AxGrad Privacy Policy

Last Modified: [05292025k]

Introduction

AxGrad ("AxGrad", "we", "us") respects your privacy and provides this Privacy Policy (the "Policy") to inform you about the personal information we may collect from you or that you may provide when you visit the website axgrad.ai, as well as our practices regarding the collection, use, and disclosure of that personal information.

As used in this Policy, "personal information" refers to information that identifies, relates to, describes, or could reasonably be linked with an identifiable natural person. This Policy applies to personal information we collect:

• On this Website.
• In email, text, and other electronic communications between you and us.
• Through any web-based tools, dashboards, or interfaces you access via the Website that facilitate interaction with our services.

This Policy does not apply to external websites, applications, or services that do not display or link to this Policy or that display or link to a different privacy statement.

Please read this Policy carefully to understand our practices regarding your personal information and how we will treat it. By accessing or using this Website, you agree to be bound by this Policy and our Terms of Use.

Information We Collect About You and How We Collect It

We may collect the following categories of personal information from and about users of our Website:

• Identifiers: such as name, email address, social media username, wallet address, or other identifying information.
• Device Information: such as internet protocol (IP) address, browser type, operating system version, device identifiers, and mobile-related metadata.
• Usage Data: such as browsing activity on our Website, session logs, search queries, page interactions, and general user behavior on AxGrad interfaces.
• Profiles and Inferences: inferred data based on your use of AxGrad, such as your preferences, engagement with agents, strategy types submitted, or participation history.
• Commercial Information: records of services you have used, subscribed to, or interacted with — including leaderboard submissions, points activity, and competition history.
• Blockchain Information: including wallet addresses, strategy-linked transactions, participation in competitions, and any on-chain activity tied to AxGrad Points. While this may not be considered personal information on its own, we may associate it with other collected data for service functionality.

We collect this information:

• Directly from you, when you submit strategies, register accounts, participate in competitions, or contact us.
• Automatically, as you navigate and interact with the Website, through cookies, beacons, and similar tracking technologies.
• From third parties, including our analytics providers, infrastructure partners, or integrated services you authorize.

Information You Provide to Us

The information we may ask you to provide, and that we will collect, may include:

• Information you provide when filling out forms or registering on our Website, including when you create an AxGrad account, submit a strategy, or subscribe to updates.
• Records and copies of your communications with us (including email addresses) if you contact us for support or feedback.
• Your responses to feedback forms or surveys that we may use to improve our services and evaluate user experience.
• Information related to your participation in AxGrad competitions, including strategy metadata, submission content, and public performance metrics.

You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although [we limit access to certain pages/you may set certain privacy settings for such information by logging into your account profile], please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic and usage data, location data, logs, and data about the pages and areas that you access and interact with on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The personal information we collect automatically is aggregated statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Remember your preferences while you use our Website.

The technologies we use for this automatic data collection may include:

• Cookies: A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Performance and Analytics Cookies: These cookies allow us to count visits and traffic sources, through various third parties, so we can measure and improve the performance of our Website. These enable us to collect information about how you use our Website or read our publications, for instance which pages are viewed by visitors most frequently and how users interact with each of our Website. This information is used to compile reports to improve the respective site, including reports on the number of visitors to the Website, where the visitors are located, marketing and referrals, and what pages the users visit on the Website. All information these cookies collect is aggregated and is not associated with an identifiable individual. If you do not allow these cookies, we will not know when you have visited our Website and will not be able to monitor site performance.
• Web Beacons: Pages of the Website [and our e-mails] may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit AxGrad, for example, to count users who have visited those pages or [opened an email] and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
• Pixel Tags: Pixel tags are tiny graphic images with a unique identifier, similar in function to cookies, that are used to track online movements of web users. In contrast to cookies, which are stored on a computer’s hard drive or web browser, pixel tags are embedded invisibly in web pages. Pixel tags are often used in combination with cookies, to trigger the placing of cookies, and/or to transmit information to us or our vendors or partners. This enables two websites to share information. The resulting connection can include information such as a device’s IP address, the time a person viewed the pixel, an identifier associated with a browser or device, the type of browser being used, and the URL of the web page from which the pixel was viewed. Pixel tags also allow us to send email messages in a format that users can read, tell us whether emails have been opened, and help to ensure we are sending only messages that may be of interest to our consumers.

Most browsers automatically accept cookies, but you may be able to control the way in which your devices permit the use of cookies, web beacons/clear gifs, and other automatic data collection technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some Website features and general functionality to work incorrectly. To opt out of tracking by Google Analytics, click here. Your browser or device settings may allow you to transmit a "Do Not Track" or a "Global Privacy Control" signal when you visit our Website. At this time we do not respond to such signals.

