Privacy Policy

This Privacy Policy is designed to help you understand how Sui Foundation, its subsidiaries and affiliates (collectively called “Sui Foundation”, “we,” “us,”) collects, uses, and shares your personal information and to help you understand and exercise your privacy rights in accordance with applicable law, including, but not limited to, the Cayman Islands Data Protection Act and, in respect of any EU data subjects, the EU General Data Protection Regulation (together, the “Data Protection Legislation”). This Policy applies when you use our websites contact our team members, engage with us on social media or otherwise interact with us. If you are an individual, this will affect you directly. If you are an entity that provides us with personal information on individuals connected to you, this will be relevant for those individuals, and you should transmit this Privacy Policy to such individuals or otherwise advise them of its content.

Disclosure Regarding the California Consumer Privacy Act (Notice at Collection). For information on our processing of personal information that is subject to the California Consumer Privacy Act (“CCPA”), please see Annex A – Supplemental CCPA Privacy Notice.

This Privacy Policy applies to personal information processed by Sui Foundation, including on our websites (including www.sui.io, bridge.testnet.sui.io, suins.io and suilink.io), and other online and offline offerings which link to this Privacy Policy. Such websites and offerings are collectively called the “Services.” For clarity, the Services do not include, the Sui Wallet mobile application, the Protocol or any other decentralized aspect of the Sui Blockchain that is not controlled by Sui Foundation due to the decentralized nature of the Sui Blockchain.

We may revise this Privacy Policy from time to time in our sole discretion. If there are any changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

The categories of personal information we collect depend on how you interact with us, our Services and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

• Account Creation. We may collect information if you create an account with us, such as your name, username, email address, or password.

• Wallet and Transaction Information. In order to engage in transactions on the Services, you may need to provide us or our third-party payment processors with access to or information about your digital wallet. We will never ask you for or collect your private keys.
  

• Other Transactions. We may collect personal information and details associated with your activities on our Services, including to deliver you your rewards associated with your use of the Services.
  

• Your Communications with Us. We may collect personal information, such as email address when you request information about our Services, register for our newsletter or marketing promotions, request customer or technical support, apply for a job or otherwise communicate with us.
  

• Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., via the Sui Foundation community, ambassador programs, commenting functionalities, forums, blogs, and social media pages). Any personal information you provide on the public sections of these features will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.
  

• Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
  

• Sweepstakes, Giveaways or Contests. We may collect personal information you provide for any sweepstakes, giveaways or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
  

• Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
  

• Business Development and Strategic Partnerships. We may collect personal information
from individuals and third parties to assess and pursue potential business opportunities.

• Job Applications. We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use this information to assess your qualifications.

• Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), Internet service provider, and metadata about the content you provide. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.

• Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.
  

• Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
  

• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
  

• Third-Party Sources. We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.

• Blockchain Information. We may obtain personal information about you through our analysis of blockchain information.

• Referrals, Sharing and Other Features. Our Services may offer various tools and functionalities that allow you to provide information about your friends through our referral service; third parties may also use these services to upload information about you. Our referral services may also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).

We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

• Managing your information and accounts;

• Verify your identity in accordance with applicable know-your-customer, money- laundering and other financial sector legislation or regulations;

• Facilitating transactions you enter into;

• Providing access to certain areas, functionalities, and features of our Services;

• Answering requests for customer or technical support;

• Communicating with you about your account, activities on our Services, and policy changes;

• Processing information about your wallet to facilitate transfers or transactions via the Services;

• Processing applications if you apply for a job, ambassador program, or other similar opportunities we post on our Services;

• Allowing you to register for events.

• Pursuing our legitimate interests such as direct marketing, research and development
(including marketing research), network and information security, and fraud prevention;

• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal
activity, and prosecuting those responsible for that activity;

• Carrying out analytics;

• Creating de-identified and/or aggregated information. If we create or receive de-identified information, we will not attempt to reidentify such information, unless
permitted by, or required to comply, applicable laws;

• Measuring interest and engagement in our Services;

• Improving, upgrading or enhancing our Services;

• Developing new products and Services;

• Ensuring internal quality control and safety;

• Authenticating and verifying individual identities, including requests to exercise your
rights under this Privacy Policy;

• Debugging to identify and repair errors with our Services;

• Auditing relating to interactions, transfers, transactions, and other compliance activities;

• Sharing personal information with third parties as needed to provide the Services;

• Enforcing our agreements and policies; and

• Carrying out activities that are required to comply with our legal obligations.

