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Privacy Policy

MB Technology Ltd, a Cayman Islands Exempted Company

Last modified: March 2026

Introduction

This Privacy Policy of MB Technology Ltd ("MakeBanc," "us," "we," and "our") describes the information we collect about you when you access our platform at makebanc.com (the "Platform"), enter into agreements with us, use our services and products, send us communications, or otherwise engage with us, and what we do with such information.

This policy also describes your rights and how you can exercise them. This Privacy Policy covers all of our services and products and all methods by which you may access our Platform.

Please read this policy carefully. If you do not agree to this Privacy Policy, do not use, access, connect to, interact with, or download any of the Services or otherwise provide your information to us.

1. Controller Details

MB Technology Ltd, a Cayman Islands Exempted Company, is the data controller responsible for your personal information.

Contact email address: hello@makebanc.com

2. Scope of This Policy

This Privacy Policy applies to all Personal Information collected by our Platform or through your use of our products or services, whether through our applications or otherwise when engaging with us.

For the purposes of this Privacy Policy, "Personal Information" means any information that can reasonably be used to identify, relate to, describe, or be associated with a particular individual or household. Personal Information also includes information that may be classified as "Personal Data" or "Personally Identifiable Information" in some jurisdictions.

This Privacy Policy does not apply to anonymized or de-identified data that cannot be used to identify you.

3. Personal Information We Collect

We may collect, store, use, and transfer the following types of Personal Information:

Identity Data

Such as name, email address, and other identification information (for example, date of birth, proof of address, where required by law for use of certain products or services).

Transaction Data

Such as cryptocurrency wallet addresses, information relating to your MakeBanc account and allocation history, including capital allocations, redemptions, and vault interactions.

Device Data

Such as internet protocol (IP) address, device type and model, device keys, device location, web browser type and version, operating system type and version, device creation and modification dates, device IDs, and device login history.

Verification Data

Where required for compliance with Know-Your-Customer (KYC) and Anti-Money Laundering (AML) obligations: identification documents, residency information, photographs, and related verification data.

4. How We Collect Personal Information

Direct Interactions

You provide Personal Information when you create an account, use our products and services, subscribe to our updates, request information, participate in a promotion, engage with our social channels, or contact us with questions or requests.

Third-Party Services

We may receive information about you from our service providers, payment processors, or other partners as part of your use of our products and services.

Automated Technologies

When you use our products and services, visit our Platform, or interact with our applications, we may collect Personal Information through cookies, web beacons, and other technologies. We may also collect cryptocurrency wallet addresses.

5. Purposes and Legal Basis of Processing

We use information that we collect about you or that you provide to us for the following purposes:

PurposePersonal DataLegal Basis
Providing the Services in accordance with our Terms of UseEmail address, IP address, device data, wallet address(es)Necessary for the performance of our contractual obligations
Verify user information and prevent fraudIP address, device data, wallet address(es), behavioral signals, device fingerprintNecessary for contractual obligations and to protect vital interests
KYC and AML compliance checksIdentification data, IP address, geolocation, transaction dataCompliance with legal obligation
Customer communications and supportEmail address, nameNecessary for contractual obligations
Improve services and resolve technical issuesIP address, device data, browser dataLegitimate interest in service improvement
Website analytics and aggregated reportingCookies, web beaconsYour consent for non-essential cookies; contractual obligations
Determine location for compliance and geo-restrictionIP address, address dataCompliance with legal obligation; protection of vital interests

In some jurisdictions, we may not be able to rely on the above lawful bases. If this is the case, we will seek your consent, and we will rely on that consent as the lawful basis of processing. You can withdraw consent at any time.

6. How We Use Your Personal Information

We use information that we collect about you or that you provide to us, including any Personal Information, for the following purposes: to present our Platform and its contents to you; to provide services including fulfilling transactions; to provide you with information that you request from us; to notify you about changes to our Platform; to allow you to participate in interactive features on our Platform; to conduct anti-money laundering and other legal checks; for research and development purposes; for marketing communications (where you have opted in or where permitted by law); for legal proceedings and requirements; and for non-marketing communications about changes to our terms, services, or policies.

We may aggregate, de-identify, or anonymize your Personal Information for research, testing, analysis, and product development to improve the user experience. This helps us make our services more convenient and easier to use, enhance the safety and security of our services, and develop new services and features.

