We take your privacy seriously. This Privacy Policy describes how we collect, use and share your personally identifiable information (“Personal Information”) that we receive from you when you visit our website or which we otherwise receive or collect from you in the course of, or in connection with, your use of our site located at https://pragma.build and all associated sites (the “Website”), the pursuit of our mission to (our “Services”) and our operations. Please read the following to learn more about our Privacy Policy. This Privacy Policy covers our treatment of Personal Information that we gather when you are accessing or using our Website and Services, but does not apply to the practices of companies we don't own or control, or people that we don't manage. When we mention the “Foundation,” “we,” “us” or “our” in this Privacy Policy, we are referring to ZkPad SA and its subsidiaries and affiliates. By using or accessing the Website and the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways. We're constantly trying to improve our Website and Services, so we may need to change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our Website or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you. Remember that your use of our Website and Services is at all times subject to the Terms of Service, which incorporates this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms of Service.

WHAT DOES THIS PRIVACY POLICY COVER?

We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with the Website and our Services, including to provide, and improve our services, to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Website and the Services. In certain cases, we may also share some Personal Information with third parties, but only as described below. By using the Website and our Services, you consent to the collection of this information and the uses and disclosures described in this policy and the Terms. We do not knowingly collect or solicit Personal Information from anyone under the age of 13. If you are under 13, please do not attempt to send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us with Personal Information, please contact us at legal@pragma.build

WHAT PERSONAL INFORMATION DOES THE FOUNDATION COLLECT?

Information you provide to us: We receive and store any information you knowingly provide to us. For example, you share information directly with us when you fill out a form, submit or post content through our Services, make a purchase, communicate with us via third-party platforms, participate in a contest or promotion, request customer support, or otherwise communicate with us. The types of personal information we may collect include your name, email address, postal address, phone number, social media handle, and payment information, and any other information you choose to provide. We may communicate with you if you've provided us the means to do so. For example, if you've given us your email address, we may email you about your use of the Services. Also, we may receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our Services. If you do not want to receive communications from us, please indicate your preference by unsubscribing.

Information collected automatically: Whenever you interact with our Website, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, “cookie” information, the type of browser and/or device you're using to access the Website, and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device's acceptance of cookies, but this may prevent you from taking advantage of some of our features. For more information about cookies and how to disable them, see the Your Choices section below. We may use this data to improve the Services – for example, this data can tell us how often users use a particular feature of the Services or Website, and we can use that knowledge to make the Services interesting to as many users as possible.

Information collected from other websites and do not track policy: Through the cookies we place on your browser or device, we may collect information about your online activity after you leave the Website. Just like any other usage information we collect, this information allows us to improve the Website and the Services, and is otherwise used as described in this Privacy Policy. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Our Website does not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Website or the Services and after you leave.

HOW DOES THE FOUNDATION USE MY INFORMATION?

We use the Personal Information we collect to maintain, and improve our Services and Website. We also use the Personal Information we collect to:

WILL THE FOUNDATION SHARE ANY OF THE PERSONAL INFORMATION IT RECEIVES?

We may share your Personal Information with third parties as described in this section. By using the Website and the Services, or engaging in any transaction or service described below, you consent to our disclosure of your Personal Information to such third parties.

Information that's been de-identified: We may de-identify your Personal Information so that you are not identified or identifiable as an individual, and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual person.

Affiliated businesses: In certain situations, businesses or third party websites we're affiliated with may sell or provide products or services to you through the Website or in connection with the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business' or websites' policies.

Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we may use a payment processing company to receive and process your transactions for us. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.

Community groups: If you are a member of a Pragma Network community group, members known as Community Advocates may have access to the content within their groups. Network administrators find it helpful to have access to the email addresses of organizers and other members of groups within their networks, to easily communicate with and administer the groups. Therefore, we may ask if you want to share your email address with your group's Community Advocate.

Business transfers: We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party. Protection of the

Foundation and others: We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law, regulation or court order; enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of the Foundation, our users, or other persons.

TRANSFERS OF INFORMATION TO OTHER COUNTRIES

We have operations and service providers in other countries, including countries outside of the European Economic Area (EEA). Therefore, we and our service providers may transfer your Personal Information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it.

YOUR CHOICES

Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.

Communication Preferences. You may opt out of receiving promotional emails from the Foundation by following the instructions in those communications or by emailing us at legal@pragma.build . If you opt out, we may still send you non-promotional emails, such as those about our ongoing business relations.

Advertising and Analytics: We allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Website and Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages, links clicked, and conversion information. This information may be used by the Foundation and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android) that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes.

We also work with third parties to serve ads to you as part of customized campaigns on third-party platforms (such as Reddit). As part of these ad campaigns, we or the third-party platforms may convert information about you, such as your activity information, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.

ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE

If you are located in the EEA, the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your Personal Information, and this section applies to you.

Legal Basis for Processing: When we process your Personal Information, we will do so in reliance on the following lawful bases:

Questions or Complaints: If you have a concern about our processing of Personal Information that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en

For individuals in the UK: https://ico.org.uk/global/contact-us/

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

CERTAIN INFORMATION FOR CALIFORNIA RESIDENTS

The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) affords consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.

California Consumer Privacy Act: In the preceding 12 months, we have collected the following categories of Personal Information: identifiers, commercial information, internet or electronic network activity information, professional or employment related information, education information, financial information, and information derived from other personal information about you. For details about the precise data points we collect and the categories of sources of such collection, please see the Collection of Information section above. We collect Personal Information for the business and commercial purposes described in the Use of Information section above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

Category of Personal Information

Categories of Recipients The Foundation does not sell your personal information. We do allow our advertising partners to collect certain electronic network activity via our Website and Services to show ads that are targeted to your interests. To opt out of having your Personal Information used for targeted advertising purposes, please see the Your Choices section above. Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose, (2) request deletion of your personal information, and (3) not be discriminated against for exercising these rights. You may make these requests by emailing legal@pragma.build . We will verify your request by asking you to provide information related to your recent interactions with us, such as information provided on a form you've filled out. We will not discriminate against you if you exercise your rights under the CCPA. If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us.

DATA SUBJECT REQUESTS AND DATA RETENTION

Subject to certain limitations, you have the right to request access to the Personal Information we hold about you and to receive your data in an accessible and portable format, the right to ask that your Personal Information be corrected or erased, and the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, please email us at legal@pragma.build . We store Personal Information for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

WHAT IF I HAVE QUESTIONS ABOUT THIS POLICY?

If you have any questions or concerns regarding this Privacy Policy, please send us a detailed message to legal@pragma.build , and we will try to resolve your concerns.