Privacy Policy

Last Updated April 2025

Recall Foundation ("Recall," "we," or "us") respects the privacy of our customers, partners, and other website visitors ("you" or "your"). This Privacy Policy describes how we collect, process, share, and safeguard personal information that is collected via our website (https://recall.network/) ("Website"), other websites that reference this Privacy Policy, and when you engage with our services generally (collectively "Services").

Recall Foundation will be the controller of your personal information in accordance with data protection laws of the European Economic Area and the United Kingdom. If you have any questions or comments about this Privacy Policy, please submit a request to data-privacy@recall.foundation.

This Privacy Policy does not apply to personal information we process as a processor or service provider on behalf of our customers when providing services to them. For example, if we process your personal information as part of the service we provide to our customers, such customer will act as the controller and its privacy policy will govern the processing of your personal information.

1. Personal Information We Collect

We collect the following categories of personal information.

• Profile and project information. This includes your name, username, contact information (including email, phone number, and address), project twitter, and individual telegram.
• Identification information. If you win an award or are otherwise subject to our Know Your Customer (KYC) checks, we and our third-party verification partners may collect identification information, such as your street address, email address, date of birth, Social Security number, and other government-issued identification.
• Financial account information. You may choose to connect financial accounts to the Services, such as your bank account or digital wallet ID. If you connect your accounts to the Services, we may collect your online login information, bank account and routing numbers, account balances, wallet ID number, and other related information.
• Wallet addresses. You may choose to use your wallet address to interact with our Services and other users of our Services.
• Transactions and commercial information. We collect information about your transactions on the Services, such as public blockchain data, your rewards, payments you send and receive, and any other transactions you make on the Services.
• Communications with us. We collect the communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
• Marketing information. This includes your preferences for receiving communications about our Services, and details about how you engage with our communications.
• Sweepstakes or Contests. We may collect personal information that you provide for any sweepstakes or contests that we offer, including our hackathons.

Automatic data collection.

We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our Services, such as:

• Device data, such as your computer's or mobile device's operating system, manufacturer and model, browser type, IP address, unique identifiers, language settings, mobile device carrier, and general location information such as city, state or geographic area; and
• Usage data, such as pages or screens you viewed, how long you spent on a page, browsing history, and access times, and page clicks, page scrolls, and page element interactions.

We may collect this information using cookies and other similar technologies. Please see our Cookie section below to learn more about how we use cookies.

Information Collected from Third Parties

• Third-party services and sources. We may obtain personal information about you from other sources, including through third-party services and applications. For example, if you access our Services through a third-party application, such a third-party login service or a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings.
• Blockchain information. We may obtain personal information about you through our analysis of blockchain information, such as wallet and smart contract addresses, transaction data and IP addresses.

2. How We Use Personal Information

We use personal information for the following purposes:

• To operate and deliver our Services. We will use your personal information to perform our contractual obligations, when it is in our legitimate business interests or based on your consent, including to:
  • Provide, operate, maintain, and secure our Services;
  • Provide support assistance and troubleshooting;
  • Allow you to use features and functionality of the Services;
  • Send you updates about administrative matters such as changes to our terms or policies;
  • Facilitate contests, process and deliver entries and rewards; and
  • Provide user support, and respond to your requests, questions and feedback.
• To improve, monitor, personalize, and protect our Services. It is in our legitimate business interests to improve and keep our Services safe, which includes:
  • Enriching your user experience and customize your relationship with us;
  • Protecting the security of our Services;
  • Preventing and detecting security threats, fraud or other criminal or malicious activities; and
  • Administering content, promotion, sweepstakes, surveys, voting polls and other Website features.
• Research and development. It is in our legitimate business interests to use personal information (including the personal information described in this Privacy Policy and personal information collected on behalf of our customers) to develop, analyze and improve the Services and our business. As part of these activities, we may create or use aggregated, de-identified or other anonymized data from personal information we collect. We anonymize data by removing information that makes the data personally identifiable. We may use this anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.
• Marketing and advertising, including to send direct marketing communications, including, but not limited to, sending newsletters, and notifying you of promotions, offers and events via email to advertise the Services. Except where consent is required, we undertake such marketing and advertising on the basis of our legitimate business interests. Where we seek your consent, you may withdraw your consent at any time.
• To comply with legal obligations and to defend Recall against legal claims or disputes. We may use your personal information to comply with our legal obligations or when it is in our legitimate business interests, which includes to:
  • Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
  • Protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);
  • Audit our compliance with legal and contractual requirements and internal policies;
  • Enforce the terms and conditions that govern the Services; and
  • Protect the security of and manage access to our premises and prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
• To facilitate corporate acquisitions, mergers or transactions. We may use your personal information, when it is in our legitimate business interests, when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.

3. How We Share Personal Information

We may share personal information with:

• Service providers. We may share personal information with companies and individuals that provide services on our behalf or help us operate our Services or our business. These service providers include hosting services, communications, LLM and other AI service providers, payment processing services, identity verification, fraud detection, investigation and prevention services, web and mobile analytics, and email and communication distribution and monitoring services.
• Professional advisors. We share personal information with 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. We may share personal information with law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate.
• Business transferees. We may share personal information with acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, us (including, in connection with a bankruptcy or similar proceedings).

4. Cookies

a. What are cookies?

Cookies are small text files placed onto your device (computer, mobile phone, etc.) by certain websites that you visit and generally collect standard internet log information and visitor behavior information. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the website.

