Arbspark

PRIVACY POLICY

Last Updated: January 11, 2022

1. Introduction

This website-hosted user interface (this “Interface”) is made available by ML2 Inc., a corporation organized and existing under the laws of Nevis (the “Company”, “us”, “we”, or “our”).

This Privacy Policy (the “Policy”) outlines our practices regarding the availability of the Interface and our methods for collecting, utilizing, managing, and sharing data obtained from our users (each, a "user", “you”, or “your”) via the Company’s digital platforms. This includes the Interface, web and mobile applications, and all related sites connected to the Interface by us or our affiliates (the “Site”). This Policy also covers all data gathered through our Site or acquired in relation to our products, Services, content, tools, and functionalities (collectively with the Site, the “Services”). We encourage you to review this Policy thoroughly, as we are dedicated to safeguarding your privacy in accordance with these terms.

We recognize you may have inquiries concerning this Policy, specifically regarding the collection and application of your personal data. For any privacy concerns or related questions, please contact us at legal@arbspark.com. Use of our Services is governed by our Terms of Services (“Terms”), which, combined with this Privacy Policy, form your legal contract with us (the “Agreement”). If you disagree with any part of this Policy, you must refrain from using our Site.

Your use of our Services signifies your acceptance of this Policy. By (i) visiting or interacting with the Services, (ii) creating an account or purchasing any Services, or (iii) clicking “accept,” “agree,” “OK,” or similar prompts regarding our Terms, you acknowledge and agree to be legally bound by the conditions set forth in this Policy.

To maintain the Site and deliver our Services, we may gather or receive specific details about you and your engagement with our platforms. You hereby grant us permission to collect and receive this information for the purposes of operating the Site and providing the Services.

2. Scope of Coverage

This Policy pertains to data gathered during your interaction with the Site and our Services. It does not extend to information collected through offline channels or via other platforms, including those operated by third parties or affiliates. In this document, "personal information" refers to data that identifies a specific individual. This definition excludes anonymized or aggregated datasets that cannot be traced back to a user. Please note that information you provide may occasionally include the personal details of third parties.

Data Acquisition and Usage When navigating the Site, we automatically record your IP address, browser specifications, and browsing activity. We may also monitor geolocation data. Acceptance of these data collection practices is a prerequisite for using our Services.

Sources of Information:

Direct submissions provided by you;
Automated tracking during your visit, including usage patterns, IP logging, and data retrieved via Cookies and similar technologies; and
External sources, such as business affiliates, service providers (e.g., Metamask), or integrated networks where you have granted access permissions.

Account holders may be asked to provide the following:

Identity Data. Information that identifies you personally, such as your full name, residential address, email, phone number, and date of birth. Providing this demographic and interest-based data is voluntary, though withholding it may limit access to certain Services.
Technical Logs. Data generated automatically by our servers, including operating system details, access timestamps, and referral URLs, to understand how you connect to our infrastructure.
Payment Details. To facilitate transactions, we may require banking credentials, card numbers, or routing information. By using these features, you permit our third-party payment processors and wallet integrations (like MetaMask) to handle this data under their own privacy guidelines.
Mobile Analytics. When using handheld devices, we capture hardware identifiers, location data, and language settings. We may also collect your phone number if provided directly.
Precise Location. We utilize GPS, Wi-Fi, and cellular data to determine your coordinates for security, risk assessment, and fraud prevention
Communication History. We maintain records of your inquiries and emails sent to us, retaining them for the duration required by legal mandates.
Research Participation. Any data or feedback provided through voluntary surveys may be stored for analysis.

To ensure a protected environment, we may request supplemental documentation—such as government IDs, passports, or utility bills—to authenticate your identity and satisfy regulatory compliance standards.

Furthermore, we may gather data through other touchpoints, such as interactions with our support staff or during specific promotional events not explicitly listed above.

3. Minor Protection and Age Requirements

Our platform is not designed for individuals under the age of 18. We prohibit anyone under this age from submitting personal data to the Site. Should we discover that we have inadvertently gathered information from a minor, we will delete that data immediately, except where retention is required by law. If you suspect we have received information regarding a person under 18, please reach out to us via the contact details provided in this Policy.

Tracking Technologies and Cookie Usage

Cookies are minor data files stored on your device's storage. When you engage with our Site or Services, we and our authorized service providers may employ cookies and similar monitoring tools (collectively, "Cookies"). These tools help us identify you, tailor content and marketing, evaluate promotional success, conduct detailed analytics, prevent fraudulent activity, and maintain a secure environment for all users.

