Privacy Policy

Last Modified: May 19, 2025

1. Introduction

Otim respects your privacy and is committed to protecting it through our compliance with this privacy policy. This policy describes the types of information we may collect from you or that you may provide when you interact with the Services, including when you create an account with us to use the Services, and our data collection and handling practices.

This privacy policy is part of the Terms applicable to the use of our Services. Please review this policy together with the Terms, to understand all of your rights and obligations, and how we operate our Services. Capitalized terms used but not defined in this policy shall have the meanings set forth in the Terms and Conditions.

This privacy policy applies to information we collect:

• On or through the Services;

• In email, text, and other electronic messages exchanged through the Services, if applicable;

• When you interact with our advertising and applications on third-party websites and services, if such advertising or applications include links to this policy; and

• Through any other means associated with or relating to the Services.

This policy does not apply to information collected by:

• Us offline or through any other means, including on any other website or application operated by Otim or any third party (including our affiliates and subsidiaries); or

• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Services.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using the Services, you agree to the terms of this privacy policy.

This privacy policy may change from time to time. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the privacy policy periodically for updates.

2. Information about Children

Our Services are not intended for children under eighteen (18) years of age. No one under age eighteen (18) may provide any personal information to us or on or through the Services.

We do not knowingly collect personal information from children under the age of sixteen (16). If you are under sixteen (16), do not use or provide any information on the Services or use them, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use.

If we learn we have collected or received personal information from a child under sixteen (16) years of age, we will delete that information. If you believe we might have any information from or about a child under the age of sixteen (16), please contact us at gm@otim.com.

3. Information We Collect About You and How We Collect It

We and our service providers may collect several types of information from and about users of our Services (some of which is considered “personal information” pursuant to applicable law), including:

• Identifiers, such as name, e-mail address, wallet ID, or any other information that the Services collect, which applicable law may consider personally identifiable, personal information, personal data, and other such designations;

• Information about the device you use to access the Services;

• Your IP address;

• Your device characteristics and functionality (including information about your operating system, hardware, mobile network, browser, browser language, etc.);

• Referring and exit web pages and URLs;

• Your browsing history, including the areas within our Services that you visit and your activities there, including remembering you and your preferences;

• Your device location or other geolocation information;

• Certain other device data, including the time of day you visit our Services; and

• Information about your internet connection and internet provider. ⠀ We and our service providers collect this information:

• Directly from you when you provide it to us, such as when filling in forms on the Services (including when you register for an account, subscribing to a service, or requesting something from us, or when you fill out surveys, if any such features are available to you);

• Automatically as you use our Services, which may include through the use of cookies, web beacons, and other tracking technologies (including information about your network or computing device) and analytics services;

• From third parties, for example, our business partners and service providers;

• Records and copies of your correspondence (including email addresses), if you contact us through the Services;

• When you engage in transactions on our Services;

• When you run searches on our Services; and

• When you contact our customer service agents, if available.

Automatic Data Collection Technologies

As you navigate through and interact with the Services, we may use third-party automatic data collection technologies to collect certain information about you, your equipment, your technology providers, and your activities, including:

• Details of your visits to the Services, including traffic data, browsing patterns, location data, logs, and other communication data and the resources that you access and use in connection with the Services; and

• Information about your device and about your internet connection and service provider, as set forth above.

You acknowledge and understand that our service providers may collect this information about you, and may monitor and intercept your communications and actions on our Application or in connection with the Services as you browse, interact with or use certain functionality, such as chat features. These service providers may use the information they collect for their own benefit, without any restriction. You specifically agree to this arrangement, and consent to your communications and information being intercepted by our third-party providers.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically may be statistical data and may also include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. This information may enable us to:

• Allow you to use and access the Services;

• Prevent fraudulent activity and improve security functionality;

• Assess the performance of the Services, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Services;

• Offer you enhanced functionality when accessing the Services, including identifying you when you sign in, and keeping track of your specified preferences;

• Deliver content relevant to your interests on the Services and third-party sites based on how you interact with our advertisements and/or content;

• Estimate our audience size and usage patterns;

• Speed up your searches; and

• Analyze our services and products and perform market research. ⠀ When you visit or leave the Services by clicking a hyperlink or when you view a third-party site that includes our plugins or cookies (or similar technology), we may automatically receive the URL of the site from which you came or the one to which you are directed.

