Colosseum Privacy Policy
Last updated: January 23, 2024
This Privacy Policy is part of the Colosseum Terms of Service at https://www.colosseum.org/
terms-of-service. All terms, conditions, and terminology are consistent with the Terms ofService, and the Terms of Service are incorporated into this document by reference.
This policy governs the use of the Colosseum website at https://www.colosseum.org and theassociated tools and services, including https://arena.colosseum.org.
Collectively, the website and the associated tools and services are referred to as the “Services” inthese terms. The operator may offer other products and services.
The Services do not include outside websites or platforms which may be linked or interconnectedto the Services. Such outside platforms may have their own terms of service, which control for
all transactions on such platforms.
Colosseum Org LLC, a Delaware limited liability company, operates the Services. It and its
affiliates are referred to in this document as the “operator,” “we,” or “us.”The Blockchain
Blockchain technology, also known as distributed ledger technology (or simply ‘DLT’), is at thecore of our business. Blockchains are decentralized and made up of digitally recorded data in achain of packages called ‘blocks’. The manner in which these blocks are linked is chronological,
meaning that the data is very difficult to alter once recorded. Since the ledger may be distributed
all over the world (across several ‘nodes’ which usually replicate the ledger) this means there isno single person making decisions or otherwise administering the system (such as an operator ofa cloud computing system), and that there is no centralized place where it is located either.
This means that by design, a blockchain’s records cannot be changed or deleted and is said
to be ‘immutable’. This may affect your ability to exercise your rights such as your right toerasure (‘right to be forgotten’), or your rights to object or restrict processing, of your personal
data. Data on the blockchain can’t be erased or changed. Although smart contracts may be used
to revoke certain access rights, and some content may be made invisible to others, it is notdeleted.
In certain circumstances, in order to comply with our contractual obligations to you (such asdelivery of tokens) it will be necessary to write certain personal data, such as your walletaddress, onto the blockchain; this requires you to execute such transactions using your wallet’s
private key.
In most cases ultimate decisions to (i) transact on the blockchain using your wallet address, aswell as (ii) share the public key relating to your wallet address with anyone (including us) rests
with you.

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If you want to ensure your privacy rights are not affected in any way, you should nottransact on blockchains as certain rights may not be fully available or exercisable by you or
us due to the technological infrastructure of the blockchain. The blockchain is available tothe public and any personal data shared on the blockchain will become publicly available.

Individuals under the Age of 18
As per our Terms of Service, individuals under the age of 18 are not permitted to use theServices. As such, we do not knowingly collect, solicit or maintain personal data from anyone
under the age of 18 or knowingly allow such persons to register for the Services.
In the event that we learn that we have collected personal data from an individual under age 18,
we will use commercially reasonable efforts to delete that information from our database. Pleasecontact us if you have any concerns. If you are a parent or guardian and you are aware that yourchild has provided personal data to the Services, please contact us so that we may remove suchdata. Note that we cannot delete information stored on public cryptographic blockchains.

Collecting
Things you and others do and provide.
••

Information and content you provide. We collect the content, communications andother information you provide when you use our Services, including when you create an
account, initiate the use of the Services, create or share content, and message orcommunicate with others. This information may include, but is not limited to:
•

Name

•

Address

•

Email

•

Phone Number•

SSN (or equivalent)•

Financial Information•

Date of Birth•

Citizenship•Payment Information

Information used to verify your identity. If required to help us verify your identity, you
may provide us a copy of your driver’s license, passport or other government issued ID.
If required to help us verify your residence, you may provide us with a utility bill, leaseor other proof of residence. You may also provide us other verification documents, suchas bank statements reflecting the source of funds, to meet U.S. Bank Secrecy Act or antimoney laundering laws, US Treasury department rules or regulations or other legal
requirements. If you seek to invest through an entity or corporation, you may provide us–2–with documentation relating to the entity’s jurisdiction of formation, legal status andownership. By providing the verification information and documents mentioned above,
you also provide us information within those records, which may include characteristics
of protected classifications like your sex, age, national origin, and citizenship.
•

Financial information. In order to transfer funds, you may need to provide us and ourthird-party financial providers or partners with certain account and other payment
information, such as information needed to make payment via ACH, wire, electronic
checks, cryptocurrency, foreign currency or any other payment methods. You may agree
to your personal and financial information being transferred, stored, and processed bysuch third parties in accordance with their respective privacy policies.

