Privacy Policy

How Lotus Terminal collects, uses, shares, and protects personal information.

Welcome to Lotus Terminal (“Lotus,” “we,” “us,” or “our”). This Privacy Policy explains how we collect, use, disclose, and protect personal information when you access or use our websites, applications, documentation, APIs, analytics tools, communications, and other related services (collectively, the “Service”).

Lotus is operated by LotusExecution, Inc. (to be incorporated) and its future affiliates.

1. Personal Information We Collect

Information you provide to us

We may collect personal information that you voluntarily provide when you interact with the Service, including when you:

• contact us with questions, feedback, or support requests;

• register interest, join waitlists, or subscribe to updates or newsletters;

• participate in events, demos, research, surveys, or community discussions;

• communicate with us via email, social media, messaging platforms, or other channels; or

• otherwise submit information through forms or direct communications.

This information may include your name, email address, username or handle, wallet address, and any other information you choose to provide.

We may also receive information about you from third-party sources, such as publicly available data, analytics providers, or partners, where permitted by law.

Automatic data collection

When you access or use the Service, we and our service providers may automatically collect certain information, including:

Device and technical data

• device type, operating system, browser type and version

• IP address, language and region settings

• approximate location (e.g., country or city level)

• network information and timestamps

Usage and interaction data

• pages, features, or screens viewed

• navigation paths and interaction patterns

• access times, session duration, and referral sources

• engagement with communications or alerts

This data helps us understand how the Service is used and improve performance and functionality.

2. How We Use Personal Information

We use personal information for the following purposes:

Service delivery and operations

• to provide, operate, maintain, and improve the Service;

• to communicate with you about the Service, including updates, alerts, and administrative messages;

• to personalise features, content, and user experience;

• to respond to inquiries, feedback, and support requests.

Research, analytics, and development

• to analyse usage trends, performance, and feature adoption;

• to test, develop, and improve products and functionality;

• to generate aggregated or de-identified data for analytics, reporting, and internal research (such data does not identify you personally).

Compliance, security, and protection

• to comply with applicable laws, regulations, and lawful requests;

• to detect, prevent, and investigate fraud, abuse, or security incidents;

• to enforce our Terms of Use and other policies;

• to protect the rights, safety, and property of Lotus, users, and others.

3. How We Share Personal Information

We may share personal information in the following circumstances:

Service providers

With trusted third-party service providers who perform services on our behalf, such as:

• cloud hosting and infrastructure

• analytics and monitoring

• communications and email delivery

• customer support tools

These providers are permitted to use personal information only as necessary to perform services for us.

Public blockchain data

If you interact with blockchain networks or third-party platforms through the Service, certain information (such as wallet addresses or transaction data) may be publicly visible on the relevant blockchain.

Lotus does not control public blockchain records.

Legal and regulatory disclosures

We may disclose information where we believe in good faith that disclosure is necessary to:

• comply with applicable laws or lawful requests;

• protect rights, safety, or property;

• investigate or prevent illegal or harmful activity.

Business transfers

If Lotus is involved in a merger, acquisition, restructuring, financing, or sale of assets, personal information may be transferred as part of that transaction, subject to applicable law.

4. Your Choices

Declining to provide information

You may choose not to provide certain personal information.

However, this may limit your ability to access certain features or receive communications.

Communications

You may opt out of non-essential communications (such as newsletters) by following unsubscribe instructions or contacting us.

Do Not Track

Some browsers send “Do Not Track” signals.

At this time, the Service does not respond to such signals.

5. Third-Party Sites and Services

The Service may contain links to or integrations with third-party websites, platforms, or services.

We do not control those third parties, and this Privacy Policy does not apply to them.

Their privacy practices are governed by their own policies.

6. Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information.

However, no system is completely secure, and we cannot guarantee absolute security.

You are responsible for safeguarding any credentials, wallets, or third-party accounts you use in connection with the Service.

7. International Data Transfers

Lotus may process and store personal information in jurisdictions outside your country of residence, including where our service providers are located.

Data protection laws in those jurisdictions may differ from those in your location.

By using the Service, you consent to such transfers as permitted by applicable law.

8. Children

The Service is not intended for use by individuals under the age of 18.

We do not knowingly collect personal information from children.

If we learn that we have collected such information, we will delete it as required by law.

9. Your Rights

Depending on your jurisdiction (including the EEA, UK, or similar regions), you may have rights to:

• access personal information we hold about you;

• request correction or deletion of personal information;

• object to or restrict certain processing;

• request portability of your personal information;

• withdraw consent where processing is based on consent.

To exercise these rights, contact us using the details below.

We may request verification of your identity and may decline requests where legally permitted.

10. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us at:

• Email: [email protected]

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

When we do, we will revise the “Effective Date” and post the updated version on the Service.

Your continued use of the Service after changes become effective constitutes acceptance of the updated Privacy Policy.