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Effective Date: May 12, 2026 · Governing Law: British Virgin Islands

Privacy Policy

1. Overview

This Privacy Policy describes how certain entities within the broader DAWN and Andrena ecosystem collect, use, disclose, process, and protect personal information in connection with the Services. Depending on the Services you access or interact with, personal information may be processed by one or more independent entities, including DAWN Ops Ltd., DAWN Foundation, DAWN TokenCo Ltd., or related token administration entities; Andrena, Inc., Andrena Holdings, LLC and its affiliated Series entities (“SPVs”), and affiliated operational, administrative, servicing, governance, or support entities (collectively, for convenience, “DAWN,” “we,” “us,” or “our”).

These entities may perform different functions within the broader ecosystem, including operation of applications, dashboards, interfaces, and related Services; protocol stewardship and ecosystem coordination; technical token-related support functions; infrastructure deployment and servicing; telecommunications operations; and infrastructure-related ownership, operational, administrative, or contractual functions. Depending on the context and applicable law, different entities may act as independent data controllers; joint controllers; processors; service providers; or operational counterparties.

This Privacy Policy applies when you access or use:

  • https://dawninternet.com;
  • https://andrena.com;
  • applications, dashboards, browser extensions, APIs, software, or related interfaces;
  • smart contract integrations;
  • Rewards Program interfaces;
  • ecosystem incentive systems;
  • protocol participation interfaces;
  • USD.infra Vault-related interfaces, dashboards, or informational systems;
  • and other applications, technologies, or services that link to or reference this Privacy Policy

(collectively, the “Services”).

Certain Services may involve interaction with blockchain networks, smart contracts, digital wallets, decentralized systems, telecommunications infrastructure, third-party protocols, independent operators, or infrastructure-owning SPVs not directly controlled by DAWN. Certain Services or features may be subject to additional terms, eligibility requirements, geographic restrictions, onboarding procedures, or separate agreements. Finally, certain Services, interfaces, protocol features, or infrastructure-related systems may not be available in all jurisdictions and may be restricted based on legal, regulatory, sanctions, compliance, risk, or operational considerations.

2. Entities Covered and Roles

This Policy applies to the following entities:

  • DAWN Foundation (Cayman Islands) – protocol governance and ecosystem coordination; and treasury and strategic oversight.
  • DAWN Ops Ltd. (BVI) – application interfaces, dashboard integrations, and operations; and user-facing product functionality.
  • DAWN Mint / TokenCo (BVI) – token minting, technical token administration, and protocol-related distribution support functions.
  • Andrena, Inc. (US) – independent telecommunications infrastructure deployment, network operations and servicing; and commercial and operational relationships with property owners, vendors, and partners.
  • Andrena Holdings, LLC and Series SPVs - ownership of infrastructure-related contracts, receivables, and associated assets; and independent operation of project-specific infrastructure entities. DAWN does not own, operate, or control infrastructure assets or Series SPVs. Series SPVs are not consumer-facing entities and generally do not directly interact with end users.

Depending on the context, entities may act as independent data controllers. In limited cases, entities may act as joint controllers. Service providers act as data processors. Each entity processes personal data only as necessary for its respective role.

3. Scope of This Policy

This Policy applies when you access or use the Services, access USD.infra Vault interfaces, interact with protocol participation systems, Rewards Programs, or USD.infra Vault-related interfaces, or engage with Andrena services or infrastructure deployments. This Policy does not apply to third-party services not controlled by DAWN or publicly available blockchain data.

