Last Updated: February 8, 2025

This Privacy Policy (“Privacy Policy” or “Policy”) describes how Blade Labs Holdings Pte. Ltd. (together with Blade Labs Inc., Blade Foundation Ltd., ZeroH, and any of our other affiliates or subsidiaries, collectively “Blade,” “we,” “us,” or “our”) collects, uses, shares, and stores personal information of visitors to our websites at • https://bladelabs.io • https://bladefoundation.io • https://bladegroup.io • https://bladewallet.io • https://zeroh.io (and any other sites or mobile applications owned or operated by Blade) (collectively, the “Sites”), and users of our various services (the “Services”), including but not limited to the Blade Wallet, Console (formerly “Launchpad”), ZeroH, and related offerings.

By visiting the Sites or using any of our Services, you agree that your Personal Data (defined below) will be handled as described in this Privacy Policy. Your use of the Sites or Services, and any dispute over privacy, is subject to this Policy as well as any applicable Terms of Use, end-user license agreements, or additional service agreements.

If you do not agree with any part of this Privacy Policy, please do not use our Sites or Services.

Term Definition Data Processing Performing any operation on data, such as obtaining, recording, collecting, storing, altering, retrieving, disclosing, or destroying data. Personal Data Information about an identifiable individual, including, but not limited to: name, date of birth, government IDs, financial info, IP addresses, wallet IDs, or transaction information. User An individual who accesses, downloads, or uses any Site or Service provided by Blade (including ZeroH).

3.1 Information Collected Directly

You may provide Personal Data when you: • Sign up for our Sites, newsletters, or marketing lists. • Register for the Blade Wallet, Console, or ZeroH. • Use the Services (e.g., creating and storing wallet keys, initiating transactions, applying for financing). • Participate in promotions, contests, or surveys. • Contact us via email, support forms, or social media channels.

Depending on the nature of Services (e.g., ZeroH financing), we may collect additional data such as financial details or verification documents to comply with Shariah principles and local regulatory requirements.

3.2 Information Collected Automatically

We may automatically collect information via cookies and similar technologies, such as: • IP address, device identifiers, and browser type • Pages visited, links clicked, or referral URLs • Session duration and activity metrics • Wallet IDs, system fingerprints, and DApp referral information (where relevant)

See our Cookie Policy for more details on these tracking technologies and your choices.

We use the collected Personal Data for purposes including, but not limited to: 1. Service Provision • Facilitating account creation for the Blade Wallet, Console, or ZeroH. • Processing user transactions, including on-chain interactions or zero-interest financing. 2. Customer Support & Communications • Responding to your requests, inquiries, or feedback. • Sending service announcements, product updates, or transaction confirmations. 3. Personalization & Improvements • Tailoring Site content and user experiences to your preferences. • Monitoring and improving user flows, feature sets, and overall performance. 4. Analytics & Development • Conducting aggregated or anonymized analytics to enhance our Services. • Developing new products or features based on usage insights. 5. Marketing & Promotions • Sending newsletters, offers, and promotions (if you opt in). • Conducting surveys, research, or contests. 6. Compliance & Regulatory • Fulfilling legal obligations under applicable laws (e.g., KYC/AML), particularly relevant for ZeroH. • Enforcing our Terms of Use, preventing fraud, or addressing security issues.

We only process Personal Data when we have a valid legal basis: • Consent: When you give explicit permission (e.g., for marketing communications). • Contractual Necessity: To fulfill agreements for Services you request (e.g., a financing contract via ZeroH, or wallet services). • Legal Obligations: Compliance with laws, regulations, or court orders. • Legitimate Interests: For business operations (e.g., risk management, fraud prevention, analytics), balanced against your rights.

We implement security measures designed to protect against unauthorized access or disclosure of your Personal Data. Examples include: • Data encryption (where feasible) and secure storage protocols • Restricted access controls and authentication mechanisms • Regular security assessments and updates

Despite our precautions, no system is entirely foolproof. You are responsible for safeguarding your own device, password, cryptographic keys, and account credentials.

You have the right to: • Access: Request copies of your Personal Data. • Rectify: Correct inaccurate or incomplete information. • Delete: Ask us to erase your Personal Data, subject to legal or regulatory obligations. • Restrict or Object: Limit certain processing activities or object to them. • Withdraw Consent: Revoke consent at any time if processing is based on consent.

To exercise these rights, please contact us at:

(If your request is specific to ZeroH, you may also direct inquiries to policies@zeroh.io.)

We may verify your identity before fulfilling certain requests. Please note we may keep some data to comply with legal obligations or for legitimate business purposes.

If you provide your email address or other contact details, we may send promotional communications about Blade or ZeroH. You can opt out of marketing at any time by: • Clicking “unsubscribe” in our emails. • Emailing us at policies@bladelabs.io.

We may still send you transactional or service-related messages (e.g., account notices, financing confirmations, security alerts).

Blade operates globally. Your Personal Data may be transferred to and processed in countries other than where you live, subject to appropriate safeguards (e.g., standard contractual clauses). By using our Services, you consent to such transfers, including as required for ZeroH’s Shariah-compliant financial processes.

Because ZeroH operates under Islamic finance principles, we may: • Collect additional documentation to confirm compliance with Shariah standards (e.g., certain KYC details, transaction structures). • Store enhanced transaction data for auditing by Shariah supervisory boards or local financial authorities. • Adhere to regional banking and finance laws, which may impose extra record-keeping or disclosure requirements.

We will update this Policy as needed if new or more stringent data obligations arise from local Islamic finance frameworks or other regulations.

If you are a California resident, you have the rights under the California Consumer Privacy Act (CCPA), including: • The right to know what Personal Data we collect, use, or share. • The right to request deletion of your Personal Data. • The right to opt out of the sale of Personal Data (if applicable). • The right not to be discriminated against for exercising your privacy rights.

To exercise these rights, contact us at:

If you are a citizen or resident of the European Union or the European Economic Area, you have the following data protection rights: • Right to Access: Obtain confirmation of whether we process your data, and request a copy. • Right to Rectification: Correct inaccurate or incomplete data. • Right to Erasure: Request deletion of your data under certain conditions. • Right to Restrict Processing: Limit our data use in certain situations. • Right to Data Portability: Receive your data in a structured, commonly used format. • Right to Object: Object to certain types of processing, including direct marketing. • Right to Withdraw Consent: At any time if processing is based on consent. • Right to Lodge a Complaint: With your local data protection authority.

We reserve the right to modify this Privacy Policy at any time. If we make material changes, we will update the “Last Updated” date above and may provide additional notice (e.g., email or on the Sites). Your continued use of the Sites or Services after any updates constitutes your acceptance of the modified Policy.

If you have questions or concerns about our privacy practices, please contact us at:

You can also direct questions specifically regarding ZeroH or its Islamic finance compliance to:

Effective Date: February 8, 2025.

If you do not agree with any part of this Policy, please discontinue use of our Sites and Services.

Final Note