Universe Platform Inc. (“Universe”, “we”, “us”, “our”) provides a web-based platform where users can purchase and sell community membership tokens. This Privacy Policy (“Policy”) describes how we collect, use, and disclose personal information obtained when you join our platform, create a member community, join a member community, mint your membership token, visit our website at https://www.universe.club/ (the “Site”), or use any of the features we make available to you through the Site or otherwise (collectively, the “Services”). By using our Services, you agree to the terms of this Policy.

Information We Collect

We collect personal information directly from you when you use our Services. We also automatically collect certain information about you and your computer, smartphone, or other such device when you use our Services. We may also collect information about you from our partners, service providers, and other third parties, such as those that offer membership tokens through the platform or social media companies.

Account registration. When you create an account through our Services, we collect the following categories of personal information:

• Registration information such as your username, password and email;
• Profile information such as your social media username; and
• User generated information such as photos, images, comments, or any other information that you choose to provide in your profile.
• We also automatically create a wallet for you to hold your membership tokens. The wallet ID, public address, private key and passphrase associated with your wallet are internal to our Services and will not be shared with third parties.

Joining a public or private community . When you join a public or private community through our Services, we may facilitate the collection of your payment card information through our third-party service provider.

Community creation. When you create a community and offer membership tokens through our Services, we collect the following categories of personal information:

• Community generated information such as your community URL, address, social media handles, images, community description, benefits description or any other information that you choose to provide as part of your community’s creation.
• Community information will be publicly available.

We may also facilitate the collection of your payment card information through our third-party service provider.

Other personal information collected through use of the Services. We collect information automatically such as your IP address when you use the Services, including when you browse our Site. To the extent that you use certain features of the Site, such as the “Feedback” or “Contact Us” feature, we will collect the personal information that you provide us, which may include your email address or social media username.

Server logs. Server logs automatically record information and details about your online interactions with us. For example, server logs may record information about your visit to our Services on a particular time and day and collect information such as your device ID and IP address.

Cookies. We also use cookies on the Services. Cookies are small files that are stored on your device through the Services. A cookie allows the Services to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect or store information about your use of the Services during your current session and over time (including the pages you view and the files you download), your mobile device’s operating system, your IP address, and your general geographic location.

Pixel tags. A pixel tag (also known as a web beacon, clear graphics interchange format (GIF), pixel, or tag) is an image or a small string of code that may be placed in an advertisement or email. It allows companies to set or read cookies or transfer information to their servers when you load a webpage or interact with online content. For example, we or our service providers may use pixel tags to determine whether you have interacted with a specific part of our Services.

SDKs and mobile advertising IDs. Our Services may include third-party software development kits (“SDKs”) that allow us and our service providers to collect information about your activity. In addition, some mobile devices come with a resettable mobile advertising ID (such as Apple’s IDFA and Google’s Advertising ID) that, like cookies and pixel tags, allow us and our service providers to identify your mobile device over time for advertising purposes.

Third-party plugins. Our Services may include plugins from other companies, including social media companies. These plugins may collect information, such as information about the pages you visit, and share it with the company that created the plugin even if you do not click on the plugin. These third-party plugins are governed by the privacy policies and terms of the companies that created them. Conduct second level review of documents for responsiveness, privilege, and noteworthiness.

Third-party online tracking. We also may partner with certain third parties to collect, analyze, and use some of the personal and other information described in this section. For example, we may allow third parties to set pixels and mobile advertising IDs through the Services. This information may be used for a variety of purposes, including analytics of our Services, as discussed below (see the section entitled “With Whom and Why We Share Your Information”).

Aggregated and deidentified information. We may also aggregate or de-identify information about your use of our Services, such as the pages you visit or your transactions, and share that information with third parties. Such aggregated or de-identified information will not identify you personally.

How We Use and Process Your Information

We use and process your information to:

• Provide you with the Services, including to provide you access to our Services content, and to administer our platform;
• Respond to your inquiries and provide you with technical support;
• Improve and personalize our Services, collect analytics, optimize our platform, and your user experience;
• Serve advertisements and market our Services;
• Market and recommend communities or offers that we believe may interest you;
• Measure the effectiveness of our advertisements and the messages that we send;
• Aggregate and de-identify information and profile data;
• Communicate with you through our social media plugins or our Services;
• Comply with legal and/or regulatory requirements; and
• Manage our business.

With Whom and Why We Share Your Information

We share your information with other parties for a variety of purposes related to the operation of our business, as described below.

Member communities. We share information with communities, so that they can issue and view your membership information, provide you with community services and benefits, manage your membership transactions, and so that they can market their products and services to you.

Private communities. We share information with private communities, so that they can view your membership information such as if you are on a waitlist to join the private community, approve your membership, provide you with private community services and benefits, manage your membership transactions, and so that they can market their products and services to you.

Other members or users. When you share personal information or otherwise interact in the public areas of our Services, such information may be viewed by all users. We also share information with other uses that you choose to message with through the platform.

