Privacy Policy

The Neverland Protocol operates in a decentralized and permissionless manner. Although we may collect and process information about users of Neverland.money or the Interface in accordance with this Privacy Policy, we do not have information about all protocol users beyond what is already publicly available and recorded on the blockchain.

This Privacy Policy (the "Privacy Policy") explains how Neverland Money ("we," "our," or "us") collects, uses, and shares information in connection with our Services as well as your rights and choices regarding such information in accordance with applicable data protection legislation, including the Data Protection Act (as amended) of the Cayman Islands (together, "Data Protection Legislation"). These terms apply to Neverland.money and the Interface and any other online location that links to this Privacy Policy (collectively, the "Services").

By using the Services, you also agree to our collection, use, and sharing of your information as described in this Privacy Policy. If you do not agree with the Terms of Use, you should not use or access the Interface or the Services.

If you are an individual, this Privacy Policy will be relevant to you directly. If you are an entity or arrangement that provides us with personal data on individuals connected to you for any reason, this Privacy Policy will be relevant for those individuals and you should transmit this Privacy Policy to such individuals or otherwise advise them of its content.

A. Information You Provide

We may collect the following information about you when you use the Services:

Correspondence and Content: When you contact us for support or other inquiries, you may share with us your contact details and contextual information relevant to your issue (such as wallet type, token or transaction details, device type, or error codes). This helps us respond and improve the Services.

You may choose to voluntarily provide other information to us that we have not solicited from you, and, in such instances, you are solely responsible for such information.

B. Information Collected Automatically

We collect the following information:

Wallet Address: We may collect the wallet address you use to connect to the Interface to block wallets that are associated with certain legally prohibited conduct from Interface. Separately, we may collect your wallet address as part of "Usage Information" (as described below) to improve the Interface and user experience of the Services.

Device Information: We may collect information about the device you use to access the Interface, such as the device type, operating system, browser type, and screen height and width. This information helps us optimize the Interface for different devices and troubleshoot any technical issues.

Usage Information: We may collect information about how you use the Interface and Services, including your wallet address, the time you access the Interface, pages you visit, the features and assets you interact with, the links you click, and the search queries you make. By analyzing this data, we gain a deeper understanding of user behavior, which in turn allows us to make continuous improvements to the Interface and enhance the overall user experience.

We will not take decisions producing legal effects concerning you, or otherwise significantly affecting you, based solely on automated processing of your personal data, unless we have considered the proposed processing in a particular case and concluded in writing that it meets the applicable requirements under the Data Protection Legislation.

We may collect and use information for our legitimate business purposes in accordance with the practices described in this Privacy Policy, including where this is necessary for the performance of a contract, where this is necessary for compliance with applicable legal or regulatory obligations or otherwise in pursuance of our legitimate interests or those of a third party to whom your personal data is disclosed. In particular, our business purposes for collecting and using information includes, but is not limited to:

Operating and managing the Services: To make the Services available to you and perform services requested by you, such as responding to your comments, questions, and requests, and providing information support; sending you technical notices, updates, security alerts, information regarding changes to our policies, and support, administrative messages; detecting, preventing, and addressing fraud, breach of Terms, and threats, or harm; and compliance with legal and regulatory requirements.

Improving the Services: To continually improve the Services and fulfill any other legitimate business purpose, as permitted under applicable laws.

Security and Compliance with Laws: As we believe necessary or appropriate to operate and maintain the security or integrity of the Interface, including to prevent or stop an attack on our computer systems or networks, investigate possible wrongdoing in connection with the Interface, enforce our Terms, and comply with applicable laws, lawful requests, and legal process.

We may share or disclose information that we collect in accordance with the practices described in this Privacy Policy and for the purposes set out in the "Use of Information" section above.

The categories of parties with whom we may share information include:

Affiliates: We share information with our affiliates and related entities, including where they act as our service providers or for their own internal purposes.

Professional Advisors: We share information with our professional advisors for purposes of audits and compliance with our legal obligations.

Service Providers: We share information with third-party service providers for business purposes, including fraud detection and prevention, security threat detection, data analytics, information technology and storage, and blockchain transaction monitoring.

Regulatory and government authorities: In certain circumstances, we may be legally obliged to share your personal data and other information with relevant regulatory or governmental authorities.

We may also integrate technologies operated or controlled by other parties into parts of the Services. For example, the Services may include links that hyperlink to websites, platforms, and other services not operated or controlled by us.

Please note that when you interact with other parties, including when you leave the Interface, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their own policies and practices.

For example, by using a third-party wallet to engage in transactions on public blockchains, your interactions with any third-party wallet provider are governed by the applicable terms of service and privacy policy of that wallet provider.

We understand that your privacy is important to you and are committed to being transparent about the technologies we use. In the spirit of transparency, this Cookies Policy provides detailed information about how and when we use cookies on our Services.

A. Do we use cookies?

We do not use cookies. If we were, we would use cookies and other technologies to understand how you use our Interface so we can improve its design and functionality.

B. What types of cookies might we use?

Strictly Necessary Cookies: These cookies are essential for the Interface to function properly and enable basic features such as page navigation and access to secure areas of the site.

Analytical/Performance Cookies: These cookies allow us to analyze how visitors use the Interface, which helps us improve its functionality and performance.

Functional Cookies: These cookies enable enhanced functionality and personalization of the website.

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet is not completely secure and we cannot guarantee the security of information about you.

Please note that we retain information we collect as long as it is necessary to fulfill the purpose for which it was collected, as outlined in this Privacy Policy, and to the extent permitted by applicable legal requirements. Where you request the deletion of your information, we may continue to retain and use your information as permitted or required under applicable laws.

We expect to delete your personal data (at the latest) once there is no longer any legal or regulatory requirement or legitimate business purpose for retaining your personal data.

You have certain data protection rights under the Data Protection Legislation, including the right to:

• be informed about the purposes for which your personal data are processed
• access your personal data
• stop direct marketing
• restrict the processing of your personal data
• have incomplete or inaccurate personal data corrected
• ask us to stop processing your personal data
• be informed of a personal data breach (unless the breach is unlikely to be prejudicial to you)
• complain, including to the Data Protection Ombudsman of the Cayman Islands
• require us to delete your personal data in some limited circumstances

The Services are intended for general audiences and are not directed at children. To use the Services, you must legally be able to enter into the Agreement. We do not knowingly collect personal information (as defined by the U.S. Children's Privacy Protection Act, or "COPPA") from children. If you are a parent or guardian and believe we have collected personal information in violation of COPPA, please contact us at contact@neverland.money and we will remove the personal information in accordance with COPPA.

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon our posting of the revised Privacy Policy. For the avoidance of doubt, your continued use of the Services indicates your consent to the revised Privacy Policy then posted.

If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us by email: contact@neverland.money