Cookies can be 'first-party' or 'third-party' depending on the domain that sets them. First-party cookies are set by us and information collected from these cookies is used by us in accordance with our Privacy Policy. Third-party cookies are set by third parties and information is collected and used in accordance with those parties' privacy policies. Our Website uses both persistent and session cookies:

• Session Cookies. These cookies are temporary cookies that remain on your computer or device until you leave our Website. They allow our Website to link your actions during a browser session. We may use these for a variety of purposes such as remembering what you clicked on, on the previous page visited. A session starts when a user opens a browser window and ends when the browser window is closed, following which all session cookies expire and are deleted;
• Persistent Cookies. These cookies remain on your device for much longer or until you manually delete them (how long the cookie remains on your device will depend on the duration or "lifetime" of the specific cookie, as well as your browser settings). Persistent cookies may be used for a variety of purposes including remembering users' preferences and choices when using a website.

b. How we use cookies

To give you the best experience possible, we use the following types of cookies:

• Strictly Necessary. These cookies are necessary for our Website to function correctly. They enable you to move around our Website and use our Website features. As these cookies are necessary for the provision of our Website to you, we do not require your consent for their use.
• Analytics. These cookies help us understand how you interact with our Website by providing information such as the pages visited, the time spent on the Website, and any issues encountered, such as error messages. The information these cookies collect are for the purposes of generating aggregated statistics and they help us improve the way our Website works. Where required by law, we will obtain your consent before placing Analytics Cookies on your device.

Depending on your location, the maximum expiration period for the cookies above is two years.

c. How to control cookies

Depending on where you access the Services from, you may be presented with a cookie banner or other tool to provide permissions prior to cookies other than Strictly Necessary Cookies being set. In this case, we will only set these cookies with your consent.

You can also limit tracking by:

• Blocking cookies on your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. If you disable or delete cookies, however, you may have to manually adjust some preferences every time you visit the Website and some functionalities may not work. Please see the following links for instructions on how to turn off or delete cookies on popular browsers: Chrome, Firefox, Microsoft Edge, Safari (Mac), Safari (Mobile/IOS). For more information on cookies and how they can be managed and deleted please visit www.allaboutcookies.org.
• Google Analytics. We use Google Analytics to help us better understand how people engage with our Services by collecting information and creating reports about how users use our Services. For more information on Google Analytics, click here. You can opt-out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
• Using privacy plug-ins or browsers. You can block our services from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

d. 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" or similar signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

5. Your Rights

Depending on where you are based, and as provided under applicable law and subject to any limitations in such law, you may have the right to:

• Access your personal information;
• Correct incomplete or inaccurate data we hold about you;
• Ask us to erase the personal information we hold about you;
• Ask us to restrict our handling of your personal information;
• Receive any personal information we hold about you in a structured and commonly used machine readable format or have such personal information transmitted to another company;
• Object to how we are using your personal information;
• Withdraw your consent to us handling your personal information.

Requests can be made to: data-privacy@recall.foundation. You may update or correct information about yourself by emailing us at data-privacy@recall.foundation.

Please note that, prior to any response to the exercise of such rights, we may require you to verify your identity. Depending on where you reside, you may be entitled to empower an "authorized agent" to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination. In addition, we may have valid legal reasons to refuse your request, and will inform you if that is the case.

Limits on your privacy rights and choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights.

Unsubscribe from direct marketing communications. You may opt out of marketing-related communications by following the opt-out or unsubscribe instructions contained in the marketing communication we send you. You may continue to receive service-related and other non-marketing communications.

6. Data Security

Recall maintains administrative, technical and physical safeguards designed to protect your personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We implement appropriate technical and organizational measures to ensure an adequate level of security, while taking into account the technological reality, cost, scope, context and purposes of processing weighed against the severity and likelihood that processing could threaten individual rights and freedoms.

While we take steps designed to protect your personal information, please be advised that no security system or means of transmitting data over the Internet can be guaranteed to be entirely secure, including concerns with respect to computer viruses, malicious software, and hacker attacks. We cannot and do not guarantee or warrant the security of your personal information or any information you disclose or transmit to us.

7. Data Retention

We may retain your personal information for as long as it is reasonably needed in order to maintain and expand our relationship and provide you with our Services; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of such data, the potential risk of harm from unauthorized use or disclosure of such personal information, the purposes for which we process it, and the applicable legal requirements. Please note that it may not be technically feasible to delete any information transmitted to and stored on the blockchain, and any such information may remain indefinitely.

8. Children

Our Services are not intended for use by children. If we learn that we have collected personal information through our Services from a child without the consent of the child's parent or guardian as required by law, we will endeavor to delete it.

9. 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. We may also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email (if you have an account where we have your contact information) or another manner.

10. Contact Us

If you have any specific questions about this Privacy Policy, you can reach us by email at data-privacy@recall.foundation.

If you wish to lodge a complaint about how we process your personal information, you can contact us using the email provided above. We will endeavor to respond to your complaint as soon as possible. Depending on where you reside, such as if you reside in the European Economic Area or United Kingdom, you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred.

General Data Protection Regulation (GDPR) – European Representative

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), the Recall Foundation has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:

• by using EDPO's online request form: https://edpo.com/gdpr-data-request/
• by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium

UK General Data Protection Regulation (GDPR) - UK Representative

Pursuant to Article 27 of the UK GDPR, the Recall Foundation has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:

• by using EDPO's online request form: https://edpo.com/uk-gdpr-data-request/
• by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom