We value and respect your right to privacy, and to this end are committed to protecting your personal data provided to us directly or indirectly. This privacy policy sets out our commitment and explains in detail what information we may gather from your visit to our platform and, why and how your personal data may be processed when you use our services.

This policy (the Policy) outlines how we collect, use, store and disclose your personal data. Please take a moment to read about how we collect, use and/or disclose your personal data so that you know and understand the purposes for which we may collect, use and/or disclose your personal data. By accessing the website at https://eclipsefi.io/ (the Website) or the app athttps://eclipsefi.io/projects/ (the App), you agree and consent to Luna Launcher Protocol Inc DBA “Eclipse Fi” (the Company), its related corporations, business units and affiliates, as well as their respective representatives and/or agents (collectively referred to herein as Eclipse Fi, us, we or our), to, collect, use, disclose and share amongst themselves the personal data/information and to disclose such personal data/information to relevant third-party providers. This policy supplements but does not supersede nor replace any other consent which you may have previously provided to us nor does it affect any rights that we may have at law in connection with the collection, use and/or disclosure of your personal data. We may from time to time update this Policy to ensure that this policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, the prevailing terms of this policy shall apply. For the avoidance of doubt, this Policy forms part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions.

This policy describes how Eclipse Fi may collect, use, disclose, process and manage your personal data, and applies to any individual’s personal data which is in our possession or under our control.

“Personal data” means data, whether true or not, about an individual who can be identified (i) from that data, or (ii) from that data and other information to which the organisation has or is likely to have access. Some examples of personal data that the company may collect are:

1. personal particulars (e.g., name, contact details, residential address, date of birth, identity card/passport details, social media handles and other social media profile information);
2. financial details (e.g., income, expenses, credit history and/or credit card and bank information);
3. information about your use of our services and website and the app;


4. usernames and password, third party account credentials (such as your Facebook login credentials, Google login credentials) and IP address;
5. banking information (e.g., account numbers and banking transactions);
6. private or public cryptographic key relating to addresses on distributed ledger networks and/or similar information; and/or
7. personal opinions made known to us (e.g., feedback or responses to surveys).

Personal data may be collected when you interact with our services or use the website and the app, or may be received by Eclipse Fi from third-party databases or service providers that provide business information.

Eclipse Fi may collect, use and/or disclose your personal data for its business purposes, including operations for these purposes. These may include, without limitation, the following:

1. Developing and providing facilities, products or services (whether made available by us or through us), including but not limited to:
   1. providing a platform for third-parties to offer digital tokens or virtual currencies for purchase;
   2. acting as intermediaries through any blockchain, network or platform developed or managed by us;
   3. recording and/or encryption on any blockchain, network or platform developed or managed by us;
   4. promoting advertisements or marketing material, whether from us or third parties;
   5. various products and/or services (whether digital or not, and whether provided through an external service provider or otherwise);
   6. providing, managing or accessing digital wallets for holding digital assets;
   7. making payments for participation in any blockchain, network or platform developed or managed by us (as applicable);
   8. various products and/or services related to digital assets;
   9. transactions and clearing or reporting on these transactions;
   10. assessing and processing applications, instructions, transactions, or requests from you or our customers.
2. Your information in relation to your usage of services through your device such as your IP address, the type of device you use to access our platform, device information, browser type, information about your browser, date and time you visit our platform, volume of data transmitted and network operator. This information will either be directly obtained by platform or through third party service providers
3. For promoting advertisements or marketing material, whether from us or third parties.
4. Airdrops or other community rewards from the listed projects on Eclipse Fi.
5. Client relationship management purpose, analyse the services you may be interested in, for internal administrative and operational processes.
6. We may also send invitations and information about events, publications, and services provided by the launchpad.
7. We may provide the essential user data to the Initial Dex Offerings (IDO) taking place at our launchpads.
8. We would collect analytics for the purposes of developing or improving our services, security, service quality, and advertising strategies.
9. We ensure that our interface and/or platform is seamlessly accessible for all users around the world, except users in the prohibited jurisdictions.
10. Communicating with you, including providing you with updates on changes to products, services and banking facilities (whether made available by us or through us) including any additions, expansions, suspensions and replacements of or to such products, services and banking facilities and their terms and conditions
11. Managing our infrastructure and business operations and complying with internal policies and procedures.
12. Responding to queries or feedback.
13. Addressing or investigating any complaints, claims or disputes
14. Verifying your identity for the purposes of providing facilities, products or services, which would require comparison of your personal information against third party databases and/or provision of such information to third party service providers.
15. Conducting credit checks, screenings or due diligence checks as may be required under applicable laws, rules, regulations or directives.
16. Complying with all applicable laws, regulations, rules, directives, orders, instructions and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities.
17. Monitoring services provided by or made available through us on the platform.

We may also use personal data for purposes set out in the terms and conditions that governs our relationship with you.

We use personal information we collect through the services as necessary for the following purposes:

1. For providing the services: We use personal information to operate, maintain, and provide features of the services.
2. For communicating with you: We use personal information to contact you for administrative and informational purposes, such as to respond to your inquiries, or to invite you to join the services.
3. For understanding and improving the services: We use personal information to understand and analyse the usage trends and preferences of our users in order to improve the services, and to develop new products, services, features, and functionalities.
4. For compliance with regulations: We use personal information to comply with financial regulations, including verifying your identity by comparing the personal information you provide against third-party databases and public records. We may use the information we collect to investigate or address claims or disputes relating to use of our services, or as otherwise allowed by applicable laws or as requested by regulators, government entities, and official inquiries.
5. For safety and security: We may use your information to help maintain the safety, security and integrity of you and our services, including to protect, investigate and deter against fraudulent, unauthorized, or illegal activities; monitor and verify identity or service access, and combat malware and security risks; perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems; and enforce our agreements with third parties, and address violations of our terms of use or agreements for other Services.
6. Other business purposes: We use personal information for compliance, risk management, and other business purposes, such as for applicable laws and regulations, fraud monitoring, and prevention.

