Half Space Labs Limited d/b/a Wynd Labs™ (Wynd Labs, we, us, or our) operates the Grass™ web extension, dashboard application, desktop application, mobile application, and related hardware, including as made available through our website www.getgrass.io (the Website, and together with our web extension, dashboard, desktop application, mobile application, and related devices, the Grass Services) that permit users to participate in a Decentralized Peer-to-Peer Internet Networking Ecosystem that facilitates access to and use of web data (the Grass Network).

The purpose of this Privacy Policy is to help you understand what types of personal information we collect, use, and disclose in connection with your access to and use of the Grass Services and participation in the Grass Network.

This Privacy Policy covers the following topics, which you can access by clicking the links below:

• What is personal information?
• Personal information that we collect
• Other information that we collect
• Use of your personal Information
• Promotional and transactional messages
• Disclosure of personal information
• Aggregated data
• Retention of personal information
• Security & protection of personal information
• Access to personal information;
• Consent; withdrawal of consent
• Links to third party resources
• Cookies
• Changes to this Privacy Policy
• Contact information

Unless you are based in the European Economic Area (EEA) or the United Kingdom (UK), by accessing or using the Grass Services or participating in the Grass Network, you agree to accept this Privacy Policy, including the terms and conditions of this Privacy Policy that relate to the ways that we collect, use, and disclose your personal information. If you are based in the EEA or the UK, please see below for our policies and procedures regarding how we process your personal data here.

You can withdraw your consent to our collection, use, or disclosure of your personal information by contacting our Privacy Officer using the contact information that is included in this Privacy Policy (see below). Please note that if you choose to withdraw your consent, we may not be able to provide you with certain services, products, communications, and opportunities, including access to and use of the Grass Services and/or participation in the Grass Network.

Personal information is any information about, relating to, or that identifies a specific individual. Under certain laws that may apply to you, personal information may also include information that identifies a specific household or device.

We may collect personal information from you based on the Grass Services that you elect to access and use. The personal information that we collect from you in connection with your use of the each of the Grass Services includes the following:

• contact and identification information, such as your email address, username, password, IP address, digital wallet public address, and any referral codes that you have been provided by us in connection with your use of the Grass Services;
• your location information; and
• any other personal information that you choose to provide to us when you contact us for support, provide us with feedback, or otherwise communicate with us.

The types of personal information that we collect will depend on what personal information you choose to provide to us based on your interactions with us and the Grass Services and Grass Network.

In addition to the personal information that we collect from you, we collect information about your use of the Grass Services and participation in the Grass Network, including your device domain you use to access the Grass Services, the operating system of your device, your device settings, application IDs, the type and version of your browser, crash data and analytics, other device identifiers, and other information relating to the manner in which you access or use the Grass Services or participate in the Grass Network.

We use the personal information that we collect to provide you with the functionality, features, and communications that are available on and through the Grass Services and to enable us to manage, maintain, and develop our operations. For example, we may use your personal information for the following purposes:

• establish, maintain, and manage our relationship with you, including by assisting you to create an account, communicate with us, and provide you with the services that you request;
• assess the quality of your IP address and determine the uptime associated with your IP address as part of the Grass Network;
• support the Grass Network by permitting our users and customers to leverage the Grass Network to facilitate their access to and use of web data. This personal information used for this purpose is limited to your IP address;
• allow you to participate in, subscribe to, and receive information, news, updates, and promotional materials from us and third parties;
• comply with your requests and preferences regarding your use of the Grass Services and the manner in which we communicate with you;
• understand your preferences and values so that we can tailor the Grass Services and communications to you;
• protect us against error, fraud, theft, and damage to our Services, business, and property;
• conduct research, analysis, evaluation, and development activities to understand the way the Grass Services are used and to improve the Grass Services, Grass Network, and our general operations, including with respect to the development of new products, services, and opportunities;
• enable us to comply with applicable laws and regulatory purposes; and
• any other reasonable purpose to which we may notify you of, or to which you consent.

Unless you are based in the EEA or UK, by consenting to our collection, use, and disclosure of your personal information on and through the Grass Services you allow us to fulfill the purposes for which we collect and use your personal information as described above.

For more information about how we use your personal information if you are based in the EEA or UK, including the legal bases we may rely on to process your personal information as an alternative to obtaining your consent, please see the EEA and UK section of this Privacy Policy.

We will collect your consent prior to sending you promotional emails and other electronic messages (e.g., texts, direct messages), unless an exception to obtaining your consent applies under applicable laws. You will have an opportunity to opt-out or unsubscribe from receiving promotional messages from us at any time. Promotional messages include, but are not limited to, our newsletter and updates about our and our partners businesses, products, and services.

By using the Grass Services, you agree to receive transactional communications about your account and activities. For example, when you create an account or reset your password you may receive an email confirming the details of such activity. You may not opt-out of receiving these transactional communications.

We may disclose your personal information and other information in the manner and for the purposes that are described in the sections below.

• Working with third parties. We may work with third parties that provide services to us that help us facilitate one or more aspects of the products, services, communications, or features that we offer to you on and through our website and Services. We may provide these third parties with your personal information directly or they may collect your personal information from you on our behalf.
• Opportunity to receive rewards. We may disclose your personal information to third parties in connection with your opportunity to receive rewards for your use of the Grass Services. For example, we may disclose your email address, username, IP address, and digital wallet public address with one or more third parties for this purpose.
• Use of the Grass Network. Users of the Grass Network, including our customers, may have access to your IP address in connection with their participation or use of the Grass Network to facilitate access to and use of web data through the Grass Network. In addition, your IP address may be visible to websites when your IP address is being used as part of the Grass Network. For example, when the Grass Network is being used to access information on a website the IP address used to access the website is visible to the website as well as the user of the Grass Network that is seeking to access the website.
• Business transactions. Your personal information may also be disclosed to a third party in connection with a business transaction, including a change of ownership of Wynd Labs or its affiliates, the sale of all or certain of our assets, or the grant of a security interest. We will take reasonable steps to ensure that the third party that receives your personal information is bound by appropriate agreements that require that your personal information is handled in a manner that is consistent with this Privacy Policy (or, if you are based in the EEA/UK, where we may notify you otherwise).
• Legal requirements. Your personal information may also be disclosed:
  • as permitted or required by applicable law or regulatory requirements;
  • to comply with valid legal processes such as a search warrant, subpoena, or court order; and
  • during emergency situations or where necessary to protect the safety of a person or a group of persons; and
  • for additional purposes for which we have obtained your consent to disclose your personal information (or, if you are based in EEA/UK, where we may notify you otherwise).

Since we may disclose your personal information to third parties (including our service providers) as described in this Privacy Policy, your personal information may be collected, used, disclosed, and otherwise processed outside of your jurisdiction of residence. As such, your personal information may potentially be accessible to law enforcement and national security authorities of another jurisdiction where local laws provide for a different level of protection for personal information. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security agencies in those other countries may be entitled to access your personal information.

If you would like further information about our policies and practices regarding the transfer and storage of your personal information, including disclosures to third parties such as our service providers, please contact our Privacy Officer using the contact details below.

Unless you are based in the EEA or UK, by providing your personal information to us, you consent to our disclosure of this information to our service providers (and other third parties) as described in this Privacy Policy, including those that may be located outside of your jurisdiction of residence.

We may disclose aggregated non-personal information and related usage information, which does not contain personal information that can identify you, with third parties, including our customers, clients, partners, advertisers, service providers, vendors, suppliers, and content providers

We do not keep your personal information forever. We will retain your personal information for as long as is reasonably necessary for us to complete our dealings with you, or as may be required by law, whichever is longer.

We endeavour to maintain commercially reasonable physical, technological, and procedural safeguards that are appropriate based on the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal, or destruction.

Please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of your personal information that is relevant to your use of the Grass Services.

You can ask to access the personal information that we have about you. If you want to review, verify, delete or correct your personal information, please contact our Privacy Officer. We may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. If you require assistance in preparing your request, please contact our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. There are situations where applicable law allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, your personal information may have been destroyed, erased or made anonymous in accordance with our record retention practices. In the event that we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons why, subject to any legal or regulatory restrictions.

If you are based in the EEA or the UK, you have other rights with respect to your access to and correction of the personal information we hold about you. Please see below for our policy on how we process your personal data.

Unless you are based in the EEA or UK or you advise us otherwise, through the access and use of our website and Services, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy. For further information about how we process your personal information if you are based in the EEA or UK, including the legal bases we may rely on to process your personal information as an alternative to obtaining your consent, please see the EEA and UK section of this Privacy Policy.

The Grass Services may contain links to other websites that may be subject to less stringent privacy standards. These links are provided for your convenience only and you assume all risk for clicking these links to other websites. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. We are not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.

We use cookies and tracking technologies that are similar to cookies. A cookie is a small file of letters and numbers that we may set on your device to store and sometimes track information about you. Cookies and similar technologies we use are designed for analytics. This allows us to distinguish you from other users of our Website. This also helps us to provide you with a good experience when you use our Website. We may use the following types of cookies on our Website:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to remember information you have typed into an online form.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to remember your preferences.
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

We may make changes to this Privacy Policy from time to time. These changes may be made as a result of changes to our legal obligations or the ways in which we collect, use, disclose, or otherwise process your personal information.

We will post an updated version of our Privacy Policy on our website when we make changes and may also notify you of the changes we have made if we are required to do so by applicable law. We encourage you to check this Privacy Policy for updates on a regular basis.

You agree that by continuing to use the Grass Services or participate in the Grass Network after an update to our Privacy Policy, you agree to accept and consent to the collection, use, and disclosure of your personal information as described in the updated version of the Privacy Policy.

If you have any questions or concerns regarding this Privacy Policy, you should contact our Privacy Officer at privacy@wyndlabs.ai.

**If you choose to communicate with us via email, please be aware that email is not a 100% secure medium for sending any personal or confidential information to us. **