# Privacy Policy

SPEEDYTURTLE PRIVACY POLICY

PART A — FOUNDATIONAL AND DATA COLLECTION PROVISIONS

Last Updated: \[●]\
Effective Date: \[●]

This Privacy Policy (this “Privacy Policy” or “Policy”) describes how SpeedyTurtle Technologies LLC, a Delaware limited liability company (“SpeedyTurtle,” “Company,” “we,” “us,” or “our”), collects, uses, discloses, and otherwise processes information in connection with your access to and use of the SpeedyTurtle platform, software, tools, and related services (collectively, the “Services”).

This Privacy Policy is incorporated by reference into the SpeedyTurtle Terms of Service (the “Terms”). Capitalized terms not defined herein have the meanings set forth in the Terms.

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1\. SCOPE AND APPLICABILITY

1.1 Covered Individuals

This Privacy Policy applies to information processed about:

* visitors to our websites and applications;
* users of the Services;
* individuals who communicate with us or interact with our content;
* prospective users, subscribers, and business contacts.

1.2 Services Covered

This Policy applies to information collected in connection with:

* our websites and web applications;
* browser extensions, APIs, and software tools;
* messaging-based interfaces (including bots);
* customer support and communications;
* marketing, analytics, and subscription management.

This Policy does not apply to third-party websites, protocols, wallets, or services that you access independently, even if linked or integrated with the Services.

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2\. NO FINANCIAL INSTITUTION OR KYC REPRESENTATION

2.1 Not a Financial Institution

SpeedyTurtle is a technology provider, not a bank, broker, money transmitter, custodian, or financial institution. Nothing in this Privacy Policy shall be construed as an admission that SpeedyTurtle is subject to sector-specific privacy regimes applicable to regulated financial institutions unless expressly required by Applicable Law.

2.2 No Routine KYC or AML Onboarding

SpeedyTurtle does not collect personal data for the purpose of routine Know Your Customer (KYC), Anti-Money Laundering (AML), or customer due diligence onboarding.

Any information we collect is not collected for identity verification as a condition of access to the Services, and nothing in this Policy creates an expectation that SpeedyTurtle performs ongoing user identity monitoring.

Any discretionary information requests made for legal or risk-mitigation purposes are exceptional, not routine, and do not establish a general compliance obligation.

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3\. INFORMATION WE COLLECT

We collect limited categories of information necessary to operate, maintain, and improve the Services. The categories of information we collect depend on how you interact with the Services.

3.1 Information You Provide Directly

You may provide the following information voluntarily:

* email address;
* username or account identifier;
* subscription or billing information (processed by third-party payment processors);
* communications sent to us (support requests, feedback, inquiries).

We do not require you to provide government-issued identification, biometric data, or financial account credentials to access core non-custodial Services.

3.2 Automatically Collected Information

When you access or use the Services, we may automatically collect certain technical and usage information, including:

* device type, operating system, browser type;
* IP address or approximate location (derived from IP);
* timestamps, pages viewed, and feature usage;
* referral URLs or campaign identifiers;
* error logs and performance metrics.

This information is collected to operate the Services, monitor performance, prevent abuse, and improve user experience.

3.3 Wallet and Blockchain Information

When you connect a Wallet or initiate transactions through the Services, we may process:

* public blockchain addresses;
* transaction hashes;
* asset identifiers and network metadata.

Public blockchain data is inherently public and is not treated as confidential or private information. SpeedyTurtle does not control the underlying blockchain and cannot alter or delete on-chain data.

Third-Party Key Infrastructure.

To facilitate transaction signing and Wallet interactions, SpeedyTurtle utilizes a secure third-party cryptographic infrastructure provider (currently Turnkey) that performs cryptographic key management and transaction signing operations within hardened, isolated environments. SpeedyTurtle does not receive, store, or have direct access to users’ private keys, seed phrases, or raw cryptographic material at any time. All signing operations are performed on a user-authorized basis through this third-party infrastructure, and SpeedyTurtle cannot initiate transactions without the user’s express direction.

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4\. INFORMATION WE DO NOT COLLECT

SpeedyTurtle intentionally limits data collection. We do not:

* collect or store users’ private keys, seed phrases, or Wallet passwords;
* have access to raw cryptographic signing material;
* custody Digital Assets;
* collect biometric identifiers;
* collect precise geolocation data;
* engage in routine identity verification.

Where cryptographic signing is required, such operations are performed by a secure third-party key infrastructure provider (such as Turnkey) acting on a user-authorized basis, without disclosing private key material to SpeedyTurtle.

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5\. COOKIES AND SIMILAR TECHNOLOGIES

5.1 Cookies

We may use cookies and similar technologies to:

* remember preferences;
* analyze usage trends;
* improve functionality and security.

You may manage cookie preferences through your browser settings. Disabling cookies may affect certain features.

5.2 Analytics Tools

We may use third-party analytics providers to understand how users interact with the Services. These providers process information on our behalf and subject to contractual safeguards.

