Privacy Policy

Privacy Policy

Effective Date: November 30, 2023

1. INTRODUCTION. This Privacy Policy (the “Policy”) explains how Peregrine Exploration 1, LLC (“Peregrine”, “we”, “our”, and “us”) collects, uses, and discloses personal information through its website and the Stable platform (the “Platform”, and collectively with the website, the “Services”). By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Policy, and you hereby consent that we will collect, use, and share your personal information in the following ways.

2. AFFILIATION WITH CUSTOMER. Our Platform is available for use by business entities (each, a “Customer”) and each of the authorized individuals who access the Platform on behalf of Customers (each, an “Authorized User”). If you are an Authorized User, we will need to collect certain personal information about you. In this Policy, we explain our practices with respect to your personal information.

3. THE BLOCKCHAIN. Blockchain technology, also known as distributed ledger technology (or simply ‘DLT’), is at the core of our business. Blockchains are decentralized and made up of digitally recorded data in a chain of packages called ‘blocks’. The manner in which these blocks are linked is chronological, meaning that the data is very difficult to alter once recorded. Since the ledger may be distributed all over the world (across several ‘nodes’ which usually replicate the ledger) this means there is no single person making decisions or otherwise administering the system (such as an operator of a cloud computing system), and that there is no centralized place where it is located either. This means that by design, a blockchain’s records cannot be changed or deleted and is said to be ‘immutable’. This may affect your ability to exercise your rights such as your right to erasure (‘right to be forgotten’), or your rights to object or restrict processing, of your personal data. Data on the blockchain can’t be erased or changed. Although smart contracts may be used to revoke certain access rights, and some content may be made invisible to others, it is not deleted. In certain circumstances, in order to comply with our contractual obligations to you (such as delivery of tokens) it will be necessary to write certain personal data, such as your wallet address, onto the blockchain; this requires you to execute such transactions using your wallet’s private key. In most cases ultimate decisions to (i) transact on the blockchain using your wallet address, as well as (ii) share the public key relating to your wallet address with anyone (including us) rests with you.If you want to ensure your privacy rights are not affected in any way, you should not transact on blockchains as certain rights may not be fully available or exercisable by you or us due to the technological infrastructure of the blockchain. The blockchain is available to the public and any personal data shared on the blockchain will become publicly available.

4. INFORMATION COLLECTED AND HOW WE USE IT. As explained further in this section, we will collect certain personal information about you. In addition, we may collect certain personal information automatically through your use of the Services. We will use this information to provide you with the functionality of our Services, to improve our Services, and to provide you with information about our Services. The rest of this section provides a more detailed explanation of the personal information we collect, how we use that personal information, and our lawful bases for processing that personal information.

5. 1. Voluntarily Disclosed Information. The following table identifies the specific purposes for which you or the Customer may voluntarily disclose your personal information to us, along with our lawful bases for processing that personal information.

Purpose	Type of Personal Information	How We Collect the Information	Lawful Basis for Processing
Account Creation	Email Address, Phone Number	Provided by you	Your consent; Performance of a contract with you; Legal compliance; Necessary to protect your (or someone else’s) vital interests
Account Creation	Name, Photo	Provided by Google upon your authorization	Your consent; Performance of a contract with the you; Legal compliance; Necessary to protect your (or someone else’s) vital interests
“Know your Customer” regulatory compliance as part of customer onboarding process, if you are (i) a beneficial owner or controlling officer of a Customer, or (ii) an Authorized User of a Customer	Name, Date of Birth, Mailing Address, Social Security Number or other government-issued identification number, Passport Number, Government-Issued ID	Provided by you or by an Authorized User of the Customer	Your consent; Performance of a contract with you and the Customer; Legal compliance
Marketing communications	Name, email address	Provided by you	Your consent

2. Automatically Collected Information. Whenever you interact with the Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, browser version and operating system, geolocation date, device identification, “cookie” and pixel tag information, the amount of time spent on the Services, and the page or feature you requested. You can learn more about our use of cookies and related technologies in our Cookie Policy. We use the data we automatically collect from you to monitor and protect against fraudulent activity, and to customize your experience on the Platform. We may also use it to improve the Services – for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible. We collect this information with your consent, for legal compliance, to perform our contract with you, and for our legitimate interest of providing a smooth user experience on the Services.

3. DISCLOSURE OF PERSONAL INFORMATION. We may disclose your personal information to the categories of third parties identified in this section.

4. 1. Personnel and Third Party Service Providers. We employ personnel and engage other companies and people to perform tasks on our behalf and need to share your personal information with them to provide products or services to you. For example, we use a third party authentication service to authenticate your identity whenever you log into the Platform, and the authentication service provider will have access to your login credentials and photo (if applicable). As another example, all data we collect is hosted on Google servers on our behalf.

   2. Analytics Services. We use analytics services like Google Analytics and Amplitude Analytics to understand how visitors engage with our Services. You can learn more about the information that Google has access to at the following website: https://policies.google.com/technologies/partner-sites.

   3. Anonymous Information. We may de-identify your personal information so that you are not identified as an individual, and use that anonymized information to monitor the performance of the Services, and how people use the Services.

