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Privacy Policy

Last updated: 17 June 2026

This Privacy Policy explains how Rovum ("Rovum", "we", "us", or "our") collects, uses, shares, and protects personal data when you use our website at rovum.net, our token-acquisition portal at app.rovum.net, and related services (together, the "Services"). It applies alongside our Terms & Conditions and Risk Disclosure.

By using the Services, you acknowledge the practices described here. If you do not agree, please do not use the Services.

1. Who We Are

Rovum is the controller responsible for the personal data processed through the Services. For privacy questions or to exercise your rights, contact us at privacy@rovum.net.

The data controller is Rovum LLC, 450 Park Avenue, Floor 21, New York, NY 10022, United States.

2. Scope

This Policy covers personal data we process about visitors, registered Users, and participants in the Presale. It does not cover third-party websites, wallets, or services that we do not control, even where we link to them.

3. Information We Collect

3.1 Information you provide

  • Account and contact data: name, email address, username, password, and preferences.
  • Identity-verification (KYC) data: where verification applies, government-issued identification, date of birth, nationality, residential address, photographs or selfies, proof of address, and source-of-funds information.
  • Communications: the content of messages, support requests, and survey or feedback responses you send us.

3.2 Information collected automatically

  • Wallet and transaction data: public wallet addresses you connect, transaction hashes, amounts, asset types, and on-chain activity related to your use of the Services.
  • Device and usage data: IP address, browser type, device identifiers, operating system, pages viewed, referring URLs, timestamps, and interactions with the Services.
  • Cookies and similar technologies: as described in Section 6.

3.3 Information from third parties

  • Verification and screening providers: identity-verification results, sanctions and politically-exposed-person ("PEP") screening, and fraud signals.
  • Analytics and infrastructure providers: aggregated or technical data about how the Services are used.
  • Public blockchains: publicly available on-chain data associated with addresses you use.

Public blockchains are transparent. Information recorded on a blockchain, including wallet addresses and transaction details, is public, permanent, and outside our control. It cannot be edited or deleted.

4. How We Use Your Information

We use personal data to:

  1. Provide, operate, maintain, and secure the Services and process Presale contributions and allocations.
  2. Create and manage your Account and authenticate you.
  3. Perform identity verification, KYC/AML, sanctions screening, and fraud prevention.
  4. Communicate with you about your Account, transactions, support requests, security, and changes to the Services.
  5. Send you product updates or marketing where permitted, from which you can opt out at any time.
  6. Analyze and improve the Services, develop new features, and conduct research.
  7. Comply with legal and regulatory obligations and enforce our Terms & Conditions.
  8. Establish, exercise, or defend legal claims and protect the rights, property, and safety of Rovum, our Users, and the public.

5. Legal Bases for Processing (EEA/UK)

Where the EU or UK General Data Protection Regulation applies, we rely on the following legal bases:

  • Performance of a contract — to provide the Services you request.
  • Legal obligation — to meet KYC/AML, tax, sanctions, and other regulatory requirements.
  • Legitimate interests — to secure, analyze, and improve the Services and prevent fraud, balanced against your rights.
  • Consent — for certain cookies and marketing, which you may withdraw at any time.

6. Cookies and Similar Technologies

We and our providers use cookies, local storage, and similar technologies to keep you signed in, remember preferences, secure the Services, and measure usage. Some are strictly necessary for the Services to function; others are analytics or preference cookies. You can control non-essential cookies through your browser settings or any cookie-preferences tool we provide. Disabling some cookies may affect functionality.

7. How We Share Information

We do not sell your personal data. We share it only as follows:

  • Service providers and processors: hosting, infrastructure, analytics, identity-verification, email delivery, customer support, and security vendors that process data on our behalf under appropriate contracts.
  • Professional advisors: lawyers, auditors, and accountants where necessary.
  • Legal and regulatory authorities: where required to comply with Applicable Law, a lawful request, or to protect rights, property, or safety.
  • Corporate transactions: in connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to confidentiality.
  • With your consent or at your direction.

8. International Transfers

We may transfer, store, and process personal data in countries other than your own, which may have different data-protection laws. Where required, we use appropriate safeguards (such as Standard Contractual Clauses or equivalent mechanisms) to protect your data in connection with such transfers.

9. Data Retention

We retain personal data for as long as necessary to provide the Services and for legitimate business or legal purposes, including compliance with KYC/AML record-keeping obligations (which may require retention for several years after your relationship with us ends), dispute resolution, and enforcement of our agreements. When data is no longer needed, we delete or anonymize it. Note that on-chain data cannot be deleted.

10. Security

We implement technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, or alteration, including encryption in transit, access controls, and monitoring. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for safeguarding your own credentials, wallet keys, and devices.

11. Your Rights

Depending on your location, you may have some or all of the following rights regarding your personal data:

  • Access — request a copy of the data we hold about you.
  • Rectification — correct inaccurate or incomplete data.
  • Erasure — request deletion, subject to legal retention obligations.
  • Restriction and objection — limit or object to certain processing, including direct marketing.
  • Portability — receive certain data in a portable format.
  • Withdraw consent — where processing is based on consent.
  • Lodge a complaint — with your local data-protection authority.

California residents have rights under the CCPA/CPRA, including the right to know, delete, correct, and opt out of "sale" or "sharing" of personal information, and the right not to be discriminated against for exercising these rights. We do not sell personal information.

To exercise your rights, contact privacy@rovum.net. We may need to verify your identity before responding, and we will respond within the timeframe required by Applicable Law.

12. Children's Privacy

The Services are not directed to, and may not be used by, anyone under 18. We do not knowingly collect personal data from children. If you believe a child has provided us data, contact us and we will delete it.

13. Automated Decision-Making

Certain fraud-prevention and verification checks may involve automated processing. Where such processing produces legal or similarly significant effects, we provide safeguards consistent with Applicable Law, which may include the ability to request human review.

14. Third-Party Links and Services

The Services may link to or integrate with third-party websites, wallets, and protocols that have their own privacy practices. We are not responsible for those practices; review their policies before using them.

15. Changes to This Policy

We may update this Policy from time to time. We will indicate changes by updating the "Last updated" date and, for material changes, by providing additional notice. Your continued use of the Services after changes take effect constitutes acceptance.

Contact: For privacy questions or to exercise your rights, email privacy@rovum.net. The only official addresses for Rovum are rovum.net and app.rovum.net.