Agara Privacy Policy

Introduction

This Privacy Policy (“Policy”) explains how Mirai Tech Inc., a company incorporated under the laws of Panama (the “Company”, “we”, “us”, or “our”, together with our affiliates, successors, and assigns), collects, uses, shares, and protects the personal information of users (“you” or “users”).

This Policy covers the Personal Data we collect anywhere in our business: on our website-hosted user interface, in our mobile and web applications, and through any smart contracts or blockchain-based protocols we make available (together, the “Interface” or the “Services”).

All use of the Services is also subject to our Terms of Service (“Terms”). The Terms and this Policy together make up your agreement with us (the “Agreement”). Please read this Policy carefully before you interact with us, connect your Digital Wallet, or use the Interface.

Accessing or using the Services means you accept this Policy and authorize us to collect and receive information about you and your activities as described here, so that we can operate the Interface and provide the Services.

If you do not agree with this Policy, please do not use the Interface.

Information We Collect

We aim to collect only what we need to operate the Interface, keep it secure, and meet our obligations. We collect the following categories of information:

• Wallet and blockchain data. Your public wallet address, your on-chain transaction history for that address (including positions, trades, deposits, withdrawals, and market resolutions), token holdings and balances, and any public name-service identifiers linked to your address. This data is public by default. When you transact, your wallet address and transaction details are recorded on a public blockchain, where anyone can read, copy, aggregate, and analyze them, whether or not they use our Interface. Once data is written to a public blockchain we cannot change, hide, or delete it, so we do not act as the controller of, and are not responsible for, on-chain data once it is published.
• Technical and device data. Your IP address, browser type and version, operating system, device and connection attributes, language and time-zone settings, and similar information collected automatically when you access the Interface.
• Approximate location data. Location inferred from your IP address, used mainly to enforce access restrictions and to detect and prevent prohibited or fraudulent use.
• Usage data. How you interact with the Interface, such as pages and features viewed, session activity, referring and exit pages, and diagnostic and performance data.
• Communications and support data. The content of messages you send us (for example, support requests, feedback, or survey responses) and the contact details you choose to share, such as an email address or messaging handle.
• Cookies and similar technologies. Information collected through cookies and similar technologies, as described below.
• Limited verification or eligibility data (only if and when requested). We generally do not require identity documents to use the Interface. In limited circumstances, such as assessing eligibility, investigating suspected prohibited or fraudulent activity, screening against applicable sanctions or restricted-party lists, or where we otherwise consider it necessary, we (or a third-party service acting on our behalf) may request additional information from you. If you choose not to provide it, we may be unable to make some or all of the Services available to you.

Sometimes the law (for example, “Know-Your-Customer” (KYC) and Anti-Money-Laundering (AML) checks) or a contract between us requires certain Personal Data. If you do not supply it when asked, we may be unable to enter into or perform our contract with you, and we may have to withhold or suspend your access to the Interface until we receive it.

How We Use Information

We use the information we collect to:

• Operate and provide the Interface, including enabling your wallet connection, displaying markets and your activity, and facilitating your interaction with our smart contracts and with external venues to which your orders are routed
• Maintain security and integrity, including detecting, investigating, and preventing fraud, market abuse, security incidents, and other prohibited or unlawful activity, and protecting our users, the Interface, and our rights
• Administer access restrictions and compliance screening, using your IP address, approximate location, wallet address, and related on-chain and analytics signals to restrict or limit access from jurisdictions where we do not make the Services available, and to screen your wallet and activity against applicable sanctions and restricted-party lists
• Run promotions and contests
• Send you promotional material about the Services, including targeted advertising, coupons, and newsletters
• Improve and develop the Services through analytics, troubleshooting, testing, research, and product development
• Communicate with you, including responding to your inquiries, providing support, and sending administrative, transactional, or marketing messages
• Comply with applicable legal obligations and enforce our Terms and other agreements.

Orders Routed to External Venues

Some markets available through the Interface are not operated, created, or settled by us. When you trade in such a market, information such as your public wallet address, order and transaction details, and related data is transmitted to and processed by one or more external venues, protocols, or liquidity sources that we do not operate or control, so that your order can be matched, routed, fulfilled, or settled.

You should be aware that:

• These external venues are independent third parties. They decide how they process the data they receive, and they operate under their own terms, privacy practices, and data-retention policies, which are outside our control and not our responsibility.
• The external venues we route to may change over time as we add, remove, or modify the markets we make available.
• Once your data has been transmitted to an external venue, or recorded on a public blockchain as part of such a transaction, we cannot control, retrieve, or delete it.

Before trading in a market routed to an external venue, we encourage you to review that venue’s terms and privacy practices. Where the Interface indicates that a market is routed externally, you can take that into account before trading. We may not always be able to identify in advance whether a particular order will be routed externally.

Information Sharing and Disclosure

We may share your personal information with third parties, for example:

• Our affiliates and subsidiaries that help run the Interface
• Business partners, so they can bring you selected products, services, and promotions
• Third-party service providers that help us provide the Services, such as payment processors, cloud storage, analytics, customer support, and fraud detection providers acting on our or a vendor’s behalf
• When law, regulation, or legal process demands it, including court orders, subpoenas, and government requests
• In connection with a corporate transaction, such as a merger, acquisition, reorganization, dissolution, bankruptcy, or a purchase or sale of businesses or assets as our business develops; in such cases your information may be among the assets transferred

Some of these companies rely on cookie data about your visits to the Interface and to other sites to show you ads for goods and services that may interest you.

We also bring in outside companies and individuals to handle certain work for us, such as technical assistance, customer service, and marketing. Our user records and configurations, for instance, sit with an outside cloud hosting provider.

Third parties that serve interest-based advertising collect and use your information on their own terms, not ours, though many of them give you ways to opt out of that collection and use.

We also study our users and Services using information in anonymized or aggregate form, which does not identify anyone personally. We may put this information to work internally, pass it to our affiliates, agents, and business and promotional partners, and use anonymous user statistics when describing our business to current or prospective partners and other third parties for lawful purposes.

Some information about you is public by design. Your wallet’s public address, username, profile photo and name, when your account was created (month and year), and the public transactions you have taken part in are all visible to anyone on the Internet, account or no account, because that is how blockchains work. The same information can travel further through APIs, SDKs, and outside services that plug into our products, where it may be viewed, reshared, or downloaded.

Personal Communication Preferences

If you registered for the Services, you can look at, correct, or erase the personal information tied to your registration, either through the Interface itself or by writing to legal@agara.xyz. Before acting on a request, we may first ask you to prove your identity.

Cookies and Tracking Technologies

Cookies keep the Interface running, help us understand how it is used, personalize what you see, and let you connect to social media. Strictly necessary cookies stay on at all times; for functional, analytics, and advertising cookies, we request your consent first.

Third-Party Analytics and Advertising

We may use third-party analytics to understand how the Services are used: compiling activity reports, gathering demographic data, and measuring performance. These providers rely on cookies, pixel tags, and similar tracking technologies to gather and analyze this data for us, for example to follow what Interface users and email recipients do, gauge how well our marketing campaigns perform, and build statistics on usage and response rates.

We may also work with retargeting providers, whose ads follow up with people who have visited our Services before as they browse other websites. These providers use cookies, pixel tags, and similar technologies to serve ads based on past visits to the Interface, and whatever data they gather for us is handled under this Policy.

Where applicable law allows consent to be given this way, you consent to the processing described in this section by using the Services.

International Data Transfers

We and our providers operate infrastructure in more than one country, so your Personal Data may be stored or processed outside the jurisdiction where you live, under privacy laws unlike your own. Using the Services means accepting that. Note that in some situations, courts, law enforcement, regulators, or security authorities in those countries can lawfully demand access to Personal Data held there. Wherever the data travels, we take reasonable steps to keep it secure and to handle it the way this Policy describes.

