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Privacy Policy

Version 1.0 Last updated February 2, 2026 Effective February 2, 2026

This Privacy Policy ("Policy") describes how HIFI Bridge, Inc. ("HIFI," "Company," "we," "us," "our") collects, uses, discloses, and protects information about you when you visit our website at https://www.hifi.com/ (the "Site") and use our related services (collectively, the "Services"). This Policy applies to information we collect through the Site and Services, as well as when you interact with us through email, telephone, or other means.

Please read this Policy carefully. By accessing or using the Site or Services, you acknowledge that you have read, understood, and agree to be bound by this Policy. If you do not agree to this Policy, please do not access or use the Site or Services.

Note regarding commercial services If you are a customer using HIFI's commercial platform (including our APIs, KYC/KYB services, fiat-to-stablecoin conversion, or payment processing services), the collection and use of your information may also be governed by your Master Services Agreement with HIFI, which may contain additional privacy terms.

Section 01

Information we collect

We collect information in the following ways:

Information you provide

We collect information you voluntarily provide to us, including:

Contact Information: Name, email address, mailing address, telephone number.

Account Information: If you create an account, username, password, and account preferences.

Communications: Information you provide when you contact us, submit feedback, or participate in surveys.

Business Information: If you inquire about our commercial services, company name, job title, and business contact information.

Information collected automatically

When you access or use the Site or Services, we automatically collect certain information, including:

Device Information: Device type, operating system, unique device identifiers, browser type and version, and mobile network information.

Log Information: IP address, access times, pages viewed, links clicked, and the page you visited before navigating to our Site.

Location Information: Approximate location based on your IP address.

Usage Information: Information about your interactions with the Site and Services, including features used and actions taken.

Information from third parties

We may receive information about you from third parties, including:

Analytics Providers: Information about your interactions with our Site and advertisements.

Marketing Partners: Information about your interactions with our marketing campaigns.

Publicly Available Sources: Information from public databases, social media platforms, and other publicly available sources.

Section 02

How we use your information

We use the information we collect for the following purposes:

Provide and Maintain Services: To provide, operate, maintain, and improve the Site and Services.

Communications: To respond to your inquiries, send you technical notices, updates, security alerts, and support messages.

Marketing: To send you promotional communications about our products, services, and events (you may opt out at any time).

Analytics: To analyze usage patterns, trends, and effectiveness of the Site and Services.

Security: To detect, prevent, and address fraud, security incidents, and other harmful activities.

Compliance: To comply with applicable laws, regulations, and legal processes.

Business Operations: To conduct internal research and development, and for other legitimate business purposes.

Section 03

How we share your information

We may share your information in the following circumstances:

Service Providers: With third-party vendors, consultants, and service providers who perform services on our behalf, such as cloud hosting, analytics, email delivery, customer support, and marketing.

Affiliates: With our parent company, subsidiaries, and affiliates for purposes consistent with this Policy.

Business Transfers: In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business.

Legal Requirements: If required by law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of HIFI, our users, or others.

With Your Consent: In any other circumstances where you have provided your consent.

We do not sell your personal information. We may share aggregated or de-identified information that cannot reasonably be used to identify you.

Section 04

Cookies and tracking technologies

We and our third-party partners use cookies, web beacons, pixels, and similar tracking technologies to collect information about your use of the Site and Services.

Cookies: Small data files stored on your device that help us improve the Site and your experience, understand which areas of the Site are useful, and track advertising effectiveness.

Web Beacons: Electronic images that allow us to count users who have visited certain pages and understand email campaign effectiveness.

Analytics: We use analytics services, such as Google Analytics, to help us understand how users interact with the Site.

Managing Cookies: Most web browsers are set to accept cookies by default. You can usually choose to set your browser to remove or reject cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Site.

For more information about the cookies we use and your choices, please see our Cookie Policy.

Section 05

Data retention

We retain your information for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements. The retention period may vary depending on the context and our legal obligations.

Section 06

Data security

We implement appropriate technical and organizational measures designed to protect the security, confidentiality, and integrity of your information. These measures include encryption, access controls, and secure storage. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us at support@hifi.com.

