Panther Privacy Policy

Last Updated: September 23, 2022

This Privacy Policy is designed to help you understand how the Panther Protocol Foundation
(“Panther,” “we,” “us,” or “our”) collects, uses, processes, and shares your personal
information, and to help you understand and exercise your privacy rights.


This Privacy Policy applies to personal information processed by us on our websites, and (each a “Site”, and
together the “Sites”).

An Important Note: This Privacy Policy does not apply to any of the personal information that
is processed on our other online or offline offerings, or the Panther Protocol.

Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole
discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the
updated Privacy Policy if you continue to useour Sites after the new Privacy Policy takes effect.


The categories of personal information we collect depend on how you interact with us, our Sites,
and the requirements of applicable law. We collect information that you provide to us,
information we obtain automatically when you use our Sites, and information from other sources
such as third-party services and organizations, as described below.

A. Personal Information You Provide to Us Directly
We may collect personal information that you provide to us.

● Your Communications with Us. We may collect personal information, such as your
email address, when you request information about our Sites or our products or
services, register for our newsletter, request customer or technical support, or otherwise
communicate with us.

● Surveys. We may contact you to participate in surveys. If you decide to participate, we
may collect personal information from you in connection with the survey.

● Interactive Features. We and others who use our Sites may collect personal
information that you submit or make available through our interactive features (e.g.,
forums, messaging and chat features, commenting functionalities, blogs, and social
media pages). Any information you provide using the public sharing features of a Site
will be considered “public,” unless otherwise required by applicable law, and is not
subject to the privacy protections referenced herein.

● Conferences, Trade Shows, and Other Events. We may collect personal information
from individuals when we attend or host conferences, trade shows, and other events.

● Business Development and Strategic Partnerships. We may collect personal
information from individuals and third parties to assess and pursue potential business

● Job Applications. We may post job openings and opportunities on our Sites. If you
respond to one of these postings, we may collect your personal information, such as
your application, CV, cover letter, and/or any other information you provide to us.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use our Sites.

● Automatic Collection of Personal Information. We may collect certain information
automatically when you useour Sites, such as your Internet protocol (IP) address, user
settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other
unique identifiers, browser or device information, location information (including
approximate location derived from IP address), and Internet service provider. We may

also automatically collect information regarding your use ofour Sites, such as pages that
you visit before, during and after usingour Sites, information about the links you click, the
types of content you interact with, the frequency and duration of your activities, and other
information about how you useour Sites.

● Cookie Policy (and Other Technologies). We, as well as third parties that provide
content, advertising, or other functionality onour Sites, may use cookies, pixel tags, and
other technologies (“Technologies”) to automatically collect information through your
use ofour Sites.

o Cookies. Cookies are small text files placed in device browsers that store
preferences and facilitate and enhance your experience.

o Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece
of code embedded inour Sites that collects information about engagement onour
Sites. The use of a pixel tag allows us to record, for example, that a user has
visited a particular web page or clicked on a particular advertisement. We may
also include web beacons in e-mails to understand whether messages have
been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories:

Operationally Necessary. This includes Technologies that allow you access toour
Sites, applications, and tools that are required to identify irregular website behavior,
prevent fraudulent activity, improve security, or allow you to make use of our

Performance-Related. We may use Technologies to assess the performance ofour
Sites, including as part of our analytic practices to help us understand how individuals
useour Sites (see Analytics below);

Functionality-Related. We may use Technologies that allow us to offer you enhanced
functionality when accessing or usingour Sites. This may include identifying you when
you sign intoour Sites or keeping track of your specified preferences, interests, or past
items viewed;

Advertising- or Targeting-Related. We may use first party or third-party Technologies
to deliver content, including ads relevant to your interests, onour Sites or on third-party
digital properties.

See “Your Privacy Choices and Rights” below to understand your choices regarding
these Technologies.

