Digital Assets Supplementary Privacy Notice

1. Scope and Applicability

This Digital Assets Supplementary Privacy Notice ("Supplementary Notice") supplements the Gauge Privacy Policy available at gauge.fun/privacy (the "Main Privacy Policy"). This Supplementary Notice applies when you access or use any digital asset features on the Gauge platform, including purchasing, selling, or trading tokens, tickets, or fractions; using a Custodial Wallet; or interacting with smart contracts.

In the event of a conflict between this Supplementary Notice and the Main Privacy Policy, this Supplementary Notice shall prevail with respect to digital asset features. All terms from the Main Privacy Policy apply unless specifically modified herein.

If you do not use digital asset features, this Supplementary Notice does not apply to you.

2. Additional Information We Collect

When you use digital asset features, we may collect the following additional information:

2.1 Wallet Data

• Custodial wallet addresses created on your behalf by our third-party wallet service provider.
• Self-custody wallet addresses you provide for asset transfers.
• Private key management data (held securely by our third-party wallet service provider; Gauge does not directly store or access private keys).

2.2 Transaction Data

• On-chain transaction history, including purchases, sales, transfers, and reward distributions.
• Token balances, ticket holdings, and fraction ownership.
• Smart contract interaction data.
• Transaction amounts, timestamps, and counterparty wallet addresses.

2.3 Compliance Data

• Identity verification data if required for regulatory compliance (e.g., KYC/AML).
• Sanctions screening results.
• Jurisdiction and residency information relevant to digital asset regulations.

3. How We Use Digital Asset Data

In addition to the uses described in the Main Privacy Policy, we use digital asset data to:

• Facilitate the creation and management of your Custodial Wallet through our third-party wallet service provider.
• Process digital asset transactions and reward payments.
• Monitor trading activity for fraud, manipulation, and wash trading.
• Comply with applicable financial regulations, sanctions requirements, and reporting obligations.
• Conduct risk assessments and security monitoring of wallet activity.
• Generate analytics related to token markets and trading patterns.
• Enforce the Digital Assets Supplementary Terms.

4. Blockchain Data

You acknowledge and accept the following about blockchain data:

4.1 Public Nature

All blockchain transactions are publicly visible and recorded on distributed ledgers. This includes wallet addresses, transaction amounts, token transfers, and smart contract interactions. Anyone can view this data using blockchain explorers.

4.2 Immutability

Once recorded on a blockchain, transaction data cannot be modified, corrected, or deleted by Gauge or any party. This is a fundamental characteristic of blockchain technology.

4.3 Pseudonymity

While wallet addresses are publicly visible, neither Gauge nor our third-party wallet service provider publicly links wallet addresses to your identity without your consent. However, third parties may independently attempt to associate wallet addresses with identities through on-chain analysis.

4.4 Cross-Chain Data

If you use the Platform across multiple blockchains (Avalanche, Base, Monad), transaction data will be recorded on each respective blockchain independently.

5. Data Sharing Specific to Digital Assets

In addition to the data sharing described in the Main Privacy Policy, when you use digital asset features:

5.1 Blockchain Networks

Transaction data is broadcast to and recorded by blockchain network participants (validators, nodes) as part of normal blockchain operations. Gauge has no control over data once it is recorded on-chain.

5.2 Infrastructure Providers

We share data with blockchain infrastructure providers including our third-party wallet service provider, node operators, RPC providers, and bridge protocols necessary to facilitate transactions. Our wallet service provider receives your account information as needed to create and manage your Custodial Wallet and is bound by contractual data protection obligations.

5.3 Regulatory and Legal Disclosures

We may disclose digital asset transaction data and identity information to:

• Financial regulators and tax authorities as required by applicable law.
• Law enforcement agencies in response to valid legal process.
• Sanctions screening and compliance service providers.

5.4 Smart Contract Transparency

Interactions with smart contracts are visible on-chain and may be viewed by any party. This includes the nature and parameters of your transactions.

6. Data Retention for Digital Assets

In addition to the retention periods in the Main Privacy Policy:

• Blockchain data: Permanently retained on-chain. This is inherent to blockchain technology and is outside Gauge's control.
• Transaction records: Minimum 7 years for financial compliance and reporting purposes.
• Custodial Wallet data: Retained for the duration of your account plus any required regulatory retention period.
• Compliance and verification data: Retained as required by applicable financial regulations, typically a minimum of 5 years after account closure.

7. Your Rights Regarding Digital Asset Data

You may exercise the rights described in the Main Privacy Policy with respect to off-chain digital asset data. However, please note:

• Blockchain data cannot be modified or deleted. The right to erasure, correction, and restriction does not apply to data recorded on public blockchains, as this data is immutable and outside Gauge's control.
• Custodial Wallet data can be deleted upon account closure, subject to regulatory retention requirements.
• Transaction records may be retained beyond your deletion request where required by law.
• You may export your digital assets to a self-custody wallet at any time, which removes your reliance on Gauge's Custodial Wallet services.

8. Security for Digital Assets

In addition to the security measures described in the Main Privacy Policy, we implement the following for digital asset features:

• Secure private key management and storage for Custodial Wallets is handled by our third-party wallet service provider, subject to their own security protocols and certifications.
• Multi-signature and access control protocols for high-value transactions.
• Monitoring of wallet activity for unauthorized access or suspicious transactions.
• Segregation of digital asset management systems from other Platform infrastructure.

While we employ commercially reasonable security measures, no system is completely secure. Digital assets are subject to risks inherent in blockchain technology, including but not limited to smart contract vulnerabilities and network-level attacks.

9. International Considerations

Digital asset regulations vary by jurisdiction. By using digital asset features, you acknowledge that:

• Your transaction data may be processed in jurisdictions with different data protection laws.
• Gauge may be required to comply with financial regulations in multiple jurisdictions.
• Certain digital asset features may not be available in all jurisdictions due to regulatory restrictions.

10. Changes to This Supplementary Notice

We may update this Supplementary Notice periodically. Material changes will be notified via email or Platform notification at least 30 days before taking effect. Continued use of digital asset features after changes constitutes acceptance.

11. Contact Us

For questions about this Supplementary Notice or how your digital asset data is handled:

Email: privacy@gauge.fun

Website: gauge.fun