Section 07

International data transfers

Our servers are primarily located in the United States. If you are accessing the Site or Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States and other countries where we or our service providers operate.

Transfer Mechanisms. When we transfer personal data from the European Economic Area, United Kingdom, or Switzerland to countries that have not been deemed to provide an adequate level of data protection, we use appropriate safeguards, including:

• European Commission Standard Contractual Clauses (SCCs) for transfers from the EEA;

• UK International Data Transfer Agreement (IDTA) or UK Addendum to the EU SCCs for transfers from the UK;

• Swiss-approved Standard Contractual Clauses for transfers from Switzerland; or

• Transfers to countries recognized as providing adequate protection by the relevant authority.

By using the Site or Services, you acknowledge that your information may be transferred internationally as described in this Policy. For more information about our transfer mechanisms or to obtain a copy of the relevant safeguards, please contact us at support@hifi.com.

Section 08

Children's privacy

The Site and Services are not intended for children under the age of 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at support@hifi.com. If we learn that we have collected personal information from a child under 18, we will take steps to delete such information promptly.

We comply with the Children's Online Privacy Protection Act (COPPA) and do not knowingly collect personal information from children under 13.

Section 09

Your privacy rights

Depending on your location, you may have certain rights regarding your personal information:

Access: Request access to the personal information we hold about you.

Correction: Request correction of inaccurate or incomplete personal information.

Deletion: Request deletion of your personal information, subject to certain exceptions.

Portability: Request a copy of your personal information in a portable format.

Opt-Out: Opt out of certain uses of your personal information, such as marketing communications.

To exercise these rights, please contact us at support@hifi.com. We will respond to your request within the timeframe required by applicable law. We may need to verify your identity before processing your request.

Section 10

U.S. state privacy rights

If you are a resident of certain U.S. states, you may have additional privacy rights under state law. This section provides information about those rights.

California residents (CCPA/CPRA)

If you are a California resident, you have rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"):

Right to Know: You have the right to request information about the categories and specific pieces of personal information we have collected, the sources of that information, the purposes for collection, and the categories of third parties with whom we share it.

Right to Delete: You have the right to request deletion of your personal information, subject to certain exceptions.

Right to Correct: You have the right to request correction of inaccurate personal information.

Right to Opt Out of Sale/Sharing: You have the right to opt out of the sale or sharing of your personal information. We do not sell personal information. We may share personal information for cross-context behavioral advertising; you may opt out using browser-based Global Privacy Control signals.

Right to Limit Use of Sensitive Personal Information: If we collect sensitive personal information, you have the right to limit its use.

Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

California "Shine the Light" Law: California residents may request information about our disclosure of personal information to third parties for direct marketing purposes. We do not share personal information with third parties for their direct marketing purposes.

Virginia residents (VCDPA)

If you are a Virginia resident, you have rights under the Virginia Consumer Data Protection Act ("VCDPA"), including the right to access, correct, delete, and obtain a copy of your personal data, and to opt out of targeted advertising, sale of personal data, and profiling. To exercise these rights, contact us at support@hifi.com. You may appeal our decision regarding your request by contacting us.

Colorado residents (CPA)

If you are a Colorado resident, you have rights under the Colorado Privacy Act ("CPA"), including the right to access, correct, delete, and obtain a copy of your personal data, and to opt out of targeted advertising, sale of personal data, and profiling. You may appeal our decision by contacting us.

Connecticut residents (CTDPA)

If you are a Connecticut resident, you have rights under the Connecticut Data Privacy Act ("CTDPA"), including the right to access, correct, delete, and obtain a copy of your personal data, and to opt out of targeted advertising, sale of personal data, and profiling.

Utah residents (UCPA)

If you are a Utah resident, you have rights under the Utah Consumer Privacy Act ("UCPA"), including the right to access and delete your personal data, and to opt out of targeted advertising and sale of personal data.

