Effective Date and Scope

Effective Date: September 30, 2025

This Privacy Policy describes how Photomadic Markets ("Photomadic Markets," "we," "us," or "our") collects, uses, discloses, and protects personal information when you access or use our websites, products, services, dashboards, APIs, and communications (collectively, the "Services"). This Policy applies to information collected from individuals in the United States of America and, where noted, provides additional disclosures for certain jurisdictions.

By using the Services, you acknowledge that you have read and understand this Privacy Policy. If you do not agree, please discontinue use of the Services.

Controller and Contact Information

Controller: Photomadic Markets, owned and operated by Van Elazinsu.

Postal Address: 7600 Kingston Pike, Knoxville, TN 37919, United States of America

Email: [email protected]

Notice at Collection: Categories of Personal Information We Collect

We may collect the following categories of personal information as defined by U.S. state privacy laws (such as the California Consumer Privacy Act, as amended by the CPRA):

Information You Provide

  • Identifiers and contact information, such as name, username, email address, postal address, and phone number.
  • Account credentials and profile details, such as display name, preferences, saved watchlists, and portfolio tracking inputs you choose to add.
  • Communications, such as inquiries, support requests, and content of messages you send to us.
  • Payment and billing information (processed by our payment processors). We do not store full payment card numbers.

Information Collected Automatically

  • Internet or other electronic network activity information, including device and browser type, operating system, IP address, app version, pages viewed, referring/exit pages, timestamps, and usage patterns.
  • Approximate geolocation derived from IP address.
  • Inferences drawn from activity to personalize content, measure engagement, or improve the Services.
  • Cookies, pixels, tags, SDKs, and similar technologies used for essential operations, analytics, performance, and (where permitted) advertising.

Information From Third Parties

  • Service providers and partners that supply analytics, fraud prevention, security, payment processing, and customer support.
  • Publicly available sources, including blockchain networks, when you choose to associate wallet addresses or public keys with features we provide.

Sensitive Personal Information

We do not seek to collect sensitive personal information (e.g., precise geolocation, government identifiers) and request that you do not submit such information. If such information is processed, it is solely for limited, disclosed purposes and not for profiling or cross-context behavioral advertising.

Purposes for Using Personal Information

  • Provide, operate, and maintain the Services, including account creation, authentication, feature delivery, and customer support.
  • Process transactions and manage subscriptions through third-party payment processors.
  • Monitor, secure, and protect the Services, including fraud detection, debugging, and incident response.
  • Analyze usage to improve Services, develop new features, and maintain quality and performance.
  • Personalize user experience, such as watchlists, preferences, and content relevance.
  • Deliver marketing and service communications, subject to your choices and applicable laws.
  • Comply with legal obligations, enforce terms, and protect rights, property, and safety.

Retention of Personal Information

We retain personal information for as long as necessary to fulfill the purposes outlined in this Policy or as required by law, including to comply with legal, accounting, or reporting obligations, resolve disputes, and enforce agreements. We use criteria such as the nature of the data, potential risk from unauthorized use or disclosure, the purposes of processing, and applicable legal requirements to determine retention periods. Where feasible, we de-identify or aggregate information for longer-term analytics.

Cookies and Similar Technologies

We use cookies and similar technologies to enable essential functions, remember preferences, perform analytics, and, where permitted, provide advertising and measure marketing effectiveness. You may control cookies through your browser settings and, where available, through in-product controls. Disabling certain cookies may impact functionality.

Blockchain and Market Data

Our Services may reference public blockchain data (e.g., wallet addresses, transaction hashes, timestamps). Such data is immutable and publicly accessible on the relevant networks. If you choose to associate wallet addresses or public keys with your account or portfolios, we may process this information to provide features like watchlists or alerts. Please consider that activities on public blockchains may be linked to your identifiers through third parties. We do not control the persistence of public blockchain records.

