This Privacy Policy is part of the 3thix Terms of Service at https://www.3thix.com/privacy. All terms, conditions, and terminology are consistent with the Terms of Service, and the Terms of Service are incorporated into this document by reference.

This policy governs the use of the 3thix website at https://3thix.com and the associated tools and services.

Collectively, the website and the associated tools and services are referred to as the “Services” in these terms. The operator may offer other products and services.

In addition to the website and the associated tools and services, the Services include:

• The 3thix payments and advertising platform
• The 3thix marketing and ecommerce websites

The Services do not include outside websites or platforms which may be linked or interconnected to the Services. Such outside platforms may have their own terms of service, which control for all transactions on such platforms. These outside platforms may include, but are not limited to:

• 3rd party payment platforms or services
• Anti-fraud, AML/BSA, and user identification services

3thix, Inc., a Delaware corporation, operates the Services. It and its affiliates are referred to in this document as the “operator,” “we,” or “us.”

3thix, Inc., a Delaware corporation, operates the Services. It and its affiliates are referred to in this document as the “operator,” “we,” or “us.”

The Blockchain

Blockchain technology, also known as distributed ledger technology (or simply ‘DLT’), is at the core of our business. Blockchains are decentralized and made up of digitally recorded data in a chain of packages called ‘blocks’. The manner in which these blocks are linked is chronological, meaning that the data is very difficult to alter once recorded. Since the ledger may be distributed all over the world (across several ‘nodes’ which usually replicate the ledger) this means there is no single person making decisions or otherwise administering the system (such as an operator of a cloud computing system), and that there is no centralized place where it is located either.

This means that by design, a blockchain’s records cannot be changed or deleted and is said to be ‘immutable’. This may affect your ability to exercise your rights such as your right to erasure (‘right to be forgotten’), or your rights to object or restrict processing, of your personal data. Data on the blockchain can’t be erased or changed. Although smart contracts may be used to revoke certain access rights, and some content may be made invisible to others, it is not deleted.

In certain circumstances, in order to comply with our contractual obligations to you (such as delivery of tokens) it will be necessary to write certain personal data, such as your wallet address, onto the blockchain; this requires you to execute such transactions using your wallet’s private key.

In most cases ultimate decisions to (i) transact on the blockchain using your wallet address, as well as (ii) share the public key relating to your wallet address with anyone (including us) rests with you.

If you want to ensure your privacy rights are not affected in any way, you should not transact on blockchains as certain rights may not be fully available or exercisable by you or us due to the technological infrastructure of the blockchain. The blockchain is available to the public and any personal data shared on the blockchain will become publicly available.

Individuals under the Age of 18

As per our Terms of Service, individuals under the age of 18 are not permitted to use the Services. As such, we do not knowingly collect, solicit or maintain personal data from anyone under the age of 18 or knowingly allow such persons to register for the Services.

In the event that we learn that we have collected personal data from an individual under age 18, we will use commercially reasonable efforts to delete that information from our database. Please contact us if you have any concerns. If you are a parent or guardian and you are aware that your child has provided personal data to the Services, please contact us so that we may remove such data. Note that we cannot delete information stored on public cryptographic blockchains.

Collecting

Things you and others do and provide.

Information and content you provide. We collect the content, communications and other information you provide when you use our Services, including when you create an account, initiate the use of the Services, create or share content, and message or communicate with others. This information may include, but is not limited to:

• Name
• Email
• Address
• Phone Number
• SSN (or equivalent)
• Financial Information
• Date of Birth
• Citizenship
• Payment Information
• Asset ownership
• Information used to verify your identity. If required to help us verify your identity, you may provide us a copy of your driver’s license, passport or other government issued ID. If required to help us verify your residence, you may provide us with a utility bill, lease or other proof of residence. You may also provide us other verification documents, such as bank statements reflecting the source of funds, to meet U.S. Bank Secrecy Act or anti-money laundering laws, US Treasury department rules or regulations or other legal requirements. If you seek to invest through an entity or corporation, you may provide us with documentation relating to the entity’s jurisdiction of formation, legal status and ownership. By providing the verification information and documents mentioned above, you also provide us information within those records, which may include characteristics of protected classifications like your sex, age, national origin, and citizenship.
• Financial information. In order to transfer funds, you may need to provide us and our third-party financial providers or partners with certain account and other payment information, such as information needed to make payment via ACH, wire, electronic checks, cryptocurrency, foreign currency or any other payment methods. You may agree to your personal and financial information being transferred, stored, and processed by such third parties in accordance with their respective privacy policies.
• Your usage. We collect information about how you use our Services, such as the types of content you view or engage with; the features you use; the actions you take; the people or accounts you interact with; and the time, frequency, and duration of your activities.
• Information about transactions made on our Services. If you use our Services for transactions of any kind, we collect information about them.
• Things others do and information they provide about you. We also receive and analyze content, communications, and information that other people provide when they use our Services.