Texas residents (TDPSA)

If you are a Texas resident, you have rights under the Texas Data Privacy and Security Act ("TDPSA"), including the right to access, correct, delete, and obtain a copy of your personal data, and to opt out of targeted advertising, sale of personal data, and profiling.

Oregon residents (OCPA)

If you are an Oregon resident, you have rights under the Oregon Consumer Privacy Act ("OCPA"), including the right to access, correct, delete, and obtain a copy of your personal data, and to opt out of targeted advertising, sale of personal data, and profiling.

Montana residents (MCDPA)

If you are a Montana resident, you have rights under the Montana Consumer Data Privacy Act ("MCDPA"), including the right to access, correct, delete, and obtain a copy of your personal data, and to opt out of targeted advertising, sale of personal data, and profiling.

Additional state privacy laws

The following states have enacted comprehensive privacy laws that provide similar rights. If you are a resident of these states, you may exercise your rights by contacting us at support@hifi.com:

State Law Effective Date
DelawareDPDPAJanuary 1, 2025
IowaICDPAJanuary 1, 2025
NebraskaNDPAJanuary 1, 2025
New HampshireNHPAJanuary 1, 2025
New JerseyNJDPAJanuary 15, 2025
TennesseeTIPAJuly 1, 2025
MinnesotaMCDPAJuly 31, 2025
MarylandMODPAOctober 1, 2025
IndianaICDPAJanuary 1, 2026

Generally, these laws provide rights to access, correct, delete, and obtain a copy of your personal data, and to opt out of targeted advertising, sale of personal data, and profiling. Response times vary by state (typically 45-60 days). You may designate an authorized agent to make requests on your behalf.

Section 11

International privacy rights

If you are located outside the United States, you may have additional privacy rights under applicable law. This section provides information about those rights.

European Economic Area (GDPR)

If you are located in the European Economic Area ("EEA"), your personal data is protected by the General Data Protection Regulation ("GDPR"). This section describes how we process your personal data and your rights under the GDPR.

Legal Bases for Processing. We process your personal data based on the following legal bases:

Consent: Where you have given us explicit consent to process your personal data for specific purposes (e.g., marketing communications). You may withdraw consent at any time.

Contract Performance: Where processing is necessary to perform our contract with you or to take steps at your request before entering into a contract.

Legitimate Interests: Where processing is necessary for our legitimate interests (or those of a third party), provided your interests and fundamental rights do not override those interests. Our legitimate interests include operating and improving our services, fraud prevention, and security.

Legal Obligation: Where processing is necessary to comply with a legal obligation to which we are subject.

Vital Interests: Where processing is necessary to protect your vital interests or those of another person.

Your Rights Under GDPR. You have the following rights regarding your personal data:

Right of Access: You have the right to request a copy of the personal data we hold about you.

Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data.

Right to Erasure: You have the right to request deletion of your personal data in certain circumstances.

Right to Restriction: You have the right to request restriction of processing of your personal data in certain circumstances.

Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller.

Right to Object: You have the right to object to processing based on legitimate interests or for direct marketing purposes.

Right to Withdraw Consent: Where we rely on consent, you have the right to withdraw consent at any time without affecting the lawfulness of prior processing.

Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence, place of work, or place of the alleged infringement.

International Transfers. Your personal data may be transferred to, and processed in, the United States and other countries outside the EEA. When we transfer personal data outside the EEA, we ensure appropriate safeguards are in place, including the European Commission's Standard Contractual Clauses (SCCs), adequacy decisions, or other approved mechanisms.

To exercise your rights, please contact us at support@hifi.com. We will respond to your request within one (1) month, which may be extended by two (2) further months where necessary.

United Kingdom (UK GDPR)

If you are located in the United Kingdom, your personal data is protected by the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018. You have the same rights as described in Section 11.1 above for EEA residents.

International Transfers. When we transfer personal data from the UK to countries outside the UK, we ensure appropriate safeguards are in place, including the UK International Data Transfer Agreement (IDTA), the UK Addendum to the EU SCCs, or transfers to countries with UK adequacy regulations.