Analytics. We may use Technologies and other third-party tools to process analytics
information onour Sites. These Technologies allow us to better understand how our
digital Site are used and to continually improve and personalizeour Sites. Some of our
analytics partners include:

o Google Analytics. For more information about how Google uses your personal
information (including for its own purposes, e.g., for profiling or linking it to other
data), please visit Google Analytics’ Privacy Policy. To learn more about how to
opt-out of Google Analytics’ use of your information, please click here.

Social Media Platforms.our Sites may contain social media buttons, such as Twitter,
Discord, Medium, and Telegram, which might include widgets such as the “share this”
button or other interactive mini programs). These features may collect personal
information such as your IP address and which page you are visiting onour Sites, and
may set a cookie to enable the feature to function properly. Your interactions with these
platforms are governed by the privacy policy of the company providing it.

C. Personal Information Collected from Other Sources
Third-Party Services and Sources. We may obtain personal information about you from other
sources, including through third-party services and organizations. For example, if you
accessour Sites through a third-party application, such as an app store, a third-party login
service, or a social networking site, we may collect personal information about you from that
third-party application that you have made available via your privacy settings.


We use your personal information for a variety of business purposes, including to provideour
Sites, for administrative purposes, and to market our products and Site, as described below.

A. Provideour Sites

We use your information to fulfil our contract with you and provide you withour Sites, such as:
● Managing your information and accounts;
● Providing access to certain areas, functionalities, and features ofour Sites;
● Answering requests for customer or technical support;
● Communicating with you about activities onour Sites, and policy changes;
● Processing applications if you apply for a job we post onour Sites; and
● Allowing you to register for events.

B. Administrative Purposes

We use your information for various administrative purposes, such as:

● Pursuing our legitimate interests such as direct marketing, research and development
(including marketing research), network and information security, and fraud prevention;
● Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal
activity, and prosecuting those responsible for that activity;
● Measuring interest and engagement inour Sites;
● Short-term, transient use, such as contextual customization of ads;
● Improving, upgrading, or enhancingour Sites;
● Developing new products and services;
● Ensuring internal quality control and safety;
● Authenticating and verifying individual identities, including requests to exercise your
rights under this Privacy Policy;
● Debugging to identify and repair errors withour Sites;
● Auditing relating to interactions, transactions, and other compliance activities;
● Sharing personal information with third parties as needed to provide a Site;
● Enforcing our agreements and policies; and
● Carrying out activities that are required to comply with our legal obligations.

C. Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content and advertisements. We
may provide you with these materials as permitted by applicable law.
Some of the ways we market to you include email campaigns, custom audiences advertising,
and “interest-based” or “personalized advertising,” including through cross-device tracking.
If you have any questions about our marketing practices or if you would like to opt out of the use
of your personal information for marketing purposes, you may contact us at any time as set forth
in “Contact Us” below.

D. With Your Consent

We may use personal information for other purposes that are clearly disclosed to you at the time
you provide personal information or with your consent.

E. Other Purposes

We also use your personal information for other purposes as requested by you or as permitted
by applicable law.

● De-identified and Aggregated Information. We may use personal information to
create de-identified and/or aggregated information, such as demographic information,
information about the device from which you accessour Sites, or other analyses we


We disclose your personal information to third parties for a variety of business purposes,
including to provideour Sites, to protect us or others, or in the event of a major business
transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provideour Sites
The categories of third parties with whom we may share your personal information are
described below.

Service Providers. We may share your personal information with our third-party service
providers and vendors that assist us with the provision ofour Sites. This includes service
providers and vendors that provide us with IT support, hosting, payment processing,
customer service, and related services.

Business Partners. We may share your personal information with business partners to
provide you with a product or service you have requested. We may also share your personal
information with business partners with whom we jointly offer products or services.

Affiliates. We may share your personal information with our company affiliates for example:
for our administrative purposes, IT management, or for them to provide services to you or
support and supplement a Site we provide.

Other Users or Third Parties. You Share or Interact With. As described above in
“Personal Information We Collect,”our Sites may allow you to share personal information or
interact with other users and third parties (including individuals and third parties who do not
useour Sites and the general public).