Cookies

We, and our partners, use cookies and similar technologies to give you the best possible content and experience. Cookies are used to remember you and to collect information about how you interact with the Services. If you have an account with the Services, we may link this usage data with other information. You may have the option to either accept or refuse these cookies. If you choose to refuse, you may not be able to use some portions of the Services.

Device Information

As described below, we collect information from and about the computers, phones, and other web-connected devices you use that interact with our Services, and we combine this information across different devices you use.

Information we obtain from these devices includes:

• Device attributes: information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins.
• Device operations: information about operations and behaviors performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).
• Identifiers: unique identifiers, device IDs, and other identifiers.
• Data from device settings: information you allow us to receive through device settings you turn on, such as access to your GPS location, camera or photos.
• Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed and, in some cases, information about other devices that are nearby or on your network.
• Cookie data: data from cookies stored on your device, including cookie IDs and settings.
• Information necessary to enable push notifications: if you enable push notifications in our services, we will collect information from your device as may be necessary to enable such notifications

Information from partners

The Services may use website and application tracking services such as Google Analytics to gather information about the computers and devices that connect to them. Although Google Analytics plants a cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser.

See the “Third-Party Data Collection” section for additional information on third-party collection of data.

When using the Services

When using the Services, we may collect and process personal data. The data will be stored in different instances. We collect and use this information to provide you the Services and to debug issues and provide support.

On the Blockchain the following data may be stored:

• Addresses of externally owned accounts
• Transactions made;
• Token balances.

You agree that this is a general requirement and compliance with regulatory requirements is required in all jurisdictions and is deemed to be part of recommendations as given by the operator.

The data will be stored on the Blockchain. Given the technological design of the blockchain, this data will become public and it will not likely be possible to delete or change the data at any given time.

1. In our web servers, we will store the following data:
   
   Addresses of externally owned accounts; and
   
   Transactions made


2. Log Data
   
   the Internet protocol address (“IP address”); and
   
   transaction id/ Hash.

Tracking and Uses

We use the information we have (subject to choices you make) as described below and to provide and support the Services. Here’s how:

• Device attributes: information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins.
• Device operations: information about operations and behaviors performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).
• Identifiers: unique identifiers, device IDs, and other identifiers.
• Data from device settings: information you allow us to receive through device settings you turn on, such as access to your GPS location, camera or photos.
• Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed and, in some cases, information about other devices that are nearby or on your network.
• Cookie data: data from cookies stored on your device, including cookie IDs and settings.
• Information necessary to enable push notifications: if you enable push notifications in our services, we will collect information from your device as may be necessary to enable such notifications

Tracking and Uses

We use the information we have (subject to choices you make) as described below and to provide and support the Services. Here’s how:

• Provide, personalize and improve our Services: We use the information we have to deliver our Services, including to personalize features and content.
• Information across devices: We connect information about your activities on different devices to provide a more tailored and consistent experience.
• Product research and development: We use the information we have to develop, test and improve our Services, including by conducting surveys and research, and testing and troubleshooting new products and features.
• Location-related information: We use location-related information—such as your current location, where you live, the places you like to go, and the businesses and people you’re near—to provide, restrict, personalize and improve our Services.
• Ads and other sponsored content: We use the information we have about you—including information about your interests, actions and connections—to select and personalize ads.

Because recognition of the Do Not Track HTTP header feature of your web browser is not standardized, the Services don’t recognize it for tracking purposes.

Third-Party Data Collection

Third parties may collect or receive certain information about you and/or your use of the Services to provide content, ads (including personalized ads), or functionality, or to measure and analyze ad performance, in or through the Services. These third parties include:

Google Cloudflare AWS X

You may choose whether to receive certain personalized (also known as targeted) advertising from participating ad networks, audience segment providers, ad serving vendors, other service providers or entities by visiting websites operated by the Network Advertising Initiative and Digital Advertising Alliance or if you are a user in the European Economic Area, Your Online Choices. We adhere to the Self-Regulatory Principles for Online Behavioral Advertising.

Retention

The Services may retain the information we gather about you for an unlimited period to ensure continued service provision.

You can request deletion of your personal data by contacting the email address provided in this policy. A valid request must include enough information to identify your personal data. Note: Information stored on public cryptographic blockchains cannot be deleted.

