Privacy Policy

Last Updated: March 17, 2026

Introduction

This Privacy Policy (the "Privacy Policy" or "Policy") describes the types of information Tempo Labs Technologies, Inc. dba Tempo and its affiliates ("Tempo," "we," "our," or "us") collects and processes from and about you when you use our website or any other online services we make available (collectively, the "Services").

By using the Services, you are agreeing to the practices described in this Privacy Policy. If you do not agree to the practices described in this Privacy Policy, please do not access or use the Services.

Undefined capitalized terms used herein shall have the meaning set forth in the Tempo Terms of Use.

Information We Collect

We collect information about you when you use our Services. The types of information we collect depend on how you use our Services. We need certain types of information to provide the Services to you. If you do not provide us with such information, or if you ask us to delete that information, you may no longer be able to access or use certain Services.

The information we collect may include data you directly provide to us, data we obtain automatically from your interactions with our Services, and data we obtain from other sources.

Information You Provide Directly to Us

We may collect information directly from you when you use the Services, including when you communicate with us or use our Services. The types of information we may collect from you directly include: (1) wallet address; (2) email address; (3) phone number; (4) information in communications with us; and (5) information related to requests and transactions you make with your self-custodial wallet.

Information We Collect Automatically

We or our third-party vendors may also collect certain information about your use of the Services and the devices you use to access the Services, including through cookies and other tracking technologies. This information may include your IP address, browser types, browser language, operating system, the state or country from which you accessed the Services, software and hardware attributes (including device IDs), referring and exit pages and URLs, platform type, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on our sites, the date and time you used the Services, error logs, and other similar information.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline cookies if you prefer. If you disable cookies, you may be prevented from taking full advantage of the Services, because the Services may not function properly. As we adopt additional technologies, we may also gather additional information through other methods.

Information We Collect from Other Sources

When you submit transactions to a blockchain network through the Services, your wallet address, transaction amounts, and other transaction data are permanently and publicly recorded on that blockchain network. This data is not controlled by Tempo and cannot be modified, hidden, or deleted by Tempo or by you. Your rights to access, correction, and deletion described in this Policy apply only to information controlled by Tempo and do not extend to data recorded on public blockchain networks.

We may collect information about you from other parties. For example, we may collect information when you communicate with us on third-party platforms, such as Telegram and X. We may combine information that we collect from you through the Services with information that we obtain from other parties and information derived from other products or services we provide.

How We Use Your Information

We may use your information to:

• Provide the Services.
• Administer and troubleshoot the Services.
• Personalize and improve the Services.
• Analyze, improve, modify, customize, and measure the Services.
• Provide support, and otherwise to respond to your comments, questions, and requests.
• Communicate with you about Tempo’s products, experiments, services, surveys, events, content, and other news and information we think may be of interest to you.
• Comply with our legal obligations or as permitted by law.
• Protect the safety and/or integrity of our users, employees, third parties, members of the public, and/or our Services, including to prevent, detect, investigate, and respond to fraud, unauthorized access/use of the Services, breaches of terms and policies, or other wrongful behavior.
• Enforce our Terms of Use and any other agreements between you and Tempo.
• As directed by you and/or to carry out any other purpose disclosed to you at or before the time of collection.

We may combine information that we collect from you through the Services with information that we obtain from other sources. We may also aggregate and/or de-identify information collected through the Services. We may use and disclose de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes.

When We Disclose Your Information

We may disclose your information for various reasons as described below.

• Vendors. We may disclose your information to employees, consultants, and other vendors who need access to such information to carry out work or perform services on our behalf, such as those who provide data storage, payment, technology support and services, customer service, analytics, fraud prevention, legal services, and marketing services.
• Affiliates. We may disclose your information to our affiliates.
• Safety and Law Enforcement. We may need to disclose or provide access to information if Tempo has a good faith belief that such action is necessary to (i) comply with the law; (ii) comply with legal processes or governmental requests; (iii) prevent, investigate, detect, or prosecute criminal offenses or attacks on the technical integrity of our website or our network; and/or (iv) to protect the rights, property, safety and security of Tempo, our employees, our users, and/or the public.
• Business Transactions. We may disclose your information in connection with, or during negotiations of, any merger, acquisition, sale of assets or any business, other change of control transaction or financing; between any future parent, subsidiary, and/or affiliated company.
• At Your Direction/Consent. We may disclose your information as otherwise permitted or required by law or as authorized by you.
• Aggregate/De-Identified Information. We reserve the right to create aggregate/de-identified data from the information we collect through the Services and our disclosure of such aggregate/de-identified data is at our discretion.

Analytics

We may use third-party web analytics services on the Services, such as PostHog. These service providers use the sort of technology described in the "Information we collect automatically" section above to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services.

