Privacy Policy

1. Introduction

Ockams Inc. ("Ockams," "Company," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our platform, website, and services (collectively, the "Platform").

By accessing or using the Platform, you consent to the data practices described in this Privacy Policy. If you do not agree with our practices, please do not use the Platform.

2. Information We Collect

2.1 Information You Provide

We collect information you voluntarily provide, including:

• Account Information: Name, email address, phone number, date of birth, residential address
• Identity Verification: Government-issued ID, passport, driver's license, selfie photos for verification
• Financial Information: Bank account details, investment history, accredited investor documentation, income verification
• Wallet Information: Blockchain wallet addresses, transaction history on the Platform
• Communications: Support inquiries, feedback, survey responses

2.2 Automatically Collected Information

When you access the Platform, we automatically collect:

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages visited, features used, time spent, clickstream data
• Location Data: Approximate location based on IP address
• Cookies and Tracking: Session cookies, persistent cookies, analytics tags

2.3 Third-Party Information

We may receive information from third parties, including:

• Identity verification services
• Background check providers
• Blockchain analytics services
• Marketing and advertising partners

3. How We Use Your Information

We use collected information for the following purposes:

Purpose	Legal Basis
Provide and operate the Platform	Contract performance
Process investments and transactions	Contract performance
Verify identity and prevent fraud	Legal obligation, Legitimate interest
Comply with AML/KYC regulations	Legal obligation
Send service-related communications	Contract performance
Improve and personalize the Platform	Legitimate interest
Marketing communications (with consent)	Consent
Analyze usage patterns and trends	Legitimate interest
Enforce our Terms of Service	Legitimate interest

4. Information Sharing and Disclosure

We may share your information with:

4.1 Service Providers

Third-party vendors who assist with identity verification, payment processing, cloud hosting, analytics, customer support, and marketing. These providers are contractually obligated to protect your information.

4.2 Regulatory and Legal Authorities

Government agencies, regulators, law enforcement, or courts when required by law, subpoena, or other legal process, or when we believe disclosure is necessary to protect our rights or comply with legal obligations.

4.3 Business Partners

Companies whose tokenized securities are offered on our Platform may receive relevant investor information to fulfill offering requirements and maintain shareholder records.

4.4 Corporate Transactions

In connection with a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred to the acquiring entity.

5. Data Security

We implement appropriate technical and organizational measures to protect your personal information, including:

• Encryption of data in transit (TLS/SSL) and at rest (AES-256)
• Multi-factor authentication for account access
• Regular security assessments and penetration testing
• Access controls and employee training
• Secure data centers with SOC 2 Type II certification
• Incident response and breach notification procedures

However, no method of transmission or storage is 100% secure. We cannot guarantee absolute security of your information.

6. Data Retention

We retain your personal information for as long as necessary to:

• Provide our services and maintain your account
• Comply with legal and regulatory retention requirements (typically 5-7 years for financial records)
• Resolve disputes and enforce agreements
• Fulfill legitimate business purposes

Upon account closure, we will delete or anonymize your information within a reasonable timeframe, subject to legal retention requirements.

7. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights:

7.1 Access and Portability

Request a copy of the personal information we hold about you in a commonly used, machine-readable format.

7.2 Correction

Request correction of inaccurate or incomplete personal information.

7.3 Deletion

Request deletion of your personal information, subject to legal retention requirements.

7.4 Restriction

Request that we restrict processing of your information in certain circumstances.

7.5 Objection

Object to processing based on legitimate interests or for direct marketing purposes.

7.6 Withdraw Consent

Withdraw consent for processing where consent is the legal basis.

To exercise these rights, please contact us using the information below. We will respond within 30 days (or as required by applicable law).

8. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Maintain your session and authentication status
• Remember your preferences
• Analyze usage patterns and improve the Platform
• Deliver targeted advertising (with consent where required)

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect Platform functionality.

9. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses approved by relevant authorities
• Data processing agreements with recipients
• Compliance with applicable cross-border transfer requirements

10. Children's Privacy

The Platform is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child, we will take steps to delete it promptly.

11. California Privacy Rights (CCPA)

California residents have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know what personal information is collected, used, and disclosed
• Right to delete personal information
• Right to opt-out of the sale of personal information (we do not sell personal information)
• Right to non-discrimination for exercising privacy rights

To submit a CCPA request, contact us at privacy@ockams.com or call our toll-free number.

12. Updates to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on the Platform and updating the "Last Updated" date. Your continued use of the Platform after changes take effect constitutes acceptance of the updated policy.

13. Contact Us