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Privacy Policy

Last updated: October 23, 2023

Purpose, Scope, and Users
In this Privacy Policy, we refer to MSCHF Product Studio, Inc. and its wholly owned subsidiaries
collectively as "MSCHF" or "we" or "us". We refer to those who visit our website and those who use our
web and mobile applications collectively as "users" or "clients". This Privacy Policy describes the specific
policies and procedures we use to collect, utilize — and disclose and share with others — user or client
information provided to us through (ii) the use of our web sites and applications and (ii) other
communications with MSCHF Product Studio, Inc. and our wholly-owned subsidiaries (collectively the
"Services"). Together with our Terms of Use, this Privacy & Security Statement governs your use of our

Services.

Using the Services

You can view the Services without providing any personal or individually identifiable information. You may
also be able to set the security settings on your browser to prevent certain tracking and logging features.
For example, your browser settings may allow you to automatically transmit a "Do Not Track" signal to
websites and online services you visit. If you do that, the Services may be less functional for you. Like
many websites and online services, the Services do not alter their practices when they receive a "Do Not
Track" from a visitor’s browser.

There are times when you may choose to give us personally identifiable information about yourself. For
example, you may wish to register, make purchases and view information, receive emails from us, receive
invitations to attend events, participate in discussions, preview new products and services, or participate
in special promotions. If you register to use the Services or if you conduct transactions through the
mschf.com website or any related mobile or website applications (including mschf.xyz, which redirects to
mschf.com), we will collect information about the transactions you engage in and your other activities. We
need certain information from you to register you, authenticate you, process your registration information
and payments, and send goods to you, as necessary.

Kinds of Information We Collect

We may collect information that you voluntarily give us, as well as location-based information and site
visitorship data as described below.

Personally Identifiable Information

In order to take advantage of certain features, you may be asked to provide personally identifiable
information about you that would enable someone to contact you directly. Personally identifiable
information includes your email address, name, postal/mailing address, telephone numbers, social
security number, shipping and billing addresses, or persistent identifier (such as a customer number held
in a cookie) which is associated with personally identifiable information, as well as other information that
you may provide voluntarily. We collect such personally identifiable information that you give us so that
we may view:

  • the date and time you access the Services;
  • your internet service provider, mobile carrier, or data services provider;
  • your Internet Protocol (IP) address;
  • the pages you visit;
  • the products you purchase and review;
  • the links you click;
  • the features used;
  • how and when you interact with the services;
  • the content, images and advertisements you select; and
  • how you arrived at the Services and where you go when you leave.

We will use the personally identifiable information we collect to provide you with specific information and
services that you request, and with additional information and services that may be of interest to you. By
providing your personally identifiable information, you fully understand and consent to the collection and
processing of such information in the United States of America and other countries. To protect your
privacy and security, we will also take reasonable steps to verify your identity, such as requiring a
password and user ID, before granting access to your data. While we strive to protect our user's personal
information and privacy, we cannot guarantee the security of any information you disclose online, and you
do so at your own risk.

We may also collect non-personal information such as your IP address and use 'cookies' on the website.
The information obtained from collecting IP addresses and using 'cookies' is not personal information
about you. For more information, please read the sections on IP addresses and cookies below. MSCHF uses
cookies to help keep track of items you put into your shopping cart including when you have abandoned your
cart and this information is used to determine when to send cart reminder messages via SMS.

Location-Based Information
We may collect information relating to your general location based on (1) information you manually
provide, (2) the IP address of your computer, (3) Global Positioning System (GPS) information sent to us
by your GPS-enabled device, and (4) the proximity of your laptop computer, mobile wireless device,
personal digital assistant, personal communication system, or other communications device (your
“Personal Communication Device”) to the nearest radio tower or cell site. We may also be able to detect
when your Personal Communication Device is activated as well as when and how you are using it.
MSCHF may collect data to verify the information you provide manually and to provide you with location-
based content. We may associate Personally Identifiable Information with location-based information
provided by you or your Personal Communication Device solely for our internal use and to improve your
experience with the Services.

