Effective Date: 11-20-2025

Note: This Privacy Policy is a general user-facing policy for Epicentral Labs' public Interfaces. Members, Core Team Members, auditors, and contractors may be subject to additional obligations under the Operating Agreement of Epicentral Labs, DAO LLC and related agreements, which control in the event of any conflict.

Privacy Policy

1. Scope

This Privacy Policy describes how Epicentral Labs, DAO LLC ("Epicentral Labs," "we," "us," or "our") handles information in connection with your use of our public Interfaces (websites, dApps, APIs, and smart-contract frontends).

This Policy applies to general users of the Interfaces.

Members, Core Team Members, auditors, service providers, and contractors may be subject to additional confidentiality, data, and record-keeping obligations under:

the Operating Agreement;
Membership Joinder Agreements;
NDAs or service agreements.

In case of any conflict between this Policy and those agreements, the latter control for the affected parties.

2. Data We Collect

Because our Interfaces are non-custodial and primarily on-chain, we aim to minimize collection of personal data.

2.1 On-Chain and Technical Data

When you use our Interfaces, we may automatically receive:

Public blockchain data, such as your Solana wallet address, transactions you broadcast, and program interactions;
Device and browser information, such as browser type, operating system, and approximate language/locale;
Usage analytics, such as pages visited, time spent, and basic interaction events, via privacy-respecting tools (for example, Plausible or similar) where configured;
IP address and approximate geolocation, to the extent necessary to operate the site, prevent abuse, or implement geofencing and sanctions-screening controls consistent with the Operating Agreement and applicable law.

2.2 Information You Voluntarily Provide

You may voluntarily provide additional information, for example:

when contacting us by email or form;
when participating in governance discussions or community channels;
if you are a Member, Core Team Member, or contractor providing details required for tax or legal compliance (for example, W-9/W-8 forms, legal name, or service address) under Article XII of the Operating Agreement.

For ordinary users, we do not require personal identity documents or legal names to interact with the protocol.

3. Data We Do Not Collect (for General Users)

For typical use of the Interfaces (e.g., visiting the site and connecting a self-custodied wallet), we do not:

request or store private keys, seed phrases, or wallet passwords;
intentionally collect traditional financial account numbers (bank accounts, credit cards, etc.);
require government-issued identification, Social Security numbers, or similar PII unless required for a specific regulated service or legal obligation;
maintain a custodial account or off-chain ledger of your balances.

If you receive payments directly from the Company as a contractor, Member, or core contributor, additional information may be required for tax and reporting purposes (for example, IRS Forms 1065, 1099, K-1, W-8/W-9), as described in Article XII of the Operating Agreement.

4. Cookies and Local Storage

We may use cookies or local storage for:

basic site functionality (for example, language settings, dark mode, UI preferences);
remembering your wallet connection status or network selection;
privacy-respecting analytics.

You can disable cookies in your browser, but some minor UX features may not function optimally. Core protocol interactions (on-chain transactions) remain available as long as you can access the front-end and your wallet.

5. How We Use Information

We may use the information we collect to:

operate, maintain, and improve the Interfaces;
monitor protocol usage at an aggregate level (not linked to real-world identities);
detect, prevent, or respond to fraud, abuse, or security incidents;
comply with sanctions, AML, and other regulatory obligations (for example, blocking access from certain IP ranges or sanctioned jurisdictions);
generate high-level, anonymized metrics for DAO governance and transparency reports;
fulfill tax, accounting, or legal obligations where Epicentral Labs is required to file information returns or maintain records under U.S. or Wyoming law.

We do not sell personal data to third parties.

We may share limited information:

With service providers (for example, hosting, analytics, or security vendors) who process data on our behalf under appropriate contractual safeguards;
With legal or regulatory authorities, if required by law, subpoena, court order, or to protect our rights or users;
With tax and regulatory bodies, where required for filings such as IRS or Wyoming state requirements relating to Members or contractors;
With auditors or legal counsel, as reasonably necessary to obtain professional advice and compliance review.

We do not share your private keys or seed phrases with anyone, and we will never ask you to disclose them.

7. Data Retention

On-chain data is recorded on the Solana blockchain and is immutable; we cannot alter or delete those records.
Off-chain records (for example, analytics logs, accounting records, Member and contractor documentation) are retained only as long as reasonably necessary:
- to provide services;
- to satisfy legal, tax, and regulatory requirements (often at least seven years for accounting/tax records);
- to maintain security logs and incident records.

Where feasible, we strive to aggregate or anonymize data rather than retain user-identifiable records.

Depending on your jurisdiction, you may have certain rights regarding your personal information, such as:

the right to request access to, correction of, or deletion of off-chain personal data we hold about you;
the right to restrict or object to certain processing;
the right to data portability.

To exercise these rights with respect to off-chain data, you may contact us at:
thelazysol@gmail.com

Important: On-chain records cannot be altered or erased by us. Your blockchain transactions are immutably stored on the Solana network and are outside our ability to modify.

9. Security Measures

We take reasonable measures to protect off-chain information we control, including:

limiting access to internal systems to authorized personnel;
using encrypted channels (HTTPS/TLS) for data in transit;
maintaining private, secure repositories for sensitive member and operational records, including any confidential channels explicitly excluded from public archiving under the Operating Agreement (for example, certain "Support" or "Operations" channels).

However:

No system is entirely secure, and we cannot guarantee absolute security of any data transmitted to or from our services.
You are responsible for securing your own devices, browsers, and wallets.

10. International Data Transfers

If you access the Interfaces from outside the United States, you understand that information may be processed in the U.S. or other jurisdictions with different data-protection laws than your own.

Where required, we will take steps to ensure an appropriate level of protection, consistent with applicable law.

11. Children's Privacy

The Interfaces are not directed to children under the age of 18, and we do not knowingly collect personal information from children. If you believe that a minor has provided us with personal data, please contact us so we can take appropriate action.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we do:

we will revise the "Effective Date" at the top; and
we may provide notice via our website, governance forums, or Realms references.

Your continued use of the Interfaces after any update constitutes acceptance of the revised Policy.

13. Contact

For privacy questions, requests, or concerns, you may contact:

Epicentral Labs, DAO LLC
Email: thelazysol@gmail.com
Mailing: 30 N Gould St Ste R, Sheridan, WY 82801

This Privacy Policy is intended to be consistent with and subordinate to the Operating Agreement of Epicentral Labs, DAO LLC and its Exhibits. In the event of any conflict, the Operating Agreement (as duly amended under its own procedures) will control.

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