Effective as of September 09, 2025
This Privacy Policy describes how Ulys Holdings Inc. (“Ulys,” “we,” “us,” or “our”) processes personally identifiable information (“Personal Information”) that we collect through our third party service providers or our products and services that link to this Privacy Policy, including, without limitation, our mobile application, website (including all top-level domain and subdomain pages), self-custodial digital asset wallet, educational resources, social media channels, marketing campaigns, rewards programs, events, business development and sales, or other activities described herein (collectively, the “Offerings”). For purposes of this Privacy Policy, Personal Information does not include de-identified or aggregated information and, to the extent permitted by law, does not include publicly available information that is lawfully made available to the general public or information that is lawfully made available from government records.
Information you provide to us. Personal Information you may provide to us through the Offerings or otherwise includes:
Contact data, name, phone number, wallet address, and email address.
Communications data, social media handles, referral information (referrer/referee wallet addresses and payout data), account balance, transaction information and history, on-chain data.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Usage-related data, which may be collected automatically by us, or through our Offerings or third-party services within our Offerings (e.g., what Offerings you use, how often you use them, anything you may publicly share or post using tools made available by our Offerings, your responses to the communications presented or made available by us).
Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Third-party sources. We may combine Personal Information we receive from you with Personal Information that we obtain from other, third-party sources, such as:
Public sources, such as social media platforms, public blockchain data and blockchain explorers, and other publicly available sources.
Private sources, such as Ulys affiliate entities, other users of the Offerings, integrations with fraud detection vendors and data analytics providers, KYC status (approve/reject) for users of the Offerings that set-up an account with Bridge or similar third parties to convert your USD/USDC.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Offerings, our communications and other online products and services, such as:
Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, uniform resource identifier addresses, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Offerings, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
Cookies and similar technologies. We will store a record of your preferences in respect of the use of these technologies in connection with the Offerings. Some of the automatic collection described above is facilitated by the following technologies:
Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers’ place.
Local storage technologies, like HTML5, provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
We may use your Personal Information for the following purposes or as otherwise described at the time of collection:
Delivery and operations. We may use your Personal Information to:
provide you with the Offerings;
enable linked third-party services;
distribute referral rewards and incentive campaign payouts;
communicate with you about the Offerings, including by sending Offering-related announcements, updates, security alerts, and support and administrative messages; and
provide support for the Offerings, and respond to your requests, questions and feedback.
Personalization. We may use your Personal Information to personalize the Offerings for you, which may include using your Personal Information to:
understand your needs and interests;
customize your experience with the Offerings and our Offering-related communications; and
remember your selections and preferences as you navigate the Offerings.
Marketing. We and our service providers may collect and use your Personal Information to send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of communications section below.
Improvements and analytics. We may use your Personal Information for research and development purposes, as well as to analyze your usage of the Offerings, improve the Offerings, improve the rest of our business, help us understand user activity on the Offerings, including which pages are most and least visited and how visitors move around the Offerings, as well as user interactions with our emails, and to develop new features, products, and services.
Compliance and security. We may use your Personal Information to:
promote the safety, security, and integrity of the Offerings;
comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the Terms of Service that govern the Offerings; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
Data sharing in the context of corporate events such as changes of control, we may share certain Personal Information in the context of actual or prospective corporate events – for more information, see How we share your Personal Information, below.
To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your Personal Information and other individuals whose Personal Information we collect. We make Personal Information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Offerings and promote our business.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your Personal Information, such as when required by law.
Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:
Technical operation. To allow the technical operation of the Offerings.
Functionality. To enhance the performance and functionality of our Offerings.
Analytics. To help us understand user activity on the Offerings, including which pages are most and least visited and how visitors move around the Offerings, as well as user interactions with our emails. For example, we may use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.
We may share your Personal Information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.
Affiliated entities. We reserve the right to provide your Personal Information to any affiliated entities we may have, including our subsidiaries. Affiliated entities are entities that we control, that control us, or with which we are subject to common control by another entity.
Service providers. Third parties that provide services on our behalf or help us operate the Offerings or maintain our business (such as cloud hosting, AI agents, fraud detection tools, payment processors (ie. on/off ramps), KYC screening, information technology, customer support, email delivery, marketing, user analytics). We will use commercially reasonable efforts to ensure that our service providers will be given access to your Personal Information only as is reasonably necessary to provide the services for which they are contracted.