Do Not Track Statement

Our website does not respond differently or limit its practices under the terms of this Policy when you access our site with a browser that uses a do not track signal.

Third Party Websites or Services

Tempo may maintain links or access to other websites or services and other websites may maintain links to the Services. This Privacy Policy applies only to the Services and not to other websites or services accessible from Tempo or that you use to access Tempo, each of which may have privacy policies materially different from this Privacy Policy. If you visit other websites or use other services, directly or through any software, automated system, smart contract, artificial intelligence model, machine learning model, or AI agent ("AI Systems"), Tempo is not responsible for the privacy practices or content of those sites or services. It is your responsibility to review the privacy policies of non-Tempo websites and services to confirm that you understand and agree with them.

Your Choices

• Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. The method for disabling cookies may vary by device and browser, but can usually be found in your device or browser preferences or security settings. If you choose to remove or reject cookies, this could affect the availability and functionality of the Services.
• Marketing Emails. You may opt out of receiving marketing emails from us by following the instructions in those marketing emails. If you choose to opt out, we will still send you non-marketing communications, such as those about your account or our ongoing business relations.

Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information. These may include the right to:

• Access the personal information we hold about you.
• Correct inaccurate or incomplete personal information.
• Delete your personal information, subject to certain exceptions.
• Receive a copy of your personal information in a portable format.
• Object to or restrict certain processing of your personal information.
• Withdraw consent where we rely on your consent to process your information.
• Opt out of the sale or sharing of your personal information for cross-context behavioral advertising (Tempo does not engage in this practice).
• Not be discriminated against for exercising your rights.

To exercise any of these rights, please contact us at support@tempo.xyz. We may need to verify your identity before processing your request and will respond within the timeframe required by applicable law. You also have the right to lodge a complaint with a data protection authority in your jurisdiction if you believe your rights have been violated.

Please note that information recorded on public blockchain networks cannot be modified or deleted by Tempo, and these rights do not extend to such data.

Data Security

We maintain administrative, technical, and physical safeguards that are designed to protect the privacy and security of personal information. However, the internet and blockchains are not a fully secure environment, and we cannot ensure or warrant the security of any information transmitted to or generated by Tempo in connection with the Services or any other service offered by Tempo.

Data Retention

We retain your personal information for as long as necessary to provide the Services, fulfill the purposes described in this Policy, and comply with our legal obligations. The specific retention period depends on the type of information and the purpose for which it was collected. When your information is no longer needed, we will delete or anonymize it in accordance with applicable law.

As a reminder, information recorded on public blockchain networks is permanent and cannot be deleted by Tempo or by you, regardless of any retention period that would otherwise apply.

Personal Information of Children

The Services and Tempo's other services are not directed to individuals under the age of 18 ("Minors"). We do not knowingly solicit or collect personal information about Minors. If you are a parent or guardian and you learn that your Minor has provided us with personal information, please contact us. If we discover that a Minor has provided us with personal information, we will delete such information if required by applicable law.

Notice to California Residents - Shine the Light

Under California Civil Code Section 1798.83 (also known as the "Shine the Light" law), users who are residents of California may request information regarding the disclosure of their personal information by us to third parties for the third parties' direct marketing purposes.

Notice to Persons Located Outside the United States - Data Transfer

If you are located in the European Economic Area, United Kingdom, or other regions with data protection laws, please note that we may transfer your personal information to countries outside your jurisdiction, including the United States, that may not provide the same level of data protection as your home country.

Where required by applicable law, we implement appropriate safeguards for such transfers, including Standard Contractual Clauses approved by the European Commission and, where applicable, reliance on the EU-U.S. Data Privacy Framework or other lawful transfer mechanisms. We also implement appropriate technical and organizational measures to protect your personal information.

You may contact us for additional information about these safeguards.

Legal Basis for Processing - EEA and UK Users

For users in the European Economic Area or the United Kingdom, we process personal information on the following legal bases:

• Contract Performance: to provide the Services you have requested, process transactions, and manage your access to the Services.
• Legitimate Interests: to improve and personalize the Services, conduct analytics, prevent fraud, and ensure the security of the Services, where our interests are not overridden by your rights.
• Legal Obligation: to comply with applicable laws, regulations, and legal processes.
• Consent: for specific activities such as marketing communications. You may withdraw consent at any time by contacting us at support@tempo.xyz or following the opt-out instructions in any marketing communication. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

Changes to the Privacy Policy

We may change this Policy to reflect changes in the law, our information practices, or the features of the Services. At the top of our Policy, we will indicate the date of the most recent update. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Policy.

Contact Us

If you have questions or concerns regarding this Privacy Policy, you should contact us by email at support@tempo.xyz.