This privacy policy describes the information Anonyome Labs, Inc. collects and how we use it within the applications, services, and websites. In addition to Anonyome Labs, Inc., all subsidiaries of Anonyome Labs, Inc. also adhere to the content in this privacy policy.

Shalibaron Incorporation and its affiliates (hereinafter, “Shalibaron”, “we”, or “us”) created this Privacy Policy ("Policy") to demonstrate our commitment to the privacy and protection of information that may be used directly or indirectly to identify you (“Personal Data”). This Policy governs Personal Data that you submit to us, or that we may collect online or offline about you, such as Personal Data collected and received on our website, available at https://www.shalibaron.com/, together with any other websites owned, operated or controlled by us (collectively referred to as the “Website”) and related to your use of our web services and mobile applications (collectively referred to as the “Service” or “Services”). We provide the Website and our Services to you subject to the following conditions, which are subject to, and incorporated by reference into, our Terms and Conditions.

For the purposes of this Policy, Shalibaron is a controller (i.e., responsible party) for the practices described in this Policy. Additionally, this Policy does not apply to the extent we process Personal Data in the role of a processor or service provider (as applicable) on behalf of our business customers. For more information about the privacy practices of a Shalibaron business customer or a customer affiliate, please contact the respective business customer directly. We are not responsible for the privacy or data security practices of our business customers, which may differ from those set forth in this Policy. We believe privacy is the power to selectively reveal oneself to the world. We provide our services and build our apps with a single intent: Give the user control. This philosophy guides everything we do.

We will only ask you for personal information necessary to use our services. In some cases, this is required by industry or government regulations.

We mandate that you use our applications and services in a lawful and respectful way. We refer to this as “responsible anonymity”.

We strive to only request data that's useful and required, not to hold that data longer than necessary, and to give you as much control as possible over your data.

We do not sell, trade, or exchange prsonal information with third parties, and never will. When you use any of our Services, we may receive, and collect certain Personal Data. Some of this Personal Data is automatically generated and collected by us when you use our Services. Other Personal Data is provided to us at your option, or at our request, or collected about you by third parties. Below are instances of the Personal Data that we collect, categorized based on their type, and how they come into our possession. We collect Personal Data about you that you choose to provide us, or that is generated by your device, when you sign up or register for Services that require registration ("User Information"), including the following:

Registration information, such as your date of birth, gender, username and password, language, address, email or phone number;

Profile information, such as your name, social media account information, and profile image;

Payment and purchase data, such as PayPal or other third-party payment information (where required for the purpose of payment), credit or debit card type, expiration date, and certain digits of your card number (for security, we never store your full card number), ZIP/postal code, mobile phone number, details of your purchase and payment history;

Your opt-in choices with respect to the features and functions of our Services and your communication preferences;

Information you submit to verify an account;

Information in correspondence you send to us, such as support tickets, feedback and complaints, through phone, email or other means;

Information you share through surveys or your participation in promotional activities or questionnaires.

When you use our Services, data is generated from your use ("Usage Data"). Generally, there are two kinds of Usage Data—(a) technical or "log" data that is usually automatically generated by the operating systems, software, programs or devices involved in your use of our Services, and (b) use data, which is data that records and reflects how you interact with or use our Services, and the history of such use or interaction.

Our reception and collection of Usage Data is usually automatic. We, or our service providers, may also use such data to support your use of our Services, or to improve our Services. When you access or use our Services through a device, we may receive and collect the following technical data that is automatically generated from your access or use:

• Uniform Resource Locator (URL) information;
• Internet Protocol (IP) address of your device;
• Information about your device such as:
  • unique device identifiers or IDs;
  • device model, brand and version;
  • mobile carrier and internet service provider;
  • network connection type;
  • operating system;
  • browser type;
  • information about network and device performance;
  • language, time zone setting and location;
  • version of the Service app;
  • any information that enables digital rights management;
  • diagnostic data, connectivity data, application usage, your setting preferences and any errors or event failures;
• Information about your device to enable connection with third party devices or applications:
  • devices on your wifi or other networks;
  • devices made available by your operating system when connecting via Bluetooth plugin, and installation;
  • and information about Shalibaron's partner applications.

We may receive and collect data that tells us how you use and interact with our Services, and how we can improve our Service in light of this information. Such Usage Data includes the following:

• Content interaction information, such as content downloads, streams and playback details, such as duration and number of streams and downloads;
• Network details showing streaming and download quality, including information about your internet service provider;
• Purchase and content use history, which we may use to provide recommendations;
• URL clickstream with respect to our Services, including data and time of URL access, products and content you viewed or searched for, page response times, download errors, length of visits to certain pages, and page interaction information;
• Third party services, devices and applications usage, in connection with our Services;
• Content you post to any part of our Services;
• Voice data (when voice features are available);
• Survey or questionnaire response information.