Sharing

The Services may share your information under the following circumstances:

• Service providers and partners: We share data with third parties who help operate the Services, such as marketing and analytics partners, identity verification services, and payment processors. Access is granted only while you have an account.
• Corporate transactions: Your data may be transferred in the case of mergers, asset sales, or similar transactions.
• Legal obligations and enforcement: We may disclose your data in response to legal requests, fraud prevention, terms enforcement, and regulatory requirements. When possible and lawful, you’ll be notified.
• Affiliates and internal use: We share data with our affiliates, who are bound by this privacy policy. This helps fulfill legal, regulatory, and operational obligations.
• Regulatory authorities: We may share your information with U.S., state, or international regulators (e.g., SEC, FINRA) to comply with legal obligations.
• Linked third-party sites: The Services may link to third-party websites. These are not controlled by us and have separate privacy practices. Always review their terms and policies.

Third Parties we may share data with include:

• VerifiNow
• Payment processors such as WorldPay, Adyen, and Nuvei
• Banking partners such as Cross River Bank and First Citizens Bank

Opt-Out

To opt out of marketing communications, click “Unsubscribe” in those emails or email us at unsubscribe@3thix.com. Note that you cannot opt out of service-related or legally required communications.

Security

We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, use, or disclosure. Access is restricted to personnel who need it and are bound by confidentiality obligations.

We also maintain procedures to detect and respond to data breaches. Where legally required, we will notify you and regulators of such breaches.

Contact

If you have any comments or questions about the privacy policies of the Services, please contact us at privacy@3thix.com.

Changes

The Services may update this privacy policy at any time. Please check this page periodically to stay informed of any changes.

CCPA Addendum – Compliance

You agree to do your respective parts to comply with the California Consumer Privacy Act (CCPA) and its regulations, consistent with the operator’s role as a “service provider”, and not as a “third party” under the law.

Cooperation

Whenever feasible and lawful, both you and the operator agree to provide prompt notice to the other party regarding user rights requests, regulatory inquiries, and other communications under the CCPA.

Both parties agree to cooperate in good faith to respond to and honor these communications and fulfill other obligations as required by the CCPA.

Prohibitions

The operator is prohibited from the following actions with personal information covered under the CCPA that you disclose:

• No sale of personal information: The operator may not sell personal information disclosed by you.
• No unauthorized use or disclosure: The operator may not retain, use, or disclose personal information for purposes beyond performing the services outlined in the Terms of Service, including any unrelated commercial purpose.
• No use outside the business relationship: The operator may not use or disclose such information beyond the scope of the direct business relationship between the operator and you.

Certification

The operator certifies that it understands and will comply with the restrictions outlined in the Prohibitions section above.

Minimization

Both you and the operator agree to limit the use of personal information covered by the California Consumer Privacy Act (CCPA) to what is reasonably necessary and proportionate to achieve the purposes described in the Terms of Service. This is consistent with the definition of a “business purpose” under the CCPA.

Subcontracting

The operator agrees to ensure that any subcontractor processing your personal information under the CCPA qualifies as a “service provider” and not a “third party” under the law.

Personal Information

The operator has collected and used for a business purpose, within the last 12 months, the following categories of personal information:

• Identifiers: Including contact information, government-issued IDs, cookies, and similar data.
• Information protected against security breaches: Such as your name, financial account details, driver’s license number, social security number, usernames and passwords, and health/medical information.
• Protected classification information: Including race, gender, ethnicity, and other legally protected attributes.
• Other personal information: Including commercial data, Internet or electronic activity, geolocation, audio/video data, employment and education history, biometrics, and derived inferences.

The operator affirms that no such information has been sold or disclosed in the past 12 months, as of the date of this agreement.

Previously Submitted Information

To request access to or changes to any previously submitted personal information, please contact the operator using the contact information provided above under the “Contact” section.

Conflicts

If there is any conflict between the terms of this addendum and those in the Terms of Service or Privacy Policy, the terms of this addendum shall take precedence.

GDPR / EU Addendum

Transferring Your Data Outside of the EU

Personal data referenced in this document is stored in the United States. We use Amazon Web Services (AWS), which is based in the US and certified under the EU-US Privacy Shield. Additionally, we use services like Google Analytics and Firebase, both operated by Google LLC, also certified under the EU-US Privacy Shield.

However, when using blockchain-related functionality, please be aware that blockchain is a decentralized, global public network. Any personal data written to the blockchain may be transferred to and stored across different jurisdictions globally.

Your Rights as a Data Subject

Under Regulation EU 2016/679 (General Data Protection Regulation or ‘GDPR’), you have specific rights regarding your personal data. These include the right to be informed, access, and request further details on how your data is used.

Right Information and access

You have the right to request information about the processing of your personal data, including the source of the data if it was not provided by you directly. This document offers that information, and you may contact us if you require further details.