Effective Date: April 2025 Version: 1.0 This Privacy Policy ("Policy") describes how Allydium Hub ("we", "our", "us", or "ProjectM LLC") collects, stores, uses, protects, and manages user information within the mobile application ("App"). By using the App, you explicitly consent to the practices described in this Policy. 1. Scope and Access The App is not available for public registration and does not collect personal data from the general public. Access is strictly limited to authorized Agents who receive credentials directly from ProjectM administrators. Unauthorized access or use is strictly prohibited. Access for companies (admins) is currently in development and will be available in a future update. During this MVP phase, only Agent functionality is fully supported. 1.1 Data Collected via Request Access Form If you submit a request to join Allydium Hub as an agent or business, we collect the following data through the 'Request Access' form: Full Name, Business Name (optional), Email, Phone (optional), and a message explaining your interest. This data is used solely to process your request and communicate with you. It is retained until your request is resolved or you request deletion, and is not shared with third parties except as required to process your application. 1.2 Role as Data Processor Allydium Hub acts as a data processor for authorized Agents and companies who use our platform. Agents and companies act as Data Controllers and are responsible for obtaining consent or having another lawful basis (e.g., legitimate interest) for processing the personal data of Referred Individuals (e.g., name, email, phone). We process this data on behalf of the Agent or company in accordance with their instructions and the Data Processing Agreement (DPA) accepted during registration. 1.3 Use of Agent and Company Data When Agents or companies register or submit a 'Request Access' form, we collect their Full Name, Business Name (optional), Email, and Phone (optional). This data is used to manage their account, communicate with them regarding their use of the App, and, if they consent, for marketing purposes such as sending updates, promotions, or information about our services. You can opt out of marketing communications at any time by contacting us at projectm.helper@gmail.com. 1.4 Feedback Data When Agents or companies submit feedback through the App, we collect the feedback title and description. This data is used to improve the App and address user concerns. It is retained until the feedback is resolved or you request deletion, and is not shared with third parties. 2. Data Collected by Agents Agents may voluntarily submit referral data about third parties ("Referred Individuals") via the App's referral management features. Referral data may include: • Names; • Email addresses; • Phone numbers; • Other relevant contact or identification information. 3. Responsibility of Agents and Companies Agents and companies must ensure that all Referral Data: • Is accurate, truthful, and up-to-date; • Has been legally obtained with explicit consent or another lawful basis, as required under GDPR, CCPA, or other applicable privacy laws. The ProjectM LLC does not independently verify the accuracy or legitimacy of Referral Data submitted by Agents or companies. Agents and companies assume full responsibility and liability for the data they provide. 4. Purpose and Usage of Data Referral Data submitted by Agents is exclusively used for CRM functions and affiliate operations within the App. Specifically, Referral Data is: • Never sold or monetized; • Never shared with third parties for advertising or marketing; • Not combined with external datasets for profiling or targeted advertising. 5. Data Retention and Deletion Referral Data is retained only for as long as necessary to fulfill its intended CRM and referral purposes. Agents or Referred Individuals have the right to request deletion of their data at any time by contacting us directly. Verified deletion requests will result in permanent and secure data removal within 30 calendar days. 6. Data Security We utilize industry-standard security measures, including encryption of data at rest and in transit, access control systems, and regular security audits. However, absolute security cannot be guaranteed, and you acknowledge inherent risks associated with digital data management. 7. User Privacy Rights (CCPA, GDPR) In jurisdictions covered by privacy laws such as GDPR (EU) or CCPA (California, USA), Referred Individuals and Agents may: • Request access to their personal data; • Request rectification or correction; • Request deletion of their data; • Withdraw previously granted consent. To exercise these rights, please contact us at the provided details below. This includes data submitted through the 'Request Access' form, such as your Full Name, Email, and other provided information. Agents and companies may also request access, correction, or deletion of their own data (e.g., Full Name, Email) collected during registration or through the 'Request Access' form. This also applies to feedback data (title and description) submitted through the App. 8. Children's Privacy The App is not intended for users under 13 years of age. We do not knowingly collect or store data from minors. If we learn of such information inadvertently collected, it will be immediately and permanently deleted. 9. Changes to this Privacy Policy We may update or modify this Privacy Policy periodically. Any significant changes will be communicated clearly within the App and posted publicly on our official website (https://projectm.space/allydium-privacy-policy). Continued use of the App after updates implies acceptance of the revised Policy. 10. Contact Information For privacy-related inquiries, data requests, deletion or corrections, legal questions, or compliance matters, please contact: • Email: allydium@projectm.space • Telegram: @projectm_admin • Website: https://projectm.space For additional details about our data practices and ownership structure, visit https://projectm.space/allydium-ownership. Effective Date: April 2025 Version: 1.0