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6\. HOW WE USE INFORMATION

We use collected information for legitimate business purposes, including to:

* provide and operate the Services;
* communicate with users;
* process subscriptions and payments;
* detect, prevent, and respond to fraud or abuse;
* comply with Applicable Law;
* improve functionality, performance, and security.

We do not sell personal information and do not use personal information to make automated decisions that produce legal or similarly significant effects.

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7\. LEGAL BASES FOR PROCESSING (WHERE APPLICABLE)

Where required by Applicable Law, our processing of information is based on one or more of the following legal grounds:

* performance of a contract (providing the Services);
* compliance with legal obligations;
* legitimate interests (security, analytics, improvement);
* your consent, where applicable.

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8\. INFORMATION SHARING AND DISCLOSURE

8.1 General Principle

SpeedyTurtle does not sell personal information. We disclose information only as described in this Policy and only to the extent reasonably necessary to operate the Services, comply with Applicable Law, or protect legal interests.

8.2 Service Providers

We may disclose information to third-party service providers who perform services on our behalf, such as:

* cloud hosting and infrastructure providers;
* analytics and performance monitoring providers;
* customer support tools;
* subscription and payment processing providers.
* cryptographic key management and signing infrastructure providers (e.g., Turnkey), which process encrypted signing requests on our behalf without providing SpeedyTurtle with access to private keys or seed phrases.

These providers are authorized to process information solely for the purposes specified by SpeedyTurtle and subject to contractual confidentiality and data protection obligations.

8.3 Legal and Compliance Disclosures

We may disclose information if we reasonably believe such disclosure is necessary to:

* comply with Applicable Law, legal process, or lawful requests from authorities;
* enforce our Terms of Service or other agreements;
* investigate or prevent fraud, security incidents, or misuse of the Services;
* protect the rights, property, or safety of SpeedyTurtle, our users, or others.

Nothing in this Policy obligates SpeedyTurtle to proactively monitor users or collect information beyond what is required by law.

8.4 Business Transfers

If SpeedyTurtle is involved in a merger, acquisition, reorganization, financing, or sale of assets, information may be disclosed or transferred as part of that transaction, subject to customary confidentiality protections.

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9\. DATA RETENTION

9.1 Retention Periods

We retain information only for as long as reasonably necessary to:

* provide the Services;
* comply with legal and regulatory obligations;
* resolve disputes;
* enforce agreements;
* protect against fraud or abuse.

Retention periods vary depending on the type of information, purpose of processing, and legal requirements.

9.2 Blockchain Data

Public blockchain data is immutable and cannot be deleted or modified by SpeedyTurtle. Any retention or deletion requests do not apply to on-chain data.

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10\. DATA SECURITY

10.1 Safeguards

We implement commercially reasonable administrative, technical, and organizational safeguards designed to protect information from unauthorized access, disclosure, alteration, or destruction.

10.2 No Absolute Security Guarantee

You acknowledge that no system can be completely secure. SpeedyTurtle does not guarantee absolute security and is not responsible for breaches resulting from factors beyond our reasonable control, including third-party systems or user error.

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11\. YOUR PRIVACY RIGHTS

11.1 U.S. State Privacy Rights

Depending on your state of residence, you may have rights to:

* request access to certain personal information;
* request correction of inaccurate information;
* request deletion of certain personal information;
* opt out of certain data processing activities where applicable.

We will respond to verifiable requests as required by Applicable Law, subject to lawful exceptions.

11.2 No Discrimination

We will not discriminate against you for exercising privacy rights, except as permitted by law.

11.3 Limitations

Your rights do not apply to:

* information that cannot reasonably be linked to you;
* public blockchain data;
* information we must retain to comply with legal obligations or defend legal claims.

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12\. INTERNATIONAL USERS

SpeedyTurtle is based in the United States. If you access the Services from outside the United States, you acknowledge that information may be processed and stored in jurisdictions with different data protection laws than those of your residence.

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13\. CHILDREN’S INFORMATION

The Services are not directed to children under 18. We do not knowingly collect personal information from minors. If we learn that information has been collected from a minor in violation of Applicable Law, we will take reasonable steps to delete it.

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14\. NO AUTOMATED DECISION-MAKING

SpeedyTurtle does not engage in automated decision-making or profiling that produces legal or similarly significant effects on users.

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15\. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. If we make material changes, we will update the “Last Updated” date and post the revised Policy. Your continued use of the Services after changes become effective constitutes acceptance of the updated Policy.

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16\. GOVERNING LAW AND DISPUTE ALIGNMENT

This Privacy Policy shall be governed by the laws of the State of Delaware, without regard to conflict of law principles. Any disputes relating to privacy or data protection shall be resolved in accordance with the dispute resolution provisions set forth in the SpeedyTurtle Terms of Service, including arbitration and class action waiver provisions, to the extent permitted by law.

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17\. CONTACT INFORMATION

If you have questions or requests regarding this Privacy Policy, you may contact us at:

SpeedyTurtle Technologies LLC\
Email: <support@speedyturtle.io>

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