please note that while we take all reasonable steps to protect your Personal Information, the US legal system may allow government authorities to access data under certain circumstances that may differ from your home country.

Is Personal Information about me secure?

Your account is protected by a password and/or a private key associated with your blockchain wallet address for your privacy and security. It is crucial to understand that you are solely responsible for maintaining the security and confidentiality of your private key. GiveSentiment does not have access to, control over, or responsibility for your private key. The security of your account and any assets or information associated with it depends entirely on your diligent protection of your private key.

If you lose your private key, GiveSentiment cannot recover it for you, and you may permanently lose access to your account and any associated assets or information. We strongly recommend using secure methods to store your private key, such as hardware wallets or other offline storage methods.

If you access your account via a third party site or service, you may have additional or different sign-on protections via that third party site or service. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password, private key, and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

Remember, GiveSentiment will never ask you for your private key. Be wary of any requests for this information, as they are likely fraudulent. Always exercise caution when dealing with your private key and never share it with anyone, including GiveSentiment representatives.

What Personal Information can I access?

Through your account settings, you may access, and, in some cases, edit or delete the following information you've provided to us:

name and password email address location user profile information, including images and videos you have uploaded to the site

The information you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on file about you, please contact us at info@givesentiment.com.

What choices do I have?

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.

You may be able to add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by emailing us at info@givesentiment.com. Some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.

Compliance with Biometric Privacy Laws

Biometric data is protected using encryption and security measures. Access to this data is strictly limited and controlled. We retain biometric data only for as long as necessary to authenticate you or as required by applicable laws, after which it is securely deleted.

GiveSentiment aims to comply with all applicable laws regarding the collection, use, and storage of biometric data, including but not limited to:

1. The Illinois Biometric Information Privacy Act (BIPA) 2. The California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) 3. The General Data Protection Regulation (GDPR) for EU residents

We obtain your explicit consent before collecting any biometric data. We inform you of the specific purpose of collecting biometric data (authentication and human verification). We do not sell or license your biometric data to third parties. We store, transmit, and protect biometric data using reasonable standards of care and in a manner as or more protective than the manner in which we store, transmit, and protect other confidential and sensitive information. We destroy biometric data when the initial purpose for collecting it has been satisfied or promptly after we have received a verified request from you for its deletion. Note that if you choose not to provide or request deletion of your biometric data, this may limit access to certain features of our services. You can request access to or deletion of biometric data at any time by contacting us at info@givesentiment.com.

Privacy Information for California Residents

This section provides additional information for California residents, supplementing the general Privacy Policy. Please refer to the main policy for information on data collection, use, and sharing practices that apply to all users.

California-Specific Rights

In addition to the rights outlined in the main privacy policy, California residents have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

1. The right to know what personal information we collect, use, disclose, and sell 2. The right to delete personal information we have collected about you 3. The right to correct inaccurate personal information 4. The right to opt-out of the sale of your personal information 5. The right to limit the use and disclosure of sensitive personal information 6. The right to non-discrimination for exercising your CCPA/CPRA rights

Exercising Your Rights

To exercise these rights, please contact us at info@givesentiment.com with the subject line "California Privacy Rights Request." Your request should:

- Provide sufficient information to allow us to verify that you are the person about whom we have collected Personal Information. - Describe your request in sufficient detail to allow us to understand, evaluate, and respond to it.

We will respond to verified consumer requests within 45 days of their receipt. If we require more time, we will inform you of the reason and extension period in writing.

Sensitive Personal Information

Under CPRA, we collect and process the following categories of sensitive personal information: - Biometric information (for authentication purposes only) - Precise geolocation data (if you choose to share it)

We do not use or disclose sensitive personal information for purposes other than those specified in Section 7027 of the CCPA regulations.

Authorized Agents

California residents may use an authorized agent to submit a request on their behalf. If you choose to use an authorized agent, we will require proof of authorization and may still contact you directly to verify your identity.

Verification Process

Our verification process for California residents' requests may include: - Matching identifying information provided by you with information we have on file - Requesting additional documentation or information if necessary - For requests related to specific pieces of information, we may require a higher level of verification

Financial Incentives

GiveSentiment may offer financial incentives, such as rewards or discounts, in exchange for the collection, retention, or sale of personal information. These incentives are based on the value provided by the data and are designed to be compliant with CCPA/CPRA requirements. You have the right to withdraw from these incentives at any time.

Metrics

As required by CCPA/CPRA for businesses handling large amounts of consumer data, we disclose the following metrics regarding data subject requests received in the previous calendar year: - Number of requests to know received, complied with in whole or in part, and denied - Number of requests to delete received, complied with in whole or in part, and denied - Number of requests to opt-out received, complied with in whole or in part, and denied - Median number of days within which we substantively responded to requests

These metrics are updated annually and can be found [insert link to metrics page].

Additional California Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Information to third parties for such third parties' direct marketing purposes. To submit such a request, please contact us at info@givesentiment.com.