While most web browsers accept cookies automatically, you have the option to modify your settings to block or delete them. Please be aware that certain features of our Services rely on these technologies to function. Consequently, disabling Cookies may restrict your access to parts of the Services or prevent them from working entirely.

Our Site may also utilize web beacons (also known as pixel tags or clear gifs) to track user traffic and gather site-related statistics, such as measuring the popularity of specific content or ensuring server stability. While web beacons cannot be disabled directly, restricting Cookies or setting your browser to alert you to new cookies can often neutralize their tracking capabilities.

Do Not Track: "Do Not Track" (“DNT”) is a browser feature intended to signal your preference against third-party tracking. While you can toggle this in your browser settings, our systems do not currently acknowledge or respond to DNT signals.

Utilization of Your Information

Processing your data accurately enables us to deliver a seamless, productive, and personalized user experience. Specifically, the data we collect via the Site may be used to:

Manage and facilitate contests, giveaways, and promotional events;
Verify data integrity and validate information through reputable third-party sources;
Generate aggregated statistical reports and analysis for internal assessment or partner collaboration;
Communicate with you regarding your account status, service usage, or specific inquiries;
Establish and maintain your user profile to tailor your future interactions with our platform;
Refine, evaluate, and enhance the overall quality, content, and interface of our Services;
Provide requested Services and dedicated technical support;
Facilitate direct interaction between users within the platform;
Optimize the operational performance of our Site in pursuit of our legitimate interests, including:
Identifying security vulnerabilities, preventing cyberattacks or illegal activities, and assisting in legal proceedings against offenders;
Analyzing user engagement levels and delivering contextually relevant advertisements;
Conducting research aimed at technological innovation and proof-of-concept testing;
Developing and testing new security protocols or service features to boost reliability and resilience;
Implementing systemic updates and feature enhancements;
Designing and launching next-generation products;
Maintaining rigorous internal quality assurance standards;
Confirming user identity to mitigate the risk of financial fraud;
Performing diagnostic debugging to resolve technical issues affecting core functionality;
Upholding our contractual policies and legal terms; and
Adhering to regulatory requirements, protecting public safety, or defending vital interests.
Address any other specific objective for which you explicitly provided the information;
Strengthen site security and, where geolocation is enabled, provide localized content, search results, and offers;
Track usage patterns to identify areas for user experience improvement;
Alert you about critical updates or changes to our platform;
Execute various duties as mandated by applicable legal frameworks;
Utilize risk-assessment tools to identify and block prohibited or suspicious activities;
Execute financial transactions and issue notifications regarding your billing or network status;
Support the continuous delivery and expansion of our offerings;
Distribute newsletters, digital coupons, and targeted marketing materials related to our ecosystem;
Solicit user feedback, settle disputes, manage fee collection, and resolve technical hurdles; and
Fulfill customer service requests and respond to personal correspondence.

As previously mentioned, we may process your data for any other purpose disclosed at the time of collection. We may also utilize your information to display targeted advertisements for our partners. While we do not share personal identifiers for this purpose without consent, your engagement with an ad may lead the advertiser to infer that you fit their target demographic.

Furthermore, you grant us authorization to use and distribute information in the following circumstances:

We may occasionally share data with external companies whose products might interest you. Depending on your jurisdiction, you may have the right to opt out of such sharing. To do so, email legal@arbspark.com with the subject "Privacy Policy." We may require identity verification before processing this request.
Information will be accessed and shared as necessary to honor our contract with you, provide support, and resolve service-related questions;
We may hire third-party specialists to handle tasks like marketing assistance or technical operations. Notably, we utilize professional cloud hosting services for data storage and configuration management;
To better understand our market, we analyze anonymized or aggregated data to improve our business operations. This data does not reveal your identity and may be shared with partners, affiliates, or for other lawful business purposes;
Data may be shared across our corporate structure, including with parent companies, subsidiaries, and entities under common ownership;
In the event of a merger, acquisition, asset sale, or bankruptcy, your information may be among the assets transferred to a successor entity; and
We may disclose information to: (i) comply with national security or law enforcement requests, (ii) satisfy legal mandates or court orders, or (iii) protect the rights, safety, and property of our company or the public.