Advertising Partners. We may share your personal information with third-party advertising
partners. These third-party advertising partners may set Technologies and other tracking
tools onour Sites to collect information regarding your activities and your device (e.g., your
IP address, cookie identifiers, page(s) visited, location, time of day). These advertising
partners may use this information (and similar information collected from other services) for
purposes of delivering personalized advertisements to you when you visit digital properties
within their networks. This practice is commonly referred to as “interest-based advertising” or
“personalized advertising.”

B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to
external parties if we, in good faith, believe doing so is required or appropriate to: comply with
law enforcement or national security requests and legal process, such as a court order or
subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or
contracts; collect amounts owed to us; or assist with an investigation or prosecution of
suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy,
receivership, purchase or sale of assets, or transition of service to another provider, your
information may be sold or transferred as part of such a transaction, as permitted by law and/or

Your Privacy Choices. The privacy choices you may have about your personal information are
determined by applicable law and are described below.

Email Communications. If you receive an unwanted email from us, you can use the
unsubscribe link found at the bottom of the email to opt out of receiving future emails.
Note that you will continue to receive transaction-related emails regarding products or
services you have requested. We may also send you certain non-promotional
communications regarding us andour Sites, and you will not be able to opt out of those
communications (e.g., communications regardingour Sites or updates to our Terms or
this Privacy Policy.

● “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in
certain web browsers. Please note that we do not respond to or honor DNT signals or
similar mechanisms transmitted by web browsers.

Cookies and Personalized Advertising. You may stop or restrict the placement of
Technologies on your device or remove them by adjusting your preferences as your
browser or device permits. However, if you adjust your preferences,our Sites may not
work properly. Please note that cookie-based opt-outs are not effective on mobile
applications. However, you may opt-out of personalized advertisements on some mobile
applications by following the instructions for Android, iOS, and others.

The online advertising industry also provides websites from which you may opt out of
receiving targeted ads from data partners and other advertising partners that participate
in self-regulatory programs. You can access these and learn more about targeted
advertising and consumer choice and privacy by visiting the Network Advertising
, the Digital Advertising Alliance, the European Digital Advertising Alliance, and
the Digital Advertising Alliance of Canada.

Please note you must separately opt out in each browser and on each device.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

Access to and Portability of Your Personal Information, including: (i) confirming
whether we are processing your personal information; (ii) obtaining access to or a copy
of your personal information; and (iii) receiving an electronic copy of personal
information that you have provided to us, or asking us to send that information to another
company in a structured, commonly used, and machine readable format (also known as
the “right of data portability”);

Request Correction of your personal information where it is inaccurate or incomplete.
In some cases, we may provide self-service tools that enable you to update your
personal information;

● Request Deletion of your personal information;
● Request Restriction of or Object to our processing of your personal information where
the processing of your personal information is based on our legitimate interest or for
direct marketing purposes; and

Withdraw your Consent to our processing of your personal information. Please note
that your withdrawal will only take effect for future processing, and will not affect the
lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us”
below. We will process such requests in accordance with applicable laws.


We take steps to ensure that your information is treated securely and in accordance with this
Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the
security of any information you provide to us. To the fullest extent permitted by applicable law,
we do not accept liability for unauthorized access, use, disclosure, or loss of personal

By usingour Sites or providing personal information to us, you agree that we may communicate
with you electronically regarding security, privacy, and administrative issues relating to your use
ofour Sites. If we learn of a security system’s breach, we may attempt to notify you electronically
by posting a notice onour Sites, by mail, or by sending an email to you.

All information processed by us may be transferred, processed, and stored anywhere in the
world, including, but not limited to, the United States or other countries, which may have data
protection laws that are different from the laws where you live. We endeavor to safeguard your
information consistent with the requirements of applicable laws.

If we transfer personal information which originates in the European Economic Area,
Switzerland, and/or the United Kingdom to a country that has not been found to provide an
adequate level of protection under applicable data protection laws, one of the safeguards we
may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal
information, please contact us as set forth below.