For any California-specific privacy requests or concerns, please contact us at info@givesentiment.com with the subject line "California Privacy Rights Request."

Privacy Information for Nevada Residents

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties. Please note that GiveSentiment does sell your Personal Information as defined in Nevada Revised Statutes Chapter 603A. To opt-out of such sales, please contact us at info@givesentiment.com with the subject line "Nevada Privacy Rights Request." We will respond to verifiable requests within 60 days. There is no fee for making a request unless it is manifestly unfounded or excessive. Please note that while we will not discriminate against you for exercising your opt-out right, doing so may impact your ability to use certain features of our Services that rely on data sharing.

Privacy Information for EU/EEA/UK/Switzerland Residents

If you are a resident of the European Union (EU), European Economic Area (EEA), United Kingdom, Switzerland, or another jurisdiction with similar data protection laws, you have certain rights under the General Data Protection Regulation (GDPR) and similar regulations with respect to your Personal Information.

Data Controller

GiveSentiment, Inc. is the controller of your Personal Information processed in connection with our Services. For any questions about this policy or our data practices, please contact our Data Protection Officer at info@givesentiment.com.

Legal Basis for Processing

We process Personal Information on the following legal bases:

Consent: Where you have given us explicit consent to process your data for a specific purpose, such as participating in surveys or receiving marketing communications. Contract: Where processing is necessary for the performance of a contract with you, including our Terms of Service and the provision of our survey and data marketplace services. Legitimate Interests: Where processing is necessary for our legitimate interests, such as improving our services or preventing fraud, and those interests are not overridden by your rights and freedoms. Legal Obligation: Where processing is necessary to comply with a legal obligation to which we are subject.

For biometric data: We process this data based on your explicit consent, which you can withdraw at any time by emailing us at info@givesentiment.com.

Your Rights Under GDPR

You have the following rights with respect to your Personal Information:

Right to Access: You can request information about the Personal Information we hold about you and request a copy of such data. Right to Rectification: You can request that we correct inaccurate or incomplete Personal Information. Right to Erasure: In certain circumstances, you can request that we erase your Personal Information. Right to Restrict Processing: You can request that we restrict the processing of your Personal Information in certain circumstances. Right to Data Portability: You can request a copy of your Personal Information in a machine-readable format and ask us to transfer it to another controller. Right to Object: You can object to our processing of your Personal Information in certain circumstances, particularly regarding processing based on our legitimate interests or for direct marketing purposes. Right to Withdraw Consent: Where we process data based on consent, you have the right to withdraw that consent at any time.

To exercise these rights, please contact us at info@givesentiment.com. We will respond to your request within one month, which may be extended by two further months where necessary.

International Data Transfers

GiveSentiment is based in the United States, and by using our Services, your Personal Information will be transferred to and processed in the US. We rely on the following legal bases for these transfers:

Your Consent: By agreeing to our Terms of Service and this Privacy Policy, you consent to the transfer of your Personal Information to the US. Contractual Necessity: The transfer is necessary for the performance of the contract between you and GiveSentiment to provide our Services.

We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk of processing your Personal Information, including: - Encryption of data in transit and at rest - Strict access controls and data minimization practices - Regular security audits and assessments

Standard Contractual Clauses for Data Licensors outside the EU

For the sale of survey responses that include Personal Information of EU data subjects:

We incorporate Standard Contractual Clauses (SCCs) approved by the European Commission into license agreements with Data Licensors. These SCCs apply whenever the Data Licensor is located outside the EU/EEA, ensuring compliance with GDPR requirements for international data transfers. For Data Licensors within the EU/EEA, while SCCs are not strictly necessary, we maintain equivalent data protection standards in our agreements. We regularly assess and update our data transfer mechanisms to ensure ongoing compliance with evolving data protection regulations. Data subjects are informed that their Personal Information may be transferred internationally as part of our data marketplace services, and that appropriate safeguards (including SCCs where applicable) are in place to protect their rights and freedoms.

For more information about our data transfer practices or to obtain a copy of the SCCs we use, please contact our Data Protection Officer at info@givesentiment.com.

Data Retention

We retain Personal Information for as long as necessary to provide our Services, comply with legal obligations, resolve disputes, and enforce our agreements. When Personal Information is no longer necessary for these purposes, we will endeavor to securely delete or anonymize it.

Specific to our data marketplace model: - Survey responses which include Personal Information are retained as long as you choose to make them available for purchase by Data Licensors, subject to your right to request erasure. - Once Personal Information is purchased by Data Licensors, their retention practices are governed by the specific license terms agreed upon at the time of purchase and their own GDPR compliance obligations.

Complaints

If you have concerns about our data practices or the exercise of your rights, please contact us at info@givesentiment.com. You also have the right to lodge a complaint with your local data protection authority in the EU/EEA, UK, or Switzerland.

What if I have questions about this policy?

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to info@givesentiment.com, and we will try to resolve your concerns.