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Privacy

PON NETWORK Privacy Policy

Current version: [June] 2023


  1. Introduction and Overview.

This Privacy Policy (the " Privacy Policy") provides a comprehensive description of how ABSTRACT SYSTEMS SEZC, a Cayman Islands company with limited liability and having its registered office situated Block 14BG, Parcel 23,91, Strathvale House, 90 North Church Street, George Town, Grand Cayman, Cayman Islands (" Abstract", " PON", " PON Network", " we", " us" or " our") collects, uses, and shares information about you in connection with the website at https://www.pon.network/ and any affiliated sub-websites, products and applications (the " Site"), as well as your rights and choices regarding such information. These terms apply to the Site and any other online location that links to this Privacy Policy, including in connection with any interaction with its protocols that allows the validation of transactions between blockchains (the " PON Network") (collectively, the " Platform Services"). It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them. It is designed to reflect the requirements of applicable privacy laws, including the Cayman Islands Data Protection Act (DPA), and the General Data Protection Regulations in the European Economic Area and the United Kingdom (" GDPR").

By accessing or using the Site, you agree to our Terms of Service (the " Terms") and understand that the Terms represent a binding agreement between you and us. By using the Platform Services, you also agree to our collection, use, and disclosure practices, as well as any other activities described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, you should immediately discontinue the use of the Platform Services and refrain from accessing the Site. If you have any questions or wish to exercise your rights and choices, please contact us at the email or postal address set forth in the "Contact Us" section below.


  1. Changes to Privacy Policy.

We reserve the right to revise and reissue this Privacy Policy anytime. Any changes will be effective immediately upon our posting of the revised Privacy Policy. For the avoidance of doubt, your continued use of the Platform Services indicates your consent to the revised Privacy Policy then posted.


  1. Information Collection.

The GDPR requires a "lawful basis" for the collection and processing of personal data. Our lawful bases include where: (i) you have given consent to the collection and/or processing for one or more specific purposes, either to us or to our service providers or partners; (ii) collection and/or processing is necessary for you to access the Platform Services; (iii) collection and/or the processing is necessary for compliance with a legal obligation, or (iv) collection and/or processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third parties subject to appropriate or suitable safeguards, such as standard contractual clauses.

We may collect the following information about you when you use the Platform Services:

  1. content, within any messages you send to us (such as feedback and questions to information support); and
  2. ther information you voluntarily provide, and, in such instances, you are solely responsible for such information.

Although, at this time, we do not automatically collect information from you when you access the Site, it is possible that we may in the future. We would utilize this information to operate and ensure the security, reliability, and robust performance of our Platform Services.

We may also use tracking technologies to automatically collect information including:

  1. Log Files , which are files that record events that occur in connection with your use of the Site. Log files are created when you view content or otherwise interact with the Platform Services.
  2. Cookies , which are small data files stored on your device that act as a unique tag to identify your browser. We will only use strictly necessary cookies in connection with the Site and Platform Services. For the avoidance of doubt, the cookies that we include are essential for you to browse the Site and use its features, including accessing secure areas of the Site.

For further information on how we use tracking technologies for analytics, and your rights and choices regarding them, please see the "Analytics" and "Your Rights and Choices" sections below.


  1. Use of Information.

We do not anticipate using, but we may collect and use the information for business purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information include:

  1. Operating and managing the Platform Services, including:

    1. performing services requested by you, such as responding to your comments, questions, and requests, and providing information support;
    2. sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
    3. detecting, preventing, and addressing fraud, breach of Terms, and threats, or harm; and
    4. compliance with legal and regulatory requirements.

  2. Protecting the security and integrity of the Platform Services, including:

    1. improving the Platform Services and other websites, apps, products, and services;
    2. conducting promotions, such as hack-a-thons, including to verify your eligibility and deliver prizes in connection with your entries; and
    3. fulfilling any other business purpose, with notice to you and your consent.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices with respect to how we use information about you, please see the "Your Rights and Choices" section below.

  1. Sharing and Disclosure of Information.

If we share or disclose information that we collect, we do so in accordance with the practices described in this Privacy Policy. The categories of parties with whom we may share information include:

  1. Affiliates. We share information with our affiliates and related entities, including where they act as our service providers or for their own internal purposes.
  2. Service Providers. We share information with third-party service providers for business purposes, including fraud detection and prevention, security threat detection, payment processing, customer support, data analytics, information technology, storage, and transaction monitoring. Any information shared with such service providers is subject to the terms of this Privacy Policy. All service providers that we engage with are restricted to only utilizing the information on our behalf and in accordance with our instructions.
  3. Professional Advisors. We share information with our professional advisors for purposes of audits and compliance with our legal obligations.
  4. Security and Compelled Disclosure. We share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities.
  5. Consent. We may share information about you with your consent.

Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the "Your Rights and Choices" section below.