Disclosures of Personal Information

We may disclose personal information to the following categories of recipients for business purposes:

  • Service providers and contractors that perform services on our behalf (e.g., hosting, analytics, security, customer support, email delivery, payment processing) under contractual obligations restricting their use of the data.
  • Professional advisors, auditors, and insurers in the course of legitimate business operations.
  • Advertising and marketing partners, where permitted by law and your preferences, for measurement and delivery of relevant content.
  • Law enforcement, regulators, courts, or other third parties when required by law or to protect our legal rights, users, or the public.
  • In connection with a corporate transaction (e.g., merger, acquisition, reorganization), subject to appropriate safeguards.

Selling/Sharing and Targeted Advertising

We do not sell personal information for monetary consideration. We may "share" identifiers and internet/network activity information with advertising and analytics partners for cross-context behavioral advertising or targeted advertising as defined by certain U.S. state privacy laws. You may opt out of such sharing or targeted advertising as described below. We do not knowingly sell or share the personal information of consumers under 16 years of age.

Your Privacy Rights

California Residents (CPRA)

Subject to exceptions, California residents may have the right to: (1) know and access the categories and specific pieces of personal information collected, used, disclosed, sold, or shared; (2) request deletion of personal information; (3) correct inaccurate personal information; (4) opt out of sale or sharing of personal information; (5) limit the use and disclosure of sensitive personal information (where applicable); and (6) not receive discriminatory treatment for exercising these rights.

Notice at Collection: We collect the categories of personal information described above for the purposes stated and retain them as described. We do not use or disclose sensitive personal information for purposes other than those permitted by law.

Virginia, Colorado, Connecticut, and Utah Residents

Depending on your state, you may have rights to access, correct, delete, obtain a portable copy of your personal data, and opt out of targeted advertising, sale, and certain profiling. You may appeal a denied request by contacting us as described below.

Nevada Residents

Nevada residents may opt out of the sale of personal information as defined by Nevada law. We do not currently sell personal information, but you may submit an opt-out request at any time.

Residents of the EEA, UK, and Switzerland

Where applicable, we process personal data under legal bases such as consent, contract performance, legitimate interests (e.g., service improvement, security), and compliance with legal obligations. You may have rights to access, rectify, erase, restrict, object, and data portability. You may withdraw consent at any time without affecting prior processing. We may transfer personal data to the United States and other countries using appropriate safeguards.

How to Exercise Your Rights

You may exercise your rights or submit privacy requests by contacting us at [email protected] or by mail at the address listed above. To protect your privacy, we may verify your request by asking for information necessary to confirm your identity and residency. Authorized agents may submit requests on your behalf subject to verification and authorization requirements.

Opt Out of Selling/Sharing/Targeted Advertising: Submit a request via email or use available in-product controls. We honor browser-based Global Privacy Control signals where required by law.

Communications Preferences

You may opt out of marketing emails by using the unsubscribe instructions included in those communications or by contacting us. We may still send you non-marketing messages related to transactions, security, or service updates.

Security

We implement reasonable and appropriate technical and organizational safeguards designed to protect personal information from unauthorized access, disclosure, alteration, and destruction. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Children’s Privacy

The Services are not directed to children under 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected such information, we will take reasonable steps to delete it. We do not knowingly sell or share personal information of consumers under 16 years of age.

Do Not Track and Global Privacy Control

Some browsers transmit Do Not Track (DNT) signals. Our Services currently do not respond to DNT. Where required by law, we honor Global Privacy Control (GPC) signals as a request to opt out of selling or sharing personal information for cross-context behavioral advertising.

Third-Party Services

The Services may allow you to interact with third-party content or tools. Your use of third-party services is subject to their privacy policies and practices, which we do not control. We are not responsible for the privacy or security practices of such third parties.

Financial Incentives

We do not offer financial incentives or price differences in exchange for the collection, retention, sale, or sharing of your personal information. If we introduce such programs in the future, we will provide a separate, clear description of the terms and how to opt in.

International Data Transfers

We may transfer, store, and process personal information in countries other than where it was collected. Where required, we implement appropriate safeguards to protect personal information during such transfers.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. The "Effective Date" indicates when this Policy was last revised. Material changes will be communicated through the Services or via direct notice where appropriate. Your continued use of the Services after a change signifies your acceptance of the updated Policy.

Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact: Photomadic Markets, Attn: Privacy, 7600 Kingston Pike, Knoxville, TN 37919, United States of America, or email [email protected].