This Privacy Policy describes how Singularity PO, Singularity Foundation Ltd. ("we", "us", "our", or "the Project") handles personal information that we collect through our digital properties that reference this Privacy Policy, including our website at https://spo.xyz (collectively, the "Service"), as well as through social media, our marketing activities, and other activities described in this Privacy Policy. 

Index 

• Personal information we collect 
• How we use your personal information 
• How we share your personal information 
• Your choices 
• Other sites and services 
• Security 
• International data transfer 
• Children 
• Changes to this Privacy Policy 
• Data Retention 

Personal information we collect 

• Contact data, such as your first and last name, salutation, email address, mailing address, professional title and company name, and phone number. 
• Project and program data, such as information about your projects, startup ideas, business plans, and participation in any potential future incubator programs or testnets. 
• Communication data, such as information you provide in your communications with us, including inquiries, feedback, and survey responses. 
• 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. 
• 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 Service, our communications and other online 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, IP address, unique identifiers (including identifiers used for advertising purposes), language settings, general location information (e.g., city/state based on IP address), and mobile device carrier. 
• Usage data, such as the pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access. 
• 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. 

Automatic data collection technologies 

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 may include "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. 
• 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. 

How we use your personal information 

We may use your personal information for the following purposes or as otherwise described at the time of collection: 

Service delivery. We may use your personal information to: 

• Provide, operate and improve the Service and our business. 
• Communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages. 
• Communicate with you about events, programs, and opportunities in which you participate. 
• Understand your needs and interests, and personalize your experience with the Service and our communications. 
• Provide support for the Service, and respond to your requests, questions and feedback. 
• Facilitate connections between participants, mentors, investors, and other stakeholders in our ecosystem (e.g., for testnet participation). 

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze, improve, and promote our business and the Service. 

Automatic data collection technologies. In addition to the other uses included in this section, we may use the Automatic data collection technologies described above for the following purposes: 

• Technical operation. To enable the technical operation of the Service. 
• Functionality. To enhance the performance and functionality of our services. 
• Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. 

Compliance and protection. We may use your personal information to: 

• Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas 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 and conditions that govern the Service. 
• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft. 

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. 

How we share your personal information 

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection. 

Affiliates. Our affiliates, subsidiaries, partners, and associated entities, for purposes consistent with this Privacy Policy. 

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, consumer research, marketing, and website analytics). 

Program participants. With your consent, we may share relevant information with mentors, advisors, potential investors, and other participants in our testnets or future programs to facilitate connections and opportunities. 

Third parties designated by you. We may share your personal data with third parties where you have instructed us or provided your consent to do so. We will share personal information that is needed for these other companies to provide the services that you have requested. 

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. Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, Singularity PO or our affiliates (including in connection with bankruptcy or similar proceedings). 

Your choices 

In this section, we describe the choices available to you. 

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services. 

Other sites and services 

The Service 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. 

Security 

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information. 

International data transfer 

We may operate in multiple countries and may use service providers that operate in other countries. Your personal information may be transferred to locations where privacy laws may not be as protective as those in your state, province, territory, or country. 

Children 

The Service is not intended for use by anyone under 18 years of age. 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 Service from a child without the consent of the child's parent or guardian as required by law, we will comply with the applicable legal requirements to delete the information. 

Changes to this Privacy Policy 

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 Service or by 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 Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy. 

Data Retention  

We retain personal information for as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law (e.g., for legal, auditing, or compliance purposes). For example, contact data may be retained for up to 7 years for tax or regulatory reasons. When data is no longer needed, we securely delete or anonymize it.