Privacy Policy

Last-updated: April 2025

1. Overview

Your privacy is important to us. Polymath Research Inc. (“Polymath”, “we”, or “us”) wants you to be familiar with how we collect, use and disclose your Personal Information.

Polymath is a technology provider providing blockchain based technologies for digital assets. For a complete description of our business please review our corporate website at www.polymath.network. This Privacy Policy (“Policy”) explains how we collect, use, and disclose your Personal Information when you visit or use services made available through our websites located at https://polymath.network (“Websites”) and associated platforms operated by us from which you are accessing this Policy (collectively, the “Services”) including:

  • The Polymesh Testnet network, through which you are able to access and interact with a foundational layer for securities tokens (“Polymesh”);
  • The Polymath smart contracts that enable you to configure and design tokens directly on the Ethereum blockchain (“Ethereum Smart Contracts”);
  • The TokenStudio platform on Ethereum, through which you are able to configure and design a securities token and interact with and engage third-party service providers (“Ethereum TokenStudio”);
  • The TokenStudio platform on Polymesh, through which you are able to configure and design a securities token and interact with and engage third-party service providers (“Polymesh TokenStudio”);
  • Polymath Capital platform on Polymesh, a white-label platform, through which you are able to configure and design a securities token, activate an investor workspace, and integrated with third-party service providers (“Polymath Capital”);
  • The Polymesh Wallet available as a browser extension through which you are able to manage your (i) digital assets created on Polymesh; and (ii) Polymesh’s native protocol token, POLYX (“Polymesh Wallet”).

This Policy also describes other important topics relating to your privacy.

If you are a user in the UK or the European Economic Area ("EEA"), please refer to our section "Users in UK and EEA" which provides information on the rights that you have specifically under the General Data Protection Regulation and the UK's Data Protection Act 2018 (collectively we call them the "European Data Protection Laws").

2. Consent

By using the Services, or by otherwise choosing to submit Personal Information to Polymath, for users outside of the UK and EEA, you are providing your consent to the collection, use, disclosure and other processing of your personal information as outlined in this Policy. If you are a user in the UK or EEA, please refer to our section "Users in UK and EEA" which provides information on the basis on which we may process your personal information. At any time, you have the right to withdraw your consent to the collection, use, disclosure, and other processing of your personal information, subject to reasonable notice and legal, contractual and technological limitations. You may make this request by writing to the e-mail address set out below.

3. Modifications

We may change this Policy from time to time. If we make material changes, we will take reasonable steps to notify you, such as by revising the effective date at the top of the Policy or placing a notice on our Websites and associated platforms through which you use our Services, or at our discretion, contacting you using any contact information you have provided. We encourage you to review the Policy whenever you access the Services to stay informed about our information practices.

4. Summary

The following is a short summary of the key elements of this Policy. You can read the full version of the Policy following this summary.

We may collect the following Personal Information and other information from you:

  • Your name;
  • Your e-mail address;
  • Your phone number;
  • Your Ethereum and Polymesh public addresses;
  • Information you provide directly to us when you request that we conduct a specific task on your behalf using the Services, or other information you provide when you communicate with us;
  • Online identifiers such as general geographic location, IP address, and details regarding your use of the Services such as how frequently you log in, the duration of each session, pages you visit, and actions like creating or editing offerings.

We may use your Personal Information for the following purposes:

  • To provide you with the functionality of the Services;
  • To contact you regarding your use of the Services;
  • To understand how you and our users use the Services in order to improve the Services, and our marketing efforts;
  • For other purposes required by applicable law, including confirming your identity to comply with our regulatory obligations.

How to contact us:

If you have questions about this Policy or would like to contact us regarding the collection, use and disclosure of your personal information, please contact us at legal@polymath.network.

5. What personal information do we collect about you?

Personal Information refers to any information about an identifiable individual.

Your Ethereum public address is collected on-chain when you utilize our Ethereum Smart Contracts to configure securities tokens directly on the Ethereum blockchain. Please see the section “Information Recorded On-Chain” for more information on how information on-chain is processed.

We collect the following Personal Information and other information from you when you use the Ethereum TokenStudio, including:

  • Your name;
  • Your e-mail address;
  • Your Ethereum public addresses.

We collect the following Personal Information and other information when you request to open an account on Polymesh and our Services provided on Polymesh, including Polymesh TokenStudio and Polymesh Wallet:

  • Your name;
  • Your e-mail address;
  • Your Ethereum public address and your Polymesh public address;
  • Your phone number (mobile).

