PRIVACY POLICY

Last Updated: December 8, 2025

Welcome to SoqWallet.com (the "Platform"), operated by Surplus Ventures, LLC ("Company," "we," "our," or "us"). We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our Platform and purchase collectibles with digital twin Real World Assets (RWAs).

By using the Platform, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with our policies and practices, please do not use the Platform.

1. Information We Collect

1.1 Personal Information You Provide

We collect information that you voluntarily provide when you:

  • Create an account
  • Make a purchase
  • Subscribe to our newsletter
  • Contact customer support
  • Participate in surveys or promotions

This may include: name, email address, phone number, shipping address, billing address, payment information, payment address, and any other information you choose to provide.

1.2 TRANSACTION DATA

When you make a purchase, we collect information about the transaction, including the collectible purchased, payment method, transaction amount, date and time, and associated digital twin RWA details.

1.3 Information Collected Automatically

When you access the Platform, we automatically collect certain information, including:

  • IP address and device identifiers
  • Browser type and version
  • Operating system
  • Pages visited and time spent on pages
  • Referring website or source
  • Clickstream data and interaction patterns

1.4 Network Data

When you interact with digital twin RWAs, we may collect your wallet address and transaction hashes. Please note that network transactions are public and permanently recorded on the network.

2. How We Use Your Information

We use the information we collect for the following purposes:

  • Process and fulfill your orders
  • Transfer digital twin RWAs to your wallet
  • Communicate with you about your account and transactions
  • Provide customer support
  • Send marketing communications (with your consent)
  • Improve and personalize your experience on the Platform
  • Conduct research and analytics
  • Detect and prevent fraud and security threats
  • Comply with legal obligations
  • Enforce our Terms of Service

3. How We Share Your Information

3.1 Service Providers

We share information with third-party service providers who perform services on our behalf, including payment processing, shipping, email delivery, analytics, and customer service. These providers are contractually obligated to protect your information.

3.2 Data Networks

Digital twin RWA transactions are recorded on public internet networks. Your wallet address and transaction details will be publicly visible.

3.3 Legal Requirements

We may disclose your information if required by law, court order, or government request, or to protect our rights, property, or safety.

3.4 Business Transfers

If we are involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.

4. Data Security

We implement reasonable technical and organizational measures to protect your personal information from unauthorized access, use, or disclosure. These measures include:

  • Encryption of sensitive data in transit and at rest
  • Secure payment processing through PCI-compliant providers
  • Regular security assessments and updates
  • Access controls and authentication requirements
  • Employee training on data protection

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee its absolute security. You are responsible for maintaining the security of your account credentials and wallet.

5. Your Rights and Choices

5.1 Access and Correction

You have the right to access and update your personal information. You can do this by logging into your account or contacting us at privacy@soqwallet.com.

5.2 Deletion

You may request deletion of your personal information, subject to certain legal obligations to retain data. Note that transactions cannot be deleted once recorded.

5.3 Data Portability

You may request a copy of your personal information in a structured, commonly used format.

5.4 Marketing Opt-Out

You can opt out of marketing emails by clicking the "unsubscribe" link in any marketing email or by updating your preferences in your account settings.

6. Cookies and Tracking Technologies

We use cookies, web beacons, and similar tracking technologies to collect information about your browsing activity and improve your experience. Cookies are small data files stored on your device.

Types of Cookies We Use:

  • Essential Cookies: Required for the Platform to function properly
  • Analytics Cookies: Help us understand how visitors use the Platform
  • Functional Cookies: Remember your preferences and settings
  • Marketing Cookies: Track your activity for advertising purposes

You can control cookies through your browser settings. Disabling certain cookies may affect the functionality of the Platform.

7. Third-Party Links and Services

The Platform may contain links to third-party websites, integrations and services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal information.

8. Children's Privacy

The Platform is not intended for children under 18 years of age. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately at privacy@soqwallet.com.

9. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that differ from your jurisdiction. By using the Platform, you consent to the transfer of your information to the United States and other countries where we operate.

10. State-Specific Privacy Rights

10.1 California Residents (CCPA)

California residents have the right to:

  • Know what personal information we collect, use, and share
  • Request deletion of personal information
  • Opt-out of the sale of personal information (we do not sell personal information)
  • Non-discrimination for exercising these rights

10.2 Nevada Residents

Nevada residents may opt-out of the sale of personal information. We do not currently sell personal information as defined by Nevada law.

10.3 European Residents (GDPR)

If you are located in the European Economic Area, you have additional rights under GDPR, including:

  • Right to access and receive a copy of your data
  • Right to rectification of inaccurate data
  • Right to erasure ("right to be forgotten")
  • Right to restrict processing
  • Right to data portability
  • Right to object to processing
  • Right to lodge a complaint with a supervisory authority

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make changes, we will update the "Last Updated" date at the top of this page. If we make material changes, we will notify you by email or through a notice on the Platform. Your continued use of the Platform after changes are posted constitutes your acceptance of the updated Privacy Policy.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Surplus Ventures, LLC

Email: contact@soqwallet.com

Support: support@soqwallet.com

Website: SoqWallet.com