We sometimes work with partners in delivering our Services to you. As such, we may receive and collect Personal Data from our partners, such as when you use our Service through or in connection with our partners. The following are some examples of Personal Data that we may obtain from third parties:

• Authentication partners: If you log in or otherwise obtain access to our Services through a third party service, we will receive your Personal Data from such third party service to enable your access to our Services.
• Linked third party applications, websites or devices: If you connect to a third party application, website or device through a Shalibaron account, we may collect, with your consent where Shalibaron is acting as a controller and where required by applicable law, certain Personal Data about you from such third parties to enable such connection. The third party apps, websites or devices may include social media, mobile phones, audio devices, smart watches, smart systems on automobiles, game consoles, or voice assistants.
• Technical service partners: We may work with third party partners who provide us with technical assistance or to deliver or improve certain content or features of our Service. We may obtain Personal Data about you from these partners, which are required to resolve technical issues that you may encounter, or to deliver certain feature or content.
• Payment and purchase partners: When you make a purchase on or through our Service, we may obtain payment information or other Personal Data about you from these payment or purchase partners to process and enable such purchase.
• Advertisement partners: We may receive certain Personal Data about you from our advertising or marketing partners, such as your user preference, email address and device ID, for advertising and marketing purposes.
• Other users of the Service: We may receive Personal Data about you from other users of the Service, in our course of providing customer service, or other services.

No cookies are needed to use the Shalibaron services. So we don't use them for those services. However, cookies are necessary for the technical operation of our website and Web3 browser (for DApps). When we have to use cookies, we choose cookies that don't hold any user-specific information and are essential for the operation of the product or service. We collect or use your Personal Data in order to perform our contractual obligations, to comply with the law, or to protect certain vital public interests, as described in greater detail below. In other circumstances, we will only collect or use your Personal Data with your consent, or when we have a legitimate interest in doing so.

In the following, we explain why we use or collect certain Personal Data:

• Purchase and delivery of content or product: We collect and use your Personal Data such as User Information, including your payment and purchase data, to receive, process and complete your orders or purchases of content or products made available through our Services.
• Troubleshooting, diagnosis, technical support, and Service improvement: We collect and use your Personal Data, usually your Usage Data such as technical data, to diagnose and fix some of the technical issues you may encounter in using our Services. We may also use such information to improve the performance and functionality of our Services. In some instances, Personal Data may also be used to develop new features, functions, technologies and otherwise improve our Services.
• Discharging legal obligations: We collect and use your Personal Data, usually your User Data, when such use or collection is required for us to comply with certain legal obligations, such as those prescribed under statutes or regulations, contractual obligations with third parties (such as our agreements with licensors of certain copyrighted content) and lawful or legitimate requests from law enforcement.
• Enforcing intellectual property rights and other rights: We collect and use your Personal Data in order to enforce intellectual property rights belonging to us and our licensors, or to prosecute or defend legal claims.
• Fraud detection and prevention: We collect and use your Personal Data to detect and prevent fraud, including fraudulent payment or fraudulent use of your account, or our Services.
• Recommendations and personalization: We collect and use Personal Data in order to deliver recommendations and personalized Services to you.
• Business reporting, planning and forecasting: We collect and analyze Personal Data, such as User Information and Usage Information, in order for us to understand our own business. Such information is necessary for us to evaluate, plan and forecast our business.
• Marketing, promotion and advertisement: We collect and use your Personal Data for marketing, promotional and advertising purposes. In particular, we may collect and use your Usage Data for interest-based or targeted advertising.
• Use of location data: We collect and use your location data, such as your physical address, IP address, zip code, city or region, or other information obtained from the GPS or other location-aware technologies, in order to set up your account, deliver to you products or services that you purchased, make local announcements and to deliver more relevant or region-specific content and services to you. We shall collect and use your location data where such collection and use is required for us to discharge our contractual obligations.

Shalibaron relies on the following legal grounds for the collection, processing, and use of your Personal Data:

• As necessary to provide a service or perform a transaction, such as when we respond to your request;
• Consent, where you have provided consent as appropriate under applicable law, such as for direct marketing or certain cookies;
• As necessary for legitimate interests, such as when we act to maintain our global business generally, including maintaining the safety and security of the Website;
• Compliance with legal obligations, particularly in the area of labor and employment law, social security and protection law, data protection law, tax law, and corporate compliance laws.

