1. Personal Information We Collect

The categories of personal information we collect depend on how you interact with the Services and the requirements of applicable law.

1.1 Information You Provide to Us

1. Wallet Information. To access the Services, you must connect a compatible self-custodial digital asset wallet. When you connect your wallet, we collect your wallet address and associated on-chain data, including current 0G token balances, a0G token balances, staking positions, unbonding status, and transaction history as visible on 0G Chain. We do not collect or have access to your private keys, seed phrases, or wallet credentials.
2. Staking and Transaction Information. When you stake 0G tokens, request unstaking, or conduct any other transaction through the Services, we may collect information about those transactions, including the amount of 0G tokens staked or unstaked, the amount of a0G tokens minted or burned, the exchange rate at the time of the transaction, unbonding period status, and the on-chain transaction hash and confirmation data.
3. Incentive Program Information. When you participate in Incentive Programs, including the Ascend Points program, the Shuttle Program, or third-party programs facilitated through the Interface (including those operated by Symbiotic and Mellow), we may collect information about your participation, accrual status, tier level, and redemption activity.
4. AI Feature Interactions. If you use AI-powered features on the Interface, including yield projections, risk simulations, and staking guidance tools, we may collect the inputs you provide and the outputs generated. This information is used to operate, maintain, and improve the AI Features and is not used to train AI models without your separate consent.
5. Communications. If you contact us for support, submit feedback, or otherwise communicate with us, we collect the content of those communications, including your email address or other contact details you provide.
6. Marketing and Event Information. If you subscribe to communications, register for events, or engage with our social media channels, we collect the information you provide in connection with those activities.

1.2 Information Collected Automatically

When you access or use the Services, we may automatically collect:

1. Device and Connection Information. Your Internet Protocol (IP) address, device type, operating system, browser type and version, screen resolution, language settings, and time zone.
2. Usage Information. Information about how you interact with the Services, including pages visited, features used, buttons clicked, staking actions initiated, Interface session duration, and navigation patterns.
3. Cookies and Similar Technologies. We use cookies and similar tracking technologies as described in Section 5.
4. Log Data. Server logs that automatically record information when you access the Services, including access times, referring URLs, and error reports.

1.3 Information from Third-Party Sources

1. Blockchain Data. We collect information publicly available on 0G Chain, including wallet addresses, staking transactions, a0G minting and burning events, validator delegation data, unbonding records, and on-chain Incentive Program activity. This data is permanently recorded on the blockchain and cannot be deleted or modified by Ascend or by you.
2. Wallet Screening Providers. We may receive information about your wallet address from third-party compliance and screening services that assess wallet addresses against sanctions lists, risk scores, and indicators of illicit activity.
3. Analytics Providers. We may receive aggregated or pseudonymous information about Interface usage from third-party analytics providers.
4. Third-Party Wallet Providers. If you connect a third-party wallet to the Services, the wallet provider may share certain information with us in connection with establishing the connection.

2. How We Use Your Information

We use your information for the following purposes:

2.1 Provide the Services

We use your information to fulfill our contract with you and provide the Services, including:

1. Enabling wallet connection, authentication, and access to the Interface.
2. Processing staking, unstaking, and redemption transactions and displaying your staking position, a0G balance, and exchange rate information.
3. Managing your participation in Incentive Programs, including tracking Points accrual, Shuttle Program tier status, and third-party program participation.
4. Operating AI Features, including generating yield projections, risk simulations, and staking guidance based on your inputs and on-chain data.
5. Displaying DeFi integration information and facilitating interactions with Third-Party Protocols and other integrated applications.
6. Communicating with you about your activity on the Services, including transaction confirmations, policy updates, and service notifications.
7. Providing customer support and responding to your inquiries.

2.2 Administrative and Compliance Purposes

We use your information for our legitimate interests and to comply with legal obligations, including:

1. Conducting wallet screening and sanctions compliance checks to prevent Sanctioned Persons and users from Sanctioned Jurisdictions from accessing the Services.
2. Monitoring for and investigating suspicious, fraudulent, or illicit activity, including potential money laundering, sanctions evasion, or market manipulation.
3. Measuring engagement and usage of the Services and Incentive Programs.
4. Improving, debugging, and enhancing the Services and underlying infrastructure.
5. Ensuring internal quality control, security, and safety.
6. Auditing interactions, transactions, and compliance activities.
7. Enforcing our Terms and policies.
8. Complying with applicable laws, regulations, legal processes, and governmental requests.

2.3 Marketing and Communications

We may use your information to send you ecosystem updates, product announcements, event invitations, and other communications about the Ascend Protocol and related developments. You may opt out of marketing communications at any time as described in Section 6.

2.4 AI Features

We use inputs provided to AI Features, including staking parameters, yield queries, and risk simulation requests, solely to generate responses for you and to operate and maintain the AI Features. We do not use AI Feature interaction data to train, fine-tune, or improve AI or machine learning models without your separate, affirmative consent.

2.5 Other Purposes

1. Consent. We may use your information for other purposes clearly disclosed to you at the time you provide it, where you have given your consent.
2. De-identified and Aggregated Data. We may derive de-identified or aggregated information from personal information and use it for any lawful purpose, including research, analytics, and product improvement. De-identified or aggregated data is not personal information and is not subject to this Privacy Policy.

3. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

3.1 Service Providers

We share information with third-party service providers that assist us in operating the Services, including cloud hosting providers, analytics services, security and compliance vendors, wallet screening providers, customer support tools, and communications platforms. These providers are contractually required to use your information only as necessary to provide services to us and to maintain appropriate security measures.

3.2 Blockchain Networks

When you conduct transactions through the Services, your wallet address, staking amounts, a0G minting and burning events, validator delegation data, and associated on-chain metadata are broadcast to and permanently recorded on 0G Chain. This information is publicly accessible to anyone with access to the blockchain and cannot be deleted, modified, or restricted by Ascend.

3.3 Compliance and Legal Obligations

We may disclose your information to governmental authorities, regulators, law enforcement agencies, or other third parties where required or permitted by applicable law, including in response to legal process, to protect the rights or property of Ascend or others, to prevent fraud or illegal activity, or to comply with sanctions and AML obligations.

3.4 Wallet Screening and Compliance Partners

We may share your wallet address and related transaction data with third-party compliance providers for purposes of sanctions screening, AML monitoring, and risk assessment. These providers may retain screening results in accordance with their own data retention policies.

3.5 DeFi Integration Partners

When you interact with Third-Party Protocols through the Interface and Incentive Program partners, information about those interactions may be shared with or independently collected by those third parties. Your use of any Third-Party Protocol is subject to that protocol’s own privacy terms. Ascend is not responsible for the privacy practices of any Third-Party Protocol.

3.6 Business Transfers

In the event of a merger, acquisition, reorganization, dissolution, or similar transaction involving Ascend or Upsteak Tech S.A., your information may be transferred to the successor entity. We will notify you of any such transfer and any material changes to this Privacy Policy as required by applicable law.

3.7 With Your Consent

We may share your information for other purposes with your consent or at your direction.

4. Blockchain Data and Public Information

The Ascend Protocol operates as a non-custodial liquid staking protocol on 0G Chain. You acknowledge and agree that:

1. Staking transactions are inherently public. When you stake 0G tokens, unstake, or redeem through the Interface, the transaction details — including your wallet address, the amount of 0G staked or redeemed, a0G tokens minted or burned, the exchange rate applied, and the transaction hash — are permanently recorded on 0G Chain and are publicly accessible.
2. Validator delegation is publicly visible. The Protocol’s delegation of aggregated staked 0G to validator node operators occurs on-chain and is publicly verifiable. While individual user allocations within the pool may not be directly attributable on-chain, your wallet address and aggregate staking position are publicly associated.
3. Unbonding requests and completions are on-chain. When you submit an unstaking request, the unbonding initiation, duration, and completion are recorded on 0G Chain and publicly visible.
4. Incentive Program activity may be on-chain. Certain Ascend Points and Shuttle Program activity may be recorded on-chain and publicly visible, depending on program design. Third-party program data (Symbiotic, Mellow) is subject to those protocols’ own on-chain data practices.
5. On-chain data is permanent. Once recorded on 0G Chain, blockchain data cannot be deleted, modified, or restricted by Ascend, regardless of any request you make under applicable privacy law. Ascend can only fulfill deletion or restriction requests with respect to off-chain data it holds about you.
6. Third parties may independently analyze your on-chain data. Blockchain analytics providers and other platforms may independently collect, aggregate, and analyze on-chain data associated with your wallet address, including staking history, regardless of your relationship with Ascend.

5. Cookies and Tracking Technologies

5.1 Technologies We Use

We use the following technologies to collect information and operate the Services:

1. Cookies. Small text files placed on your device that store preferences, enable platform functionality, and help us understand how you use the Interface.
2. Pixel Tags and Beacons. Small pieces of code embedded in the Services or emails that help us track engagement and measure the effectiveness of communications.
3. Local Storage. Technologies such as HTML5 local storage that store information about your session, preferences, and wallet connection status.
4. Analytics Tools. We use third-party analytics services to collect and analyze usage information. These services may set their own cookies and collect data in accordance with their own privacy policies.

5.2 Categories of Cookies

1. Strictly Necessary Cookies. Required for the Services to function, including wallet connection authentication, session management, and security. These cannot be disabled without affecting core functionality.
2. Performance and Analytics Cookies. Help us understand how users interact with the Interface, including which features are used most frequently and where errors occur.
3. Functional Cookies. Enable enhanced functionality, such as remembering your display preferences and wallet connection settings.

We do not use advertising or behavioral targeting cookies.

5.3 Your Cookie Choices

You can manage cookie preferences through your browser settings. Blocking certain cookies may affect the functionality of the Services, including wallet connection and Interface features.

5.4 Do Not Track

Some browsers offer a “Do Not Track” (“DNT”) setting. We do not currently respond to DNT signals, as no uniform technical standard for DNT has been established.

