Scope and Applicability

This Privacy Policy describes how HWBTA (Home of Web3, Blockchain, Tokens & Airdrops) collects, uses, discloses, and protects personal information when you visit our website, use our services, participate in airdrops, subscribe to communications, or otherwise interact with us in the United States. This Policy applies to information collected online and offline, including through any forms, tools, or features we provide. By accessing or using our services, you acknowledge that you have read and understand this Policy.

Identity of the Business and Contact Information

HWBTA is owned and operated by Brennan Lockridge. For questions or to exercise your privacy rights, please contact us using the details below.

Business/Owner: Brennan Lockridge

Postal Address: 5215 Oakton St, Skokie, IL 60077, United States

Email: [email protected]

Information We Collect

Personal Information You Provide

• Identification and contact details: name, email address, postal address, phone number.
• Account details: usernames, preferences, saved settings.
• Content and communications: inquiries, feedback, survey responses, support requests.
• Airdrop participation data: wallet addresses, eligibility details, referral codes, country or state of residence, attestations, and any information submitted to join an airdrop.
• Compliance and verification: where applicable, information submitted for identity verification or eligibility screening (e.g., date of birth, government-issued ID details, sanctions screening data) through us or our service providers.
• Transactional information: records of services requested or received, and related metadata. We do not store full payment card numbers on our systems.

Information Collected Automatically

• Device and usage data: IP address, device identifiers, browser type, operating system, language, referring/exit pages, clickstream data, pages visited, and timestamps.
• Analytics and performance data: session information, events, error logs, and diagnostics.
• Location information: approximate location derived from IP address.
• Cookie and tracking data: identifiers associated with cookies, pixels, tags, and similar technologies.

Information from Third Parties

• Service providers and partners: identity verification vendors, analytics providers, advertising partners, anti-fraud and security partners, and cloud hosting providers.
• Public sources: public databases and public blockchain networks.
• Social and referral sources: when you interact with our content or participate in promotions, referrals, or affiliates.

Public Blockchain and On-Chain Data

Some activities involve public, permissionless blockchain networks. Wallet addresses, transaction hashes, token balances, and other on-chain data may be publicly visible and permanently recorded by the applicable blockchain. We do not control third-party blockchain protocols, their availability, or their retention practices. Linking a wallet address to your identity can render on-chain activity identifiable. Exercise caution when sharing wallet addresses and transacting on-chain.

Cookies, Pixels, and Similar Technologies

We use cookies, pixels, local storage, and similar technologies to operate our services, remember preferences, analyze traffic, improve performance, prevent fraud, and deliver or measure advertising.

Types of Cookies

• Strictly necessary: essential for site operation, security, and fraud prevention.
• Functional: remember choices and enhance features.
• Analytics: measure usage and performance.
• Advertising: personalize, deliver, and measure ads; enable cross-site tracking for interest-based advertising.

Your Choices

You can manage cookies through your browser settings and, where available, through on-site consent tools. If you use a browser-enabled Global Privacy Control (GPC) signal, we will treat it as an opt-out of sale/sharing for the browser sending the signal, to the extent required by applicable law.

Purposes of Use

• Provide, operate, and maintain our website, tools, and services.
• Enable participation in airdrops, listings, comparisons, and educational resources.
• Process requests, respond to inquiries, and provide support.
• Personalize content and improve user experience.
• Conduct analytics, research, and product development.
• Deliver, measure, and improve marketing and advertising.
• Detect, investigate, and prevent fraud, abuse, security incidents, and illegal activities.
• Comply with legal obligations, including sanctions screening, KYC/AML (where applicable), tax, and regulatory requirements.
• Establish, exercise, or defend legal claims and enforce our terms.

Disclosure of Personal Information

• Service providers: hosting, analytics, security, email and communications, customer support, identity verification (including KYC/AML vendors), and advertising partners.
• Business and marketing partners: with your consent or as permitted by law.
• Legal, compliance, and safety: to comply with law, lawful requests, or to protect rights, property, users, or public safety.
• Corporate transactions: in connection with mergers, acquisitions, financing, or asset transfers, subject to appropriate safeguards.

We do not sell personal information for money. We may “share” or allow the collection of personal information (such as device identifiers, IP address, and browsing activity) by advertising and analytics partners for cross-context behavioral advertising or targeted advertising, as those terms are defined by certain U.S. state laws. You may opt out as described in the Your Privacy Rights section below.

Retention of Personal Information

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, including providing services, complying with legal obligations, resolving disputes, and enforcing agreements. Typical retention periods include: account and communication records for the life of the account and up to 3 years after inactivity; transactional and compliance records for up to 7 years or longer as required by law; cookie and analytics data per cookie lifespan or for up to 25 months unless a shorter or longer period is justified for security, legal, or product improvement purposes. Public blockchain data is retained by the relevant blockchain and is beyond our control.