Data Retention, Your Choices and Rights

We keep Personal Data only while we still need it: to run the Interface and keep it available to you, to carry out the purposes this Policy sets out, to meet our legal obligations, to resolve disputes, and to enforce our agreements. Where we have collected identity verification records, AML/CFT rules typically oblige us to hold them for five to seven years after an account closes. For everything else, the retention period turns on how much data there is, how sensitive it is, what damage unauthorized access could cause, why we are processing it, and whether the same purpose could be served another way.

Depending on where you live, you may have rights over your personal information, which may include the right to access, correct, delete, or receive a copy of it, to object to or restrict certain processing, and to withdraw consent where we rely on it. You can opt out of marketing communications at any time using the unsubscribe mechanism in those messages.

To make a request, contact us at legal@agara.xyz. We may need to verify your identity before responding, and we will respond as required by applicable law. Some rights are not absolute: we cannot alter or delete information recorded on a public blockchain, information held independently by external venues, or information we are required to retain. Where information that identifies you is held off-chain, we can delete it at your request even though the underlying on-chain record remains.

Confidentiality and the Security of Your Data

We apply appropriate safeguards so that your Personal Data is not accidentally lost and cannot be used, accessed, altered, or disclosed without authorization.

• Technical measures: Traffic is encrypted (SSL/TLS), and our servers sit behind firewalls on hardened infrastructure.
• Organizational measures: Only the employees, agents, contractors, and other parties who genuinely need your Personal Data for their work can reach it.
• Non-custodial risks: Your private keys and Digital Wallet are yours alone to protect. Where you rely on a third-party wallet, its security is beyond our reach. We will never ask you for your private keys or seed phrase.

Still, no way of moving information across the Internet, and no way of storing it electronically, is entirely secure. We cannot promise that our safeguards will never be breached, or that your information could never be accessed, disclosed, altered, or destroyed as a result. Please protect yourself too, starting with keeping your password to yourself. Information you send us travels at your own risk, and we are not answerable if someone circumvents the privacy or security settings of the Services.

Minors’ Data

The Interface is for adults. You must have reached 18, or the age of majority in your place of residence if that is higher, to use it. We do not permit Minors on the Interface and do not knowingly gather their Personal Data.

If you are a Minor, stop using the Interface now. Should we confirm that a Minor’s Personal Data has reached our servers, we will delete it without delay.

Links to Other Websites

Here and there, the Services link out to third-party services, applications, or websites that have no affiliation with us. What those third parties collect is not within our control, so look over the privacy statement of any of them that asks for your Personal Data. Anything you hand to a third party falls outside this Policy, and we cannot vouch for how safely it will be kept.

Outside parties may also place cookies, web beacons, or similar trackers while you use our Services. What they gather may end up linked to your Personal Data, or may map your activity across other sites and services over time, and can feed interest-based ads or other targeted content. Their tracking tools answer to them, not to us. For questions about a particular ad, or to stop a particular third party from contacting you, go to that provider directly.

Changes to This Privacy Policy

We may update or modify this Policy at any time without prior notice. When we do, we will revise the date at the top of this page. It is your responsibility to review this Policy periodically, and your continued use of the Interface after any changes constitutes your acceptance of the revised Policy. If you do not agree to this Policy, please do not use the Interface.

Governing Law and Dispute Resolution

This Policy is governed by and construed in accordance with the laws of Panama. Any dispute arising out of or relating to this Policy will be settled by binding arbitration in Panama City, Panama, under the Rules of Arbitration of the International Chamber of Commerce. We offer the Services, including the Interface, from Panama, and nothing about them is meant to bring us under the laws or the courts of anywhere else.

Contact Us

Questions or comments about this Policy can be sent to legal@agara.xyz.