We may also receive location data passed to us from third-party services or GPS-enabled devices that you have set up, which we may use for fraud prevention and security purposes, and to understand our audiences. We may also use this information to provide customized information or content that may be of interest to you. If you no longer wish for us, our affiliates, or our service providers to collect and use location information, you may disable the location features on your device. Consult your device manufacturer settings for instructions on how to do this. Please note that if you disable such features, your ability to access certain features, services, content, or products may be limited or disabled.

The technologies we may use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Note that while you can set your browser to not allow cookies, we may not be able to honor that request, and may track your activity and collect information about you and your online activities even when the browser is set to “do not track”;

• Flash Cookies. Certain features of the Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Services. Flash cookies are not managed by the same browser settings as are used for browser cookies and you may not be able to shut down our collection of and use of information through this technology;

• Web Beacons, Pixels and Tags. Pages of the Services and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity);

• Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Services, such as information about the links you click on;

• ETag, or entity tag. An ETag, or entity tag, is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. It is one of several mechanisms that HTTP provides for web cache validation. These allow websites to be more efficient and not serve content again, when data is already cached and ready to view;

• Fingerprinting. Fingerprinting refers to the collection and analysis of information from your device, such as your operating system, plug-ins, system fonts and other data, for purposes of identification;

• Recognition Technologies. Recognition technologies refers to various technology features used by websites, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user); and

• Log Files. These may track actions occurring on the Services, and which may help us collect your IP address, browser type, Internet service provider, the webpages from which you came or to which you go before and after visiting the Services, and the date and time of your visits.

Do Not Track

Do Not Track (“DNT”) is a concept promoted by certain regulatory authorities and industry groups for development and implementation of a mechanism that would allow internet users to control the tracking of their online activities across websites. Currently, various browsers (including Internet Explorer, Firefox, and Safari) offer a DNT option that allows a user to set a preference in the browser to not have his/her activities on the internet tracked. You can usually access your browser’s DNT option in your browser’s preferences. When a user’s browser is set to DNT, some cookies and other tracking technologies may become inactive, depending on how the website visited responds to DNT browser settings. If that occurs, the website visited will not recognize you upon return, save your passwords or user names, and some other features of a website may become unavailable or not function properly. Given a lack of standards in the industry, our Website may not respond to DNT signals at all times.

Third-Party Use of Cookies and Other Tracking Technologies

The Services may include some content or applications served by third-parties, including advertisers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

4. How We Use Your Information

⠀We may use information that we collect about you or that you provide to us, including any personal information:

• To present the Services and their contents to you;

• To provide you with information, products, or services that you request from us;

• To fulfill any other purpose for which you provide it;

• To provide you with notices about your account and/or the Services;

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection, if needed;

• To notify you about changes to our Services or any products or services we offer or provide though it;

• To allow you to participate in interactive features on our Services, if any;

• To develop and improve our products and services;

• For any other purpose as needed for our business;

• In any other way we may describe when you provide the information;

• For any other purpose with your consent;

• To contact you about our own and third-parties’ goods and services that we think may be of interest to you; and

• To enable us to display advertisements to our advertisers’ target audiences. ⠀

5. Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our affiliates;

• To contractors, service providers, and other third parties we use to support our business and assist us in providing services and offering our products;

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Otim’s assets or stock, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Otim about our Services users is among the assets transferred;

• To third parties to market their products or services to you;

• To fulfill the purpose for which you provide it;

• For any other purpose disclosed by us when you provide the information; and

• With your consent.

⠀We may also disclose your personal information:

• To comply with any court order, law, or legal process, including responding to any government or regulatory request;

• To enforce or apply the Terms, including this privacy policy, and any other agreements between us, including for billing and collection purposes; and

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

6. Data Security

We have implemented measures intended to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. However, the safety and security of your information also depends on you. We do not have access to your keys or seed phrase, and cannot help you change it or recover it. It is your responsibility to secure that information.

Unfortunately, the transmission of information via the internet is not completely secure. Although we try to protect your personal information, we cannot guarantee the security of your personal information transmitted through or collected through the use of our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

7. California Residents

California Civil Code Section § 1798.83, known as the “Shine The Light” law, permits users of our website who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding year, and the names and addresses of those third parties. You may request this information from us no more than once a year, but such request will be handled by us free of charge to you. To make such a request, please send an email to gm@otim.com.

8. Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account, if applicable. We may also post a notice on our website home page. The date this privacy policy was last revised is identified at the top of this page. You are responsible for periodically visiting our Services and this privacy policy to check for any changes.

9. Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

E-mail: gm@otim.com