•

Your usage. We collect information about how you use our Services, such as the types ofcontent you view or engage with; the features you use; the actions you take; the people oraccounts you interact with; and the time, frequency, and duration of your activities.

•

Information about transactions made on our Services. If you use our Services fortransactions of any kind, we collect information about them.

•Things others do and information they provide about you. We also receive andanalyze content, communications, and information that other people provide when theyuse our Services.

Cookies
We, and our partners, use cookies and similar technologies to give you the best possible content
and experience. Cookies are used to remember you and to collect information about how you
interact with the Services. If you have an account with the Services, we may link this usage datawith other information. You may have the option to either accept or refuse these cookies. If you
choose to refuse, you may not be able to use some portions of the Services.

Device Information
As described below, we collect information from and about the computers, phones, and otherweb-connected devices you use that interact with our Services, and we combine this information
across different devices you use.
Information we obtain from these devices includes:•

Device attributes: information such as the operating system, hardware and software
versions, browser type, app and file names and types, and plugins.

•

Device operations: information about operations and behaviors performed on the device,
such as whether a window is foregrounded or backgrounded, or mouse movements(which can help distinguish humans from bots).

•

Identifiers: unique identifiers, device IDs, and other identifiers.

•

Data from device settings: information you allow us to receive through device settings
you turn on, such as access to your GPS location, camera or photos.

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•

Network and connections: information such as the name of your mobile operator or ISP,
language, time zone, IP address, connection speed and, in some cases, information aboutother devices that are nearby or on your network.

•

Cookie data: data from cookies stored on your device, including cookie IDs and settings.

•

Information necessary to enable push notifications: if you enable push notifications in
our services, we will collect information from your device as may be necessary to enable
such notifications

Information from partners.
•

The Services use Google Analytics and other Google services to gather information about
the computers and devices that connect to them. Although Google Analytics plants acookie on your web browser to identify you as a unique user the next time you visit thissite, the cookie cannot be used by anyone but Google. Google’s ability to use and share
information collected by Google Analytics about your visits to this site is restricted by
the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent
Google Analytics from recognizing you on return visits to this site by disablingcookies on your browser.

•

See the “Third-Party Data Collection” section for additional information on third-party
collection of data.

When using the Services
When using the Services, we may collect and process personal data. The data will be stored indifferent instances. We collect and use this information to provide you the Services and to debug
issues and provide support.
1. On the Blockchain the following data may be stored:• addresses of externally owned accounts•

transactions made; and•token balances.

The data will be stored on the Blockchain. Given the technological design of the blockchain,
this data will become public and it will not likely be possible to delete or change the data at
any given time.
2. In our web servers, we will store the following data:• addresses of externally owned accounts; and•transactions made.

3. Log Data
• the Internet protocol address (“IP address”); and•transaction id/ Hash.

–4–Tracking and Uses
We use the information we have (subject to choices you make) as described below and to provide
and support the Services. Here's how:

Provide, personalize and improve our Services.
We use the information we have to deliver our Services, including to personalize features andcontent.
•

Information across devices: We connect information about your activities on different
devices to provide a more tailored and consistent experience.

•

Product research and development: We use the information we have to develop, test
and improve our Services, including by conducting surveys and research, and testing andtroubleshooting new products and features.

Provide measurement, analytics, and other business services.
The Services use Google Analytics to gather information about their use. Google Analytics
collects information such as how often users visit this site, what pages they visit when they doso, and what other sites they used prior to coming to this site. The Services use the information
we get from Google Analytics only to improve this site. Google Analytics collects only the IP
address assigned to you on the date you visit this site, rather than your name or other identifying
information.