7. Sharing Your Personal Information

We may disclose aggregated, anonymized information about our users without restriction. We may disclose Personal Information that we collect or you provide as described in this Privacy Policy:

  • To our subsidiaries and affiliates.
  • To contractors and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential.
  • To our partners who provide services necessary for the Platform to function, including Ceffu (custody infrastructure) and blockchain analytics providers.
  • To a buyer or successor in the event of a merger, restructuring, dissolution, or other transfer of assets.
  • To comply with any court order, law, or legal process.
  • To enforce our Terms of Use and other agreements.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of MakeBanc, our users, or others.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

8. Blockchain Data and Permanent Information

Interactions with blockchain systems (including smart contract logs and events) may result in the permanent recording of certain information, which cannot be altered or deleted. Blockchain technology operates independently, and MakeBanc has no control over its immutability.

Transactions on the blockchain are not anonymous. Your public key and wallet address are visible to anyone. To the extent your public key or wallet address can be linked back to you, it would be possible for someone to determine your identity and the digital assets you hold.

9. Cookies and Similar Technologies

Cookies are small text files sent from a site to a user's device to store bits of information. We use the following types of cookies:

  • Strictly Necessary Cookies allow us to provide basic platform functions such as browsing capabilities and secure access.
  • Functional Cookies allow us to provide enhanced functionality, such as account notifications and personalized settings.
  • Performance and Analytics Cookies collect information about how you use our Platform, in aggregated form.
  • Marketing Cookies may be set on our Platform by our advertising partners to track online activities and provide relevant advertising.
  • Wallet Cookies are generated by the Platform when users perform blockchain-based transactions and may store wallet addresses and transaction information.

You can manage your cookie preferences through your browser settings. Most browsers are set to accept cookies by default. Disabling cookies may affect your ability to use certain features of the Platform.

10. Personal Information Retention

We will retain Personal Information we collect as long as 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 Personal Information or where your account is terminated, we may continue to retain and use it as permitted or required under applicable laws, for legal, tax, or regulatory reasons, or legitimate and lawful business purposes.

11. Your Rights Regarding Personal Information

Depending on your jurisdiction, you may have certain rights over your Personal Information. These rights may include:

  • Right to Access: You may request details about the Personal Information we hold about you and details of our processing.
  • Right to Rectification: If any Personal Information we hold is inaccurate, you may request correction.
  • Right to Erasure (Right to be Forgotten): You may request the deletion of your Personal Information under certain circumstances.
  • Restriction of Processing: You may request the restriction of processing under certain circumstances.
  • Objection to Processing: Under certain circumstances you may object to processing based on legitimate interest or direct marketing.
  • Right to Data Portability: You may request a copy of your Personal Information in a structured, machine-readable format.
  • Consent Withdrawal Right: Where we rely solely on consent for processing your Personal Information, you may withdraw it at any time.
  • Automated Decision-Making: You have the right to object to decisions based solely on automated processing, including profiling.

To exercise these rights, please contact us at hello@makebanc.com. If you believe your rights have been violated, you may lodge a complaint with a competent data protection supervisory authority.

12. Personal Information of Minors

Our services and products are not intended for individuals under the age of eighteen (18). We do not knowingly collect Personal Information related to minors.

13. Security

We use industry-standard security measures to protect your Personal Information from unauthorized access, use, or disclosure. We implement technical, administrative, and physical security measures to prevent personal information from loss, theft, leakage, alteration, or damage. However, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Platform.

14. International Data Transfer

We may transfer information collected about you, including Personal Information, to affiliated entities or to other third-party service providers across borders and from your country or jurisdiction to other countries or jurisdictions around the world, solely for legitimate business purposes. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. Where required, we enter into appropriate data processing agreements and standard contractual clauses approved by the applicable data protection regulatory authority.

15. Third-Party Websites

We may have links to unaffiliated third-party websites on our Platform. These third-party websites have their own privacy policies. We have no involvement with their policies and are not responsible for their practices. You are encouraged to review the privacy policies of all third-party websites you visit.

16. Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Platform and this Privacy Policy to check for any changes.

17. Contact

If you have any questions about this Privacy Policy, please contact us at hello@makebanc.com.

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MakeBanc is a technology platform that connects capital owners with independent asset managers. MakeBanc does not provide investment advice, custody services, or banking services. All economic ownership resides with users. The platform interacts with open, permissionless smart contract vaults and third-party financial infrastructure, enabling users to activate, allocate, and automate their capital through their own wallets. All actions are user-initiated, and users remain in full control of their capital at all times.

© 2026 MB Technology Ltd, Cayman Islands. All rights reserved.