Privacy Policy

Polar Bear Express Inc. (“Company,” “we,” “our,” or “us”), a Delaware corporation registered in the State of Colorado with its principal place of business at 792 Pine Brook Rd, Boulder, Colorado 80304, operates the web-based interfaces located at pbx.earth and terminal.pbx.earth (collectively, the “Interface”). This Privacy Policy describes our practices with respect to the collection, use, storage, disclosure, and protection of information we receive from users of the Interface.

This Privacy Policy applies solely to information collected through the Interface and does not apply to information collected through any other channel, including without limitation information collected by Third-Party DEXs (as defined in our Terms of Service), the PurpleAir sensor network, or any other third-party service.

The Interface is designed to minimize data collection. We do not require account creation or registration, do not conduct know-your-customer (KYC) or identity verification procedures, and do not collect payment card or banking account information. Public wallet addresses on the Solana blockchain are pseudonymous identifiers that are not, on their own, considered personal information under most applicable privacy frameworks.

We use the information we collect for the following purposes:

• (a)to operate, maintain, monitor, and improve the Interface and its underlying infrastructure;
• (b)to display relevant on-chain and off-chain data to connected Wallets, including token balances, transaction history, leaderboard standings, competition eligibility, and Signals;
• (c)to enforce the geographic access restrictions set forth in our Terms of Service, including the prohibition on access by U.S. persons and users in OFAC-sanctioned jurisdictions;
• (d)to detect, investigate, and prevent fraudulent activity, unauthorized access, abuse, and security incidents;
• (e)to comply with applicable legal and regulatory obligations, including responding to lawful governmental requests, court orders, and subpoenas; and
• (f)to respond to user inquiries and support requests.

We do not use your information for advertising, behavioral tracking, or the sale or transfer of personal data to third parties for commercial purposes.

The Interface and Protocol make periodic API calls to PurpleAir, LLC to retrieve real-world Air Quality Data (PM2.5 concentration readings) for cities listed on the Protocol. The frequency and timing of these API calls may vary and are subject to change as the Protocol evolves. No user personal information or wallet data is transmitted to PurpleAir in connection with standard Interface operation.

We do not sell, rent, or otherwise transfer your personal information to third parties for commercial purposes. We may share information in the following limited circumstances:

We and our service providers may use cookies, pixel tags, local storage, and similar tracking technologies in connection with the operation of the Interface for the following purposes: maintaining session state and Interface functionality; remembering user preferences; enforcing geographic access restrictions; and analyzing aggregate usage patterns to improve the Interface. Vercel Analytics, used on pbx.earth, is a cookieless analytics solution that does not deploy tracking cookies.

You may configure your browser to refuse, delete, or alert you to the use of cookies. Please note that disabling cookies may affect the availability or functionality of certain features of the Interface.

We retain automatically collected usage and technical data only for as long as is necessary to fulfill the purposes described in this Privacy Policy and to comply with applicable legal and regulatory obligations, and in any event for no longer than twenty-four (24) months from the date of initial collection, unless a longer retention period is required by law.

Wallet address data associated with trading competitions, leaderboard programs, or similar features is retained for the duration of the relevant program and deleted or anonymized within a commercially reasonable period following the conclusion of such program, unless retention is required for legal compliance, regulatory purposes, or the resolution of a bona fide dispute.

On-chain transaction data recorded on the Solana blockchain is permanently and immutably stored and is entirely outside our technical control to delete, modify, or restrict.

We implement and maintain reasonable and appropriate technical and organizational security measures designed to protect the information we collect against unauthorized access, disclosure, alteration, destruction, or loss. Our hosting infrastructure providers, Vercel and Render, maintain their own security certifications and operational security practices applicable to the services they provide.

Notwithstanding the foregoing, no security system is completely impenetrable, and we cannot guarantee the absolute security of information stored or transmitted in connection with the Interface. You are solely and exclusively responsible for maintaining the security and confidentiality of your Wallet private keys and seed phrases. The Company has no technical capability to recover lost or stolen private keys, restore inaccessible Wallets, or reverse unauthorized blockchain transactions. The loss of private keys may result in the permanent and irrecoverable loss of all digital assets associated with the affected Wallet.

The Interface integrates with or provides links to the following third-party services, each of which operates under its own independent privacy policy:

• (a)PurpleAir, LLC — Air Quality Data provider (PM2.5 sensor network, 70,000+ sensors, used by the U.S. Environmental Protection Agency);
• (b)Orca Finance — Solana automated market maker and liquidity provider;
• (c)Jupiter Aggregator — Solana token swap aggregation platform;
• (d)Vercel Inc. — Hosting and privacy-preserving analytics for pbx.earth (vercel.com/legal/privacy-policy); and
• (e)Render Services, Inc. — Hosting and service analytics for terminal.pbx.earth (render.com/privacy).

The Company is not responsible for, and expressly disclaims all liability arising from, the data collection, privacy practices, security measures, or terms of service of any third-party service provider. We encourage you to review the privacy policies of all third-party services you access in connection with your use of the Interface.

If you are a resident of the State of California, the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), provides you with the following rights with respect to your personal information:

• (a)Right to Know. You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you in the preceding twelve (12) months, the categories of sources from which such information was collected, the business or commercial purpose for collecting the information, and the categories of third parties with whom we share the information.
• (b)Right to Delete. You have the right to request the deletion of personal information we have collected about you, subject to certain exceptions permitted by applicable law.
• (c)Right to Opt Out of Sale or Sharing. We do not sell or share personal information for cross-context behavioral advertising purposes.
• (d)Right to Correct. You have the right to request the correction of inaccurate personal information we maintain about you.
• (e)Right to Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights.

To submit a verifiable consumer request to exercise any of the above rights, please contact us at team@pbx.earth. We will respond to verified requests within forty-five (45) calendar days as required by applicable law, subject to any extensions permitted by law.

If you are a resident of the State of Colorado, the Colorado Privacy Act (“CPA”), C.R.S. § 6-1-1301 et seq., provides you with the following rights with respect to your personal data: the right to access personal data we process about you; the right to correct inaccurate personal data; the right to delete personal data; the right to obtain a portable copy of personal data; and the right to opt out of the processing of personal data for targeted advertising, the sale of personal data, and profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise your rights under the CPA, please contact us at team@pbx.earth. We will respond to authenticated consumer requests within forty-five (45) calendar days, with a possible extension of an additional forty-five (45) days where reasonably necessary as permitted by law.

The Interface is subject to geographic access restrictions and is not available to U.S. persons, as described in the Terms of Service. The Interface is intended for use by individuals located outside the United States.

EU and EEA Users. The Company does not currently direct marketing activities toward residents of the European Union or European Economic Area. If you are located in the EU or EEA and access the Interface, you may have rights under the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679), including rights of access, rectification, erasure, restriction of processing, data portability, and objection to processing. To submit a data rights request under the GDPR, please contact us at team@pbx.earth.

The Interface is not directed at, marketed to, or intended for use by individuals under eighteen (18) years of age. We do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected personal information from a person under the age of eighteen, we will take prompt steps to delete such information from our records. If you believe we may have collected information from a minor, please contact us at team@pbx.earth.

We reserve the right to modify this Privacy Policy at any time to reflect changes in our data practices, the Interface, applicable law, or other circumstances. Material changes will be reflected in a revised effective date at the top of this document. Your continued use of the Interface following the posting of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree to any revision of this Privacy Policy, you must immediately cease all use of the Interface.

Questions, comments, or requests regarding this Privacy Policy or our data practices should be directed to:

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