Privacy Policy

EFFECTIVE DATE: Febuary 15, 2024

Oyl Corporation, d/b/a Oyl Dynamics and our subsidiary Sandshrew, Inc. (collectively, "Company," "we" or "us") provide Sandshrew (operated by Sandshrew, Inc.), a high-performance remote procedure call (RPC) service for bitcoin and ordinals. and the Oyl wallet (operated by Oyl Dynamics), which enables integration of multiple marketplaces, digital assets and liquidity sources into a single wallet. In this Privacy Policy ("Policy"), we describe Company's collection, use and disclosure of personal data related to Sandshrew, Oyl and other Company products and services that display this Policy (collectively, the "Products"), as well as Sandshrew.io, Oyl.io and other Company websites that display this Policy (collectively the "Sites").

This Policy applies to the personal data that Company collects and processes as a "business" or "controller" related to the Sites and Products (collectively, the "Services"). including the personal data we collect when you register for, use or interact with the Services, visit the company website, contact us about the Services, or otherwise interact with us related to the Services. This Policy does not apply to any products or services that do not display this Policy.

Your use of our Services, and any dispute over privacy, is subject to this Policy and the Company Terms of Service, available at sandshrew.io/privacy-policy, including their applicable limitations on damages and the resolution of disputes.

1. Information Collected

As further described below, we may collect personal data about you directly (e.g., when you register or contact us) as well as from others (e.g., if you have an enterprise or team account, we may receive personal data about you from your account admin). We may also collect or derive information about you and your use of the Services, which may be personal data.

Information Directly Collected. The personal data we collect varies depending upon your use of the Services and interactions with us, but generally includes:

  • Registration and account data. Users may register for a Company account as an individual developer or as part of a team or enterprise account To register, users can create an account by providing their email address and creating a username and password, or by logging in with their Github account We may also collect addition optional profile information about you, such as a photo, additional email addresses, job title, and skills and experience
  • Enterprise and Team Accounts. Enterprise and team accounts must appoint one or more designated admins to administer and manage the account on behalf of the team or enterprise If you are an enterprise or team user, your user account may be registered and created as well as administered and managed by an account admin for your enterprise or team account, who can adjust your privacy and other account settings and access, use and delete your account ane account data (including content)
  • Your content. When you use our Services, we collect Personal Data included as part of the information you provide such as code, inputs, text, documents, images, or feedback
  • Support and other communications. When you seek customer support, we collect details about your support issue, including any content, files or data submitted as part of your support request When you email, call, or otherwise communicate with us and with members of our team, we collect and maintain a record of your contact details, communications and our responses We also maintain records communications and information that you post in chat sessions, forums and other areas of the Services
  • Payments and billing. We and our third-party payment processors collect payment and billing information so that we can bill you for the Services such as credit card number and applicable billing address We also maintain records about your past payments and transactional account records such the volume of request processed by you or through your account
  • AML and KYC data. When you use certain Services, we collect additional information necessary to identify you and comply with anti-money laundering (AML) and know-your-customer (KYC) requirements, such as (a) source of funds for participating in token launches; (b) additional identity information, such as your country and place of birth, and nationality; and (c) other information required to comply with anti-money laundering (AML) laws and know-your-customer (KYC) requirements We may run checks of your information against third-party databases and sources and maintain records of this data
  • Surveys and feedback. We collect information that you provide us as feedback or submit to us through surveys, reviews, or other interactive features
  • Events and requests. We also collect personal data related to your participation in our events as well as other requests that you submit to us related to our Services For example, it you register for or attend an event that we host or sponsor, we may collect information related to your registration for and participation in such event When you fill out a "Contact Us" form, signup for our mailing lists, or otherwise request information from us, we collect and maintain records of your requests

Information Collected When You Use Sandshrew as default RPC provider. When you use Sandshrew as your default RPC provider, Company will collect your IP address and your wallet address when you send a transaction. However, if youre using your own node or a third-party RPC provider, then Company will collect your IP address or wallet address (but you should be aware your information will be subject to whatever information collection performed by the RPC provider you are using and their terms regarding such collection).

Third Party Content and Integrations. The Oyl wallet allows you to integrate different marketplaces and liquidity sources to allow users to make Bitcon purchases with their own keys directly from the wallet. Accordingly, you may view, have access to, and use the informational content, products, or services of one or more third parties ("Third Party Services"). In each such case, you agree that you view, access or use such Third Party Services and related content at your own election. These Third Party Services have their own Privacy Policies. It is your responsibility to understand the terms and conditions of Third Party Services, including how those service providers use any of your information under their privacy policies.