4. Information We Collect

DAWN and Andrena seek to limit collection of personal data to information reasonably necessary for operational, contractual, legal, security, compliance, telecommunications, infrastructure servicing, and business purposes. We collect the following categories of information:

4.1 Information You Provide

  • name, email address, service address
  • billing information, billing address
  • account credentials
  • wallet addresses
  • smart contract interaction identifiers
  • blockchain account identifiers
  • protocol interaction metadata
  • communications (support requests, feedback)
  • business or partner information (for Andrena services)

4.2 Technical Information

  • IP address
  • device type, browser, operating system
  • log data, timestamps
  • network performance and usage data

4.3 Blockchain and Protocol Data

  • wallet addresses
  • transaction hashes
  • Rewards Program participation data
  • protocol interaction activity
  • smart contract interaction data
  • vault interaction data (where applicable)
  • protocol interaction data

Note: Blockchain data is publicly visible and immutable.

4.4 USD.infra Vault-Related Data

Where applicable, we may process wallet activity linked to USD.infra Vault interfaces, interaction with protocol dashboards, and system-level participation metrics.

Personal information may be shared between DAWN entities, including Andrena and affiliated entities, to operate the DAWN Services and support infrastructure operations, including infrastructure-owning special purpose vehicles and service providers, where necessary to support operational, technical, or contractual functions.

Such entities operate independently and may process data in accordance with their own legal obligations. Certain data processing activities relate to protocol-level services, while others relate to infrastructure operations. These activities are distinct and may involve different entities within the DAWN and Andrena ecosystem.

4.5 Read-Only Access Data

We may also process limited compliance and access-control data used to determine jurisdictional eligibility, read-only access restrictions, sanctions screening, or feature availability.

4.6 Andrena Commercial and Operational Data

Andrena may collect property owner and partner contact details, site access and installation data, service and maintenance records, vendor and contractor information, and operational network performance data. In addition, Andrena, Inc. may collect operational and infrastructure-related information, including installation, service, and performance data, solely for purposes of providing infrastructure services.

4.7 Cookies and Tracking Data

We use cookies and similar technologies (see Section 10).

4.8 No Financial Account Data

DAWN does not generally collect traditional bank account credentials, brokerage credentials, or private wallet keys.

4.9 Sensitive Information

Unless specifically required for a particular Service, DAWN and Andrena generally request that users do not provide government-issued identification numbers, financial account credentials, private wallet keys, biometric information, precise geolocation information, health information, or other sensitive categories of information. Users should never share private keys, seed phrases, authentication credentials, or wallet recovery information with DAWN, Andrena, or any third party.

5. How We Use Information

5.1 Personal Data

We use personal data to operate and maintain the Services, provide protocol functionality, application interfaces, and infrastructure coordination systems, support USD.infra Vault interfaces (informational and technical functions only), provide protocol functionality, application interfaces, and infrastructure coordination systems, provide Andrena services and infrastructure operations, improve performance and user experience, communicate with users and partners, detect and prevent fraud or misuse, comply with legal obligations, conduct sanctions screening, fraud prevention, and jurisdictional access controls, and enforce feature restrictions and compliance-related eligibility requirements.

Personal information may also be used to support infrastructure operations conducted by Andrena and its affiliated entities.

5.2 Legal Bases for Processing

To the extent applicable under the GDPR, UK GDPR, Swiss data protection laws, or similar laws, DAWN and Andrena process personal data pursuant to one or more of the following legal bases performance of a contract or steps taken prior to entering into a contract, compliance with legal obligations, legitimate interests, including operation of the Services, fraud prevention, network security, infrastructure management, protocol administration, telecommunications operations, analytics, and business operations, consent, where required by law, and protection of legal rights, security, safety, and operational integrity.

Legitimate interests may include operating and improving the Services, supporting protocol and infrastructure systems, fraud detection and prevention, sanctions screening, network management, cybersecurity, infrastructure servicing, customer support, legal compliance, and protection of DAWN’s, Andrena’s, users’, counterparties’, and third parties’ rights and interests.

Where consent is required by applicable law, users may withdraw consent at any time, subject to legal and operational limitations

6. Entity-Specific Processing

6.1 DAWN Foundation

Processes data for governance and coordination, ecosystem analytics, and ecosystem coordination, governance administration, analytics, and operational oversight.

6.2 DAWN Ops Ltd.

Processes data for application functionality, user interface operations, and integrations and platform performance.

6.3 TokenCo

Processes limited data strictly for technical support functions relating to token administration or protocol-related distributions, and smart contract interactions.

6.4 Andrena, Inc.

Processes data for infrastructure deployment and servicing, commercial relationships, customer relationships, operational performance and maintenance, and compliance with telecom and regulatory obligations.

6.5 Andrena Holdings and Series SPVs

Series SPVs may maintain operational and contractual records, and may process limited data related to infrastructure performance or contractual obligations. SPVs operate independently and do not provide user-facing services.

6.6 Marketing and Transactional Communications

DAWN and Andrena may send operational communications, transactional notices, onboarding communications, service-related announcements, security notifications, support communications, and, where permitted by law, marketing or promotional communications.

Users may opt out of marketing communications at any time by using unsubscribe functionality or contacting DAWN or Andrena directly.

Users may continue to receive operational, transactional, compliance, legal, security, onboarding, or account-related communications necessary for operation of the Services.

7. How We Share Information

DAWN and Andrena may share personal information, technical information, blockchain-related information, operational data, or other information as reasonably necessary to operate and maintain the Services; support protocol functionality and infrastructure systems; provide customer support; administer Rewards Programs or related interfaces; comply with legal and regulatory obligations; prevent fraud, abuse, sanctions violations, or security incidents; enforce contractual rights; support infrastructure deployment and servicing activities; and conduct operational, compliance, governance, security, analytics, or business functions. Information may be shared in the following circumstances:

7.1 Between DAWN Entities

Personal information may be shared between DAWN entities, including Andrena and affiliated entities, to operate the DAWN Services and support infrastructure operations; and affiliated operational, administrative, governance, servicing, or support entities.

7.2 With Service Providers

Information may be shared with cloud hosting providers, analytics providers, security and compliance vendors, and customer support systems. Service providers may process information only as reasonably necessary to provide services on behalf of DAWN or Andrena, subject to applicable contractual, legal, operational, security, or compliance restrictions.

7.3 With Regulators or Authorities

DAWN and Andrena may disclose information where required by applicable law, regulation, subpoena, court order, governmental request, or legal process; to comply with sanctions obligations, anti-money laundering obligations, fraud prevention requirements, or other compliance obligations; to protect the rights, safety, integrity, security, or property of DAWN, Andrena, users, counterparties, or third parties; to investigate suspected fraud, abuse, unauthorized access, security incidents, sanctions violations, or unlawful activity; or in connection with audits, examinations, investigations, litigation, dispute resolution, or regulatory inquiries.

Information may also be shared with regulators; law enforcement; governmental agencies; sanctions-screening providers; blockchain monitoring providers; legal advisors; auditors; insurers; financing counterparties; trustees; and other compliance or operational counterparties where reasonably necessary.

7.4 With Business Counterparties and Infrastructure Participants

In connection with infrastructure operations, telecommunications activities, deployment services, servicing arrangements, or related operational functions, DAWN and Andrena may share information with property owners; landlords; utilities; telecommunications carriers; vendors; contractors; installers; infrastructure operators; maintenance providers; financing counterparties; infrastructure managers; servicing agents; and other operational or commercial counterparties.

Such sharing may occur for purposes including infrastructure deployment; maintenance and servicing; operational coordination; contract administration; compliance; technical troubleshooting; billing and accounting; financing or servicing administration; infrastructure monitoring; and telecommunications operations.

Certain infrastructure systems or contractual arrangements may involve independent SPVs or third-party entities operating separately from DAWN or Andrena.

7.5 Public Blockchain

Certain Services may involve interaction with public blockchain networks or decentralized systems. Blockchain transactions, wallet addresses, smart contract interactions, protocol activity, and related metadata may be publicly visible, immutable, permanently accessible, and independently indexed by third parties.

DAWN and Andrena do not control public blockchain records; third-party blockchain indexing; decentralized storage systems; validator activity; blockchain explorers; or independent blockchain analytics providers.

Users should understand that blockchain-related information may remain publicly accessible indefinitely and may be associated with wallet addresses, transaction history, protocol interactions, or related metadata.

DAWN and Andrena do not sell personal information for monetary consideration. However, certain data-sharing activities involving analytics, compliance, infrastructure monitoring, advertising technologies, or blockchain-related systems may constitute “sharing” under certain laws depending on applicable legal interpretations.

7.6 Third-Party Protocols and Blockchain Systems

Certain Services may interact with or rely upon third-party blockchain networks; wallet providers; smart contract systems; decentralized protocols; validators; oracles; bridges; liquidity systems; blockchain analytics providers; compliance providers; decentralized applications; infrastructure coordination systems; or protocol-related technologies that are not owned, operated, administered, or controlled by DAWN or Andrena.

Information transmitted to or through such systems may be processed independently by third parties pursuant to their own terms, privacy policies, operational practices, or legal obligations. DAWN and Andrena are not responsible for the privacy or security practices of third-party systems; blockchain functionality; wallet security; smart contract operation; validator conduct; protocol governance decisions; third-party data processing; or failures, outages, exploits, or vulnerabilities associated with third-party infrastructure. Users interact with third-party blockchain systems and wallet providers entirely at their own risk.

7.7 Corporate Transactions

Information may be disclosed or transferred in connection with mergers, acquisitions, financings, restructurings, reorganizations, insolvency proceedings, sales of assets, securitizations, infrastructure financings, servicing transfers, or other corporate or commercial transactions.

Recipients may include counterparties, lenders, investors, trustees, servicers, professional advisors, insurers, auditors, and financing participants.

8. International Data Transfers

8.1 International Transfer Safeguards

Where required by applicable law, DAWN and Andrena implement safeguards intended to protect personal data transferred internationally, including Standard Contractual Clauses (“SCCs”), contractual data protection obligations, technical and organizational safeguards, adequacy decisions, transfer impact assessments, and other legally recognized transfer mechanisms.

Users acknowledge that personal data may be transferred to and processed in jurisdictions that may provide different levels of legal protection than their jurisdiction of residence.

9. Data Retention

We retain data only as long as necessary to provide Services, meet legal obligations, resolve disputes, and enforce agreements. Retention varies by data category. We retain personal data based on operational, legal, and compliance requirements. Retention periods vary depending on the type of data, including Account data: retained while account is active and for a reasonable period thereafter; Technical logs: typically retained up to 12 months; Compliance-related data: retained as required by law. Certain blockchain-related data, including public wallet addresses and blockchain transaction records, may remain publicly accessible indefinitely due to the nature of blockchain systems.

DAWN and Andrena may also retain personal data to establish, exercise, or defend legal claims, comply with legal, accounting, telecommunications, tax, sanctions, or regulatory obligations, enforce agreements, conduct audits, maintain security and fraud prevention systems, and preserve business and operational records.

Retention periods may vary depending on applicable legal requirements, operational needs, contractual obligations, infrastructure servicing requirements, dispute resolution needs, and the nature of the Services involved.

10. Cookies and Analytics

10.1 Types of Cookies

  • Essential cookies
  • Performance/analytics cookies
  • Functional cookies
  • Marketing cookies (where applicable)

Users may control cookie preferences through browser settings or consent tools where available.

10.2 Analytics

We may use third-party analytics tools (e.g., Google Analytics) to understand usage, and improve Services. Analytics providers may include blockchain analytics, wallet-screening, sanctions-compliance, fraud-detection, or protocol monitoring providers.

10.3 Cookie Control and Consent Management

Users may manage or disable cookies and similar technologies through browser settings; device-level privacy controls; cookie consent banners or preference centers (where available); and industry-standard opt-out mechanisms.