Site Visitorship Data
Site visitorship data is information about the way a website is used that is not associated with an
individual’s identity. We use anonymous data regarding online behavior to better understand how people
use our Services. To that end, we may use aggregated, anonymous online traffic behavior along with
information from third parties to track usage trends and thereby improve the Services. We may also use
this aggregated, anonymous information to develop reports that we may share with third party marketing
partners and affiliates. The kind of information we may collect includes:

  • the date and time you access the Services;
  • your internet service provider, mobile carrier, or data services provider;
  • your Internet Protocol (IP) address;
  • the pages you visit;
  • the products you purchase and review;
  • the links you click;
  • the features used;
  • how and when you interact with the services;
  • the content, images and advertisements you select; and
  • how you arrived at the Services and where you go when you leave.

Most site visitorship data is collected using data collection tools such as web beacons, cookies,
embedded web links and other software (together, “Data Collection Tools”). Data Collection Tools are
typically small data files or software that are sent to your browser and stored on your computer or mobile
device hard drive. Most browsers and display software can be set to inform you when Data Collection
Tools are being used or other tracking software is being sent to your computer or Personal
Communication Device. They also provide you with the option of refusing such Data Collection Tools.
However, refusing to allow the use of Data Collection Tools may, in some cases, preclude you from using,
or negatively impact the display or function of, certain areas or features of the Services, including
preventing you from purchasing products.

Data Collection Tools may store the information in your shopping cart and allow us to relate your use of
the Services to other information about you, including your Personal Information. We may do this to
improve and personalize your experience with the Services and help resolve problems you experience
through your use of the Services.

Do Not Track
We do not adjust or alter our Site’s data collection and use practices when receiving Do Not Track
transmissions from your browser.

Disclosure of Information
MSCHF will not release any personally identifiable information to third parties without your consent except
as follows:

● By providing us your personally identifiable information grants MSCHF, the right to use such

information for the provision of Services to you and for the benefit of MSCHF without
restrictions for the purposes that include, without limitation, research, marketing, and content,
product and lead development.

● MSCHF may share information we collect with our business and third party marketing

partners. If we share your information, we will request that such third parties treat your
information in accordance with this Privacy Policy and refrain from disclosing or using your
personally identifiable information for purposes other than for the provision of Services to you
or for the benefit of MSCHF. MSCHF does not provide personally identifiable information to
unaffiliated third parties for use in marketing directly to you. To the extent required, you
hereby authorize this use of your personally identifiable information.

● We may disclose information we collect, including personally identifiable information, to third

parties as required or permitted by law. For example, we may disclose information:

○ to regulators;

○ to law enforcement authorities pursuant to an official request;

○ to vendors who provide us with services; and

○ to companies that may acquire part or all of MSCHF or an affiliated company.

MSCHF is not responsible for the protection of the information you provide to other websites. You should
be aware that when you voluntarily disclose personally identifiable information through other applications
and websites, such information can be collected and used by others and may result in unsolicited
communications.

Advertising
We may use third-party companies to serve ads and provide content through the Services. These
companies may use cookies and other Data Collection Tools that are not sent by us to learn about your
use of the Services and other websites and apps in order to present personalized advertisements and
other messages that may be of interest to you. MSCHF is not responsible for such cookies and tracking
software.

Corporate Transactions
Circumstances may arise where, whether for strategic or other reasons, we decide to sell, buy, merge or
otherwise reorganize our business. Such a transaction may involve the disclosure of personally
identifiable information to prospective or actual purchasers or joint venture partners, or the receipt of it
from sellers. It is our practice to seek appropriate protection for information in these types of transactions.

Information Security
Whenever you enter an area of the site that carries or requires you to enter sensitive information such as
your credit card details, a padlock icon will appear in the address bar of your browser, indicating that the
page is secure. MSCHF uses the Secure Sockets Layer (SSL) and Private Communications Technology
security standards that are supported by Microsoft Internet Explorer 4.0 or later and other popular
browsers. SSL encodes your personal information by encrypting credit card number, name, address,
phone number, identification number and your password so that they cannot be read by unauthorized
parties.

While we may provide encryption technologies and use other reasonable precautions to protect
confidential information and provide suitable security, we do not guarantee that information transmitted
through the Internet is secure, or that such transmissions will be free from delay, interruption, interception
or error.

MSCHF may implement certain physical, technological and managerial procedures to safeguard the
personally identifiable information we collect. However, these procedures do not guarantee that the
information will remain secure against theft or misuse.