We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

Notice Regarding Use of the Blockchain. Aspects of our Services may be hosted on or interact with the blockchain. Where you use aspects of our Services that are hosted on or interact with the blockchain, information about your interactions and/or transactions will be provided to the applicable blockchain network and may be accessible to third parties due to the nature of the blockchain protocol. Because entries to the Sui Blockchain are, by their nature, public, and because it may be possible for someone to identify you through your pseudonymous, public wallet address using external sources of information, any transaction you enter onto the Sui Blockchain could possibly be used to identify you, or information about you.

• Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers and vendors that provide us with IT support, hosting, customer service, and related services.

• Google Analytics. For more information about how Google uses your data (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.

• Microsoft Clarity. We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

• Business Partners. We may share your personal information with business partners to
provide you with a product or service you have requested. We may also share your
personal information to business partners with whom we jointly offer products or
services.

• Affiliates. We may share your personal information with members of our corporate affiliates.

• Other Users of the Services and Parties You Transact With. Some of your personal
information may be visible to other users of the Services (e.g., information featured on
generally accessible parts of your profile; usernames of other Sui Foundation Services
users). In addition, to complete transfers via the Services, we will need to share some of
your personal information with the party that you are transacting with.

• Advertising Partners. We may share your personal information with third-party
advertising partners. These third-party advertising partners may set Technologies and
other tracking tools on our Services to collect information regarding your activities and
your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day).
These advertising partners may use this information (and similar information collected
from other services) for purposes of delivering personalized advertisements to you when
you visit digital properties within their networks. This practice is commonly referred to as
“interest-based advertising”, “targeted advertising,” “personalized advertising,” or
“cross-context behavioral advertising.

Your Privacy Choices. The privacy choices you may have about your personal information are
determined by applicable law and are described below.

• Email Communications. If you receive an unwanted email from us, you can use the  unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transfer-related emails regarding Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms of Service or this Privacy Policy).

• Text Messages. You may opt out of receiving text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us.

• Mobile Devices. We may send you push notifications through our mobile application. You
may opt out from receiving these push notifications by changing the settings on your mobile
device. With your consent, we may also collect precise location-based information via our
mobile application. You may opt out of this collection by changing the settings on your mobile device.

• “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

• Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.
  
  The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
  
  Please note you must separately opt out in each browser and on each device.


Your Privacy Rights. In accordance with applicable law, you may have the right to:

• Be informed about the purposes for which your personal data are processed;

• Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; or (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (aka the right of data portability);

• Stop direct marketing;

• Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;

• Request Deletion of your personal information in some limited circumstances;

• Request to Opt-Out of Certain Processing Activities including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in “profiling” in furtherance of certain “decisions that produce legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws);

• Request Restriction of or Object to our processing of your personal information, including where the processing of your personal information is based on our legitimate interest or for direct marketing purposes;

• Withdraw Your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal;

• Be informed of a personal information breach (unless the breach is unlikely to be prejudicial to you); and

• Complain, including to the Cayman Islands Data Protection Ombudsman;

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take commercially reasonable steps to verify your identity before fulfilling requests submitted under applicable privacy laws. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to confirm the email address we have associated with you.

Only you, or someone legally authorized to act on your behalf in certain jurisdictions, may make a request to exercise the rights listed above regarding your personal information. If your personal information is subject to a law that allows an authorized agent to act on your behalf in exercising your privacy rights and you wish to designate an authorized agent, please provide written authorization signed by you and your designated agent using the information found in “Contact Us” below and ask us for additional instructions.

Some laws may allow you to appeal our decision if we decline to process your request. If applicable laws grant you an appeal right and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries which may not offer equivalent protection of personal information as under the Data Protection Legislation and otherwise may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws, including Data Protection Legislation and, in such cases, we will process personal information or procure that it be processed in accordance with the requirements of the Data Protection Legislation, which may include having appropriate contractual undertakings in legal agreements with service providers who process personal information on our behalf.