Most browsers permit users to review stored cookies; delete cookies; block third-party cookies; block all cookies; or receive notifications before cookies are placed. Disabling or restricting certain cookies may affect the availability, functionality, performance, or user experience of certain Services, interfaces, dashboards, or features.

Certain Services may continue to use essential or strictly necessary cookies required for authentication; security; fraud prevention; network management; compliance; load balancing; session integrity; or operation of core functionality. In addition, certain third-party analytics, blockchain analytics, wallet-screening, compliance, fraud-detection, or infrastructure-monitoring providers may use cookies or similar technologies subject to their own privacy practices and terms. Users may also manage advertising and analytics preferences through industry-standard tools, browser extensions, or applicable platform privacy controls where available.

10.4 Global Privacy Control (GPC) and Browser Privacy Signals

Where required by applicable law, DAWN and Andrena recognize Global Privacy Control (“GPC”) signals and certain browser-based opt-out preference signals intended to communicate a user’s privacy preferences. Depending on applicable law and technical feasibility, recognized signals may be treated as requests to opt out of certain categories of data sharing or targeted advertising; limit certain tracking technologies; or apply privacy preference settings associated with the requesting browser or device.

GPC and related privacy preference signals may apply only to the browser or device transmitting the signal; and specific categories of processing subject to applicable law. Certain processing activities may continue notwithstanding such signals where necessary to provide requested Services; required for security, fraud prevention, sanctions compliance, or legal obligations; necessary for strictly necessary or essential operational functions; or otherwise permitted under applicable law.

DAWN and Andrena do not guarantee that third-party services, blockchain systems, wallet providers, analytics providers, or external platforms recognize or honor GPC or similar browser-based privacy signals.

10.5 Compliance and Blockchain Monitoring

We may use third-party compliance, analytics, blockchain monitoring, sanctions-screening, fraud-detection, or wallet-risk assessment providers to help prevent fraud or abuse; enforce geographic restrictions; comply with sanctions and legal obligations; and monitor the integrity of the Services.

10.6 Do Not Track Signals

Certain browsers may transmit “Do Not Track” (“DNT”) signals. Because there is no universally accepted standard for DNT signals, DAWN and Andrena do not currently respond to DNT browser signals except as otherwise required by applicable law.

11. Data Security

11.1 Security Incidents

In the event of a suspected or confirmed security incident involving personal data, DAWN and Andrena may investigate, contain, remediate, cooperate with authorities, notify affected parties, and take other actions consistent with applicable law, operational requirements, legal obligations, and security practices.

Nothing in this Privacy Policy constitutes a guarantee against security incidents, cyberattacks, unauthorized access, or third-party compromises.

11.2 Security Safeguards

DAWN and Andrena implement commercially reasonable administrative, technical, organizational, and physical safeguards designed to protect personal data against unauthorized access, disclosure, alteration, misuse, destruction, or loss. Such safeguards may include: encryption; access controls; authentication measures; network monitoring; security testing; logging and auditing; incident response procedures; vendor and infrastructure security reviews; and role-based access restrictions. Access to personal data is limited to personnel, contractors, service providers, and affiliated entities that reasonably require such access for operational, legal, security, compliance, or support purposes. Despite these measures, no system, network, blockchain, wallet integration, smart contract system, cloud environment, communication channel, or data transmission method can be guaranteed to be completely secure or error-free.

Certain Services may involve interactions with public blockchain networks; smart contracts; digital wallets; decentralized infrastructure; third-party protocol systems; wallet providers; blockchain bridges; validators; oracles; analytics providers; and other third-party infrastructure outside DAWN’s or Andrena’s control. Such systems may involve additional risks, including smart contract vulnerabilities; exploits; blockchain forks; wallet compromise; validator failures; bridge failures; irreversible transactions; protocol attacks; data corruption; unauthorized third-party access; operational outages; and loss of digital assets or protocol positions.