Communications
From time to time, MSCHF and its affiliates may communicate with you regarding your transactions and
the administration of your account, current projects, special offers, invitations to events, offers for
services, new product previews and updates to the Services, press releases and announcements
concerning the services we provide, contests and sweepstakes, as well as important changes in our
Terms of Use and this Privacy Policy. By providing us with your e-mail address and/or your mobile phone
number, you consent to receiving such communications. If at any time you decide for any reason that you
no longer wish to receive such communications, you may “opt out” of receiving them by using one of the
following methods:

● Select the "opt out" or "unsubscribe" link, or follow the opt-out instructions that may be

included in such communication.

● Where applicable, return to the web page(s) or service where you originally registered your

preferences and follow the opt-out instructions.

● E-mail us at [email protected]. Be sure to provide your name, e-mail address and postal

address, and specific relevant information about the particular service you no longer wish to
receive.

Please be aware that when you opt out of receiving communications, it may affect the services you have
chosen to receive from us where accepting the communications is a condition of receiving such services.
By registering as a user or purchasing products, you consent to receiving administration and transaction
related communications.

Hyperlinks and Referrals
Other websites accessible through the Services (through hyperlinks, advertisements or otherwise) have
their own privacy policies and data collection, use and disclosure practices. Please consult their terms
and conditions and privacy policies prior to use.

We do not, even periodically, review the privacy policies or terms of use of third parties and we are not
responsible or liable for their privacy practices, availability or reliability of the services they may provide,
or the accuracy or completeness of their content.

Children’s Privacy
We do not knowingly collect or distribute personally identifiable information from children under the age of 13.
As one measure to ensure that we do not gather personally identifiable information from children
under 13, we require that all individuals provide a valid credit card number before completing a purchase
order. If you are the parent or guardian of a child under the age of 13 and believe that we have collected
personally identifiable information contrary to this policy or, in the United States, the Children’s Online
Privacy Protection Act (COPPA), please contact us by email so that we may delete such information. You
can learn more about COPPA at the United States Federal Trade Commission website:

http://www.ftc.gov/privacy/privacyinitiatives/childrens.html

Safe Harbor Data Privacy Notice
In the US, MSCHF adheres to the Safe Harbor Principles published by the U.S. Department of Commerce
(the "Safe Harbor Principles") with respect to personally identifiable information it receives from the
European Union. This notice outlines MSCHF’s general policy and practices in compliance with the Safe
Harbor Principles, including the type of information to which this notice applies, how we use information,
and your choices regarding our use of, and your ability to correct, your personally identifiable information.
For purposes of this notice, “personally identifiable information” includes information (a) transferred from
the European Union to the United States; (b) recorded in any form by us; and (c) pertaining to a specific
individual who is identified in, or is identifiable from, the data. This notice applies to all personally
identifiable information we handle, including on-line (except as noted below), off-line, and manually
processed data. If there is any conflict between this Privacy Policy and the Safe Harbor Principles, the
Safe Harbor Principles will apply.

Notice and Choice
We obtain personal information only as permitted by the Safe Harbor Principles or with the consent of the
individual affected. We may ask for your consent to collect, use, and/or disclose personal information in
certain ways, and you may be required to give your consent in order to use our services. To the extent
permitted under the Safe Harbor Principles, we reserve the right to process personal information in the
course of providing services through the Services without the knowledge of individuals involved.

Transfers
MSCHF will obtain assurances from its affiliates that they will safeguard personal information consistently
with this Privacy Policy. If we learn that an affiliate is using or disclosing personal information in a manner
contrary to this Privacy Policy, we will take steps to prevent or stop the use or disclosure.

Security & Enforcement
MSCHF will take reasonable precautions to protect personal information in its possession from loss,
misuse and unauthorized access, disclosure, alteration and destruction, and it will conduct compliance
audits of its relevant privacy practices to verify adherence to this Privacy Policy. We cannot guarantee, in
every circumstance, the security of the personal information you provide through the Services. All
incoming encrypted information is routed through our firewall, which serves as a gatekeeper for our
system. Only data containing the correct authorisation is permitted past the firewall. Attempts to pass the
firewall are constantly monitored for suspicious activity.

Your California and GDPR Privacy Rights

Note: MSCHF’s data uses and disclosures are covered under the Gramm Leach Bliley Act and are
therefore not subject to the California Consumer Privacy Act.