There is legitimate interest to process your Personal Data when the collection or use of certain Personal Data brings a clear benefit to you, to us or a third party, when such collection or use has little risk of infringing your privacy, and when it is reasonable to expect that the Personal Data would be collected or used in that way. Whether there is a legitimate interest is context specific, and you may contact Shalibaron as stated in the “Contact Us” section below to request further information about our legitimate interest in processing your Personal Data, to the extent applicable.

The provision of your Personal Data is partly a statutory requirement and partly a contractual obligation. Other than as described in this Policy, we do not sell Personal Data unless we have your consent or as otherwise permitted by applicable law. Otherwise, we may disclose Personal Data to third parties in the following ways:

• Transactions involving third parties: We sometimes make available through our Services products, content, services or applications provided by third parties. These third parties may offer content or products that you directly purchase through our Services. We may also offer services, content or products jointly with third-parties. We may disclose Personal Data related to these transactions to the third parties who are involved in these transactions in order to process and complete these transactions.
• Third party service providers: We engage and employ third parties to perform certain functions or services on our behalf. These third parties may receive Personal Data required to perform their functions or services, and may not use such information for other purposes. For instance, Personal Data may be used by third party application, services and devices such as social media applications, audio and mobile devices, smart watches, smart systems on automobiles, or voice assistants. Personal Data may also be used by our various partners to provide on our behalf customer support, technical support and assistance, marketing, promotions and advertisements.
• Affiliated Companies: We may disclose Personal Data to subsidiaries, affiliates or strategic partners as needed to provide our Services and generally as necessary in the administration of Shalibaron's business.
• Legal compliance and protection: We disclose Personal Data where we believe in good faith that such disclosure is necessary to comply with the law, legitimate law enforcement requests, and our legal obligations arising from our Terms of Use and contracts with others. We may also disclose Personal Data in order to protect or vindicate the rights and property of us, you, and others. For instance, we may disclose Personal Data to enforce intellectual property rights, to protect the safety of another person, or to prevent fraud and reduce credit risks.
• Corporate transactions: As Shalibaron grows, we may purchase, acquire or merge with other businesses or services. Information and data about users of our Services, including Personal Data, may be disclosed in a corporate transaction.
• Other situations with your consent: If we need to disclose your Personal Data to third parties in circumstances that are not mentioned above, you will be notified about such disclosure, and you will have an opportunity to refuse such disclosure, or elect not to disclose.

The websites may contain links to third party websites. When you click on a link to any other website or location, you will leave our website and go to another site, and another entity may collect personal information or anonymous data from you. We have no control over, do not review, and cannot be responsible for these third-party websites or their content. By submitting personal information through our websites, Applications or Services, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy. If you do not agree with our policies and practices, you can choose to stop using our websites, Applications and Services.

A Note to Users Outside of the United States

If you are a non-U.S. user of our websites, by visiting the websites and providing us with data, you acknowledge and agree that your personal information may be processed for the purposes listed in this Privacy Policy. In addition, your personal information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of personal information may be less stringent than the laws in your country. By providing your data, you consent to such transfer. The privacy laws applicable in different jurisdictions confer certain rights over your Personal Data. The rights available to you depend on our reason for processing your Personal Data and the requirements of applicable law. Depending on where you are located, you may have the following rights:

• Access: The right to be informed of and request the Personal Data that we collect and process about you.
• Correction: The right to request that we correct or amend your Personal Data where such information is inaccurate or incomplete.
• Deletion: The right to request that we delete certain Personal Data that we collect about you.
• Restriction and objection: The right to restrict, object or request that we stop collecting or processing certain Personal Data.
• Portability: The right to request a copy of your Personal Data in electronic format, and to transmit that data to another's device.
• Withdraw consent: The right to withdraw consent where we rely on your consent to process your Personal Data. Such withdrawal of consent will not affect the lawfulness of the processing prior to the consent withdrawal.
• Right to prohibit the sale or sharing of Personal Data: At this time, Shalibaron is not subject to the laws that require recognition of the right to prohibit the sale or sharing of Personal Data; however, you may opt-out of the sharing (in this context, “share” means use of your Personal Data for cross-contextual behavioral advertising) of your Personal Data for third party marketing by following the instructions listed below.
• Automated decision-making and profiling: The right not to be subject to automated decision making, such as profiling, when such decisions have legal or other significant effects on you.
• Right to non-discrimination: The right not to be discriminated against for exercising your rights listed herein.