If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.


For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.


To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.


We expect to delete your personal information (at the latest) once there is no longer any legal or regulatory requirement or legitimate business purpose for retaining your personal information.

The Services are not directed to children under 16 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth in “Contact Us” below. If we learn that we have collected a child’s personal information in violation of applicable law, we will promptly take steps to delete such information unless we have a legal obligation to keep it.

The Services may contain links to other websites/applications (such as GitHub) and other websites/applications may reference or link to our Services or the Services may allow you to interact with third-party services, such as cryptocurrency exchanges. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the third party’s actions or omissions, including but not limited to their privacy practices, content of such other websites or applications, and errors or bugs in their software. Providing personal information to third-party websites or applications is at your own risk.

Sui Foundation is the controller of the personal information we process under the Privacy Policy.

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:


Sui Foundation

9 Forum Lane, Camana Bay, Suite 3119

Grand Cayman KY1-9006, Cayman Islands

privacy@sui.io

This Supplemental CCPA Privacy Notice supplements our Privacy Policy and only applies to our processing of personal information that is subject to the CCPA.

• Personal Information Collected. See the section of this Supplemental CCPA Privacy Notice titled “Overview of Personal Information Collected, Disclosed, Sold and/or Shared” for a list of personal information which may be collected. If we have previously collected personal information in the past 12 months, we may collect that personal information from you.

• Uses of Personal Information. See the section of this Supplemental CCPA Privacy Notice titled “Uses of Personal Information” for a list of the purposes for which we use personal information.

• Is Personal Information “Sold” or “Shared” for “Cross-Context Behavioral Advertising”? Yes. See the section of this Supplemental CCPA Privacy Notice titled “Overview of Personal Information Collected, Disclosed, Sold and/or Shared” for more details. If we have previously “sold” personal information or “shared” personal information for “cross-context behavioral advertising” in the past 12 months, we may “sell” or “share” that personal information if collected from you. See the section of this Supplemental CCPA Privacy Notice titled “Right to Opt Out of ‘Sales’ of Personal Information and/or ‘Sharing’ for ‘Cross-Context Behavioral Advertising’ for instructions on how to opt-out of these activities.

• How Long is Personal Information Retained For? To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

• Additional Information. For more information on our privacy practices, please review this Supplemental CCPA Privacy Notice and our Privacy Policy. Importantly, the section of our Privacy Policy titled “Your Privacy Rights” includes important details about how you can exercise some of the rights which you have under the CCPA.

• Providing the Services as further described in our Privacy Policy;

• Processing for administrative purposes as further described in our Privacy Policy;

• Processing for marketing purposes as further described in our Privacy Policy;

• Processing with your consent or direction as further described in our Privacy Policy;

• Auditing related to counting ad impressions to unique visitors, verifying positioning and
quality of ad impressions, and auditing compliance with this specification and other
standards;

• Helping to ensure security and integrity to the extent the use of personal information is
reasonably necessary and proportionate for these purposes;

• Debugging to identify and repair errors that impair existing intended functionality;

• Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with Sui Foundation;

• Maintaining or servicing accounts, providing customer service, processing or fulfilling
orders and transactions, verifying customer information, processing payments, providing
financing, providing analytic services, providing storage, or providing similar Services;

• Providing advertising and marketing services;

• Undertaking internal research for technological development and demonstration;

• Undertaking activities to verify or maintain the quality or safety of a service or device that
is owned, manufactured, manufactured for, or controlled by Sui Foundation, and to
improve, upgrade, or enhance the service or device that is owned, manufactured,
manufactured for, or controlled by Sui Foundation.

• To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.

• To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted personal information.

• To resist malicious, deceptive, fraudulent, or illegal actions directed at Sui Foundation and to prosecute those responsible for those actions.

• To ensure the physical safety of natural persons.

• For short-term, transient use;

• Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services.

• To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by Sui Foundation, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by Sui Foundation.

• For purposes that do not infer characteristics about individuals.