# Privacy & Policy

This Privacy Policy (this “Policy”) explains how **Omnex Layer Labs Company Limited** (“**Omnex Layer**” or “**we**”) may collect, use, disclose, and protect personal data through our portal website (the “**Site**”) in connection with your access to and/or use of the Site.

This Policy does not apply to any products, services, websites, or content offered or provided by third parties, and we are not responsible in any way for those third-party offerings. Please review any separate privacy policies made available by those third parties.

### 1. Information We Collect

We collect the following personal data from users of the Site:

#### (a) Information You Provide to Us

When you access the Site, we may collect the following information:

* **Your name, email address, company/organization, and role:** This information is provided if you complete and submit certain enquiry forms via the Site or if you contact us via email through the Site.
* **Your public wallet address:** This is provided when you connect your wallet to **Omnex Layer**.

#### (b) Information Collected Automatically

We may automatically collect certain limited information when you access, use, or interact with the Site or complete and submit certain enquiry forms via the Site, such as:

* Device type, browser type and version
* Operating system and version
* IP address
* Publicly available blockchain data
* Cookies – see “**Cookies**” below

We may also collect analytics regarding aggregate numbers of users and usage types (e.g., number of page views, event counts, and aggregate acquisition metrics), and aggregate location data across users, including countries and regions from which users access the Site. Such data is collected on an anonymous basis and does not identify you personally.

For personal data collected via cookies and similar technologies that remember preferences and help detect irregular or fraudulent activity, see section **3** below.

We will indicate (e.g., by an asterisk on a form) where it is mandatory for you to provide personal data to us. If you do not provide such mandatory data, we may not be able to provide the Services or otherwise engage with you.

If you provide personal data of any other individual to us, you must give them a copy of this Policy and ensure that you have obtained their consent to provide their data for processing in accordance with this Policy.

***

### 2. How We Use Your Information

We may use your personal data to:

* Communicate essential service-related information;
* Provide, maintain, support, and improve the Site and respond to inquiries related to the same;
* Comply with applicable legal and regulatory obligations;
* Prevent, detect, and investigate fraudulent, abusive, or harmful activities;
* Allow you to personalize or customize your experience with the Site and **Omnex Layer**;
* Send direct marketing communications to you about the Site, **Omnex Layer**, the Services, events, and other products or services offered by us, our affiliates, or selected third parties that we believe may be of interest to you — but only with your consent. You may unsubscribe at any time;
* Provide support for the Services, including resolving issues and responding to your questions and feedback;
* Analyze usage trends to manage access to the Site;
* Enforce our Terms of Use, this Policy, and/or other policies; and
* Take other actions that you have asked us to take and provided consent for.

You acknowledge and agree that we may use information that does not identify you personally (including aggregated or de-identified data) for any purpose except where prohibited by applicable law.

***

### 3. Cookies

While you access the Site, we may use the industry practice of placing a small amount of data saved by your browser (“cookies”). This information can be stored on your computer or other devices used to visit our Site. As described above, we and certain third parties may collect information using cookies and other similar technologies.

We use cookies to provide content or features on the Site, remember you and your preferences, and improve your user experience by making the Site more efficient and relevant. We, our service providers, and/or agents acting on our behalf use the following types of cookies on the Site:

#### • Strictly Necessary Cookies

These cookies are essential for the Site and **Omnex Layer** to function properly and cannot be disabled. Without them, certain Site features cannot be provided. These cookies do not gather information for advertising purposes. For example, they are used to:

* Remember information entered when performing activities on the Site (e.g., “remember me”);
* Pass information between pages (e.g., during form submissions);
* Read your browser and device settings to optimize Site display;
* Identify misuse of the Site or **Omnex Layer**;
* Load the Site uniformly to maintain accessibility; and
* Prevent fraud.

#### • Functional Cookies

We use functional cookies to remember your preferences and tailor the Site’s features to provide enhanced and personalized content. These are not used for advertising. While these cookies can be disabled, doing so may reduce functionality. For example, we use them to:

* Provide a personalized experience (e.g., remembering customizations to the Site);
* Retain information entered during Site interactions; and
* Store preferences such as language, location, dark/light mode, layout, and scroll settings.

#### • Performance or Analytics Cookies

These cookies help us understand how the Site is accessed, used, and performs. They may collect information about content viewed, your first and subsequent visits, referring and exit websites, and technical/geographic information. Such data helps us:

* Maintain and continually improve **Omnex Layer** and the Site;
* Track visitor numbers and session lengths;
* Determine page visit order and feature usage;
* Identify Site performance issues; and
* Assess which areas of the Site require improvement.

You can configure your browser to block or alert you about cookies, though this may affect functionality or your user experience.\
Session cookies are created when you begin browsing the Site and are deleted when the browser is closed. Persistent cookies remain stored on your device until a specific expiration date.

***

### 4. Data Sharing and International Data Transfers

We may share your personal data, subject to applicable confidentiality and security obligations, as follows:

(a) **With our affiliates**, where necessary to provide or improve the Services, comply with legal obligations, support the Site and our operations, prepare internal reports, or otherwise operate our business; and\
(b) **With third-party service providers** that support our Site, Services, and operations — including banks, accountants, auditors, legal advisors, IT providers, marketing firms, event hosts, logistics and analytics providers, email delivery services, database management companies, and other professional service providers.

We may also share your personal data in connection with a business transaction, including mergers, acquisitions, reorganizations, or a sale or transfer of all or part of our assets.

We may disclose personal data as required by applicable law, regulation, court order, subpoena, or other binding request from a competent authority, or to establish, exercise, or defend legal claims, in any jurisdiction.

Your personal data may be transferred to other jurisdictions outside your country of residence. Such jurisdictions may not have data protection laws equivalent to those in your own country. In such cases, we will take reasonable measures to ensure appropriate safeguards that provide a comparable level of protection.

You may also authorize us to share your information with other entities or individuals of your choosing. Such disclosures will also be governed by the privacy policies of the recipients.

***

### 5. Data Security

We implement reasonable technical and organizational measures to protect your personal data against unauthorized or accidental access, processing, loss, or use.

However, as data transmission over the internet, wireless networks, or other channels cannot be fully secured, we cannot guarantee the privacy or security of data transmitted through such means.

***

### 6. Children’s Information

The Site and **Omnex Layer** are intended for general users aged 18 years or older and are not directed at children. We do not knowingly collect personal data from minors (e.g., under 18 years of age in Hong Kong).

If you believe such data has been collected in error, please contact us at **<privacy@omnexlayer.io>** to notify us. If we discover that a minor’s data has been submitted, we will take steps to delete it as soon as possible.

***

### 7. Changes to This Policy

We reserve the right to modify this Policy from time to time by updating it on the Site. Please review it periodically for any changes. Where required by applicable law, we will obtain your consent to significant updates.

***

### 8. Your Rights

You have certain rights under applicable data protection laws regarding your personal data, including the right to:

* Request access to, correction of, or deletion of your personal data;
* Request information about how your personal data is processed;
* Withdraw consent to processing of your personal data; and
* Lodge a complaint about our data processing activities.


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