When you access our website and the app, we, or companies we hire to track how our website and the app is used, may place small data files called cookies on your computer or other device. For example, we send a "session cookie" to your computer any time you log in to your account. This type of cookie helps us to recognize you if you visit multiple pages on our site during the same session, so that we don't need to ask you for your password on each page. We use these technologies to recognize you as a user, customize content and advertising, measure promotional effectiveness, and collect information about your computer or other access device to mitigate risk, help prevent fraud, and promote trust and safety.

You may set up your web browser to block cookies from monitoring your website visit. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies, you may not be able to use certain features and functions of our website and the app.

This Privacy Policy grants you certain rights with respect to your personal data as set out below:

1. Right to Consent: By using our Services and/or on providing your personal data, you agree to allow us to collect, hold, use, and disclose such data in accordance with this privacy policy. You have the right not to consent/provide us any such data, however, if you do so, we may not be able to provide you with the services, or the products and/or services offered through the Platform.
2. Access: You have the right to request details of your personal data from us.
3. Data Erasure: You can request for deletion of your personal data. However, if such data is required for the provision of the services, you may be required to delete your profile and/or may not be able to use our services.
4. Correction: If you believe any personal data held by us is inaccurate, obsolete/outdated, incomplete, irrelevant, or misleading, please contact us to correct such information, or update the same via your account, if allowed.
5. Concerns and Queries: If you have any concerns and queries on how we process, handle, and keep your personal data, please contact us with full details of your concerns and queries. We will take appropriate steps to address them.
6. Unsubscribe: To unsubscribe from our e-mail or to opt-out of any communications, please contact us at the address provided in this privacy policy or where available, use opt-out option.

The fulfilment of any rights above are limited by the availability of such information or functionality by third-party providers and subject to reasonable costs to action. Certain data may be stored on an immutable blockchain at your request and may not be possible to erase or correct.

The platform may contain links to other websites. That website or the app is not governed by this privacy policy. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. Please read the privacy policy and terms and conditions of such websites or the app before using such websites or the app. We have no control over and shall not be responsible for the content, privacy policies or practices of any third-party sites or services.

You are aware that your personal information will continue to be stored and retained by us or by a third-party processor engaged by us for KYC verification while using or accessing our platform and the services, and/or after the usage of the services for a reasonable period of time stipulated under the applicable law.

If you:

1. have queries about our data protection processes and practices;
2. wish to request access to and/or make corrections to your personal data in our possession or under our control; or
3. wish to withdraw your consent to our collection, use or disclosure of your personal data,

please submit a written request (with supporting documents, (if any) to our Compliance Officer at: [email protected] . Our Compliance Officer shall endeavour to respond to you within 30 days of your submission. Please note that if you withdraw your consent to any or all use or disclosure of your personal data, depending on the nature of your request, we may not be in a position to continue to provide our services or products to you or administer any contractual relationship in place. Such withdrawal may also result in the termination of any agreement you may have with us. Our legal rights and remedies are expressly reserved in such event.

We may charge you a fee for processing your request for access. Such a fee depends on the nature and complexity of your access request. Information on the processing fee will be made available to you.

Without prejudice to the inherent risk of sharing and accessing data over the internet, we will use appropriate security measures (organizational and technical) to prevent your personal data from being accidentally lost, used, damaged, or accessed in an unauthorised or unlawful manner, altered, or disclosed. In addition, we will allow access to your personal data only to those employees, agents, contractors and other third parties who have a legitimate business need to know and are subject to a duty of confidentiality. Despite the fact that we have implemented appropriate security measures, we cannot guarantee that your personal data collected will not be shared/disclosed in a way that is inconsistent with this Privacy Policy.

We reserve the right to update this privacy policy at any time and at our sole discretion. Any changes to or modifications of this privacy policy shall be in effect as of the “last updated date” referred to at the top of this page. We encourage you to periodically review this privacy policy. If you do not agree, either partially or wholly with the revised privacy policy, you should discontinue accessing or using our services. Your continued access to and use of our services after any changes to this privacy policy constitutes your consent to any changes and your agreement to continue using the services.

By accessing, connecting, clicking on, using, or engaging in Our Services, you indicate and confirm that you have consented and agreed to the terms of this Privacy Policy. We will not use your Personal Information for any other purpose that has not been covered in this Privacy Policy or the T&C’s without providing you prior intimation or obtaining your consent. If you do not agree, either partially or wholly, to this Privacy Policy, you must immediately discontinue accessing, connecting, using, or engaging in our services and the platform. This Privacy Policy does not apply to services offered by other companies or service providers or other websites or the app linked from our platform.

As provided in our T&C’s, our services are not intended for anyone under the age of 18 or minor under the law of the country where the services are accessed (“Minor”). We do not intend to or knowingly collect any personal data related to a minor. If you believe that personal data of any minor has been collected or provided to us, please contact us.

For queries on any aspect of this privacy policy or to provide any feedback, please contact our office at: [email protected]