Promote safety, integrity and security.
We use the information we have to verify accounts and activity, combat harmful conduct, detectand prevent spam and other bad experiences, maintain the integrity of our Services, and promote
safety and security.

Communicate with you.
We use the information we have to send you marketing communications, communicate with you
about our Services, and let you know about our policies and terms. We also use your information
to respond to you when you contact us.
Because recognition of the Do Not Track HTTP header feature of your web browser is notstandardized, the Services don’t recognize it for tracking purposes.

Retention
The Services may keep the information we gather about you an unlimited length of time.
To request that information collected about you be deleted, please contact us at the email
provided in this policy. A valid request must include sufficient information to identify yourpersonal data. Note that we cannot delete information stored on public cryptographic
blockchains.

Sharing
The Services only share information about you with others as follows:–5–•We employ other companies to perform functions on our behalf, such as service providers
that assist in the administration of the Services and our advertising and marketing efforts,
identity verification services, data analytics companies that help us target our offerings,
marketing partners, and payment providers. We may need to share your information withthese companies. These partners may access this information so long as you have an
account on the Services.

•

We may also transfer your personal data to a third party as a result of a businesscombination, merger, asset sale, reorganization or similar transaction or to governmental
authorities when we reasonably believe it is required by law or appropriate to respond tolegal process.

•We will also share your information with third-party companies, organizations or
individuals if we have a good faith belief that access, use, preservation or disclosure ofyour information is reasonably necessary to detect or protect against fraud or security
issues, enforce our terms of use, meet any enforceable government request, defend
against legal claims or protect against harm our legal rights or safety. In any such event,and to the extent legally permitted, we will notify you and, if there are material changes
in relation to the processing of your data, give you an opportunity to consent to suchchanges. Any third party with whom we share your data with will be required to provide
the same or equal protection of such data as stated in our Privacy Policy.

•

To operate the Services, we share information about you as needed with our service
providers, including financial institutions, accountants, auditors, lawyers, payment
processors, information technology consultants, advisors, and our affiliates. We only
share information to the extent it is required to fulfill our obligations to you and to
regulators, and to operate the Services. The information is only shared so long as you arehave an account on the Services.

•

We routinely share information with companies closely related to us – our “affiliates” –for certain purposes under this policy. Our affiliates will be entitled to enjoy our rights
under this Privacy Policy and we will be responsible for our affiliates’ conduct related
thereto.

•We may share information about you with US, state or international regulators, SEC, or
FINRA where we believe doing so is required or appropriate to comply with any laws,
regulations or other legal processes or law enforcement requests, such as court orders,search warrants, or subpoenas.

•

The Services may contain links to third party websites and may redirect you to third party
websites. These sites include, among others, service providers who have a relationshipwith the operator. Third party websites are not under our control, and we are notresponsible for any third party websites, or the accuracy, sufficiency, correctness,reliability, veracity, completeness, or timeliness of their information, links, changes or
updates. The inclusion or access to these websites does not imply an endorsement by theoperator, or of the provider of such content or services, or of any third party website.
Please be aware that when you enter a third party website, any information you provide,–6–

including financial information, is subject to the terms of use and privacy policy of thatwebsite.

Opt–Out
If you wish to stop receiving marketing or promotional communications or to opt out of use ofyour information for the purposes described in this policy, please follow the opt-out instructions,such as clicking “Unsubscribe” (or similar opt-out language), in those communications. You canalso contact us at hello@colosseum.org to opt out. Despite your indicated email preferences, we
may send you service-related communications, including notices of any updates to our terms ofservice or this policy. Please understand that you will not be allowed to opt–out of certain
communications required to comply with applicable laws, rules and regulations or other legal
and related notices concerning your relationship to the Services.

Security
We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we
limit access to your personal data to those employees, agents, contractors and other third parties
who have a business need to know. They will only process your personal data on our instructions
and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify
you and any applicable regulator of a breach where we are legally required to do so.

Contact
If you have comments or questions about the privacy policies of the Services, contact
hello@colosseum.org.