If we plan to use your data in a way not covered by this Policy, we will notify you before or during the collection process. Regarding Protection and Storage: We prioritize your data security but acknowledge that no digital transmission is entirely immune to risk. We employ administrative and technical safeguards—including firewalls, encryption, and restricted employee access—to defend your information. However, we cannot guarantee absolute security against unauthorized breaches. We encourage you to protect your credentials and never share passwords. All data transmission is conducted at your own risk.

8. How We Share Personal Information with Other Parties

We may share your information with our business partners to offer you certain products, Services, and promotions. We may also use third-party advertising companies to serve ads when you visit the Site. These companies may use information about your visits to the Site and other websites that are contained in web cookies in order to provide advertisements about goods and Services of interest to you.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

Some personal information is public information (this may include your web3-enabled wallet’s public address, username, profile photo, profile first and last name, month, and year of account creation, and public transactions in which you've been involved), and may be seen by anyone on the Internet due to the nature of the blockchain, whether or not they have an account with us. Public information may also be seen, accessed, reshared or downloaded through APIs, SDKs, or third-party Services that integrate with our products.

We may share your personal information with:

Law enforcement, government officials, or other third parties if we are compelled to do so by a subpoena, court order or similar legal procedure, when it is necessary to do so to comply with law, or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the Terms of Services, or as otherwise required by law.
Third-party Services providers who assist us in providing the Services to you or who provide fraud detection or similar Services on our or any vendor’s behalf.
Other third parties with your consent or at your direction to do so, including if you authorize an account connection with a third-party account or platform:
For the purposes of this Policy, an "account connection" with such a third party is a connection you authorize or enable between your account and a payment instrument, or platform that you lawfully control or own. When you authorize such a connection, we may exchange your personal information and other information directly with such third-party. Examples of account connections include, without limitation: linking your account to a social media account or social messaging Services; connecting your account to a third-party data aggregation or financial Services company, if you provide such company with your account log-in credentials; or using your account to make payments to a merchant or allowing a merchant to charge your account.
If you connect your account to other financial accounts, directly or through a third-party Services provider, we may have access to your account balance and account and transactional information, such as purchases and funds transfers. If you choose to create an account connection, we may receive information from the third party about you and your use of the third-party’s Services. For example, if you connect your account to a social media account, we will receive personal information from the social media provider via the account connection. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this Policy.
Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third party that will gain access to your personal information as part of the account connection.

We will not disclose your credit card number or bank account number to anyone except with your express, written permission or if we are required to do so to comply with a subpoena or other legal process. We do not send your personal information to third-party social networks unless you have specifically requested or authorized us to do so. When you broadcast information to such third-party social networks, such information is no longer under our control and is subject to the terms of use and privacy policies maintained by such third parties.

9. External Connections

Our Services may feature links to—or permit integration with—independent third-party platforms, applications, or websites. We maintain no oversight over the data collection practices of these external entities. We advise our users to remain vigilant when departing our platform and to examine the privacy disclosures of any third-party service that gathers personal data. Information shared with third parties falls outside the scope of this Policy, and we cannot verify the security or confidentiality of such exchanges.

Furthermore, third parties might employ Cookies, web beacons, or alternative tracking tools to monitor your activity while you use our Services. This data may be linked to your identity or used to profile your online behavior across various sites over time. These entities typically utilize such insights to deliver interest-based marketing or tailored content. We do not govern these tracking technologies or their application. For inquiries regarding specific advertisements or content, please contact the relevant provider. You are responsible for directly managing your communication preferences with these third parties if you wish to opt out of their correspondence.

10. Analytical Services and Retargeting

We may engage third-party analytics providers (such as Google Analytics) to assess your interaction with the Services, generate activity reports, gather demographic insights, and evaluate performance metrics. These providers utilize cookies and pixel tags to facilitate data analysis. For example, web beacons may be used to track site navigation and email engagement, helping us measure the impact of our marketing efforts and compile statistical usage data.

By utilizing our Services, you grant consent, as permitted by law, for these analytical entities to process your data according to the objectives stipulated in this Privacy Policy.

To learn more about these providers or to explore available opt-out mechanisms, please visit the links provided below. Note that opting out of certain analytical services may impact the functional depth of our platform.