DAWN and Andrena are not responsible for the security, availability, integrity, or operation of third-party blockchain systems, wallet providers, smart contracts, or decentralized infrastructure not directly controlled by DAWN or Andrena.

Users are solely responsible for maintaining the security of their wallets, devices, credentials, and accounts; safeguarding private keys and authentication credentials; verifying transaction details; and assessing the security of any third-party systems or services they choose to use. In the event of a security incident affecting personal data, DAWN and Andrena may investigate, mitigate, notify affected parties, and cooperate with authorities as required by applicable law.

12. Your Privacy Rights

12.1 Privacy Rights

Depending on your jurisdiction and applicable law, you may have certain rights regarding your personal data, including the right to:

  • request access to personal data we maintain about you;
  • request correction of inaccurate or incomplete data;
  • request deletion of certain personal data;
  • request restriction of certain processing activities;
  • object to certain categories of processing;
  • withdraw consent where processing is based on consent;
  • request portability of eligible personal data;
  • opt out of certain categories of data sharing or targeted advertising; and
  • lodge complaints with applicable regulatory authorities.

These rights may be subject to legal limitations, verification procedures, fraud prevention requirements, security considerations, technical feasibility, operational requirements, and applicable legal exemptions.

12.2 Blockchain and Decentralized System Limitations

Certain requests may not apply to publicly accessible blockchain data, immutable blockchain records, smart contract interactions, wallet addresses, blockchain transaction records, decentralized storage systems, validator activity, protocol interaction data, security logs, compliance-related information, fraud prevention systems, or information retained for legal, regulatory, contractual, operational, telecommunications, infrastructure servicing, sanctions, cybersecurity, audit, or security purposes.

Due to the decentralized, distributed, and immutable nature of blockchain systems, certain information recorded on public blockchains cannot be modified, deleted, anonymized, restricted, or controlled by DAWN or Andrena once published to the blockchain.

This may include wallet addresses, transaction records, smart contract interactions, protocol activity, validator activity, timestamps, metadata, and other blockchain-related information that may remain permanently publicly accessible and independently indexed by third parties.

DAWN and Andrena do not guarantee the deletion, removal, anonymization, or restriction of information that has been published to public blockchain systems, has been independently retained by third parties, has been stored in decentralized systems, or must be retained for legal, security, compliance, audit, fraud prevention, operational, telecommunications, infrastructure servicing, or regulatory purposes.

12.3 Submitting Privacy Rights Requests

Users may submit privacy rights requests by contacting: [email protected] or [email protected]

Requests should specify the nature of the request, sufficient information to verify identity, and details necessary to process the request.

DAWN and Andrena may require verification of identity or authority before processing requests. Authorized agents may be required to provide proof of authorization where required by applicable law.

DAWN and Andrena may deny, limit, or condition requests where permitted by applicable law, including where identity cannot reasonably be verified, requests are excessive, repetitive, or abusive, compliance would impair legal, operational, security, fraud prevention, infrastructure servicing, telecommunications, or compliance functions, or information must be retained pursuant to legal, regulatory, contractual, accounting, sanctions, cybersecurity, dispute resolution, audit, or operational obligations.

DAWN and Andrena may retain records of requests and related communications for compliance, legal, audit, fraud prevention, security, dispute resolution, and operational purposes.

12.4 Automated Processing and Compliance Screening

DAWN and Andrena may use automated systems, analytics tools, sanctions-screening systems, fraud-detection systems, wallet-screening technologies, geolocation systems, and compliance tools in connection with eligibility determinations, access restrictions, fraud prevention, sanctions compliance, abuse prevention, infrastructure protection, security monitoring, and operational risk management.

Such systems may contribute to automated decisions relating to access restrictions, feature availability, compliance determinations, fraud prevention measures, or risk assessments, subject to applicable law.

13. California Privacy Rights

California residents may have rights under the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), including rights to:

  • know the categories of personal information collected;
  • know the categories of sources from which personal information is collected;
  • understand the business or commercial purposes for processing;
  • know the categories of third parties with whom information is shared;
  • request deletion of certain personal information;
  • request correction of inaccurate personal information;
  • limit certain uses of sensitive personal information where applicable; and
  • receive equal service and pricing without unlawful discrimination for exercising privacy rights.

DAWN and Andrena do not currently sell personal information for monetary consideration. Certain processing activities involving analytics, advertising technologies, blockchain analytics, compliance providers, wallet-screening systems, or infrastructure monitoring providers may constitute “sharing” under California law depending on applicable legal interpretations.

California residents may exercise applicable rights by contacting: [email protected]

We may require verification of identity prior to processing requests. Certain rights and requests may not apply where information is retained for legal, security, fraud prevention, compliance, or operational purposes; is publicly available through blockchain systems; is deidentified or aggregated; or is otherwise exempt under applicable law.

DAWN and Andrena are not responsible for the privacy, security, or data handling practices of third-party websites; wallet providers; blockchain protocols; smart contract systems; analytics providers; compliance providers; decentralized applications; or other third-party services not controlled by DAWN or Andrena.

14. Children’s Privacy

The Services are not directed to individuals under the age of eighteen (18), and DAWN and Andrena do not knowingly collect personal information from children.

If DAWN or Andrena becomes aware that personal information has been collected from an individual under the applicable age of consent without appropriate authorization, reasonable steps may be taken to delete such information.

Parents or guardians who believe that a child has provided personal information may contact [email protected] or [email protected]

15. Third-Party Links

The Services may contain links to, integrations with, or references to third-party websites, applications, wallet providers, blockchain networks, smart contract systems, analytics providers, decentralized protocols, infrastructure providers, social media platforms, APIs, or other third-party services.

DAWN and Andrena do not control and are not responsible for the privacy practices; security practices; availability; content; data handling; operational integrity; or terms and policies of any third-party services or systems.

Interactions with third-party services are governed solely by the applicable third party’s terms, privacy policies, and operational practices.

Users access and interact with third-party services entirely at their own risk. DAWN and Andrena encourage users to review the privacy policies and terms of all third-party services before interacting with them.

16. Changes

DAWN and Andrena may update or modify this Privacy Policy from time to time for operational, legal, regulatory, security, technical, or business reasons.

Updated versions will be posted with a revised effective date. Where required by applicable law, DAWN and Andrena may provide additional notice regarding material changes.

Continued access to or use of the Services following publication of updated terms constitutes acknowledgment of the revised Privacy Policy to the extent permitted by law.

17. Privacy and Contacts

17.1 Contacts

Questions, concerns, privacy requests, regulatory inquiries, or complaints regarding this Privacy Policy or personal data practices may be directed to: [email protected] or [email protected]

DAWN and Andrena may request additional information to verify identity, authority, or request scope before responding to inquiries or exercising applicable rights. Communications transmitted via email or the internet may not be completely secure. Users should avoid transmitting sensitive information, private keys, seed phrases, or highly confidential information through unsecured communication channels.

17.2 EU and UK Privacy Representatives

Where required by applicable law, DAWN or Andrena may designate an EU GDPR representative, UK GDPR representative, or other local privacy representative. Representative information will be made available where legally required.

18. Relationship to Terms

This Privacy Policy is incorporated into and forms part of the DAWN Terms of Use; Rewards Program Terms; USD.infra Vault Terms of Use and Risk Disclosure; Andrena Commercial Terms; and any supplemental agreements, clickwrap terms, onboarding flows, investor materials, or interface-specific agreements governing particular Services, applications, dashboards, protocol features, infrastructure systems, or interactions. In the event of a conflict between this Privacy Policy and any separate written agreement governing specific Services, the applicable separate agreement may control to the extent of such conflict.