Right to Lodge a Complaint. You have the right to lodge a complaint with the Information Commissioner's Office (ICO) at https://ico.org.uk/.

Switzerland

If you are located in Switzerland, your personal data is protected by the Swiss Federal Act on Data Protection ("FADP") and, where applicable, the revised FADP (nFADP) effective September 1, 2023. You have rights similar to those described in Section 11.1 above, including the rights of access, rectification, erasure, data portability, and objection.

International Transfers. When we transfer personal data from Switzerland, we ensure appropriate safeguards are in place, including the Swiss-approved Standard Contractual Clauses or transfers to countries recognized by the Swiss Federal Data Protection and Information Commissioner (FDPIC) as providing adequate protection.

Right to Lodge a Complaint. You have the right to lodge a complaint with the FDPIC at https://www.edoeb.admin.ch/.

Canada (PIPEDA)

If you are located in Canada, your personal information is protected by the Personal Information Protection and Electronic Documents Act ("PIPEDA") and, where applicable, substantially similar provincial legislation (such as Alberta's PIPA, British Columbia's PIPA, and Quebec's Law 25).

Your Rights Under PIPEDA. You have the following rights regarding your personal information:

Right of Access: You have the right to request access to your personal information and to be informed of its use and disclosure.

Right to Correction: You have the right to challenge the accuracy and completeness of your personal information and have it amended as appropriate.

Right to Withdraw Consent: You have the right to withdraw consent to the collection, use, or disclosure of your personal information, subject to legal or contractual restrictions.

Right to Complain: You have the right to file a complaint with the Office of the Privacy Commissioner of Canada at https://www.priv.gc.ca/.

Disclosure Without Consent. Under PIPEDA, we may disclose your personal information without consent in limited circumstances, including:

• To a lawyer representing us;

• To collect a debt owed to us;

• To comply with a subpoena, warrant, or court order;

• To a government institution that has requested the information for law enforcement purposes;

• To an investigative body for fraud prevention;

• In an emergency threatening life, health, or security;

• For statistical or scholarly research;

• To an archival institution;

• Twenty (20) years after the individual's death;

• If the information is publicly available; or

• As otherwise required by law.

Quebec Residents. If you are a resident of Quebec, you have additional rights under Quebec's Law 25 (Act respecting the protection of personal information in the private sector), including the right to data portability and the right to be informed of automated decision-making. You may also request de-indexing of personal information from search results.

Brazil (LGPD)

If you are located in Brazil, your personal data is protected by the Lei Geral de Proteção de Dados ("LGPD"). You have rights similar to those under the GDPR, including the rights of access, correction, anonymization, blocking or deletion of unnecessary data, data portability, information about sharing, and the right to revoke consent. To exercise these rights, contact us at support@hifi.com. You may lodge a complaint with the Autoridade Nacional de Proteção de Dados (ANPD).

Section 12

Do-not-track and global privacy control

Do-Not-Track Signals: Some web browsers transmit "do-not-track" signals to websites. Because there is no uniform standard for how these signals should be interpreted, our Site does not currently respond to browser do-not-track signals.

Global Privacy Control (GPC): We honor Global Privacy Control signals as a valid opt-out request for the sale or sharing of personal information for targeted advertising, where required by applicable law. If you enable GPC in your browser, we will treat this as a request to opt out of the sale or sharing of your personal information.

Section 13

Third-party links

The Site may contain links to third-party websites, applications, or services that are not operated by us. This Policy does not apply to any third-party websites, applications, or services. We encourage you to review the privacy policies of any third-party websites or services you visit.

Section 14

Changes to this policy

We may update this Policy from time to time. If we make material changes, we will notify you by updating the "Last Updated" and "Effective" dates at the top of this Policy and, where required by law, by providing additional notice (such as posting a notice on the Site or sending you a notification). We encourage you to review this Policy periodically.

Section 15

Contact us

If you have any questions or concerns about this Policy or our privacy practices, you may contact us at:

HIFI Bridge, Inc.
Attn: Privacy
111 Town Square Place
Jersey City, NJ 07310
United States of America
Email: support@hifi.com