Your Privacy Rights

Depending on your state of residence, you may have rights regarding your personal information, including access, correction, deletion, portability, and opting out of certain processing activities, including sale/share/targeted advertising and certain profiling.

California Notice at Collection and CPRA Rights

Categories of personal information we may collect, use, and disclose for business purposes include: identifiers (e.g., name, email, IP address, device IDs, wallet addresses); commercial information (e.g., services used, participation details); internet or network activity (e.g., browsing history, interactions); geolocation (approximate); inferences drawn from other personal information; and sensitive personal information where necessary (e.g., government ID details for verification, if you choose to complete KYC through a provider). We collect these categories to operate our services, process requests, secure our systems, conduct analytics, comply with law, and market our services. We disclose these categories to service providers and contractors, subject to written agreements. We do not use or disclose sensitive personal information for purposes other than those permitted by California law.

We do not sell personal information for monetary consideration. We may share personal information with advertising partners for cross-context behavioral advertising. You have the right to opt out of sale or sharing, limit certain uses of sensitive personal information, and request:

• Access to the categories and specific pieces of personal information collected.
• Correction of inaccurate personal information.
• Deletion of personal information, subject to legal exceptions.
• Information about the categories of personal information collected, sources, purposes, and categories of recipients.

How to exercise your rights: email [email protected] or write to the postal address above. To opt out of sale/sharing for cross-context behavioral advertising, contact us using the methods above or use a browser that sends a Global Privacy Control (GPC) signal; we will honor GPC to the extent required by law. We will verify your request by matching information you provide with information in our records or by requesting additional details. You may designate an authorized agent to act on your behalf; we may require proof of authorization and verification of your identity. We will not discriminate against you for exercising your rights.

Virginia, Colorado, Connecticut, and Utah Residents

Residents of these states may have rights to access, correct, delete, obtain a portable copy of personal data, and opt out of targeted advertising, sale, and certain profiling. To exercise these rights, contact us at [email protected]. Where applicable, you may appeal our decision by replying to our response and stating that you wish to appeal.

Nevada Residents

Nevada residents may opt out of the sale of covered information by emailing [email protected]. We do not currently sell covered information as defined under Nevada law.

Marketing Communications and CAN-SPAM

If you subscribe to our updates, we may send you newsletters, educational content, and promotional messages. You can unsubscribe at any time by using the unsubscribe instructions in our emails or by contacting us at [email protected]. We will identify commercial messages as advertisements where required and include our valid physical postal address.

Financial Incentives and Airdrops

We may offer airdrops, rewards, referrals, or other promotions that could be considered financial incentives under certain state laws. Participation is voluntary and subject to the applicable terms. If an incentive is offered, we will describe the material terms, including the categories of personal information involved, how to opt in, and how to withdraw. We estimate the value of such incentives based on our good-faith assessment of the benefit to our business from the data collected and the cost of providing the incentive.

Security

We implement reasonable and appropriate technical and organizational measures to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. No method of transmission or storage is completely secure. You are responsible for maintaining the security of your accounts, credentials, and wallet keys.

Data Transfers and Storage Location

We are based in the United States and process information in the United States. If you access our services from outside the United States, you understand that your information may be transferred to, stored in, and processed in jurisdictions that may have data protection laws different from those in your jurisdiction.

Third-Party Services and Links

Our services may include links to third-party websites, tools, wallets, exchanges, or protocols, and integrations with third-party providers (e.g., analytics, advertising, KYC). We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy policies before providing personal information or interacting with their services.

Automated Decision-Making and Profiling

We may use automated systems (such as fraud detection, abuse prevention, or eligibility screening) that analyze information to help secure our services or assess airdrop eligibility. You may contact us to request more information about such processing and, where required by law, to request a review by a human.

Do Not Track

Some browsers offer a Do Not Track (DNT) setting. There is no industry consensus on how to respond to DNT signals. We respond to Global Privacy Control (GPC) signals as described above.

Children’s Privacy

Our services are not directed to children under 13, and we do not knowingly collect personal information from children under 13. If we learn that a child under 13 has provided personal information, we will delete it. California residents under 16 have additional rights regarding sale or sharing; we do not knowingly sell or share personal information of consumers under 16.

Changes to This Policy

We may update this Privacy Policy from time to time. The Effective Date below indicates the date of the latest revision. Material changes will be posted on this page, and we will take additional steps as required by law.

How to Contact Us

If you have questions about this Privacy Policy or our privacy practices, or if you wish to exercise your rights, please contact us at:

HWBTA c/o Brennan Lockridge
5215 Oakton St, Skokie, IL 60077, United States
Email: [email protected]

Effective Date

Last Updated: 2025-10-07