Privacy Policy

1. Introduction and Who We Are

Priime is the controller of the personal data described in this Policy. We process personal data in accordance with applicable data protection law, which may include the EU General Data Protection Regulation (GDPR), the UK GDPR, and U.S. state privacy laws. This Policy forms part of, and should be read with, our Terms of Service at https://priime.finance/terms.

2. Personal Data We Collect, Why, and the Legal Basis

We collect and process the following categories of personal data.

Information you provide to us:

• Contact and communications data, such as your name, email address, and the content of messages you send us by email or through social channels.
• Wallet addresses and on-chain identifiers you submit or connect.
• Job application information, where you apply for a role.
• A beta invitation request: the email address you leave for an invitation, and the vault or page you left it from.

Information collected automatically:

• Your public blockchain address and publicly available on-chain information associated with it, including transaction history, when you connect a wallet or interact with the Services.
• Technical and usage data, such as IP address, approximate location derived from IP, device and browser information, dates and times of access, the pages and features you use, and the API endpoints you call.
• Cookies, local storage, and similar technologies, as described in Section 8.
• Recordings of your sessions on priime.finance, where you accept them, as described in Section 8.
• Records of the priced decisions shown on build.priime.finance, as described in Section 8.

Why we process it, and our legal bases:

• To provide, operate, and secure the Services and perform our agreement with you (performance of a contract).
• To maintain the security, stability, and integrity of the Services, to prevent fraud and abuse, and to improve and develop the Services (legitimate interests).
• To screen for sanctions and legal-eligibility purposes and to comply with our legal obligations (legal obligation and legitimate interests).
• To run our data room: to control access, answer the questions you send, and record entries (legitimate interests).
• To count how often priced decisions are shown and their pricing details opened, and to check those prices against what the markets did afterwards (legitimate interests). The pricing model learns from market data, not from information about you.
• To set analytics cookies and record sessions, where you accept them (consent, which you may withdraw at any time through Cookie settings).
• To send you updates or marketing where you have asked us to (consent, which you may withdraw at any time).
• To send you a beta invitation, where you have asked for one (consent, which you may withdraw at any time).

We keep beta invitation requests in our waitlist database, and each new request notifies our team. To be removed from the list, write to privacy@priime.finance.

We do not sell your personal data.

3. Blockchain Data Is Public and Permanent

When you connect a wallet or submit a transaction, you interact directly with public blockchain networks. Your wallet address, balances, and transactions are visible to anyone and are recorded on a public ledger that is, by design, permanent and immutable. Priime cannot edit, delete, or restrict on-chain data, and rights that would otherwise allow correction or erasure cannot be applied to information recorded on a blockchain. You should consider this before transacting.

4. Wallets and Third-Party Services

You access the Services using a third-party wallet that you control. Your use of any wallet is governed by that provider's own terms and privacy policy, and we expressly disclaim liability for the acts or omissions of, or your use of, any third-party wallet, including any use or disclosure of your personal data by it. The Services also rely on third-party infrastructure such as blockchain networks, node and RPC providers, oracles, and analytics and security providers; their processing of data is governed by their own policies.

5. How We Share Personal Data

We may share personal data with: service providers and processors that help us operate, secure, and analyze the Services, such as hosting, content-delivery, analytics, blockchain-analysis, and sanctions-screening providers; professional advisers such as auditors, lawyers, and accountants; and authorities or other parties where we believe in good faith that disclosure is required by law, to enforce our Terms, or to protect the rights, safety, or property of Priime, our users, or others. We may also share data in connection with a corporate transaction such as a merger, financing, or acquisition. We require our processors to protect personal data and to process it only on our instructions.

6. International Transfers

We may transfer, store, and process personal data in countries other than the one in which you are located, including countries that may not provide the same level of data protection as your own. Where we transfer personal data out of the EEA or the UK, we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses, the UK addendum to those clauses, or an applicable adequacy decision.

7. Your Rights

Depending on where you live, you may have the right to: access the personal data we hold about you; request correction of inaccurate data; request erasure in certain circumstances; restrict or object to certain processing; request portability of data you provided to us; withdraw consent where we rely on it; opt out of marketing; and lodge a complaint with your supervisory authority. U.S. state residents may have additional rights, including the right to appeal a decision on a request. To exercise a right, contact us at privacy@priime.finance. We may need to verify your identity before acting, and some rights are limited, including for information recorded on public blockchains as described in Section 3.

