SCOPE

This Privacy Policy (“Policy”) describes how Synonym Software Ltd. treats personal information on the Pubky platform and the products, services and features made available as part of the platform (collectively, the “Platform”).

POLICY SUMMARY

Policy Summary This summary offers a concise overview of how Synonym Software Ltd. (“Synonym”) collects, uses, shares, and protects your personal information on the Pubky platform. For full details, please read the complete Privacy Policy.

• What We Collect:
  • Identifiers (e.g. name, email, public keys)
  • Contact & account data (e.g. mailing address, bio, profile picture)
  • Commercial & payment information (e.g. wallet addresses, transaction history)
  • Device & usage data (e.g. IP address, browser type, usage patterns)
  • Visual & inference data (e.g. uploaded photos; inferences about preferences)


• Why We Collect It:
  • To deliver, maintain, and improve the Platform and services
  • To communicate with you (e.g. account notices, policy updates)
  • To secure our Platform and investigate issues (e.g. fraud prevention)
  • As required by law or with your consent


• How We Share It:
  • With our subsidiaries and affiliates for internal business purposes
  • With vendors and service providers (e.g. email processors, analytics)
  • Publicly on the Platform when you choose to post content
  • With successors in the event of a merger or sale
  • VWhen required by law (e.g. court orders, law-enforcement requests)


• Your Rights & Choices:
  • Access, correct, or delete your personal data
  • Object to or limit certain processing activities
  • Withdraw consent where we rely on it
  • Opt-out of “sale” or sharing for cross-context marketing (we do not currently sell or share)
  • Control cookies and similar technologies via your browser settings


• Data Retention & Transfers:
  • We retain your information as long as necessary to provide services, comply with legal obligations, and resolve disputes.
  • Your data may be stored or processed in the United States or other jurisdictions.


• Children & COPPA:
  • The Platform is intended for users aged 13 and older. We do not knowingly collect data from children under 13.

Updates & Contact:

• We may update this Policy; material changes will be communicated as required by law.
• For questions or to exercise your rights, email privacy@synonym.to

NOTICE AT COLLECTION

We collect, and in the past 12 months have collected, the following categories of information from and about you: identifiers; commercial information; internet or similar network activity; visual information; and inferences drawn from other personal information. We collect these categories of information from you in order to provide our services to you, to run our business, to communicate with you, and as required by law. We may have disclosed each of these categories of personal information for a business purpose as described below. We have not “sold” or “shared” personal information in the past 12 months, as those terms are defined by the CCPA.

For a description of your rights under the CCPA, and instructions on how to exercise your rights, please see the Your Privacy Rights section below.

We will retain each of these categories of personal information based on several factors, including is reasonably necessary to: (i) provide our products and services or administer our relationship with a consumer; (ii) protect our business, employees, organization, and others; (iii) fulfill our legal and regulatory obligations; and (iv) investigate and address issues which may include safety concerns, potential security incidents or policy violations.

TYPES OF INFORMATION WE COLLECT

We collect information from you and about you. Here are some examples of the information we may collect:

• Contact Information. For example, we may collect your telephone number and email address. We may also collect your mobile phone number.
• Information You Submit. We may collect information when you send us a message through the “Contact Us” page or similar features on our Platform. It also includes collecting information that you publicly post via the Platform.
• Payment Information. We, through our vendors, may collect and store your payment information. This may include wallet addresses or keys.
• Account Information. Certain portions of the Platform allow you to create a user account. In connection with that account, we collect your public key. We will also collect any information you use to complete your profile. This may include your name, a short bio, and a picture that you upload.
• Device Information. For example, we may collect information about the type of device you use to access our Platform. We may also collect your device identifier, IP address or mobile operating system. We may also infer your general location based on your IP address.
• Other Information. If you use our website, we may collect information about the browser you are using. We might look at what site you came from, or what site you visit when you leave us.

HOW WE COLLECT YOUR INFORMATION

We collect your information in different ways. Below are some examples of how we may collect your information.

• Directly From You. For example, when you create a profile, post on the Platform, or submit an inquiry to us.
• Passively. For example, when you visit and navigate our Platform on any device. We may also collect information about users over time and across different websites and devices when you use the Platform.
• From Third Parties. We may receive information about you from other sources. For example, this may include receiving information from our business partners, including analytics vendors.
• By Combining Information.We may combine information that we collect offline with information we collect through our Platform. We may also combine information we collect about you from the different devices you use to access our Platform.

HOW WE USE YOUR INFORMATION

Examples of how we may use your information include:

• To Run and Improve Our Platform and Business. We may use your information to operate and improve the Platform. We may also use your information to provide you with information about our business.
• Passively. For example, when you visit and navigate our Platform on any device. We may also collect information about users over time and across different websites and devices when you use the Platform.
• To Respond to Your Requests or Questions. This may include responding to your feedback.
• To Communicate With You.We may communicate with you about your account or our relationship. We may also contact you about this Policy or our Platform terms and conditions.
• For Security Purposes.This could include protecting our company and consumers who use our products and services. It may also include protecting our Platform.
• As Otherwise Permitted By Law or As We May Notify You.
• As Requested or Directed By You.