How We Use Your Information

We use personal information that we collect about you or that you provide to us, including any personal information:

• To provide access to the AxGrad platform and its services, including our agent discovery tools, leaderboards, evaluations, and trading competitions.
• To operate, maintain, and improve the functionality, stability, and user experience of our Website and related products.
• To communicate with you regarding your use of AxGrad, including transactional updates, competition notices, account status, and relevant service alerts.
• To support community features such as leaderboard participation, agent submissions, and reward systems (including AxGrad Points).
• To analyze blockchain activity and performance data to improve our benchmarks and ensure accurate agent tracking across the ecosystem.
• To fulfill any other purpose for which you provide the information.
• To process user job applications, grant platform access for developers, or facilitate bounties or partnerships.
• To notify you about updates to our Website, Terms of Use, or features within the AxGrad ecosystem.
• For other purposes disclosed by us at the time you provide the information.
• For any purpose with your consent.

We may use information we collect to enable personalized experiences and improve how we display content (e.g., custom leaderboards, recommended agents, or tailored updates). We may also use your information for marketing purposes and platform growth strategies. If you interact with third-party advertisements or off-site features, they may receive limited information (e.g., public wallet data or IP address) consistent with standard browser behavior.

Disclosure of Your Information

We may disclose aggregated or anonymized information about our users — or information that does not identify any individual — without restriction.

We may disclose personal information that we collect or you provide as described in this policy:

• To our parent entities, subsidiaries, affiliates, or DAO-aligned contributors who help operate AxGrad infrastructure and services.
• To contractors, validators, node operators, service providers, and other third parties supporting the development or operation of AxGrad, provided they are bound by confidentiality and use limitations.
• In the event of a DAO migration, protocol spinout, acquisition, or transfer of platform governance — including during bankruptcy, liquidation, or similar proceedings — in which user information is considered part of the platform’s operational records.
• To fulfill the purpose for which you provide the information (e.g., to confirm an AxGrad Points transaction or leaderboard submission).
• For any purpose we disclose at the time of collection.
• With your consent.

We may also disclose your personal information:

• To comply with applicable law, regulatory requirements, court orders, or lawful requests by public authorities (including KYC/AML compliance or DAO jurisdictional reporting duties).
• To enforce our Terms of Use and other agreements, including for fraud prevention, token misbehavior, or dispute resolution.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of AxGrad, the community, users, contributors, or third parties. This may include coordination with third-party compliance services, Web3 security partners, or law enforcement.

How We Use Your Information

We use personal information that we collect about you or that you provide to us, including any personal information:

• To provide our Website and its contents to you, including access to features such as AI agent leaderboards, evaluations, competitions, and AxGrad Points.
• To provide you with information, products, or services that you request from us, including notifications related to performance metrics, agent submissions, and community features.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account, including information about usage history, reward activity, or in-platform purchases.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing, token usage, or collection.
• To notify you about changes to our Website or any products or services we offer or provide through it.
• To process job applications, grant contributor access, conduct background checks, and assess your skills, qualifications, and interest in our contributor or team opportunities.
• For any other purpose we may disclose when you provide the personal information.
• To analyze users' blockchain activity and on-chain agent performance to improve our services, benchmarking methodology, and platform experience.
• For any other purpose with your consent.

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this policy:

• To our subsidiaries and affiliates, including entities operating under the AxGrad ecosystem or governance.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of AxGrad’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
• To fulfill the purpose for which you provide it. For example, if you give us an email address to sign up for our newsletter, we may transmit your email address to our third-party service provider that sends the newsletter on our behalf.
• For any other purpose disclosed by us when you provide the personal information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including responding to any government or regulatory request.
• To enforce or apply our Terms of Use and other agreements, including for billing, dispute resolution, or token-related matters.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of AxGrad, our contributors, our users, or others. This includes exchanging information with other companies and organizations for the purposes of conducting background checks, complying with Know Your Customer and anti-money laundering laws, fraud protection, and credit risk reduction.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of personal information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk.

Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website, register for the newsletter, make any purchases through the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 18, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at [email protected]

Your Privacy Rights

California’s Shine the Light

Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties during the immediately preceding calendar year for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. California residents who would like to make such a request may submit a request via the contact information provided below. The request should attest to the fact that the requester is a California resident and provide a current California address. We are only required to respond to a customer request once during any calendar year. Please be aware that not all information sharing is covered by California’s “Shine the Light” law and only information sharing that is covered will be included in our response.

Nevada

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us here. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us.

Contact Us

Questions regarding this policy can be directed to:

[email protected]