Robonet Privacy Policy

Last Updated: March 30, 2026

This Privacy Policy (the "Policy") explains how Robonet Services, Ltd., a BVI business company ("Robonet", "we", "us" or "our") collects, uses, and shares data in connection with the website, any other website or service that we own or control and that links to this Privacy Policy, our AI-powered strategy generation tools and autonomous on-chain trading agents (the "Services"). Your use of the Services is subject to this Policy as well as our Terms of Service.

Additionally, for individuals located in the European Economic Area, the United Kingdom and Switzerland (collectively, "Europe" or "European"), please see the "Notice to European Users" at the end of this Privacy Policy.

For the purposes of the British Virgin Islands Data Protection Act (as revised) (the “DPA”), Robonet acts as a “data user” in respect of the personal data it processes. We process personal data in accordance with the requirements of the DPA and other applicable data protection laws.

You should not submit sensitive personal data, regulated financial information, or any information subject to heightened legal protections unless explicitly required and supported by the Services.

We may also process personal data where such processing is otherwise permitted or required under applicable law.

Where required under the DPA, we will obtain your consent to the processing of your personal data. In other cases, we rely on lawful bases for processing as permitted under applicable law, including where processing is necessary for the performance of a contract, compliance with legal obligations, or other permitted purposes.

The Services are not available to citizens or residents of the United States, persons physically located in the United States, persons accessing or using the Services from the United States, or U.S. Persons (as defined in our Terms of Service). If you are located in the United States or are a U.S. Person, you are not permitted to access or use the Services. Robonet does not knowingly collect or process personal information of individuals who are not permitted to access or use the Services. If we become aware that such data has been collected, we will take reasonable steps to delete it.

The Services may evolve over time, and the nature of the personal information we collect and process may change accordingly, subject to this Privacy Policy and applicable law.

Personal Information We Collect

Information you provide to us:

● Contact details and registration information, such as your first name, last name, email address, username, and blockchain wallet address. ● User profile information, such as your display name, image, and tagline. ● User content, such as your prompts and instructions you provide to describe your trading strategies when you use our natural language strategy generation and autonomous trading features. This includes information about your strategy configurations, trading preferences, Strategy Code, and Deployment configurations. You acknowledge that Robonet processes Strategy inputs, prompts, and related configurations solely as a technical service provider and does not determine the underlying purpose or intent of such data. You are solely responsible for the content, legality, and use of any such data. ● Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise. ● Marketing data, such as your preferences for receiving our marketing communications, and details about your engagement with them. ● Social content, such as comments, "likes," and other content you choose to post on the Services. Such content may be viewable publicly, by other users of the Services. ● Payment data and transaction information. Please note that for conducting cryptocurrency transactions, we work with third-party electronic wallet extensions such as Privy, MetaMask, and WalletConnect. We also may use a prepaid, credits-based billing system. Your interactions with third-party electronic wallet extensions and payment providers are governed by those businesses' own privacy policies. ● Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

We take reasonable steps to limit the personal information we collect to what is necessary for the purposes described in this Privacy Policy; however, due to the nature of the Services, certain data collection may be inherent to system functionality.

Third party sources

We may combine personal information we receive from you with personal information we obtain from other sources, such as:

● Social media. We may maintain pages on social media platforms, such as Discord, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider's privacy policy will apply to your interactions and their collection, use, and processing of your personal information. You or the platforms may provide us with personal information about you through the platform, and we will treat such information in accordance with this Privacy Policy. ● Third-party login information. When you link, connect, or log in to our Services with a third-party service, you may direct the service to send us information controlled by that service or as authorized by you via your privacy settings on that service. ● Other sources. We may obtain personal information from other third parties, such as marketing partners, publicly-available sources, and data providers.

Automatic data collection

We, our service providers, and our advertising partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Services (in your capacity as our customer's authorized user), our communications and other online services, such as:

● Device data, such as your computer's or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area. ● Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Services, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.

Cookies and similar technologies

Our Services may use the following technologies:

● Cookies, which are text files that websites store on a visitor's device to uniquely identify the visitor's browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising. ● Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications. ● Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

How We Use Personal Information

We use your personal information for the following purposes:

Service delivery, to:

● Establish and maintain your account and provide you with our Services; ● Conduct research and analysis relating to the Services and our business; ● Process payments and complete transactions with you; ● Communicate with you about the Services, including by sending surveys, offers, announcements, updates, security alerts, and support and administrative messages; and ● Provide support for the Services, and respond to your requests, questions and feedback. ● Facilitate your interactions with Vaults you create or in which you participate, including maintaining records of Vault configurations, deposits, withdrawals, and performance data as described in our Terms of Service.

Research and development

As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect ("Aggregated Data" or "Derived Data"). We may use this anonymous data and share it with third parties for our lawful business purposes. Where we use personal information to generate Aggregated Data or Derived Data for model training or improvement, such data will be de-identified and processed in a manner that is not reasonably capable of identifying any individual. We do not use 4

personal information to train models in a way that results in outputs that are specific to, or identifiable with, any individual user.