HOW WE SHARE YOUR INFORMATION

We may share your information in the following ways:

• Internally.We may share your information with our parent, subsidiary, and affiliate entities.
• Passively. For example, when you visit and navigate our Platform on any device. We may also collect information about users over time and across different websites and devices when you use the Platform.
• With Our Service Providers.We may share your information with third parties who perform services on our behalf. For example, this may include companies that send emails on our behalf or help us run our Platform.
• On the Platform.If you choose to make posts on the Platform, anything that you post will be posted publicly on the Platform and visible to other users.
• With Any Successors to All or Part of Our Business.For example, if we merge with, are acquired by, or sell part of our business to another entity. This may include an asset sale, corporate reorganization or other change of control.
• To Comply With the Law or To Protect Ourselves.For example, this could include responding to a court order or subpoena. It could also include sharing information if a government agency or investigatory body requests. We might share information when we are investigating a potential fraud.
• For Other Reasons We May Describe to You.
• As Requested or Directed By You.

CHILDREN UNDER 18

The Platform where this Policy is located is meant for adults. We do not knowingly collect personally identifiable data from persons under the age of 18, and strive to comply with the provisions of COPPA (The Children’s Online Privacy Protection Act). If you are a parent or legal guardian and think your child under 13 has provided us with information, please contact us at privacy@synonym.to. You can also write to us at the address listed at the end of this website Policy. Please mark your inquiries “COPPA Information Request.” Parents, you can learn more about how to protect children’s privacy on-line here.

CHOICES REGARDING YOUR INFORMATION

You have certain choices about how we use your information. Certain choices you make are browser and device specific.

Cookies & Other Tracking Technologies:

• Cookies You can adjust your browser to control cookies to require your affirmative acceptance for new cookies, automatically reject cookies and/or delete or disable existing cookies. How you do so depends on the type of cookie and the browser that you are using. For more information on how to control browser cookies, click here. If information about your browser is not available through this page, please search your browser for instructions about how to opt-out of cookie collection.
• Email Tools:You can also change your email settings to block the automatic download of images in email messages, as such images may contain technologies that help us understand how you interact with the message.
• Note that deleting or blocking cookies may impact your experience on our website, as some features may not be available. Certain options you select are browser and device specific.

Our Do Not Track Policy:

• Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain features on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop.
• Options you select are browser and device specific.

YOUR PRIVACY RIGHTS

Based on your state or country of residence, you may have the rights listed below with respect to the personal information that we maintain about you. We may take steps to verify your identity, as permitted or required under applicable law, before we process your request. Verification may include asking you to provide information about yourself that we can match against information already in our possession.

• Notice.This means that you can request that we disclose what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we have disclosed personal information, and the specific pieces of personal information we have collected about you.
• Access. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Deletion.This means that you can request that we delete personal information about you which we have collected from you. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Correction.This means that you can request that we correct inaccurate personal information that we maintain about you.
• Object to Specific Processing.This means that you may object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Withdraw Consent.Where we are relying on consent to process your personal information, you may withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Limit the Use or Disclosure of Sensitive Personal Information.The California Consumer Privacy Act (“CCPA”) provides a right for consumers to request that business limit the use or disclosure of their “sensitive” personal information. In our normal business operations, we do not process “sensitive personal information” as that term is defined under CCPA. Please do not submit this information to us.
• Opt-Out of the Sale or Sharing of Personal Information.You may have the right to opt out of the “sale” or sharing of personal information with third parties for cross-contextual marketing purposes. We do not knowingly “sell” or “share” any personal information, including any personal information relating to consumers under the age of 16, as we understand those terms to be defined under applicable law.

Agents that you have authorized to act on your behalf may also submit requests as instructed below. The agent must also provide evidence that they have your written permission to submit a request on your behalf. If we are unable to verify the authenticity of a request, we may ask you for more information or may deny the request.

Individuals who wish to exercise their rights under this section can contact us at privacy@synonym.to. Please include your name, public key, and email address, and indicate you are making a “Privacy Rights” request. If we deny your rights request and you would like to appeal, you may contact us at privacy@synonym.to.

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the supervisory authority of your state or country.

SECURITY

The Internet is not 100% secure. We cannot promise that your use of our Platform will be completely safe. We encourage you to use caution when using the Internet. We use reasonable means to safeguard personal information under our control. A user id and a password are needed to access certain areas of our Platform. It is your responsibility to protect your username and password.

STORAGE AND TRANSFER OF INFORMATION

Information we maintain may be stored in or outside of the United States. If you live outside of the United States, you understand and agree that we may transfer your personal information to the United States. This Platform is subject to the laws of the United States, which may not provide the same level of protections as those in your own country. Personal information processed and stored in another country, including the United States, may be subject to disclosure or access requests by the governments, courts or law enforcement or regulatory agencies in that country according to its laws.

By using our Platform or by providing us with personal information, you consent to any such transfer of information outside of your country.

LINKS

Our Platform may contain links to other third-party sites that are not governed by this Policy. If you click on a link to a third-party site, you will be taken to a site we do not control. We are not responsible for the privacy practices used by third-party sites. We suggest that you read the privacy policies of those sites carefully. We are not responsible for these third-party sites.

HOW TO CONTACT US

If you have any questions, comments or concerns with respect to our privacy practices or this Policy, or wish to update your information, please feel free to contact us at privacy@synonym.to.

CHANGES IN POLICY

From time to time, we may change our Policy. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy on our Platform. Please check our Platform periodically for updates.