   4. Business Transfers. If we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, personal information could be one of the assets transferred to or acquired by a third party.

   5. Legal Compliance. We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with governmental requests, law enforcement or court orders, or enforce or apply our Terms of Service and other agreements.

5. INTERNATIONAL TRANSFERS. We may transfer the personal information of users from the European Economic Area or United Kingdom to the United States. When doing so, we rely on adequacy decisions, data transfer agreements, or other legally compliant mechanisms for such transfers, including standard contractual clauses. You can ask for a copy of these standard contractual clauses by contacting us as set out below.

6. SECURITY. We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. In addition, we rely on the technical safeguards provided by the third party service providers we use to host, store, and process your personal information. We cannot, however, ensure or warrant that your personal information on the Services may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

7. YOUR RIGHTS.

   Who To Exercise Your Rights With. You may have rights under data protection laws in relation to your personal information. You can learn more about your rights further down in this section. If we have collected your personal information because you, as an individual, are our customer, we are a “controller” of that personal information and you can exercise your rights with respect to your personal information by following the instructions below. However, if we have collected your personal information because you are an Authorized User for a Customer, we are a “processor” of your personal information and the Customer controls our use of your personal information and determines how and for what purpose we process your personal information.

If we are a processor of your personal information, and you have any questions or concerns about how your personal information is handled or would like to exercise your rights as a data subject, you should contact the Customer. We will provide assistance to the Customer to address any concerns you may have, in accordance with the terms of our contract with the Customer and applicable law.

2. Rights of Users in the EEA and UK. If you reside in the EEA or the UK and we are a controller of your personal information, you have the following rights:

   1. Request access to your personal information. You may request a copy of the personal information we hold about you and to check that we are lawfully processing it. Where we have good reason, and where data protection law permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reason(s) for doing so.

   2. Request correction of your personal information. You may request that we correct any incomplete or inaccurate data we hold about you.

   3. Request erasure of your personal information. You may request that we delete or remove personal information where there is no good reason for us continuing to process it. You may also ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your personal information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. You may not request the removal of de-identified, anonymous, or aggregate data from our databases.

   4. Right to Object to or Restrict Processing. In certain circumstances, you have the right to object to our processing of your personal information (for example, if we are processing your personal information on the basis of our legitimate interests but there are no longer any compelling legitimate grounds to justify our processing overriding your rights and interests). You may also restrict our processing of your personal information, for example during a period in which we are verifying the accuracy of your personal information in circumstances where you have challenged the accuracy of that personal information.

   5. Request the transfer of your personal information to you or to a third party. In certain instances, you have a right to receive the personal information that we hold about you (or a portion thereof) in a structured, commonly used and machine-readable format. In such circumstances, you can ask us to transmit your personal information to you or directly to a third-party organization on your behalf. While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organization’s systems. We are also unable to comply with requests that relate to personal information of others without their consent.

   6. Withdraw consent. You may withdraw your consent for our processing of your personal information where we are relying on consent to process that personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Stable Cookie Policy

This Cookie Policy provides information about cookies, how we and third parties use them on the Services, and how you can manage our use of cookies with respect to your experience on the Services.

What is a Cookie?

A cookie is a small text file that can be stored on and accessed from your device when you visit and use our Services. Cookies enable us to “personalize” the Services for users by remembering information about our users. The Services use cookies to administer the Services, store your preferences, display content to personalize your visit, analyze trends on the Services, and track your movements around the Services.

How to Manage Cookies

Cookies are managed through web browsers, so please review your web browser settings to modify your cookie settings, to disable the use of cookies, or to delete cookies. Please note that if you delete, or choose not to accept, cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential.

Types of Cookies

Cookies can be categorized in different ways:

• First-Party vs. Third-Party Cookies: If we were to use first-party cookies, we would put those first-party cookies on your device. Third party cookies are placed on your device by a third party. You can learn more about the third-party cookies used on the Services below.

• Duration:

• • Session Cookies: Temporary cookies that expire once your session on the Services ends or your web browser is closed.

  • Persistent Cookies: Cookies that remain on your device for a longer period until you manually erase them or until their expiration date.

• Purpose:

  • Necessary Cookies - These cookies are necessary for us to operate the Services and their core features (e.g., account login).

  • Functionality Cookies – These cookies enable us to operate the Services in accordance with the choices you make. These cookies permit us to “remember” you in between visits. For instance, we will recognize your username and remember how you customized the Services (e.g., language preference, location), and these cookies allow us to provide you with the same customizations during future visits.

  • Analytical - These cookies analyze how the Services are used (e.g., browsing habits) and how the Services are performing. These cookies include, for example, Google Analytics cookies.

First-Party Cookies That We Use

We do not use any first-party cookies.

Third-Party Cookies That We Use

• Analytics Cookies - We use third-party analytics services like Google Analytics and Amplitude Analytics to analyze our web traffic and improve user experience. These services use cookies to generate statistical information about how our Services are being used. For more information on how Google Analytics uses these cookies, please see here.

Web Beacons.

A web beacon is an unobtrusive feature on web pages or emails that enables us to check whether a user has accessed some content. We may use web beacons to better understand how you and other users interact with the Services.