We implement reasonable safeguards designed to prevent personal information from being unintentionally reproduced, disclosed, or inferred through AI-generated outputs; however, we do not guarantee that such outcomes will never occur.

Marketing and advertising

We may collect and use your personal information for marketing and advertising purposes, including:

● Direct marketing. We may send you direct marketing communications as permitted by law, including, but not limited to, notifying you of special promotions, offers and events. You may opt out of our email marketing communications as described in the "Opt out of marketing communications" section below. ● Interest-based advertising. We and our partners, including third party advertising companies and social media companies may display ads across the web. These companies may use cookies and similar technologies to collect information about your interaction (including the data described in the "Automatic data collection" section above) over time across our Services, our communications and other online services, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the "Online tracking opt out" section below.

Compliance and protection

We may use your personal information to:

● Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities; ● Protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims); ● Audit our internal processes for compliance with legal and contractual requirements and internal policies; ● Enforce the terms and conditions that govern the Services; and
● Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

You acknowledge that any use of the Services, including any features involving data processing, analytics, or AI-generated outputs, is undertaken at your own risk, and that Robonet is not responsible for how you interpret, use, or rely on any such outputs.

Nothing in this Privacy Policy shall be construed as creating any fiduciary, advisory, or special confidentiality relationship between you and Robonet beyond those required by applicable law.

We do not guarantee the accuracy, completeness, or timeliness of any personal information processed through the Services.

How We Share Personal Information

We may share your personal information with:

Affiliates

Our corporate affiliates, for purposes consistent with this Privacy Policy.

Service providers

Companies and individuals that provide services on our behalf or help us operate our Services or our business (such as hosting, information technology, customer support, email delivery, and website analytics services). We also depend on and share your personal data with third-party artificial intelligence and machine learning service providers that help us provide AI-powered features of our Services, including natural language processing and strategy code generation capabilities. As described in our Terms of Service, the Platform uses machine learning, large language models, or similar automated services ("AI Services") to translate your strategy into executable Strategy Code. Certain AI Services may be provided by third-party providers that process data on infrastructure outside of Robonet’s control. Such providers may process personal data in accordance with their own terms and privacy practices, and may transfer data across jurisdictions.

Advertising partners

Third party advertising companies, including for the interest-based advertising purposes described above, that may collect information on our Services through cookies and other automated technologies.

Professional advisors

Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others

Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above. We reserve the right to cooperate with any law enforcement authority, regulator, court, arbitrator, governmental authority, or other third party in connection with any investigation, inquiry, request, subpoena, court order, legal process, or other lawful demand, and to preserve, review, and disclose information as permitted by our Terms of Service. Such disclosures may occur without prior notice to you where permitted or required by applicable law.

Business transferees

Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Robonet or our affiliates (including, in connection with a bankruptcy or similar proceedings).

How You Share Information on the Services

Third-party platforms

By enabling features or functionality that connect your account to a third-party platform (such as by logging in to the platform using your account with the third-party), you choose to disclose certain of your personal information to those platforms. We do not control those third parties' use of your personal information.

Blockchain

Robonet does not control, process, or determine the purposes or means of processing any personal data that is recorded on public blockchains. Such data is publicly available, immutable, and not subject to deletion or modification by Robonet.

Other Robonet users

When you use the Services, you may share certain information with the Robonet community. This information may include your profile information and other content you choose to submit on the Services. You may also interact with Vaults deployed by other users (as a "Participant") or deploy your own Vaults (as a "Creator"). Please note that some of your activities are visible on-chain and associated transaction data is publicly accessible on the applicable blockchain. Due to the immutable nature of blockchain technology, on-chain transaction data cannot be modified or deleted once recorded.

Your Choices

Access to information

To keep your information accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct information in our possession that you have previously submitted via the Services.

Opt out of marketing communications

You may opt out of marketing-related email communications by following the opt out or unsubscribe instructions contained in the marketing communications we send you.

Online tracking opt-out

There are a number of ways to limit online tracking on our Services, which we have summarized below:

● Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit All About Cookies. ● Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes. ● Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: Google Analytics Opt-out. ● Services opt outs. The following advertising partners offer opt out features that let you opt out of use of your information for interest-based advertising: ● Google: Ad Settings
● Advertising industry opt out tools. You can also use these opt out options to limit use of your information for interest-based advertising by participating companies: ● Digital Advertising Alliance for Websites: About Ads ● Digital Advertising Alliance for Mobile Apps: Your Ad Choices ● Network Advertising Initiative: Network Advertising

Note that because these opt out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track

Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals because there is no commonly accepted standard for how online services should respond to such signals. If a standard is established in the future, we may revise our practices accordingly. To find out more about "Do Not Track," please visit All About DNT.

