Privacy Policy

Last Modified: February 2026

Animoca Minds (“We”) respect your privacy and commit to protecting it through our compliance with the practices described in this notice. This notice describes our practices for collecting, using, maintaining, protecting, and disclosing the personal data we may collect from you or that you may provide when you visit our website or other communications or forms that link or refer to this notice (our “Website”). This notice applies to the personal data collected through our Website, regardless of the country where you are located. The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. We do not control these third-party websites, and we encourage you to read the privacy notice of every website you visit.

Please read this notice carefully to understand our policies and practices for processing and storing your personal data. By engaging with our Website, you accept and consent to the practices described in this notice. This notice may change from time to time. Your continued engagement with our Website after any such revisions indicates that you accept and consent to them, so please check the notice periodically for updates.

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We collect and use different types of data from and about you including:

• Personal data that we could reasonably use to directly or indirectly identify you, such as your name, email address, wallet address, user name, social media handle or other similar social identifier, or any other identifier we may use to contact or interact with you online (“personal data”).
• Non-personal data that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, statistics, or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Website feature.
• Non-personal details about your Website interactions or activities, including the full Uniform Resource Locators (URLs), clickstream information to, through, and from our Website (including date and time), products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from the page.

If we combine or connect non-personal, demographic, or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal data.

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We use different methods to collect data from and about you including through:

• Direct interactions. You may give us information about you by filling in forms or by corresponding with us by phone, email or otherwise. This includes information you provide when you create an account and log into such account, participate in discussion boards or other social media functions on our Website, participate in a campaign, promotion or survey, and when you report a problem with our Website.
• Automated technologies or interactions. As you interact with our Website, we may automatically collect technical data about your device or equipment, location, browsing actions and use patterns (including, as applicable, any use of or input to any AI tools) as specified above. We collect this information by using cookies, server logs, and other similar technologies.
• User contributions. You may provide information, content (which may include images, audio, video or text) or other input (including AI Inputs) for us to process in order to provide products or services to you, or to publish or display on public Website areas or transmit to other Website users or third parties (collectively, “User Contributions”). Please be aware that no security measures are perfect or impenetrable and you submit User Contributions at your own risk. Additionally, we cannot control the actions of any third party with whom you choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.
• Third parties or publicly available sources. We may receive information about you if you visit other websites employing our cookies or from third parties including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, data brokers, or aggregators. We may also collect information that is publicly available such as public blockchain data.

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We provide AI agents to assist with your tasks. Those agents use AI models to understand, analyse and respond to your inputs, which may include commands, questions, prompts, information and content that you submit or upload or to which you grant access in order to use our services such as social media or wallet and trading information (collectively, “AI Inputs”), and execute tasks on your behalf. Those AI Inputs may include personal data.

The AI agents have persistent memory which means those agents retain key information from your interactions, such as preferences, configurations or attributes that you share with or create for those agents or that can be derived from your usage patterns or interactions with those agents (“Memory Data”). That Memory Data will enable the AI agents to deliver more personalized and customized responses and to maintain context.

You are reminded that (i) once you elect to use the agentic AI services on the Website, you will be required to provide AI Inputs which will be processed by AI agents with persistent memory, creating Memory Data, and by doing so, you will be taken to have consented to the processing of your personal data comprised in such AI Inputs and Memory Data for the purposes of providing the agentic AI services to you; and (ii) the persistent memory feature of an AI agent cannot be disabled and whilst instructions can given to an AI agent to “forget” or disregard specific information, there is no guarantee that any specific Memory Data can be fully removed from the AI agent’s context.

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Our Website uses cookies (small files placed on your device) or other automatic data collection technologies to distinguish you from other Website users. This helps us deliver a better and more personalized service when you browse our Website. It also allows us to improve our Website by enabling us to improve your user experience on the Website.

You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, your user experience may be affected and certain features may not work correctly. Unless you adjust your browser settings to refuse cookies, our system will issue them.

Our Website pages may contain web beacons (small transparent embedded images or objects, also known as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count website page visitors or to compile other similar statistics such as recording Website content popularity or verifying system and server integrity.