8. Cookies and Similar Technologies

We use cookies, local storage, and similar technologies to operate the Services, keep them secure and stable, remember your preferences, and measure usage to improve the Services. Strictly necessary cookies are required for the Services to function.

On priime.finance and build.priime.finance we measure usage with PostHog, an analytics provider. A cookie card asks for your choice the first time analytics runs, and your choice applies to both sites:

• Before you choose, and after you decline, PostHog stores nothing on your device: no cookie, no local storage, and no session storage. Visits are measured without cookies, with a new random identifier on each page, and no session is recorded.
• If you accept, PostHog stores a cookie, shared across priime.finance subdomains, and local storage, so it can recognize your browser across pages and visits, and it can record your sessions on priime.finance (session replay). Session replay starts only after you accept.
• If you decline, we stop any recording, go back to measuring without cookies, and delete PostHog's cookie and stored data from your browser.

A cookie named priime_consent keeps your choice for 180 days on priime.finance and its subdomains. You can change your choice at any time through the Cookie settings link in the footer of either site.

On build.priime.finance, PostHog records which template or tracked market a visit starts from and which steps of composing, reviewing, and publishing a vault it reaches, and, when you request a beta invitation, which form you used. There it does not record a wallet address, an email address, or anything you type, and it records no sessions. If you accept, the shared cookie links those steps to earlier visits to priime.finance.

Priced decisions are counted per showing. Some cards on build.priime.finance show one, such as the router's next move. PostHog records each time such a card is shown and whether you open its pricing details ("How this was priced"). Each record holds the kind of move, where the card appeared, its verdict, and the version of the pricing model. When the move was priced, it also holds an identifier for the decision, the same for everyone shown it on that day's market data. Each showing gets a random identifier. It is not stored on your device or reused. The records do not include a wallet address, an email address, anything you type, the amount you set on the card, or any dollar figure it shows. Whatever you choose for cookies, none is linked to your other visits or any profile.

Our data room on priime.finance is open to invited visitors, who enter an email address and an access password at its gate. When you enter, the gate sets two cookies for seven days: dr_auth, which keeps you signed in, and dr_email, which holds the email address you entered and can be read by the room's pages. We use dr_email to apply access rules, to attach the questions you send from the room to your email address, and, only if you accept analytics, to link your activity in the room, including session recordings, to that email address. Each time you unlock the room at its gate, we record that entry, with your email address and approximate location, in our access log and in our analytics. Your browser keeps your review progress, the sections and slides you have viewed, in local storage under a key named drprog followed by your email address; it stays on your device.

You can also control cookies through your browser settings; blocking some cookies may affect how the Services work.

9. Retention

We retain personal data only for as long as necessary for the purposes described in this Policy, including to provide the Services, to meet our legal, accounting, or reporting obligations, and to resolve disputes and enforce our agreements. When data is no longer needed, we delete or anonymize it. PostHog keeps the records of priced decisions under the same retention setting as our other analytics data. Counts drawn from them carry no identifier for a visitor. As noted in Section 3, on-chain data is permanent and is not within our control.

10. Security

We maintain technical and organizational measures designed to protect personal data against loss, misuse, and unauthorized access, disclosure, or alteration. No method of transmission or storage is completely secure, however, and we cannot guarantee that such events will never occur. You are responsible for the security of your wallet, devices, and private keys.

11. Children's Privacy

The Services are not directed to, and are not intended for use by, anyone under the age of eighteen (18) or the age of majority where they live. We do not knowingly collect personal data from children. If you believe a child has provided us personal data, contact us and we will take appropriate steps to delete it.

12. Links to Other Sites

The Services may link to websites and resources operated by third parties. We are not responsible for the content or privacy practices of those third parties, and this Policy does not apply to them. We encourage you to review their policies.

13. Changes to this Policy

We may update this Policy from time to time. When we do, we will revise the effective date and, where appropriate, provide additional notice. Your continued use of the Services after the changes take effect constitutes your acknowledgment of the updated Policy.

14. Contact

If you have questions about this Policy or how we handle personal data, or to exercise a right, contact:

Priime
Attention: Privacy
Email: privacy@priime.finance

This Privacy Policy is effective as of September 25, 2026.