• For Google Analytics, visit: [https://www.google.com/analytics](https://www.google.com/analytics). This service monitors and reports on website traffic, sharing insights with other Google services to personalize advertisements within its network. Review Google’s privacy standards here: [https://policies.google.com/privacy?hl=en](https://policies.google.com/privacy?hl=en), and their data protection guidelines here: [https://support.google.com/analytics/answer/6004245](https://support.google.com/analytics/answer/6004245)

We also utilize retargeting services to display ads on third-party sites to previous visitors of our platform. These providers use tracking technologies to serve advertisements based on your past interactions with us. Any data gathered through these methods is governed by this Policy. By using our Services, you consent to this data processing by remarketing providers. For opt-out information, please consult the respective provider links:

11. Managing Personal Communications

Registered users can review, modify, or delete their personal details via the Site's settings or by emailing legal@arbspark.com with the subject “Privacy Policy.” We may require identity verification before executing requests to access or alter your data records.

You may also opt out of marketing materials by clicking the “Unsubscribe” link in any promotional email or by contacting us at legal@arbspark.com with the subject “Unsubscribe from Marketing.” Please note that transactional or administrative messages essential to account management cannot be disabled. While we make every effort to update our databases promptly in accordance with law, complete removal of all historical data remnants may not always be feasible.

12. International Data Transfers

Your information may be moved to—and stored on—servers located outside your home jurisdiction, where privacy laws may be less stringent. By engaging with our Services, you acknowledge that your data may be transferred globally. In such cases, local authorities or law enforcement in those jurisdictions may be granted access to your information under their respective legal frameworks.

We are committed to taking reasonable measures to ensure your data is handled securely and in alignment with this Policy. Transfers will only occur to organizations or countries that demonstrate adequate safeguards regarding the protection of personal information.

13. Your Privacy Rights

Depending on your place of residence, you may hold specific rights over your personal data. If certain rights listed below are not mandated by law in your jurisdiction, we reserve the right to grant them at our sole discretion.

These rights are not absolute and may be limited if (a) the law requires us to do so; (b) it would infringe upon the privacy of others; (c) it is necessary to protect our legal interests; or (d) the request is deemed unreasonable. We will verify your identity before fulfilling any requests.

Right of Access. You may request a copy of the information we hold about you by contacting legal@arbspark.com.
Right to Rectification. If your data is inaccurate or incomplete, you can request an update by emailing legal@arbspark.com with the subject line “Correction or Rectification.”
Right to Object. You may object to the processing of your data by contacting us. If we cannot accommodate the objection, we will explain why, allowing you to decide whether to withdraw consent or pursue other options. Use the subject line “Object to Processing.”
Right to Restriction. You can request that we limit how we process your information. Please specify your requirements in an email with the subject “Restrict Processing.”
Right to Portability. You have the right to receive your data in a structured, machine-readable format. Submit your request via legal@arbspark.com with the subject “Portability / Personal Information.”
Right to Withdraw Consent. Where processing is based on consent, you may revoke it at any time by emailing “WITHDRAW CONSENT” to our legal team. We will stop processing your data upon confirmation.
Right to Erasure. To have your data permanently removed from our systems, email legal@arbspark.com with the subject “Erasure / Personal Data Deletion.” We will notify you once the deletion is complete.

Residents of the UK, EEA, Switzerland, or Brazil also maintain the right to file a complaint with their local data protection authority regarding our processing practices.

14. Data Restitution and Removal

Upon receiving your formal request, we will make every effort to: (i) provide you with all personal data processed during your use of the Services in a structured, standard, and machine-readable format, followed by the removal of all current records and backups; or, (ii) permanently destroy and erase all personal information processed in relation to the Services, including any physical media, digital materials, copies, and archived backups.

18. Amendments to this Policy

We reserve the right to modify this Policy at our discretion. When updates occur, the revision date at the beginning of this document will be updated. We advise users to visit this page regularly to stay informed of our data handling practices. You acknowledge and concur that it is your obligation to review this Privacy Policy frequently to remain aware of any changes. Your continued interaction with the Site after amendments are published constitutes your legal acceptance of the revised terms. If you find any part of this Policy unacceptable, you must discontinue your use of the Site.

19. Governing Law

The Services and the Site are operated by us from Panama. These offerings are not intended to subject the Company to the legal requirements or judicial authority of any country, state, or territory outside of Panama.

Contact Us

For inquiries, feedback, or concerns regarding the details of this Policy, please reach out to our legal department via email at legal@arbspark.com.