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We use your personal data to provide you with access to the Website, improve your user experience on the Website, communicate with you or to conduct other business operations, such as using data to improve and personalize your experiences. Examples of how we may use the personal data we collect include to:

• Present our Website and provide you with the information, products, services, and support that you request from us.
• Fulfill the purposes for which you provided the data or that were described when it was collected.
• Notify and communicate with you about changes to our Website, products, or services.
• Administer our Website and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
• Improve our Website, products or services (including train our models that power our services), marketing, or customer relationships and experiences.
• Protect our Website and the offering of our products and services on the Website.
• Make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.
• Prevent fraud, cyberattacks, illegal or unlawful activities or any abuse or misuse of our products and services on the Website.
• Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or comply with legal requirements.

We may also use non-personal data for any business purpose.

We will use your personal data for one or more of the following purposes and for the following lawful bases:

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We may share the following categories of your personal data with the following categories of recipients:

We may also disclose your personal data to third parties:

• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• to a buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where one of the transferred assets is the personal data we hold;
• to comply with any court order, law, or legal process, including responding to any government or regulatory request; and to protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.

We may share non-personal data without restriction.

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We will retain your personal data for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you (for example, for as long as you have an account with us);
• The amount, nature, purpose of collection and sensitivity of the data;
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

You are also reminded that certain data which is available on the public blockchain (for example, on-chain trading data of digital assets (such as transaction time stamps, wallet addresses, etc.)) will be retained on the blockchain permanently.

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We are based in Hong Kong. We may process, store, and transfer the personal data we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own.

In particular, we may transfer the personal data we collect to (i) our other group companies, which operate in (among others) Australia and the United Kingdom; and (ii) any other country in which we engage our service providers or in which our business partners operate, to the extent that those service providers or business partners are involved in the offering of our products and services on the Website. We use appropriate safeguards for transfer for such data transfers, including the European Commission’s model contracts and standard contractual clauses, unless the data transfer is to a country that has been determined by the European Commission or other relevant authority, as applicable, to provide an adequate level of protection for personal data.

By submitting your personal data or engaging with our Website, you consent to this transfer, storing, or processing.

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Personal data comprised in AI Inputs and Memory Data may be accessed or shared with other AI agents for the purposes of execution or coordination of tasks or through communication platforms that are open to such AI agents. Please be aware that your personal data may be disclosed or transferred to third parties where you have chosen to use our agentic AI services with persistent memory features.

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You may send us an email at compliance@animocabrands.com to request access to, correct, or delete personal data that you have provided to us. We may not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or negatively impact the information’s accuracy.

You have the following rights with respect to your personal data (subject to any limitations which are expressly identified in this notice):

• Right of access to personal data provided
• Right to correct incomplete, inaccurate, or to update outdated data
• Right to information on the possibility of not providing consent and on the consequences of such denial
• Right to withdraw or revoke consent
• Right not to be subject to a decision based solely on automated processing, or profiling, which produces legal effects or negatively affects the individual
• Right to have data deleted or erased
• Right to either opt out of or object to certain processing
• Right to have the data ported (transferred) to a different third-party provider
• Right not to be subject to discrimination
• Right to restriction of processing — this will only apply in certain circumstances
• Right to data portability — this will only apply in certain circumstances
• Right to object — this will only apply in certain circumstances
• Existence of the right to lodge a complaint with a local data protection authority

In the event that any of your questions or requests cannot be resolved, you may reach out to the Hong Kong Office of the Privacy Commissioner for Personal Data or the UK Information Commissioners’ Office.

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The security of your personal data is very important to us. We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse, and unauthorized access, use, alteration, or disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password or any other sensitive personal data (such as social security numbers, health or banking information) with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website. Any transmission of personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website.

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We do not direct our Website to minors and we do not knowingly collect personal data from children under 16 years of age or as defined by local legal requirements. If we learn we have mistakenly or unintentionally collected or received personal data from a child without appropriate consent, we will delete it. If you believe we mistakenly or unintentionally collected any information from or about a child, please contact us at compliance@animocabrands.com.

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Since the agentic AI services on the Website is launched as a beta product, data handling practices such as data retention periods and third party processing may change. We will post any changes we may make to our privacy notice on this page and indicate on the Website home page that we updated this privacy notice. If the changes materially alter how we use or treat your personal data we will notify you by email to the primary email address specified in your account. Please check back frequently to see any updates or changes to our privacy notice.

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Please address questions, comments, and requests regarding this privacy notice and our privacy practices to compliance@animocabrands.com.

Details of our data protection officer: