Legal

1. INTRODUCTION

1.1

MOBI Automation FZCO ("Company," "we," "us," or "our") is a limited liability company duly incorporated under Dubai Law No. 16 of 2021 and regulated by the Dubai Integrated Economic Zones Authority (DIEZ). We respect your privacy and are committed to protecting information processed in connection with your use of the Atlantus Coin Market (“ACM”) and its related services (collectively, the “Platform”). This Privacy Policy (“Policy”) governs the collection, processing, storage, and protection of information obtained through your interaction with ACM.

1.2

ACM operates as a decentralized, VMCC Builder DAO-enabled platform and is designed to collect and process only information necessary for protocol execution, platform functionality, security, and compliance purposes. By accessing or using the Platform, you acknowledge that you have read, understood, and agreed to this Policy and the applicable Terms of Use [hyperlink]. Continued use of the Platform constitutes ongoing acceptance of this Policy, including any updates implemented to reflect regulatory, operational, or technological changes.

1.3

This Policy describes: (i) the categories of data processed in connection with ACM; (ii) the lawful bases and purposes for such processing; (iii) technical and organizational safeguards applied to protect data; (iv) your rights as a data subject where applicable; and (v) the limited circumstances under which data may be disclosed to third parties. You are encouraged to review this Policy in full to understand how information is handled within the ACM environment.

1.4

We adhere to recognized data protection principles, including transparency, purpose limitation, data minimization, and accountability. Information is processed lawfully and securely in accordance with applicable data protection laws and regulatory standards, while accounting for the unique characteristics of blockchain-based systems, including immutability and public ledger visibility.

1.5

Your use of ACM and any information associated with your interaction with the Platform are subject to this Privacy Policy and the Terms of Use, each of which may be amended from time to time. Any updates will take effect upon publication, and continued access to the Platform constitutes acceptance of such amendments.

2. WHAT PERSONAL INFORMATION DO WE COLLECT?

MOBI Automation operates a decentralized system in which privacy is treated as a foundational design principle. To provide secure access, enable community participation, and comply with applicable legal and operational standards, the VMCC Builder DAO collects and processes certain user information. Within this architecture, the Atlantus Coin Market (ACM) does not independently collect or originate user identity or membership data. All personal or account-related information processed by ACM has already been submitted, verified, and validated through the Virtual Mining and Construction Company (VMCC) Builder Workstation framework. VMCC Builder Workstation and ACM operate as integrated components of the same VMCC Builder DAO and under the same governance and control structure, and are not regarded as third parties for data protection or disclosure purposes. Accordingly, references in this Policy to “data processed by ACM” relate solely to information propagated from VMCC Builder Workstation through interoperable, blockchain-based systems and processed by ACM for access control, execution, marketplace functionality, and protocol operations. When you interact with the Platform, ACM processes the following categories of information as part of this unified and interoperable data environment.

2.1 Publicly-Available Blockchain Data

When you connect your non-custodial blockchain wallet to the Platform, we collect and log your publicly available blockchain address to learn more about your use of the Platform. Note that blockchain addresses are publicly available data that are not created or assigned by us or any central party, and by themselves are not personally identifying.

2.2 Information From Your Wallet Address

our third-party service providers may access and collect information from your wallet address to provide and personalise the Platform and features of the Platform for you across sessions. For example, we may use this information to read the Genesis Keys available in your wallet.

2.3 Information From Other Sources

We may receive information about your wallet address or transactions made through the Platform from our service providers to prevent the use of our Platform in connection with fraudulent or other illicit activities.

2.4 Survey or Usability Information

Suppose you participate in a survey or usability study with us. In that case, we may record any information you directly provide to us (for example, your name or email), the responses you provide to us, and your interactions with the Platform. Survey participation may also generate usage data related to your interactions.

2.5 Correspondence

We will receive any communications and information you provide directly to us via customer support, social media or another support channel (such as Telegram, X or Email ), or when you participate in any surveys or questionnaires.

2.6 Information Automatically Collected

When you use the Services, our servers automatically collect information about your activity. This includes your IP address, device and browser type, operating system, pages or features you visit, time spent on those pages, usage frequency, search terms, clicked links, and related analytics data. We gather this information through server logs, cookies, and similar tracking technologies. We use it to understand usage trends, improve Service performance, administer the platform, track user navigation, develop aggregate insights, and support advertising.

3. WHY DO WE COLLECT THIS INFORMATION?

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience and transactions. We generally use personal information to create, operate, deliver, and improve our Platform, content, and for loss prevention and anti-fraud purposes. We may use this information in the following ways:

3.1 To Provide and Maintain our Platform

We process your personal information to operate and deliver ACM’s services to you. When you create an ACM account and configure your CHLZ, we collect certain details necessary to generate and manage your digital profile, execute your DCA preferences, and maintain accurate records of your activity. This information is stored both on-chain and off-chain to support smart contract interactions, transaction processing, and overall platform functionality. Without this data, we would be unable to create your CHLZ, execute automated allocations, or provide core ACM services.

3.2 Personalization and User Experience

We use your information to understand your needs and interests, and to tailor your experience so interactions with the Services feel more relevant and intuitive

3.3 Business and Analytics Activities

We process your information for business functions such as data analysis, audits, product development, performance reviews, tracking usage trends, evaluating promotional efforts, and supporting the growth of our operations.

3.4 To Protect Our Users

We use the information collected to protect our platform and your accounts and safeguard your interests.

3.5 To Comply with Legal and Regulatory Requirements

We collect and use your personal information to comply with legal and regulatory obligations. Some data, such as your VMCC membership details, is stored off-chain to improve platform functionality and user experience. In contrast, on-chain data, including wallet addresses and transactions, is publicly visible by design. We prioritize the privacy and security of all off-chain data and do not share it with third parties except when required by law, regulation, or legal process.

3.6 To Measure Platform Performance

We use this personal information to analyze platform usage and improve our platform and offerings. We also use it in analyzing and tracking data to determine the usefulness or popularity of certain content and to better understand the online activity of our platform users. We may use data from log files to analyze trends, administer the platform, track your movements around the platform, and better tailor our Platform to your needs.

3.7 To Enforce Our Terms of Use and Other Agreements

We are strict about compliance with the Terms of Use. We review, investigate, and prevent any potentially prohibited or illegal activities that violate our Terms of Use. We reserve the right to terminate the provision of service to any user found engaging in activities that violate our Terms of Use.

3.8

We may use third-party tools to collect, process, and store your personal information. We take all necessary measures to ensure that these third-party providers handle your personal information securely and process it lawfully, in compliance with applicable data protection regulations.

4. WHO DO WE SHARE DATA WITH?

At MOBI Automation, user privacy and data protection are core design principles. We do not sell, rent, or broadly share your personal information with unrelated third parties. Data sharing is strictly limited to what is necessary for platform security, operational continuity, and seamless user experience across the VMCC Builder DAO.

4.1 Blockchain Networks & Interoperability

The VMCC License generated through the Platform is recorded both on-chain and off-chain. This dual-storage structure enables seamless interoperability across VMCC Builder DAO applications. For example, a valid VMCC License is used to authenticate access to the Atlantus Coin Market (ACM) without requiring repeated data submission or re-onboarding. This blockchain-based interoperability ensures that license verification and access credentials remain consistent, secure, and reusable across authorized VMCC dApps.

4.2 Security Enhancement Partners

We may share minimal, strictly necessary information with trusted technology and security partners whose sole role is to help protect our systems from fraud, cyber threats, or data loss. These partners are contractually bound to process your data only under MOBI Automation’s instructions and cannot use it for unrelated commercial purposes.

4.3 Transparency & Auditability

To maintain integrity across the ecosystem, on-chain data like wallet addresses and transaction records remain publicly visible as part of the blockchain’s inherent transparency. However, personal data you provide off-chain, such as your VMCC name, general location, Telegram, and VMCC Name description, remains protected in our off-chain systems.

4.4 No Unnecessary Disclosure

We do not share your personal information with advertisers, brokers, or external analytics platforms. Data is only shared when strictly necessary for technical operations, legal compliance, or security purposes, in line with our internal governance and security protocols. This security-first approach ensures cross-platform functionality and trusted interoperability within the VMCC Builder DAO while keeping your personal information private, secure, and under your control.

4.5 User-Initiated Marketplace Visibility

Where the Platform enables marketplace features, certain information is made visible to other users strictly as a result of your voluntary actions. This includes creating listings, offerings, or participating in transactions within ACM or other authorised VMCC dApps. Only information necessary to support marketplace functionality, such as license status, offering details, pricing parameters, and associated on-chain identifiers, is displayed. No sensitive personal or off-chain data is disclosed to other users unless you expressly choose to include it. This visibility is inherent to decentralized marketplace operations and remains limited to the scope required for transactional transparency and trust.

5. WHAT ARE OUR SECURITY PRECAUTIONS?

We prioritize the security of your wallet and transactions and implement industry-standard blockchain security measures to protect your assets and data. Our precautions include:

5.1 Decentralized Architecture

Our platform operates on a decentralized blockchain network, ensuring that your transactions are immutable, transparent, and resistant to tampering.

5.2 Encryption Protocols

All sensitive information is secured using advanced encryption standards (AES) and SSL/TLS protocols to protect your data during interactions with our platform.

5.3 Wallet Integration Security

We only support secure wallet integrations that use private key encryption. Your private keys remain under your sole control and are never stored on our platform.

5.4 Smart Contract Audits

Our smart contracts undergo audits to identify and mitigate potential vulnerabilities, ensuring the reliability and security of transactions involving all our digital assets.

5.5

Continuous Monitoring

We employ blockchain monitoring tools to detect and respond to suspicious activities, supporting a secure environment for all users.

5.6 User Responsibility

While we implement robust security measures, the safety of your assets also depends on your actions. We strongly recommend keeping your private keys secure and confidential, using trusted devices and networks to access your wallet, and staying vigilant against phishing attempts and unauthorized access. By combining industry-standard blockchain technology with proactive security practices, we strive to provide a secure platform for your transactions and digital assets.