The California Shine the Light Law (California Civil Code Section 1798.83) permits residents of California
to request certain details about how their Personal Information has been shared during the prior calendar
year with third parties for those third parties’ own direct marketing purposes. This information includes the
categories of Personal Information and types of services provided to the individual, as well as a list
containing the names and addresses of all third parties to which the visitor information was disclosed.

The General Data Protection Regulation (“GDPR”) permits residents of the European Union to request
certain details about how their Personal Information has been shared during the prior calendar year with
third parties for those third parties’ own direct marketing purposes. This information includes the
categories of Personal Information and types of services provided to the individual, as well as a list
containing the names and addresses of all third parties to which the visitor information was disclosed. In
addition, GDPR provides residents of the European Union with a right to access, a right to delete, and a
right to port any data profile (i.e., data collected and usage of collected data) possessed by MSCHF.

If you are a California resident or a European Union resident and you would like to receive this
information, please contact us at [email protected]

You must put the statement “Your California Privacy Rights” or “Your GDPR Privacy Rights” in the subject
field of your email or in the address line of your envelope. You must include your name, street address,
city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do
not have complete information.

Consent to Transfer Information to the United States

MSCHF is based in the United States and the information we collect is governed by United States law. By
accessing or using the Services or providing us with any information, you consent to the transfer,
processing and storage of your information in and to the United States and other countries, jurisdictions in
which the privacy laws may not be as comprehensive as those in the country where you reside and/or are
a citizen.

Limits on Sharing Information

In the section below, we list the reasons companies, such as MSCHF, can share their users' Personal
Information, whether MSCHF chooses to share, and whether you can limit this sharing.

| Reasons we can share your Personal Information | Does MSCHF share your information? | Can you limit this sharing? |
| ---------------------------------------------- | ---------------------------------- | --------------------------- |
| For our everyday business purposes — such as   | Yes                                | No                          |
| to process your transactions, maintain your    |                                    |                             |
| account(s), respond to court orders and legal  |                                    |                             |
| investigations, or report to credit bureaus    |                                    |                             |
| ---------------------------------------------- | ---------------------------------- | --------------------------- |
| For our business operations and transactions — | Yes                                | No                          |
| such as corporate acquisitions, mergers,       |                                    |                             |
| consolidation, restructuring, bankruptcy, or   |                                    |                             |
| sale of certain assets                         |                                    |                             |
| ---------------------------------------------- | ---------------------------------- | --------------------------- |
| For third party services providers — to        | Yes                                | No                          |
| facilitate or support the Services             |                                    |                             |
| ---------------------------------------------- | ---------------------------------- | --------------------------- |
| For our marketing purposes — to offer our      | Yes                                | Yes                         |
| products and services to you                   |                                    |                             |
| ---------------------------------------------- | ---------------------------------- | --------------------------- |
| For our affiliates' everyday business purposes | Yes                                | No                          |
| — information about your transactions and      |                                    |                             |
| experiences                                    |                                    |                             |
| ---------------------------------------------- | ---------------------------------- | --------------------------- |
| For our affiliates' everyday business purposes | No                                 | We do NOT share             |
| — information about you creditworthiness       |                                    |                             |
| ---------------------------------------------- | ---------------------------------- | --------------------------- |
| For our affiliates to market to you            | Yes                                | No                          |
|                                                |                                    |                             |
| ---------------------------------------------- | ---------------------------------- | --------------------------- |
| For non-affiliates to market to you —          | Yes                                | Yes                         |
| California Residents, please see above for     |                                    |                             |
| additional information on "Your California     |                                    |                             |
| Privacy Rights."                               |                                    |                             |
| ---------------------------------------------- | ---------------------------------- | --------------------------- |

MSCHF may also use and/or disclose Personal Information for purposes disclosed to you at the time the
Personal Information is collected or otherwise with your consent. The above excludes text messaging
originator opt-in data and consent; this information will not be shared with any third parties.

Effective Date

This is our most current Privacy Policy and is effective as of February 11, 2023. We reserve the right to
change any of our terms and policies at any time, without notice. If we change it, we will post the then-
current Privacy Policy on this page. Any changes to this Privacy Policy will be effective as of the date
posted.

Contact Us
If you have questions or comments about our policies, please contact [email protected]

Definitions

Affiliates

Companies related by common ownership or control. For example, M Payments, LLC is an affiliate of
MSCHF Product Studio, Inc.

Non-affiliates

Companies not related by common ownership or control.