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Privacy Policy

FIBER WALLET

Effective Date: May 29, 2026

Merkle Software Inc. ("Fiber," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and protect information about users of the Fiber non-custodial wallet application, website, and related services (collectively, the "Services" or "Offerings"). By using the Services, you agree to the practices described in this Privacy Policy.

Fiber is built with a privacy-first design. Your wallet credentials are secured using industry-standard security infrastructure so that they are never exposed to Fiber's backend systems. We minimize data collection and processing to only what is necessary to provide and improve the Services.

In summary, for Fiber users this means that we:

  • Do not expose your wallet credentials to our backend systems.
  • Do not sell your personal information.
  • Do not collect or retain personal information unless necessary to provide you the Services and a good user experience.
  • May temporarily process your IP address only where required to provide the Services, prevent DDoS attacks, comply with sanctions obligations, or improve your experience.
  • Do not collect financial payment or banking information unless required for specific features, in which case it is submitted to third-party providers.

1. About This Policy

This Privacy Policy applies to all users of the Fiber wallet and related Services provided by Merkle Software Inc.. When you use the Services, you are agreeing to the practices described here, as well as our Terms and Conditions. We act as the data controller with respect to personal information collected through the Services, meaning we determine how and why that information is processed.

If you are using the Services on behalf of a business or organization, that entity is responsible for ensuring its users are aware of this Privacy Policy and that its use of the Services complies with applicable law.

2. Personal Information We Collect

We collect personal information about you as described in this section. Some information you provide to us directly; other information is collected automatically. All information we collect is subject to the use limitations described in Section 3.

2.1 Information You Provide Directly

We collect information you voluntarily provide, including:

  • Email address and/or phone number, if you choose to create an account or subscribe to communications. Please note that neither an email address nor phone number is required to create or use a wallet with Fiber.
  • Account and profile information, if you create an account for certain features.
  • Support inquiries and correspondence, including your name, contact details, and the content of your communications with us.
  • Feedback, survey responses, or other information you choose to provide.
  • Wallet address and transaction-related information, where you choose to provide it in connection with your use of the Services.

2.2 Information Collected Automatically

When you use the Services, we may automatically collect limited technical information, including:

  • Device type, operating system version, and app version.
  • Internet protocol (IP) address. We may temporarily process your IP address only where required to provide the Services (including for basic functionality, routing requests to improve performance, latency measurement, and regional optimization), to comply with legal obligations (including sanctions screening), and to ensure the safety, security, and integrity of the Services (including prevention of DDoS attacks). Users who wish to further limit the collection of device and usage information may consider the use of a virtual private network (VPN).
  • General location information inferred from IP address (e.g., city or state).
  • Hardware and software information, browser type, device identifiers, date/time stamps, and crash data.
  • Usage analytics and session replay data (e.g., pages and features accessed, clicks, scrolling, and navigation) where you participate in optional analytics data collection. Inputs are masked in session replays. We store this data pseudonymously and do not link it to other personal information without informing you. You may disable this feature at any time.
  • Cookie data and similar technologies, as described in Section 7.

We do not collect or store your wallet balances or transaction history.

2.3 Blockchain Data

Blockchain transactions are inherently public and recorded on a distributed ledger not controlled by Fiber. While we incorporate privacy-enhancing technologies to minimize on-chain linkability, we cannot guarantee the privacy of public blockchain data. We do not collect or aggregate your on-chain transaction history.

2.4 Rewards Program Data

If you participate in the rewards program, we may receive confirmation of eligibility or activity from integrated third-party protocols. We do not receive or store your wallet balance or detailed transaction data in connection with rewards.

2.5 Information from Other Sources

We may collect information about you from third parties, such as marketing partners or researchers, and may combine this information with information we collect from you as described in this Privacy Policy.

3. How We Use Your Information

We use the personal information we collect for the following purposes, and only for the purposes for which it is collected:

  • To create your account or profile, if required, for your use of the Services.
  • To provide, operate, maintain, and improve the Services.
  • To respond to your support requests and communications.
  • To send you important notices, security alerts, and administrative communications.
  • Subject to any consent requirements, to send marketing materials, updates about product features, or other promotional materials. You will always be provided with an opportunity to opt out.
  • To detect, investigate, and prevent fraudulent, unauthorized, or unlawful activity, and to protect the safety, security, and integrity of the Services.
  • To comply with applicable laws, regulations, and legal processes, including preventing the Services from being accessed by individuals in sanctioned territories or by sanctioned individuals.
  • To conduct aggregate or de-identified analytics to understand usage patterns and improve the Services. De-identified data is not considered personal information.
  • For customer and third-party relationship management.

We do not use your information to serve you targeted advertising. We do not sell your personal information to third parties for their marketing purposes.

Please note that we may use AI-enhanced tooling in the course of our day-to-day business. For example, when you engage with our customer support team, AI tooling may be used to summarize content and respond to your queries efficiently. We always use AI tools responsibly.

4. How We Share Your Information

4.1 Service Providers

We may share information with trusted third-party service providers who assist us in operating the Services (e.g., cloud hosting, network management, analytics, cybersecurity, customer support, feature testing and rollouts). These providers are contractually obligated to use your information only as directed by Fiber and in accordance with this Privacy Policy.

4.2 Legal Compliance and Safety

We may disclose personal information when we believe in good faith that disclosure is necessary to: (a) comply with applicable laws, regulations, or legal process, including valid court orders or subpoenas; (b) protect the rights, property, or safety of Fiber, our users, or the public; or (c) detect, prevent, or address fraud, security, or technical issues.

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or substantially all of our assets, your information may be transferred to the successor entity. We will use reasonable efforts to notify you of any transfer to an unaffiliated third party and the choices available to you.

4.4 Strategic Business Partners

Where you have provided your consent, we may share your personal information with our strategic business partners in limited circumstances, for example for marketing purposes.

4.5 Third-Party Platforms

Your personal information may be shared with third-party services or platforms where you have requested to interact with them through the Services. Where permitted and possible, we seek to limit the personal information shared through the use of proxies. Please see Section 10 for more information on Third-Party services.

4.6 No Sale of Personal Data

Fiber does not sell, rent, or trade your personal information to third parties for their own marketing or commercial purposes.

5. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, or as required by applicable law, including in relation to any legal claim, complaint, litigation, or regulatory proceedings. When information is no longer needed, we delete or anonymize it.

6. Security and Storage

We implement industry-standard technical and organizational security measures to protect your information against unauthorized access, disclosure, alteration, or destruction. These measures include encryption in transit and at rest, access controls, and regular security assessments.

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee its absolute security. IF YOU BELIEVE YOUR PRIVACY HAS BEEN BREACHED THROUGH USE OF THE SERVICES, PLEASE CONTACT US IMMEDIATELY.

When you use the Services, personal information about you will be stored in the United States.

7. Cookies and Tracking Technologies

Our application may use limited local storage or session data solely for functional purposes (e.g., remembering app preferences). Our website may use cookies and similar technologies as described below.

Global Privacy Control (GPC) is a setting you can enable in your web browser to communicate your preference for not having certain information about your website visits collected across websites. We honor GPC signals where required by applicable law.

We do not use third-party tracking cookies for behavioral advertising. Subject to your consent, we may use first-party analytics and limited third-party analytics services to analyze aggregate usage of the Services.

Our website analytics include session replay, which reconstructs the pages you viewed and the interactions you made during a visit so we can diagnose usability problems. Text entered into form fields is masked before the replay leaves your browser. Where local law requires your prior consent, analytics and session replay stay off until you accept them; elsewhere they run until you turn them off using the analytics settings link in the website footer.

8. Your Privacy Rights

8.1 General Rights

Depending on your location, you may have rights with respect to your personal information, including:

  • Right to Access or Right to Know: the right to obtain access to the personal information we hold about you and information about our processing.
  • Right to Rectification or Correction: the right to correct inaccurate or incomplete information.
  • Right to Erasure or Deletion: the right to request deletion or anonymization of your personal information, subject to legal limitations.
  • Right to Object to Processing: the right to object to processing based on legitimate interests or for direct marketing purposes.
  • Right to Restrict Processing: the right to stop processing other than for storage purposes in certain circumstances.
  • Right to Portability: the right to receive your personal information in a structured, commonly used, machine-readable format.
  • Right to Withdraw Consent: the right to withdraw any consent you previously provided at any time, without affecting the lawfulness of processing before withdrawal.
  • Right to Lodge a Complaint: the right to lodge a complaint with a supervisory authority in your country of residence, place of work, or where an incident took place.
  • Right Against Discrimination: we will not discriminate against you for exercising your rights.

8.2 California Residents (CCPA/CPRA)

California residents have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including the right to know what personal information is collected and how it is used, the right to delete personal information, the right to opt out of the sale or sharing of personal information for targeted advertising (Fiber does not sell personal information), and the right to non-discrimination for exercising privacy rights. To opt out of sharing for personalized advertising purposes, contact us as described in Section 12 or enable Global Privacy Control (see Section 7).