  1. Other Parties.

We may integrate technologies operated or controlled by other parties into parts of the Platform Services. For example, the Platform Services may include links that hyperlink to websites, platforms, and other services not operated or controlled by us. Please note that when you interact with other parties, including when you leave the Site, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and where they store information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.


  1. Analytics.

We may allow others to provide analytics services and serve advertisements on our behalf across the Internet and in applications. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Site or the Interface and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked and conversion information. This information may be used by Abstract systems and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests the Site and the Interface, and other websites, and better understand your online activity. For more information about interest-based ads, or to opt-out of having your web browsing information used for behavioral advertising purposes, please visitwww.aboutads.info/choices.


  1. Cookies.

We will only use strictly necessary cookies. These cookies are essential for you to browse the Site and use its features, including accessing secure areas of the Site

Do Not Track. Your browser settings may allow you to automatically transmit a "Do Not Track" signal to the online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to "Do Not Track" signals.

Essential Site Functions Cookies: These cookies are necessary to allow you to browse the Site and use Site functions. Without these cookies, the Site would not function properly. The data processed by this type of cookie is more of a technical than a personal nature and concerns e.g. the type and settings of your device.

Analytical cookies

We use analytical cookies to see, for example, which content on the Site is highly frequented and also to analyze if content should be updated or improved. These cookies are also used to provide you with personalized content based on the pages you have shown interest in. These cookies process and save data like your browser type, referrer URLs, operating system, date/time stamp, views and clicks on the Site, and your (truncated) IP address. We use these cookies only if you have consented via our cookie settings page.

You can manage/disable/delete the cookies set by our website - please find the relevant instructions from your browser provider, for easy reference here below are links on how to implement the deletion in major browsers:

For Google Chrome browser please refer here

For Firefox browser please refer here

For Safari browser please refer here

For Microsoft Edge browser please refer here


  1. Data Security.

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.


  1. International Transfer.

The personal data we collect will be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations, in particular, the Cayman Islands. If you are located in the European Economic Area (" EEA") or the United Kingdom, we commit to complying with the safeguards set out in Commission Implementing Decision (EU) 2021/914 of 4 June 2021 (the " Standard Contractual Clauses") as a data importer, and you can enforce your rights against us as a data subject as set out in the Standard Contractual Clauses. If you are in the United Kingdom, the Standard Contractual Clauses will be deemed amended to the extent necessary to apply in the context of the UK's privacy legislation. Onward transfers of your personal information to recipients outside the EEA or United Kingdom will be made pursuant to appropriate safeguards, including:

(i) ensuring that recipients or the country in which they are located are deemed to provide adequate protection for personal information by the European Commission or, where applicable, under the UK Data Protection Act 2018 or regulations made by the UK Secretary of State; and

(ii) ensuring that transfers are subject to the Standard Contractual Clauses.

We will take appropriate steps to ensure that your personal data is treated securely and in accordance with applicable law and this privacy notice regardless of where it is processed. If you wish to enquire further about the safeguards we use, please contact us using the details set out in the section "Contact Us" below.


  1. Your Rights.

In accordance with applicable privacy law you have the following rights in respect of the personal information that we hold:

  1. Right of access.

You have the right to obtain:

(i) confirmation of whether, and where, we are processing your personal information;

(ii) information about the categories of personal information we are processing, the purposes for which we process your personal information, and information as to how we determine applicable retention periods;

(iii) information about the categories of recipients with whom we may share your personal information; and

(iv) a copy of the personal information we hold about you.

  1. Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

  2. Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.

  3. Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified. Notwithstanding the foregoing, we cannot edit or delete information that is stored on a particular blockchain. This information may include transaction data (i.e., purchases, sales, and transfers) related to your blockchain wallet address and any NFTs held by your wallet address.

  4. Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you. You also have a right to object to any processing based on our legitimate interests. There may, depending on the particular circumstances, be compelling reasons for continuing to process your personal information despite your objection, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

  5. Complaint. You also have the right to lodge a complaint to your national data protection authority:

(a) If you are in the Cayman Islands, you have the right to complain to the Data Protection Ombudsman of the Cayman Islands. You can access their website here: ombudsman.ky.

(b) If you are in the UK, the relevant authority is the Information Commissioner's Office – please see https://ico.org.uk/make-a-complaint/ for more information.

(c) If you are in the European Economic Area, further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data protection/bodies/authorities/index_en.htm.

To exercise any of these rights, please contact us via our email or postal address listed in the "Contact Us" section below and specify which right you are seeking to exercise. We will respond to your request within thirty (30) days. We may require specific information from you to help us confirm your identity and process your request. Please note that we retain information as necessary to fulfill the purpose for which it was collected and may continue to retain and use information even after a data subject request in accordance with our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.


  1. Contact Us.

If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us:

By email: [email protected]

By mail

ABSTRACT SYSTEMS

Block 14BG, Parcel 23,91, Strathvale House,

90 North Church Street, George Town, Grand Cayman, Cayman Islands