Information We Derive or Collect Automatically. We may derive and automatically collect personal data about you and related to your use of our Services. including

  • Activities and usage Data. We collect activity and usage information related to your use of the Services such as information about volume of requests processed by your and through your account, the features used, time spent logged in, and your activities and interactions with others within the Services
  • Device and browsing information. We use cookies, log files, pixel tags and other tracking technologies to automatically collect information when users access or use our Sites or certain Services, such as IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, internet service provider, referring and exiting URLs, operating system, language, clickstream data, and similar device and usage information For more information see Section 4 Cookies Targeting and Analvtics, below

Other Sources. We may collect personal data about you from third party sources, such as public databases, marketing partners and lead generation sources, third party platforms or other third parties. For example:

  • Marketing and lead data. We may receive lead and prospect information from third parties adour prospective customers that may be interested in our Services We may also engage with third parties to enhance or update our customer information
  • Third-party platforms. If you log in to our Services with Github or another third-party account or engage with us or our content on third party platforms or social media, we may collect personal data about you from that third party platform or account These third-party platforms and services control the information they collect and share about you For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies
  • Third-party integrations. You may be able to integrate data from third party accounts (including Third Party Services) If you grant us permission to access this data by enabling this sharing, we will access and store this content For information about such sharing, including to revoke our access to your third-party content, you should consult their respective privacy notices and terms and review your privacy settings for such third-party account
2. Purposes of Use and Processing

Generally. we collect, use, disclose and otherwise process the personal data we collect for the following ourposes and as otherwise requested or authorized by you:

  • Services and support. To provide and operate our Services, communicate with you about your use of the Services provide troubleshooting and technical support respond to your inquires, fulfill your orders and requests, process your payments, communicate with you about the Services and for similar service and suport purposes
  • Analytics and improvement. To better understand how users access and use the Services, and our other products and offerings and for other research and analytical purposes such as to evaluate and improve our services and business operations, to develop services and features, and for internal quality control and training purposes
  • Customization and personalization. to tailor content and experiences within the Services, including to offer location customization and personalized help and instructions
  • Marketing. For marketing and advertising purposes For example, to send you information about our Services, such as offers, promotions, newsletters and other marketing content, including affiliate and third-party products and services we think may interest you, as well as any other information you sign up to receive
  • Research and surveys. To administer surveys and questionnaires, such as for market research or member satisfaction purposes
  • Security and protection of rights. To protect the Services and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Service
  • Compliance and legal process. To comply with the law and our legal obligations, to respond to legal process and related to legal proceedings
  • General business and operational support. To consider and implement mergers acquisitions, reorganizations, bankruptcies, and other business transactions, and related to the administration of our general business, accounting, auditing, compliance, recordkeeping, and legal functions
3. Disclosures of Personal Data

We may disclose the personal data that we collect as necessary for the purposes described above, including as follows:

  • Vendors and service providers. We may disclose personal data we collect to our service providers, processors and others who perform functions on our behalf These may include, for example, IT service providers, help desk, payment processors, analytics providers, consultants, auditors and legal counsel
  • Our affillates. We may disclose personal data we collect to our affiliates and subsidiaries, who will use and disclose this personal data consistent with the principles of this Policy
  • Enterprise and team accounts. If you have an enterprise or team account, your organization's admin(s) may access, utilize and share your account data (including your content and files, API keys, details on how you use the Services, and other personal data), add and remove users from your team or enterprise account, and delete your account and any account data (including any content you have created or contributed to in addition, other enterprise or team users may be able to access (read), edit (write), share and contribute to your content and files
  • Third party providers and networks. We may disclose or make available personal data to third partv platforms and providers that we use to provide or make available certain features or portions of the Services, or as necessary to respond to your requests
  • Marketing. We may upload customer list information (such as emall address and other contact information) to third party platforms so that we can better target ads and content to current and prospective customers across third party sites and social media platforms In some cases, these third parties may help us to enhance our customer lists with additional demographic or other information, so we can better target our advertising and marketing campaigns We may also make browsing and user data available (e g , via cookies and pixels on our Site) to third parties in support of our marketing, analytics, advertising and campaign management (see Section 4 Cookies, Targeting and analytics for more information) Please note that we do not share your content files or transaction data with third parties for marketing and advertising purposes
  • In support of business transfers. If we or our affiliates are or may be acquired oy merged with, or invested in by another company, or it any of our assets are or may be transterred tc another company, whether as part of a bankruptcy or insolvency proceeding or otherwise we may transter the information we have collected from you to the other company We may also share certain persona data as necessary orior to the completion of such a transfer such as to lenders, auditors, and third-party advisors, including attorneys and consultants, asoar o que c loence or as necessarv o oan ore ransier
  • Compliance and legal obligations. We may also disclose personal data to third parties to comply with our legal and compliance obligations and to respond to legal process For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements This may include requlators, government entities, and law enforcement as required by law or legal process In addition, it may include certain disclosures that we are required to make under applicable laws, such as the names of sweeptsakes and contest winners
  • Security and protection of rights. We may disclose personal data where we believe doing so is necessary to protect the Services, our rights and property, or the rights, property and safety of others For example, we may disclose personal data in order to (i) prevent, detect, investigate and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety or legal rights of any person or third party, or (il) enforce, and detect, investigate and take action in response to violations of, our Terms of Service We may also disclose information, including personal data, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions

Aggregate and Non-identifiable Data. We may also use and disclose aggregate, anonymous, and other non-identifiable data related to our business and the Services for quality control, analytics, research, development and other purposes

4. Cookies, Targeting and Analytics

We and our third-party providers use cookies, pixels and similar tools to automatically collect information browsing, activity, device and similar information within our Services. We use this information to, for example, analyze and understand how users access, use and interact witn others through our Services, as well to identify and resolve bugs and errors in our Services and to assess secure, protect, optimize and improve the pertormance of our Services. We may also use cookies, pixels and similar tools to reach visitors to our Sites with targeted advertising and content on third-party sites and services and measure and improve are marketing and advertising. You have certain choices about our use of cookies and tracking within the Services. as described in this section.

Third-Party Analytics and Tools. We use third party analytics tools on the Site and in certain Products, such as Google Analytics. These third-party analytics companies may collect usage data (using cookies, pixels and similar tools) related to our Services on our behalf, in order to provide us with reports and metrics that help us to evaluate usage of our Services and improve performance and user experiences. You can download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at hites://tools.google.com/dipage/gaoptout.

Targeted Advertising. We work with third parties, such as ad networks, channel partners. mobile ad networks, analytics and measurement services and others ("third-party ad companies") to manage our advertising on third-party sites, mobile apps and online services. We may share certain information with these third-party ad companies, and we and they may use cookies, pixels, and similar tools to collect usage and browsing information on our Sites. as well as on third-party sites, apps and services, such as IP address, location information, device ID, cookie and advertising IDs, and other identifiers, as well as browsing information. We and these third-party ad companies use this information to provide you more relevant ads and content on third-party sites and apps, and to evaluate the success of such ads and content.

  • Browser settings. If you wish to prevent cookies from tracking your activity on our website or visits across mulaple websites, you can set your browser to block certain cookles of notify you when a cookie is set; you can also delete cookies The Help portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notity you when you receive a new cookie, or how to delete cookies Visitors to our Services who disable cookies will be able to browse the Site, but some features mav not function
  • Industry ad choice programs. You can also control how participating third-party ad companies use the information that they collect about your visits to our websites and use of our mobile applications, and those of third parties, in order to display more relevant targeted advertising at: https://aboutads info/choices (Digital Advertising Alliance) You may also download the DAA AppChoices (https://youradchoices com/appchoices) tool in order to help control interest-based advertising on apps on your mobile device) Please note that opting out of participating ad networks does not opt you out of being served advertising You may continue to receive generic or "contextual" ads as well as targeted ads on other websites from companies that do not participate in the above programs
5. Your Privacy Choices

Review, correction and deletion. You can update much of the personal data we maintain about you, by logging into and updating your account data. It you would like to delete your account. please contact us as set forth below. if you are an enterprise or team user. your organization's administrator manages and administers your account, including profile information content and other account data.

Marketing communications.You can opt out of receive marketing emails from us by using the unsubscribe link in the footer of each marketing email we send to you or by logging in to your account and changing your marketing/communications preferences

For more information about our privacy practices and your privacy choices. or to submit a privacy request to us, please contact us as set forth in the "Contact Us" section below.

6. Children / Minors

Our Services are not designed for children and we do not knowingly collect personal data from children under 13. If we discover that a child under 13 has provided us with personal data in violation of applicable law, we will delete such information from our systems. If you're a parent and you believe we have collected your child's information in violation of applicable law, please contact us as set forth below, in Section 9. Contact Us.-

7. Security

We have implemented safeguards that are intended to protect the personal data we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security. There are also certain steps you can take to better protect against unauthorized access to your personal data. For example, you should choose a strong password for your account that is unique to the Services: you should not reuse passwords across multiple sites and services or share your password or API keys with others. If you believe that your password or account has been compromised, please reset your password immediately.

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We change the Last Updated date and post any updates to Policy https://oyl.io/privacy-policy. If we make material changes to how we collect, use and disclose the personal data we have previously collected about you, we will endeavor to provide you prior notice, such as by emailing you or posting prominent notice through on our website or within the Services

9. Contact Us

If you have questions about this Policy or our privacy practices, you may contact us at privacy@oyl.io.