1. Introduction

This Privacy Policy explains how Quantum3 Labs, Pte. Ltd., 68 Circular Road #02-01, 049422, Singapore, collects, uses, and protects information in connection with the Prism mobile application and related services (the "Services").

By using Prism, you consent to this Policy.

Prism is a self-custodial dollar wallet. You hold digital assets, primarily USDC, in an embedded wallet provisioned through our technology partner, Privy. You can fund the wallet, receive payments, and pay merchants in supported countries via QR code. Settlement to merchants in local currency is handled by our licensed QR payment partner.

Prism is a software provider, not a bank. Your private keys are controlled on your device through our wallet partner. We cannot move funds out of your wallet without an authenticated instruction from you.

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2. Information We Collect

a. Account Information

When you create an account, a self-custodial wallet is generated through our authentication partner (Privy). We collect your email address and, optionally, a display name. We record the wallet addresses provisioned for you so we can display your balance and transaction history.

b. Identity and Verification Data

To comply with know-your-customer and anti-money-laundering laws, we use a licensed identity verification partner (Didit) to verify your identity. Through this process, we or our partner collect your full name, date of birth, nationality, residential address, a government-issued identity document, and a live selfie or liveness check. This is required before you can transact.

c. Payment and Transaction Data

When you pay a merchant via QR code, we record transaction details needed to operate the service: the merchant name and country, the local amount and currency, the USD equivalent, the exchange rate quoted by our QR payment partner (SQRIL), the fee, and the on-chain transaction hash of your direct USDC transfer to SQRIL's designated deposit address, which we reference to display status in the app.

d. Technical and Usage Data

We collect device type, operating system, app version, IP address, crash logs, and usage diagnostics to maintain performance and security. We read on-chain balance and transaction data for your wallet addresses through a blockchain indexer (Alchemy).

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3. Information We Do Not Collect

• Private keys. Your keys are controlled on your device through our wallet partner. We cannot access or export them.
• Your device passcode or biometrics. The passcode and biometric unlock on Prism are stored locally on your device and not transmitted to our servers.
• Funds in wallets outside Prism. We only see what is associated with your account.

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4. How We Use Information

We use the information we collect to:

• Create and operate your account and wallet
• Verify your identity and screen against sanctions and politically-exposed-persons lists
• Process QR payments and instruct settlement to merchants
• Detect and prevent fraud and abuse
• Provide customer support
• Comply with anti-money-laundering, counter-terrorist-financing, tax, sanctions, and other legal obligations
• Maintain and improve the Services

We process personal data on the basis of contract performance, legal obligation, legitimate interest, and consent, consistent with applicable data protection laws.

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5. Information Sharing

We share limited information only where necessary to operate the Services or comply with law:

• Privy (authentication and embedded wallet provisioning)
• Didit (KYC identity verification)
• SQRIL (QR payment decoding, FX, and fiat settlement to merchants)
• Alchemy (blockchain data indexing)
• Cloud hosting, analytics, and communications providers
• Merchants you pay, who receive the payment and, where required by local payment rails, limited sender details
• Regulators, courts, law enforcement, and tax authorities where we are legally compelled or where necessary to prevent fraud or financial crime

We do not sell personal data.

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6. Blockchain and Public Transactions

Every payment you make using Prism results in a transaction on a public blockchain, primarily Base. Transactions are public, permanent, and cannot be deleted by us, you, or any authority. Wallet addresses are pseudonymous, not anonymous. If your address is linked to your identity, past and future transactions from that address can be traced. Our ability to honour deletion requests is limited by this technical fact.

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7. Data Security and Retention

We use industry-standard technical and organizational measures to protect your information, including encryption in transit and at rest and strict access controls. No system is fully secure.

We retain personal data for as long as needed to operate the Services and to meet legal obligations. Identity verification and transaction records are kept for at least five years after account closure, as required by anti-money-laundering laws in the jurisdictions where we operate. When data is no longer needed, we delete or irreversibly anonymize it.

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8. Your Rights

Depending on where you live, you may have the right to access, correct, or delete your personal data, object to or restrict certain processing, withdraw consent, request data portability, and lodge a complaint with your local data protection authority. To exercise these rights, email admin@quantum3labs.com and cc to contact@quantum3labs.com . We may need to verify your identity before responding.

Some rights are limited in practice. We cannot alter or delete on-chain data (see Section 6), and we cannot delete records we are legally required to keep.

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9. International Transfers

Your information may be processed outside your country of residence, including in jurisdictions where our partners operate (for example, the United States, the United Kingdom, the European Economic Area, Canada, and Singapore).

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10. Children

Prism is not intended for anyone under 18. We do not knowingly collect data from minors. If you believe a minor has provided information to us, contact us and we will delete it.

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11. Updates

We may update this Policy from time to time. Material updates will be communicated in-app or by email. The "Version" and date at the top reflect the current version. Continued use of Prism after an update constitutes acceptance of the revised Policy.

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12. Contact

Quantum3 Labs, Pte. Ltd., 68 Circular Road #02-01, 049422, Singapore, contact@quantum3labs.com / admin@quantum3labs.com .