Third-party service providers. Universe uses third-party service providers that perform services on our behalf, including, payment systems, web-hosting companies, IT infrastructure and support, marketing, and other similar services. These service providers may collect and/or use your information, including information that identifies you personally, to assist us in achieving the purposes discussed above. Our service providers are not allowed to use information about you for their own purposes and are contractually obligated to maintain confidentiality.

Analytics. We partner with certain third parties to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use server logs or pixel tags, and they may set and access cookies on your computer or other device. In particular, the Services use Google Analytics to help collect and analyze certain information for the purposes discussed above. You may opt out of the use of cookies by Google Analytics here.

Interest-based advertising. The Services also enable third-party tracking mechanisms to collect information about you and your computing devices for use in online interest-based advertising. For example, third parties, such as Facebook, may use the fact that you visited our Services to target online ads to you about our Services. In addition, our third-party advertising networks might use information about your use of our Services to help target advertisements based on your mobile activity in general. For information about interest-based advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.

The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer or other device, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance by opting out here. Although our Services currently do not respond to “do not track” browser headers, you can limit tracking through these third-party programs and by taking the other steps discussed above.

If you use the Services through your mobile device, you may also opt-out of interest-based by adjusting the advertising preferences on your mobile device. You may further opt out for companies that participate in the Digital Advertising Alliance's AppChoices tool by downloading it here and following the instructions on the website.

Legal purposes. We also may use or share your information with third parties, including government agencies or other regulatory bodies and law enforcement officials, when we believe, in our sole discretion, that doing so is necessary:

• To comply with applicable law, including, a court order, subpoena, or other legal process or otherwise cooperate with appropriate law enforcement or regulatory investigations;
• To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
• To establish, protect, or exercise our legal rights or defend against legal claims; or
• To facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.

Your Privacy Choices

If you want to learn more about the personal information that Universe has about you, or you would like to update, change, or delete that information, please contact us at contact@universe.club.

If you are a resident of a jurisdiction with an applicable data privacy law, you may have certain rights available to you in relation to your personal information. These rights may include:

• The right to be informed about our data collection practices;
• The right to access and correct your data;
• The right to erase or delete your data;
• The right to data portability;
• The right to opt out of the sale or sharing of your information;
• The right to opt out of targeted advertising;
• The right to opt-out of marketing emails and text messages;
• The right to limit our use of any automated decision-making processes; and
• The right to withdraw consent (to the extent applicable).

To exercise any of the rights listed above, please contact us via email at contact@universe.club. We will respond to your request as soon as reasonably possible and within the timeframe required under applicable law. Prior to complying with your request, we will first verify your identity by comparing the information you provide with the information we have on file for you.

Additionally, you may authorize an agent to make a request on your behalf. To designate an agent, please provide a written and signed document by both you and the agent that authorizes the agent to act on your behalf. You may also use a power of attorney. We will still require you to provide information to allow us to reasonably verify that you are the person about whom we collected personal information.

Depending on your jurisdiction, you may have also have the right to appeal our decision regarding your data privacy rights, as well as the right to lodge a complaint to your supervisory authority.

Email Communications

Email is an important communication channel for us. We may use your email address to send you information about your transactions on the platform as well as services and products that we believe may be of interest to you. If you do not want to receive marketing emails, you may opt out from receiving our communications through your account settings, by emailing us at contact@universe.club, or by selecting to unsubscribe as may be provided in the applicable correspondence.

External Links

Our Site may contain links to third-party websites or services. If you use these links, you will leave our Services. We have not reviewed these third-party websites and do not control and are not responsible for any of these sites, their content, or their privacy policy. Thus, we do not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third-party sites through our Services, you do so at your own risk.

Data Security

We employ physical, technical, and administrative procedures to safeguard the personal information we collect online. However, no website is 100% secure, and we cannot ensure or warrant the security of any information you transmit to the Services or to us. You transmit such information at your own risk.

Data Retention

We retain personal information about you necessary to fulfill the purpose for which that information was collected or as required or permitted by law. We do not retain personal information longer than is necessary for us to achieve the purposes for which we collected it. When we destroy your personal information, we do so in a way that prevents that information from being restored or reconstructed.

International Transfers

The information that we collect through or in connection with our Services is transferred to and processed in the United States for the purposes described above. We may also subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using the Services or by providing any personal or other information to us, you expressly consent to such transfer and processing.

Minors

Our Services are intended for adult use. We do not knowingly collect personally identifiable information from children under the age of 13. If a parent or legal guardian becomes aware that his or her child is using our Services, or has provided us with any personally identifiable information, such parent should contact us at contact@universe.club. We will promptly delete such information along with the child’s registered account.

Updates to this Policy

Universe reserves the right to modify its Policy at any time, for any reason. Universe will post all such changes on the Site. We encourage you to review this page periodically to review the current Policy in effect.

How to Contact Us

Should you have any questions or concerns about this Policy, you can contact us by, sending us an email at contact@universe.club or by mail at:

Universe Platform Inc.

69 Charlton St.

New York, NY 10014