6. WHAT RIGHTS DO YOU HAVE OVER YOUR DATA?

As a user of our platform, you have important rights regarding your personal information. These rights are designed to give you greater control, transparency, and assurance over how your data is used, stored, and shared. Specifically, you may:

6.1 Access Your Data

Request a copy of the personal information we hold about you, along with details about how and why it is processed. This helps you understand and verify how your information supports your activities within the ecosystem.

6.2 Rectify Your Data

Ask us to correct or update any inaccurate or incomplete personal data, ensuring your records remain accurate and valid across VMCC platforms.

6.3 Request Erasure

In specific circumstances, such as where personal data is no longer necessary for the purposes for which it was collected, or where you withdraw consent (where applicable), you may request the deletion of your personal information, subject to applicable legal and regulatory obligations.

Please note that any data recorded on a public blockchain is, by its nature, immutable and permanent, and cannot be altered, deleted, or erased once written on-chain. As a result, erasure requests apply only to off-chain personal data under our control. Requesting erasure of off-chain data may result in the loss of access to certain features of the Platform, as such data is required to validate membership status, enable interoperability across the VMCC Builder DAO, and maintain account continuity.

6.4 Restrict Processing

Request that we limit the processing of your data if you contest its accuracy, object to its processing, or need it preserved for legal claims while your request is being reviewed. Restricting certain processing activities could affect your ability to fully use the platform or benefit from its features.

6.5 Object to Processing & Withdraw Consent

Withdraw consent where processing is based on consent, and object to certain uses of your data, such as for direct marketing.

6.6 Data Portability

Where technically feasible and legally required, request a copy of your personal data in a structured, commonly used, machine-readable format, or request that we transfer it to another service provider.

6.7

We are committed to making it simple and transparent for you to exercise these rights. Please be aware that while we respect your rights, exercising some of them, like deletion or restriction, may limit or remove your ability to use parts of the platform that rely on that data

7. DATA RETENTION

We retain personal information only for as long as necessary for smooth use of the ACM platform, meet legal or regulatory requirements, maintain security, resolve disputes, and to enforce our agreements. While the retention periods are periodically reviewed, different categories of information are stored for different periods based on their purpose:

7.1

Account and identification information is retained while your VMCC account remains active, and for a limited period after closure to support record-keeping, fraud prevention, and compliance obligations.

7.2

Usage, analytics, and technical data are retained for the time needed to operate, secure, and improve the Platform.

7.3

Information collected during onboarding, including social actions linked to Genesis Key verification, is kept only for verification, audit, and fraud-prevention purposes.

7.4

If we are required to keep information for a longer period due to legal, regulatory, or operational requirements, we will retain it only for the duration of those obligations.

7.5

After retention periods expire, we delete the information or de-identify it so it no longer identifies any user.

8. LEGAL AGE AND JURISDICTION

8.1 Minor

The Platform is available only to users 18 years of age or older. We do not knowingly collect or process personal data from minors. By using the Platform, you confirm that you meet this age requirement, as further stated in the Terms of Use. Any account found to involve a minor may be suspended or terminated, and associated data removed, in accordance with applicable law.

8.2 Users Outside Our Jurisdiction

The Platform is operated and administered in accordance with the laws and regulations applicable in the United Arab Emirates. Access to or use of the Platform from jurisdictions where such access or use is prohibited, restricted, or subject to additional regulatory approval is not permitted. Users who access the Platform from outside our primary operating jurisdiction do so at their own initiative and are solely responsible for ensuring compliance with all applicable local laws, regulations, and data protection requirements. We make no representations that the Platform is appropriate or lawful for use in all jurisdictions

9. COOKIES

9.1

Cookies are small data files stored in your browser by a website. They transmit information about your use of the Platform to its operator or to third parties that placed the cookie. Some cookies are “session cookies” that expire when you close your browser, and others are “persistent cookies” that stay on your computer or mobile device until you delete them.

9.2

Our Platform and applications use both session and persistent cookies to enable you to sign in and use our Platform and applications, store your preferences and settings within them, analyze how they perform, personalize your experience with them, and for other lawful purposes. We may also use other similar technologies for these purposes, such as web pixels that track browsing activity, social media widgets that facilitate interaction with social media platforms, unique device identifiers, and third-party software embedded in our mobile applications. In some cases, these cookies and similar technologies are used by third parties.

Using advertising industry opt-out tools on each device or browser where you use the Platform, available at http://optout.networkadvertising.org.

10. UPDATES

As a result of the dynamic nature of law and use of platform policies, we may revise this privacy policy from time to time. Notice of any material change will be announced on the platform, and your consent will be required before using your information for any purpose. It is at your sole discretion to provide such information. However, the use of our platform might be restricted or limited if you fail to provide such information.

11. CONTACT US

You can reach out to our community managers directly with any questions about the terms, your data, and how we use it via our VMCC Tech Support Telegram

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