Comarketing; cross-promotion; Sponsorship. We may participate with another company or individual, for the purposes of jointly promoting our Offerings, events, or promotions, or their products, services, campaigns, or contests. We reserve the right to disclose Personal Information to them for the purposes of (i) compensation, transaction-processing, fulfillment, and support; and (ii) providing you other Offerings, features, products, services, or promotions.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
Business transferees. We may disclose Personal Information in the context of actual or prospective business transactions (e.g., investments in Ulys, financing of Ulys, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain Personal Information with prospective counterparties and their advisers. We may also disclose your Personal Information to an acquirer, successor, or assignee of Ulys as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which Personal Information is transferred to one or more third parties as one of our business assets.
Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Offerings may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning.
Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect Personal Information to provide certain Offerings. If you do not provide the information identified by us or a service provider as required or mandatory, we may not be able to provide those Offerings.
Questions. If you have any questions or concerns regarding our Privacy Policy, please do not hesitate to contact us at support@ulysapp.com
The Offerings may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
We have established commercially reasonable safeguards to protect the Personal Information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, but we cannot guarantee that your Personal Information will never be disclosed in a manner inconsistent with this Policy (e.g., as a result of unauthorized acts by third-parties that violate applicable law, or our or our affiliated providers’ policies). Please be aware that despite our efforts, no data security measures can guarantee 100% security. Your account is protected by a password for your privacy and security. (We may use passwords and other technologies to register or authenticate you and to enable you to take advantage of our Services.) You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and by limiting access to your computer or device and browser by signing-off after you have finished accessing your account. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized password activity.
Your Personal Information is stored and processed in our servers located in the United States and may also be stored or processed in other countries by our service providers, if and to the extent compliant with law. You understand and agree that Ulys may collect, use, disclose, and otherwise utilize the information you provide as described in this Policy, even if you are from an area outside the United States. Your Personal Information may be disclosed in response to inquiries or requests from governmental authorities or to respond to judicial processes in the United States or other jurisdictions. We will retain your Personal Information for as long as it is needed to provide you with the Offerings, comply with legal obligations, or protect our or others' legitimate interests. All Personal Information is encrypted during transmission using industry-standard TLS protocols and stored with appropriate security measures.
Ulys is proudly headquartered in the United States, but may use service providers that operate in other countries. Your Personal Information may be transferred out of the United States to other locations where privacy laws may not be as protective as those in your state, province, or country.
The Offerings are not intended for use by anyone under 18 years of age. We do not knowingly receive Personal Information from children. If you are a parent or guardian of a child from whom you believe we have collected Personal Information in a manner prohibited by law, please contact us. If we learn that we have collected Personal Information through the Offerings from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Offerings or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Offerings after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Offerings and our business.
California Residents
If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA):
Right to Know what Personal Information we collect, use, disclose, or share;
Right to Delete Personal Information we have collected;
Right to Correct inaccurate Personal Information;
Right to Opt Out of the sale or sharing of Personal Information;
Right to Limit Use of Sensitive Personal Information, where applicable;
Right to Non-Discrimination for exercising these rights.
To exercise these rights, you may submit a request by emailing us at: contact@ulysapp.com
To protect your privacy and security and the limited amount of information we collect in order to provide our Offerings, we may take steps to verify your identity before complying with your request and we may decline your request if we are unable to verify your identity. Furthermore, we may reject requests that are unreasonably repetitive, illegitimate (e.g. the information you provide doesn’t match the account or device activity), suspicious in nature, risk the privacy of others, require disproportionate technical effort (e.g., developing a new system or fundamentally changing an existing practice), or would otherwise be extremely impractical (e.g., requests for information residing in backup storage that is not easily accessible).
We do not sell your Personal Information for monetary value. However, we may “share” personal data (such as device identifiers) for analytics or functionality, which may be considered a “sale” under California law. You can opt out by emailing us anytime.
Email: contact@ulysapp.com
In compliance with Apple App Store requirements, Ulys discloses the following data handling practices specific to our iOS app:
Identifiers: Email address, phone number, device ID (for account setup and authentication)
Contact Information: Name and email address (for support and updates)
User Content: Wallet addresses, app usage data (to support and improve services; airdrop programs)
Diagnostics and Performance Data: App crash logs, usage statistics (to enhance functionality and security)
For account verification, service functionality, and to send important updates
To provide user support and respond to inquiries
For analytics and app improvement
To comply with legal obligations and safeguard platform integrity
With service providers (e.g., analytics, support tools)
With legal authorities as required
No user data is sold or used for third-party advertising
The app does not track users across third-party apps or websites
No use of third-party advertising SDKs
Users can opt out of email marketing communications via unsubscribe links
iOS users can restrict data collection through system-level privacy settings
For more information about your Apple device privacy controls, visit: https://support.apple.com/en-us/HT212025