Changes
The Services may change their privacy policy at any time. Check this page for the latest.

CCPA Addendum – Compliance
You agree to do your respective parts to comply with the California Consumer Privacy Act andits regulations, consistent with the operator’s role as a “service provider”, and not as a “third
party”, under that law.

Cooperation
Whenever it is feasible and legal to do so, both the operator and You will give the other prompt
notice of user rights requests, regulatory inquiries, and other communications under the
California Consumer Privacy Act. Both sides agree to cooperate in good faith to respond to andhonor such communications, and to meet other obligations under the California Consumer
Privacy Act.

Prohibitions
The operator may not:–7–•sell personal information collected from consumers covered by the California Consumer
Privacy Act that You disclose to the operator•

retain, use, or disclose such information for any purpose other than for the specificpurpose of performing the services in the Terms of Service, including retaining, using, ordisclosing such information for a commercial purpose other than providing the services
Terms of Service•

retain, use, or disclose such information outside of a direct business relationship between
the operator and You

Certification
The operator understands the restrictions in Prohibitions and will comply with them.

Minimization
Both You and the operator agree to limit use of personal information covered by the California
Consumer Privacy Act to that reasonably necessary and proportionate to achieve the purpose of
the Terms of Service, consistent with the meaning of “business purpose” under that law.

Subcontracting
The operator agrees to ensure that each subcontractor that processes Your information covered by
the California Consumer Privacy Act will also qualify as a “service provider”, and not as a “third
party”, under that law.

Personal Information
Of the following categories of personal information:• identifiers (such as contact information, government IDs, cookies, etc.),•

information protected against security breaches (such as your name and financial account,driver’s license, social security number, user name and password, health/medical
information),•

protected classification information (like race, gender, ethnicity, etc.),•other information, including commercial information, Internet/electronic activity,
geolocation, audio/video data, professional or employment related information, education
information, biometrics, and inferences from the foregoing;

The operator has collected and used for a business purpose such data within the last 12 months.
The operator has not sold or disclosed any such data within the last 12 months, as of the date ofthis agreement.

Previously Submitted Information
To request access or changes to information previously submitted, please contact the operator at
the address provided above (under the “Contact” heading).

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Conflicts
If the terms of this addendum conflict with terms of the Terms of Service or Privacy Policy, theterms of this addendum take precedence.

GDPR / EU Addendum
Transferring Your data outside of the EU
The data mentioned in this document will be stored in the United States.
But, when interacting with the blockchain, as explained above in this Policy, the blockchain
is a global decentralized public network and accordingly any personal data written onto
the blockchain may be transferred and stored across the globe.

Your Rights as a Data Subject
You have certain rights under applicable legislation, and in particular under Regulation
EU 2016/679 (General Data Protection Regulation or ‘GDPR’). We explain these below. You canfind out more about the GDPR and your rights by accessing the European Commission’s
website.

Right Information and access
You have a right to be informed about the processing of your personal data (and if you did notgive it to us, information as to the source). This document provides that information, and you
may contact us for additional information.

Right to rectification
You have the right to have any inaccurate personal information about you rectified and to have
any incomplete personal information about you completed. You may also request that we restrict
the processing of that information. The accuracy of your information is important to us. If you do
not want us to use your Personal Information in the manner set out in this Privacy Policy, or needto advise us of any changes to your personal information, or would like any more information
about the way in which we collect and use your Personal Information, please contact us at theabove details.

Right to erasure (right to be ‘forgotten’)You have the general right to request the erasure of your personal information in the following
circumstances:othe personal information is no longer necessary for the purpose for which it wascollected;oyou withdraw your consent to consent based processing and no other legal justification
for processing applies;o

you object to processing for direct marketing purposes;owe unlawfully processed your personal information; and

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o

erasure is required to comply with a legal obligation that applies to us.