We store the personal information we collect as described in this Privacy Policy for as long as
you useour Sites, or as necessary to fulfill the purpose(s) for which it was collected, provideour
Sites, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business
purposes, enforce our agreements, and comply with applicable laws.


This Supplemental Notice for California Residents only applies to our processing of personal
information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA
provides California residents with the right to know what categories of personal information
Panther has collected about them, and whether Panther disclosed that personal information for
a business purpose (e.g., to a service provider) in the preceding twelve months. California
residents can find this information below:

Category of Personal Information Collected by Panther Category of Third Parties
Personal Information is Disclosed to for a Business Purpose


● Service Providers
● Business Partners
● Affiliates
● Other Users or Third Parties You Share or Interact With

Personal information categories listed in the California
Customer Records statute (Cal. Civ. Code § 1798.80(e))

● Service Providers
● Business Partners
● Affiliates
● Other Users or Third Parties You Share or Interact With

Commercial information

● Service Providers
● Business Partners
● Affiliates
● Other Users or Third Parties You Share or Interact With

**Internet or other electronic network activity **

● Service Providers
● Business Partners
● Affiliates
● Other Users or Third Parties You Share or Interact With

Professional or employment-related information

● Service Providers
● Affiliates

The categories of sources from which we collect personal information and our business and
commercial purposes for using personal information are set forth in “Personal Information We
Collect” and “How We Use Your Personal Information” above, respectively.

“Sales” of Personal Information under the CCPA

For purposes of the CCPA, Panther does not “sell” personal information, nor do we have actual
knowledge of any “sale” of personal information of minors under 16 years of age.

Additional Privacy Rights for California Residents

Non-Discrimination. California residents have the right not to receive discriminatory treatment
by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a
verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To authorize an agent, provide written
authorization signed by you and your designated agent and contact us as set forth in “Contact
Us” below for additional instructions.

Verification. To protect your privacy, we will take steps to reasonably verify your identity before
fulfilling your request. These steps may involve asking you to provide sufficient information that
allows us to reasonably verify you are the person about whom we collected personal information
or an authorized representative, or to answer questions regarding your account and use ofour

If you are a California resident and would like to exercise any of your rights under the CCPA,
please contact us as set forth in “Contact Us” below. We will process such requests in
accordance with applicable laws.

De-Identified Information. If we create or receive de-identified information, we will not attempt
to reidentify such information, except to comply with applicable law.


If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal
information to third parties who intend to license or sell that personal information. You can
exercise this right by contacting us at with the subject line “Nevada Do
Not Sell Request” and providing us with your name and the email address associated with your
account. Please note that we do not currently sell your personal information as sales are
defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact
us as set forth in Contact Us below.


The Sites are not directed to children under 16 (or other age as required by local law), and we
do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to our
Sites without your consent, you may contact us as described in “Contact Us” below. If we
become aware that a child has provided us with personal information in violation of applicable
law, we will promptly take steps to delete such information.


Third-Party Websites/Applications. The Sites may contain links to other websites/applications
and other websites/applications may reference or link to our Sites. These third-party services
are not controlled by us. We encourage our users to read the privacy policies of each website
and application with which they interact. We do not endorse, screen, or approve, and are not
responsible for, the privacy practices or content of such other websites or applications.
Providing personal information to third-party websites or applications is at your own risk.

Supervisory Authority. If your personal information is subject to the applicable data protection
laws of the European Economic Area, Switzerland, or the United Kingdom, you have the right to

lodge a complaint with the competent supervisory authority or attorney general if you believe our
processing of your personal information violates applicable law.
EEA Data Protection Authorities (DPAs)
Swiss Federal Data Protection and Information Commissioner (FDPIC)
UK Information Commissioner’s Office (ICO)


Panther is the controller of the personal information we process under this Privacy Policy.
If you have any questions about our privacy practices or this Privacy Policy, or to exercise your
rights as detailed in this Privacy Policy, please contact us at:

Panther Protocol Foundation
Madison Building, Midtown, Queensway, Gibraltar, GX11 1AA