Other Sites and Services

Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information. To the fullest extent

permitted by law, Robonet disclaims any liability for unauthorized access to or loss of personal information except to the extent required by applicable law.

Children

The Services are not intended for use by anyone under the age of capacity in their jurisdiction (e.g., 18 years old). If we learn that we have collected personal information through our Services from a person under the age of capacity in their jurisdiction without the consent of that person's parent or guardian as required by law, we will delete it.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by email or updating the date of this Privacy Policy and posting it on the Services.

Governing Law

This Privacy Policy and any dispute arising out of or relating to this Privacy Policy shall be governed by and construed in accordance with the laws of the British Virgin Islands, without regard to its conflict of law principles. Any legal action or proceeding arising under this Privacy Policy shall be brought exclusively in the courts of the British Virgin Islands, and you hereby consent to the personal jurisdiction and venue therein.

How to Contact Us

You can reach us by email at support@robonet.finance or via Robonet's Discord server (link to the server can be found at the bottom of robonet.finance website)

Notice to European Users

The information provided in this "Notice to European Users" section applies only to individuals in Europe.

Personal information

References to "personal information" in this Privacy Policy are equivalent to "personal data" governed by European data protection legislation.

Controller

Robonet Services, Ltd. is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation.

Legal basis for processing

We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described in the table below.

Processing purpose Legal basis

Contract Performance

Where you have entered into an agreement with us, processing is necessary to fulfil our contract with you, including to provide you with access to the Services, process your transactions, and fulfil our contractual obligations. This also includes processing necessary to take steps at your request prior to entering into a contract, such as during account registration.

Legitimate Interests

We process personal information for certain business purposes based on our legitimate interests, provided those interests are not overridden by your rights and freedoms. These purposes include: (a) research and development to improve our Services; (b) marketing and advertising, including direct marketing and interest-based advertising; (c) compliance, fraud prevention, and safety measures; and (d) sharing personal information with third parties as described in this Privacy Policy. We conduct balancing tests to ensure our legitimate interests do not unfairly impact your rights. You have the right to object to processing based on legitimate interests at any time by contacting us.

Compliance with Legal Obligations

Processing is necessary to comply with legal obligations to which we are subject, including responding to lawful requests from law enforcement or regulatory authorities, fulfilling tax and accounting requirements, and meeting our obligations under applicable data protection laws.

Robonet has no obligation to monitor, verify, or validate the accuracy, legality, or appropriateness of any personal information submitted to or processed through the Services.

Consent

Where required by law, we process your personal information based on your freely given, specific, informed, and unambiguous consent. This includes processing for purposes such as receiving marketing communications or enabling certain optional features. You have the right to withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. To withdraw consent, use the method indicated at the time consent was given, adjust your settings within the Services, or contact us directly. We will action your withdrawal request promptly.

Use for new purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Retention

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require your personal information for the purposes described in this Privacy Policy, we will securely delete or anonymize it. In general, we retain personal information for the duration of your account relationship with us plus an additional period of up to seven years thereafter to comply with legal, accounting, and reporting obligations, or as otherwise required by law.

In certain cases, personal data may be retained in backup systems or archives for a limited period and will be securely isolated from further processing until deletion is practicable.

You acknowledge that certain data, including blockchain data and system logs, may not be capable of complete deletion due to technical or legal constraints.

Where personal information has been shared with or processed by third parties in accordance with this Privacy Policy, Robonet is not responsible for the deletion or removal of such information from those third parties’ systems.

**Cross-border Data Transfer **

If we transfer your personal information from Europe to another country such that we are required to apply appropriate safeguards to your personal information under European data protection laws, we will do so. Please contact us for further information about any such transfers or the specific safeguards applied.

Where we rely on Standard Contractual Clauses (SCCs) approved by the European Commission or the UK Information Commissioner's Office, or other lawful transfer mechanisms, we will implement the required supplementary measures to ensure an adequate level of protection for your personal information.

If personal information is transferred to the British Virgin Islands (where Robonet Services, Ltd. is incorporated), we will ensure appropriate safeguards are in place in accordance with applicable data protection laws.

You acknowledge that personal data transferred to jurisdictions outside your place of residence may be subject to different data protection standards and may be accessible to governmental authorities under applicable laws in those jurisdictions.

**Data Breach Notification **

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority without undue delay and, where feasible, within 72 hours of becoming aware of the breach. Where the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly, unless there is an exception under applicable law.

Your rights

European data protection laws may give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

● Access. Provide you with information about our processing of your personal information and give you access to your personal information. ● Correct. Update or correct inaccuracies in your personal information. ● Delete. Delete your personal information. ● Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice. ● Restrict. Restrict the processing of your personal information. ● Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

This Privacy Policy does not form part of any contract and does not create legal rights or obligations beyond those required by applicable law.

You may submit these requests by email to support@robonet.finance or via Robonet's Discord server (link to the server can be found at the bottom of robonet.finance website). We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.