6. Your Privacy Choices and Rights

6.1 General Rights

Depending on your jurisdiction, you may have certain rights with respect to your personal information, including the right to:

1. access and obtain a copy of your personal information we hold;
2. correct inaccurate or incomplete personal information;
3. request deletion of your personal information held by Ascend (noting that on-chain data cannot be deleted as described in Section 4);
4. restrict or object to certain processing of your personal information;
5. request portability of your personal information in a structured, machine-readable format; and
6. withdraw your consent to processing, where processing is based on consent.

To exercise any of these rights, please contact us at privacy@ascend.finance. We will process requests in accordance with applicable law and within the timeframes required. Please note that certain rights are limited in scope and may not apply in all circumstances; in particular, rights relating to on-chain blockchain data cannot be fulfilled due to the immutable nature of the blockchain.

6.2 Marketing Communications

You may opt out of marketing emails by following the unsubscribe instructions in any marketing email or by contacting us at support@ascend.finance. Opting out of marketing communications does not affect transactional or service-related communications.

6.3 Wallet Disconnection

You may disconnect your wallet from the Interface at any time. Disconnecting your wallet ends your active session but does not delete your on-chain staking history or any off-chain information Ascend holds about you. To request deletion of off-chain data, contact us as described in Section 6.1.

7. International Data Transfers

Upsteak Tech S.A. is incorporated in Panama and operates the Services globally. Personal information we collect may be transferred to, stored in, or processed in countries other than your country of residence, including Panama and countries where our service providers operate, which may have different or less protective data protection laws than your jurisdiction.

Where personal information is transferred from the European Economic Area (EEA), the United Kingdom, or Switzerland to countries that have not received an adequacy determination, we implement appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission or equivalent mechanisms, to ensure your information receives an adequate level of protection. For more information about the safeguards applicable to your transfer, please contact us at support@ascend.finance.

8. Retention of Personal Information

We retain personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, including to provide the Services, comply with legal obligations, resolve disputes, and enforce our agreements. When determining the appropriate retention period, we consider the nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the information, and applicable legal requirements.

Off-chain personal information that is no longer necessary will be deleted or anonymized. Note that on-chain data associated with your wallet address including staking transactions, a0G minting and burning events, and validator delegation records is permanently recorded on 0G Chain and cannot be deleted by Ascend or by you.

9. Security of Your Information

We implement appropriate administrative, technical, and organizational measures designed to protect your personal information against unauthorized access, disclosure, alteration, and destruction. These measures include access controls, encryption of data in transit, and vendor security assessments.

However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security. If we become aware of a security breach affecting your personal information, we will notify you and any applicable regulatory authorities as required by applicable law.

10. Minors

The Services are not directed to individuals under the age of eighteen (18) or such higher age as required by applicable law. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected information from a minor, please contact us at support@ascend.finance and we will promptly delete it.

11. Supplemental Notice for EU/UK Residents (GDPR)

This section applies to individuals located in the European Union, the United Kingdom, or Switzerland whose personal information is subject to the General Data Protection Regulation (GDPR) or equivalent legislation.

11.1 Data Controller

For the purposes of applicable data protection law, Upsteak Tech S.A. (Panama) is the data controller responsible for your personal information processed through the Services. As Upsteak Tech S.A. is established outside the EEA and UK, we are in the process of assessing whether a local representative is required under Article 27 GDPR; please contact us at privacy@ascend.finance for further information.

11.2 Legal Bases for Processing

We process your personal information on the following legal bases:

1. Performance of a Contract. Where processing is necessary to perform our Terms of Service or to take steps at your request before entering into a contract, including enabling wallet connection, processing staking transactions, and operating Incentive Programs.
2. Legitimate Interests. Where processing is necessary for our legitimate interests, provided those interests are not overridden by your rights — including for security and fraud prevention, sanctions screening, analytics, and improving the Services.
3. Compliance with Legal Obligations. Where processing is necessary to comply with applicable law, including AML, sanctions, and data protection obligations.
4. Consent. Where you have provided explicit consent, for example for marketing communications or AI Feature model improvement.

11.3 Your Rights Under GDPR

In addition to the rights described in Section 6, if you are in the EU or UK you have the right to:

1. lodge a complaint with the supervisory authority in your EU member state or the UK Information Commissioner’s Office;
2. request information about the safeguards used for international transfers of your personal information; and
3. object to processing based on legitimate interests, in which case we will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.

Please note that certain GDPR rights — particularly erasure and restriction — cannot be fulfilled with respect to on-chain blockchain data, which is immutable and beyond Ascend’s ability to modify or delete.

12. Governing Law and Dispute Resolution

This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of Panama, without regard to its conflict of law principles. Any dispute arising out of or relating to this Privacy Policy shall be resolved through binding arbitration in accordance with Section 16 of our Terms of Service. Nothing in this section limits your right to lodge a complaint with a data protection supervisory authority.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the “Last Updated” date and provide notice on the Interface or by other reasonable means. Your continued use of the Services after any update constitutes acceptance of the revised Privacy Policy. We encourage you to review this Privacy Policy periodically.

14. Contact Us

If you have questions about this Privacy Policy, our data practices, or wish to exercise your privacy rights, please contact us at:

Upsteak Tech S.A.

Email: legal@ascend.finance

© 2026 Upsteak Tech S.A. All rights reserved.