8.3 Residents of the EEA, UK, Turkey, and Switzerland

If you are located in the European Economic Area (EEA), United Kingdom, Turkey, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR) or equivalent laws. Our legal bases for processing include: performance of a contract (to provide the Services), legitimate interests (security, fraud prevention, improving the Services, compliance), and compliance with legal obligations. You may also lodge a complaint with the relevant supervisory authority in your jurisdiction. You have the right to appeal any refusal by us to act on a data subject rights request by contacting us at privacy@fiber.so.

When we transfer your personal information internationally, we ensure that relevant safeguards are in place, including by relying on EU Commission adequacy decisions or standard contractual clauses as appropriate.

8.4 Exercising Your Rights

To exercise any of your privacy rights, please contact us at privacy@fiber.so. We will respond to verified requests within the timeframe required by applicable law. We may need to verify your identity before fulfilling certain requests. Note that applicable laws contain certain exceptions and limitations to each of these rights. You may authorize an agent to exercise rights on your behalf with proper written authorization.

9. Children's Privacy

The Services are not directed to individuals who have not reached the age of majority in their jurisdiction of residence. We do not knowingly collect personal information from minors. Consistent with the requirements of the Children's Online Privacy Protection Act (COPPA), if we learn that we have received any information directly from a child under age 13 without first receiving verified parental consent, we will use that information only to inform the child that they cannot use the Services, and will subsequently delete that information.

If you believe a minor has provided us with personal information, please contact us at privacy@fiber.so.

10. Third-Party Links and Services

The Services may enable you to interact with certain third-party services, decentralized applications, and platforms. This Privacy Policy does not apply to those third-party services, and we are not responsible for their privacy practices. The inclusion of a link or integration in the Services does not imply that we endorse the practices of the linked service. Your use of third-party platforms and those platforms' use of your personal information is subject to their respective terms of service and privacy notices.

11. Changes to This Privacy Policy

We reserve the right to amend this Privacy Policy at any time to reflect changes in the law, our data collection, use or sharing practices, or advances in technology. We will make the revised Privacy Policy accessible throughout the Services. You should review this Privacy Policy periodically. By continuing to access or use the Services, you confirm that you have read and understand the latest version of this Privacy Policy.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, or if you wish to exercise your privacy rights, please contact us:

Merkle Software Inc.

Email: privacy@fiber.so

Website: https://fiber.so/privacy

Supplemental Privacy Notice: EEA, UK, Turkey, and Switzerland

Effective: May 29, 2026

This Supplemental Privacy Notice applies to you if you are a natural living person located in the European Union, a European Free Trade Association country, Turkey, Switzerland, or the United Kingdom. It is incorporated into and forms part of the Global Privacy Policy above.

Legal Bases for Processing

Our legal bases for processing your personal information in this region include:

  • Consent: where you have consented to the use of your personal information.
  • Contract: the performance of a contract with you to provide the Services, such as creating and securing your account and responding to your inquiries.
  • Legitimate Interest: we have a legitimate business interest in processing your personal information to provide and improve the Services, communicate with you, and ensure compliance, fraud prevention, and safety, provided such interests do not override your fundamental rights and freedoms.
  • Legal Obligation: we may process your personal information to comply with applicable legal obligations, including anti-money laundering laws, tax and accounting obligations, and to establish, exercise, or defend legal claims.

International Data Transfers

If you provide us with your personal information from the EEA, UK, Turkey, or Switzerland, your information may be transferred to and processed in the United States or other countries. When we transfer your personal information internationally, we ensure that appropriate safeguards are in place, including reliance on EU Commission adequacy decisions or standard contractual clauses.

Complaints

You have the right to contact the appropriate supervisory authority at any time to lodge a complaint. The list of EU supervisory authorities is maintained by the European Data Protection Board at edpb.europa.eu.

Supplemental Privacy Notice: U.S. States with Privacy Laws

Effective: May 29, 2026

This Supplemental Privacy Notice applies to residents of any U.S. state with a privacy-related consumer protection law. It is incorporated into and forms part of the Global Privacy Policy above. We are continuously working to comply with these laws and will update our practices as implementing rules are finalized.

We Do Not Sell Your Personal Information

We do not sell your personal information. Your personal information is 'sold' when it is provided to a third party for monetary or other valuable consideration for a purpose that is not a 'business purpose' as defined under applicable law.

Sharing for Advertising

We do not use your information for targeted advertising. To the extent any of our practices constitute 'sharing' of personal information as defined under applicable state law, you may opt out by contacting us as described in Section 12 or by enabling Global Privacy Control (see Section 7).