We also collect information that you provide directly to us when you access and use the Services, including:

  • Information that you provide when you request that a token be configured using the Services, such as information describing the tokens and the issuer as well as e-mail addresses for intended token recipients;
  • Information regarding the services you use, such as information you provide for identification purposes, such as your name, nationality, and birth date;
  • Information that you provide when you request customer support from us.

Please note that where you provide us with the information of another person such as a token recipient, you must have their permission to give it to us for that purpose.

6. Information that we collect

When you access or use the Services, we collect certain information using cookies, web beacons, and similar tracking technologies. Cookies are small data files stored directly on a user’s device that allow us to recognize the user’s computer or device when they return. Cookies may provide us and our service providers with information that we will use to personalize our Services in accordance with a user’s preferences, improve the functionality of our Services, and enable us to track activities and trends so that we can improve the Services. This information includes:

  • Online identifiers such as IP address, device information, and browser type;
  • Details regarding how you interact with the Services, such as time spent on the Services and which links you click on;
  • Metrics such as number of visitors to our Websites, pages visited, frequency of clicks to assess behaviors, usage data, failed attempts, spam attempts, and similar information.

Your browser gives you the ability to reject cookies and you may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, setting your browser or device to reject cookies generally hinders performance and may adversely affect your experience while using the Services.

We may also use a third party to help us gather and analyze information about the areas that users visit on the Websites to evaluate and improve the customer experience and convenience of the Websites.

7. How do we use your personal information?

Information we collect is used by Polymath and its service providers to:

  • Provide you with the functionality of the Services and fulfil your requests;
  • When you configure a token using Polymesh TokenStudio and/or Ethereum TokenStudio, we will use the information that you provide to us;
  • Create your account and associated decentralized identity to enable you to access the Services;
  • Send you technical notices, updates, security alerts and support and administrative messages including confirmations and receipts;
  • Respond to your comments, questions and requests and provide customer service;
  • Communicate with you about products, services, and events we think will be of interest to you;
  • To understand users and potential users and their interests in Polymath products and services, manage our relationship with users, enhance user experience on our platform and applications, and improve our platforms and applications;
  • Conduct audits to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
  • Carry out any other purpose for which the information was collected and for which you have provided your consent; and
  • For other purposes that are permitted or required by applicable law such as verifying your identity in accordance with our client identification requirements.

We may aggregate and anonymize Personal Information so that it may not be used to identify you or any other individual.

8. Who do we share your information with?

We share information about you as follows or as otherwise described in this Policy:

  • To service providers selected by you in order to request services on your behalf;
  • To analytics vendors, including Google Analytics;
  • To other third-party service providers that assist us with carrying out the purposes we describe in this Privacy Policy;
  • In response to a request for information if we believe disclosure is required or permitted in accordance with any applicable law, regulation or legal process;
  • To cooperate with law enforcement, protect our rights or those of third parties;
  • In connection with, or during negotiations of, any actual or potential merger, consolidation, restructuring, sale of company assets;
  • With other third parties when we have your consent.

We may aggregate and anonymize Personal Information so that it may not be used to identify you or any other individual.

9. Information recorded on-chain

“On-chain” operations refer to those operations that occur on a blockchain such as Ethereum and Polymesh and are permanently recorded.

Any information that you attach to an “on-chain” operation may be viewed by the public. If you choose to voluntarily disclose Personal Information in an “on-chain” operation, that information will be available to the public.

10. Rights as data subjects

As a data subject, you have the following rights under the European Data Protection Laws:

  • Object to processing;
  • Access personal data relating to you;
  • Rectification;
  • Restriction;
  • Data portability;
  • Erasure;
  • Withdraw your consent.

11. Retention

We retain Personal Information for as long as we have ongoing business needs to do so. We may retain anonymous and aggregate information indefinitely.

12. Security

Polymath uses appropriate security measures to help protect information about you from loss, theft, misuse and unauthorized access.

13. We may transfer personal information outside of your country

Some or all of the Personal Information we collect may be stored or processed outside of your jurisdiction of residence, including in the United States.

14. This Policy does not apply to third party sites

Our Services may contain links to websites owned by third parties. We are not responsible for the privacy practices or the content of any website(s) owned and operated by third parties.

15. Access and correction

If you have any questions about this Policy or how we process your Personal Information, please contact our Policy Department at legal@polymath.network.

16. Contact Us

If you have any questions about this Policy or how we process your Personal Information, please contact our Policy Department at legal@polymath.network.