But, when interacting with the blockchain we may not be able to ensure that your personal
data is deleted. This is because the blockchain is a public decentralized network andblockchain technology does not generally allow for data to be deleted and your right toerasure may not be able to be fully enforced. In these circumstances we will only be able toensure that all personal data that is held by us is permanently deleted.
We will proceed to comply with an erasure request without delay unless continued retention isnecessary for:o

Exercising the right of freedom of expression and information;oComplying with a legal obligation under EU or other applicable law;o

The performance of a task carried out in the public interest;oArchiving purposes in the public interest, scientific or historical research purposes, or
statistical purposes, under certain circumstances; and/oro

The establishment, exercise, or defense of legal claims.

Right to restrict processing and right to object to processing
You have a right to restrict processing of your personal information, such as where:oyou contest the accuracy of the personal information;owhere processing is unlawful you may request, instead of requesting erasure, that we
restrict the use of the unlawfully processed personal information;o

we no longer need to process your personal information but need to retain yourinformation for the establishment, exercise, or defense of legal claims.

You also have the right to object to processing of your personal information under certain
circumstances, such as where the processing is based on your consent and you withdraw thatconsent. This may impact the services we can provide and we will explain this to you if you
decide to exercise this right.
But, when interacting with the blockchain, as it is a public decentralized network, we will
likely not be able to prevent external parties from processing any personal data which has
been written onto the blockchain. In these circumstances we will use our reasonableendeavors to ensure that all processing of personal data held by us is restricted,
notwithstanding this, your right to restrict to processing may not be able to be fully
enforced.

Contact
If you have comments or questions about the privacy policies of the Services, contact
hello@colosseum.org.

Right to data portability
Where the legal basis for our processing is your consent or the processing is necessary for the
performance of a contract to which you are party or in order to take steps at your request prior to– 10 –

entering into a contract, you have a right to receive the personal information you provided to us
in a structured, commonly used and machine-readable format, or ask us to send it to anotherperson.

Right to freedom from automated decision-making
We do not use automated decision-making, but where any automated decision-making takes
place, you have the right in this case to express your point of view and to contest the decision, as
well as request that decisions based on automated processing concerning you or significantly
affecting you and based on your personal data are made by natural persons, not only bycomputers.

Right to object to direct marketing (‘opting out’)
You have a choice about whether or not you wish to receive information from us. We will notcontact you for marketing purposes unless:oyou have a business relationship with us, and we rely on our legitimate interests as thelawful basis for processing (as described above)oyou have otherwise given your prior consent (such as when you download one of ourguides)

You can change your marketing preferences at any time by contacting us on the above details.
On each and every marketing communication, we will always provide the option for you to
exercise your right to object to the processing of your personal data for marketing purposes(known as ‘opting-out’) by clicking on the ‘unsubscribe’ button on our marketing emails or
choosing a similar opt-out option on any forms we use to collect your data. You may also opt-out
at any time by contacting us on the below details.
Please note that any administrative or service-related communications (to offer our services, ornotify you of an update to this Privacy Policy or applicable terms of business, etc.) will solely bedirected at our clients or business partners, and such communications generally do not offer an
option to unsubscribe as they are necessary to provide the services requested. Therefore, please
be aware that your ability to opt-out from receiving marketing and promotional materials does
not change our right to contact you regarding your use of our Services or as part of a contractual
relationship we may have with you.

Right to request access
You also have a right to access information we hold about you. We are happy to provide you withdetails of your Personal Information that we hold or process. To protect your personal
information, we follow set storage and disclosure procedures, which mean that we will require
proof of identity from you prior to disclosing such information. You can exercise this right at any
time by contacting us on the above details.

Right to withdraw consent
Where the legal basis for processing your personal information is your consent, you have theright to withdraw that consent at any time by contacting us on the above details.

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Raising a complaint about how we have handled your personal data
If you wish to raise a complaint on how we have handled your personal data, you can contact us
as set out above and we will then investigate the matter.

How to contact the appropriate authority
Should you wish to report a complaint or if you feel that we have not addressed your concern ina satisfactory manner, you may contact the Information Commissioner’s Office in yourjurisdiction.

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