In addition to the rights listed above, you may also have the following options available:

• You can update, add or delete information about you in your account information or settings page found on our Websites or mobile apps.
• As described above, you can disable cookies by adjusting your browser preferences. As noted, you may not be able to access certain functions and features of the Website if you disable cookies, some of which are essential to your use of our Services.
• You can manage your privacy preferences, advertising preferences or opt-out of certain data usage described in this Policy, by adjusting your settings on our Website and mobile apps.
• You can manage your privacy preferences, and disable certain tracking features such as GPS tracking, and targeted advertising features, by adjusting your mobile device settings.
• You can opt-out of marketing or advertising emails that we may send you by clicking the "unsubscribe" link that may be available on our Website or emails, or by following the instructions noted in our Website or emails.

Your rights and our responses will vary based on your state of residency. Please note that you may be located in a jurisdiction where we are not obligated, or are unable, to fulfill a request. In such a case, your request may not be fulfilled.

We do not discriminate against individuals who exercise any of their rights described in this Policy.

However, we may require use of your Personal Data to provide access to the Services. Therefore, when you exercise your deletion right, in particular, you may lose access to certain aspects of the Services that require your Personal Data.

Shalibaron collects very little information about our users. As a result, it might be difficult to verify whether a request regarding privacy rights has actually been submitted by the person concerned. We therefore encourage you to delete your personal data by uninstalling the Shalibaron app. Note that this doesn’t remove your account information on public blockchains. For instance, this doesn't remove Ethereum account information, which has a history on the Ethereum blockchain.

Verification Process

Only you, or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Data.

If you designate an authorized agent to submit requests to exercise certain privacy rights on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.

The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Our verification process may also include a request for additional information to confirm your identity or your authorized agent’s identity (such as your name, email address and date of birth) or to obtain proof that you have given your authorized agent permission to act on your behalf. If our verification process is successful, we will respond to your request within the time and in the manner required by applicable law. If we cannot validate the identity of you and/or your authorized agent or obtain proof that you have given your authorized agent permission to act on your behalf, we will attempt to contact you to inform you. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm that the Personal Data relates to you.

We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We will deliver our written response by mail or electronically, at your option. For data portability requests, we will select a format to provide your Personal Data that is readily usable and should allow you to transmit the Personal Data from one entity to another entity without hindrance, such as by electronic mail communication. Further, if you would like to appeal any decision we make about your request, you may contact us as stated in the “Contact Us” section below. How long we retain your Personal Data depends on the context in which, and purposes for which, we collected it. We only keep your Personal Data for as long as necessary to fulfill the purposes described in this Policy, for which such Personal Data is collected, or as otherwise permitted under applicable law.

When we have no ongoing business need to process your Personal Data, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible. We are committed to protecting your Personal Data. To this end, we implement the appropriate technologies and policies, such as encryption, rigorous authentication measures, anonymization of your data where appropriate, and strict retention and deletion policies to prevent unauthorized and unintended access, use and disclosure of your Personal Data.

Do note that the protection of your Personal Data is a joint effort between you and us. We encourage you to protect your account by using a strong password, and keeping that password confidential and secure. Remember to log out once you have finished using our Services.

We are also committed to improving our privacy protection and data collection practices. In this vein, we welcome any concerns, feedbacks or recommendations that you may have with our data collection practices, which you can communicate to us through our customer support or by contacting as described in the “Contact Us” section below. In course of providing our Services to you, we may disclose your Personal Data to our affiliates or partners in other countries where privacy and data protection laws are less rigorous than those that apply where you live, or which govern our business.

When this happens, we take certain measures to raise or enhance the security of the data transferred to these countries. For instance, we may employ standard contractual clauses with these international partners, and require them to accord your Personal Data with safeguards and protections equivalent with those applicable in the European Union or the United Kingdom.

We will not knowingly transfer your Personal Data to places where there are no adequate controls or legal safeguards possible to ensure the protection and security of such data. We may make changes to this Policy from time to time. The revised Policy will be effective immediately at the time of posting, unless a later effective date is expressly stated therein. We will also revise the "Last updated" date stated above. Where such changes are significant or material, we will bring such changes to your attention through a prominent notice that we consider appropriate, such as by sending you an email or in-app notification.

It is your responsibility to periodically review this Policy. Users are bound by any changes to this Policy by using our Services after such changes have been first posted. If you do not agree to the new posted Policy, your only remedy is to discontinue use of the Website. For any questions or assistance with the content or implementation of this Policy, you should address to help@shalibaron.com.