Version 1.0

Last Revised on 03-20-2023 
This Privacy Policy for Sphere Global, Inc. (“Company”, “we”, “us” “our”) describes how we collect, use and disclose information about users of the Company’s website (, mobile cryptocurrency  payment application, the SphereOne Merchant Platform and other services, tools and features (collectively,  the “Services”). For the purposes of this Privacy Policy, “you” and “your” means you as the user of the  Services. Please read this Privacy Policy carefully. By using, accessing, or downloading any of the Services, you  agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you  do not agree to this Privacy Policy, please do not use, access or download any of the Services. 1. UPDATING THIS PRIVACY POLICY We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date  at the top of this Privacy Policy. If we make material changes to the way in which we use information we  collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you  provided us, by posting notice of such changes on the Services, or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this  Privacy Policy please do not access or continue to use the Services. 2. COMPANY’S COLLECTION AND USE OF INFORMATION When you access or use the Services, we may collect certain categories of information about you from a  variety of sources, which may include:  • The following contact information: name, email address and phone number. We collect basic  contact details to communicate with you and provide you with the Services.  • The following account information: username. We collect account information to maintain and  secure your account with us. If you choose to use the Services and register an account, you are  responsible for keeping your account credentials safe. We highly recommend that you do not share  your username, password, or other access details with anyone else. If you believe your account has  been compromised, please contact us immediately. • The following third-party wallet (“Wallet”) information: public wallet address, encrypted Wallet  private keys (although we cannot see your private keys) and token IDs that you own. We collect  third-party Wallet information in order to facilitate your use of the Services. • The following payment information: bank account information and credit or debit card numbers.  We collect payment information to link your bank account to the Services and to enable you to  complete transactions through the Services.  • The following identification information: driver’s license, passport, social security number and  other relevant government identification cards, depending on your country of residence. We collect  identification information for certain know-your-customer and other identity verification reviews  and to comply with our anti-money laundering policies. The following information we automatically collect about your interaction with the Services: IP  address, location, session data (e.g., length of the session), unique device identifier, device type,  browser type, operating system and clickstream data and ad impressions. We use the information  we collect automatically to tailor the Services to you, to run analytics and better understand user  interaction with the Services and to market to you. • Any other information you choose to include in communications with us, for example, when  sending a message to us through the Services In addition to the foregoing, we may use any of the above information to comply with any applicable legal  obligations, to enforce any applicable terms of service, and to protect or defend the Services, our rights, and  the rights of our users or others. 3. HOW THE COMPANY SHARES YOUR INFORMATION In certain circumstances, the Company may share your information with third parties for legitimate  purposes subject to this Privacy Policy. Such circumstances may include:  • With vendors or other service providers, such as o Payment service providers, including Banxa, Onramper, Wert, and Sardine o Know-your-customer and other identity verification service providers o Blockchain analysis service providers o Data analytics vendors • To comply with applicable law or any obligations thereunder, including cooperation with law  enforcement, judicial orders, and regulatory inquiries • In connection with an asset sale, merger, bankruptcy, or other business transaction • To enforce any applicable terms of service • To ensure the safety and security of the Company and/or its users • When you request us to share certain information with third parties, such as through your use of  login integrations • With professional advisors, such as auditors, law firms, or accounting firms 4. COOKIES AND OTHER TRACKING TECHNOLOGIES Do Not Track Signals Your browser settings may allow you to transmit a “Do Not Track” signal when you visit various websites.  Like many websites, our website is not designed to respond to “Do Not Track” signals received from  browsers. To learn more about “Do Not Track” signals, you can visit Cookies and Other Tracking Technologies Most browsers accept cookies automatically, but you may be able to control the way in which your devices  permit the use of cookies, web beacons/clear gifs, other geolocation tracking technologies. If you so choose,  you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause  some of the Services, including any portal features and general functionality, to work incorrectly. To opt out of tracking by Google Analytics, click here. If you have questions regarding the specific information about you that we process or retain, as well as your  choices regarding our collection and use practices, please contact us using the information listed below. 5. THIRD PARTY WEBSITES AND LINKS We may provide links to websites or other online platforms operated by third parties. If you follow links to  sites not affiliated or controlled by us, you should review their privacy and security policies and other terms  and conditions. We do not guarantee and are not responsible for the privacy or security of these sites,  including the accuracy, completeness, or reliability of information found on these sites. Information you  provide on public or semi-public venues, including information you share on third-party social networking  platforms (such as Facebook or Twitter) may also be viewable by other users of the Services and/or users  of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion  of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners  or operators, except as disclosed on the Services.  6. THIRD PARTY WALLET EXTENSIONS Certain transactions conducted via our Services, will require you to connect a Wallet to the Services. By  using such Wallet to conduct such transactions via the Services, you agree that your interactions with such  third party Wallets are governed by the privacy policy for the applicable Wallet. We expressly disclaim any  and all liability for actions arising from your use of third party Wallets, including but without limitation, to  actions relating to the use and/or disclosure of personal information by such third party Wallets.  7. USER GENERATED CONTENT Certain features of the Services may allow you to upload content (i.e., images to be used as profile pictures) (“User-Generated Content” or “UGC”). We or others may store, display, reproduce, publish, or otherwise  use UGC, and may or may not attribute it to you. Others may also have access to UGC and may have the  ability to share it with third parties. If you choose to submit UGC to any public area of the Services, your  UGC will be considered “public” and will be accessible by anyone, including the Company. Please note that we do not control who will have access to the information that you choose to make available  to others, and cannot ensure that parties who have access to such information will respect your privacy or  keep it secure. We are not responsible for the privacy or security of any information that you make publicly  available on the features permitting creation of UGC or what others do with information you share with  them on such platforms. We are not responsible for the accuracy, use or misuse of any UGC that you  disclose or receive from third parties through the forums or email lists. 8. CHILDREN’S PRIVACY Children under the age of 18 are not permitted to use the Services, and we do not seek or knowingly collect  any personal information about children under 13 years of age. If we become aware that we have  unknowingly collected information about a child under 13 years of age, we will make commercially  reasonable efforts to delete such information from our database. If you are the parent or guardian of a child under 13 years of age who has provided us with their personal  information, you may contact us using the below information to request that it be deleted. 9. DATA SECURITY Please be aware that, despite our reasonable efforts to protect your information, no security measures are  perfect or impenetrable, and we cannot guarantee “perfect security.” Please further note that any  information you send to us electronically, while using the Services or otherwise interacting with us, may  not be secure while in transit. We recommend that you do not use unsecure channels to communicate  sensitive or confidential information to us.  10. HOW TO CONTACT US Should you have any questions about our privacy practices or this Privacy Policy, please email us at or contact us at 1221 South Congress, Suite 350, Austin, TX 78704.