2Factor Points Program Privacy Policy

Last updated: July 2026

Introduction

Fragments Inc. and its affiliates (“2Factor”, “the Company”, “we”, “us” or “our”) are committed to protecting and respecting your privacy.

This Privacy Policy explains how we collect, use, store, share and protect the personal data we collect from you when you take part in the 2Factor points program (the “Program”), including through our website, our community channels, and any campaign or quest platforms we use to run parts of the Program.

Fragments Inc. is the data controller of the personal data we hold about you in connection with the Program. If you have a question, see the “Contact us” section below.

Please read this alongside our Points Program Terms, which govern how the Program itself works.

The personal data we collect

“Personal data” is information that identifies you personally, or from which your identity can reasonably be worked out.

We collect personal data that you give us directly, for example when you join the community, enter the Program, complete a quiz or survey, refer someone, or contact us. This can include:

• Contact and identity information: your name, email address, and any social or messaging handles you provide (for example Telegram, Discord, or X handles).
• Program participation data: your points (“Marks”) balances, tier, multipliers, actions completed, quiz responses, referral activity, and any referral codes you use or share.
• Wallet information: any public wallet address you choose to connect or provide in connection with the Program.
• Correspondence: comments, feedback, and support requests.

We also collect certain data automatically about how you access and use our Program surfaces, including your IP address, device and browser type, and general usage information. Where this data can identify you, we treat it as personal data.

We do not ask for private keys or seed phrases, and we will never ask for them. You should never share them with anyone.

How we use your personal data

We use personal data in order to:

• Operate the Program, including calculating and recording Marks, tiers, multipliers, and referral activity, and administering any rewards we choose to offer.
• Communicate with you about the Program, your participation, and any changes to it.
• Verify eligibility and enforce the Points Program Terms.
• Detect, investigate, and prevent fraud, abuse, self-referral, botting, multi-accounting, and other activity that breaches our terms.
• Improve and secure the Program and our related products and services.
• Send you news, updates, and marketing where you have agreed to receive it, or where we are otherwise permitted to do so.
• Comply with our legal and regulatory obligations, and cooperate with law enforcement where legally required.

Legal bases for processing (EEA and UK)

Where the General Data Protection Regulation (Regulation EU 2016/679, “GDPR”) or the UK GDPR applies, we rely on the following legal bases:

• Contract: to operate the Program and provide participation you have asked for.
• Legitimate interests: to run, secure, and improve the Program, and to prevent fraud and abuse, balanced against your rights.
• Consent: for marketing communications and any non-essential cookies, which you can withdraw at any time.
• Legal obligation: where we must process data to comply with the law.

Cookies and analytics

Our Program surfaces may use cookies and similar technologies, including third-party analytics, to make them work and to understand how they are used. Where required, we ask for your consent to non-essential cookies. You can control cookies through your browser settings.

Sharing your personal data

We share personal data only where needed, with the following categories of recipients:

• Service providers who process data on our behalf, for example hosting, email delivery, analytics, and fraud prevention providers, under a duty of confidentiality and only for the purposes we instruct.
• Community and support platforms we use to run the community and answer questions, including Telegram, Discord, and X. These platforms handle your data under their own privacy policies.
• Program infrastructure providers, for example any campaign or quest platform we use to run parts of the Program, again under their own privacy policies.
• Professional advisers, auditors, and insurers where reasonably needed.
• Law enforcement, regulators, courts, and other parties where we are legally required to do so, or where we reasonably believe it is necessary to enforce our terms, prevent harm, or protect our rights, property, or safety.
• A successor entity in connection with any merger, acquisition, financing, or reorganization of our business.

We do not sell, rent, or trade your personal data.

International transfers

We may transfer and store personal data in countries outside your own, including outside the EEA and UK. Where we do, we put appropriate safeguards in place, such as standard contractual clauses, so that your data receives an adequate level of protection.

Marketing

We may send you emails with information about 2Factor and the Program. Where the law requires consent, we will ask for it. You can opt out at any time using the unsubscribe link in our emails or by contacting us. Opting out of marketing does not stop essential messages about your participation in the Program.

Security, storage, and retention

We use appropriate technical and organizational measures to protect personal data against loss, misuse, unauthorized access, alteration, and disclosure. We limit access to personal data to those who need it, under a duty of confidentiality.

We keep personal data only for as long as necessary for the purposes described here, or for as long as we are required to keep it for legal, regulatory, tax, or accounting reasons. We have procedures to handle suspected data breaches and will notify you and any relevant regulator where the law requires.

Your rights

Depending on where you live, and in particular under the GDPR and UK GDPR, you may have the following rights:

• Access: to obtain a copy of the personal data we hold about you.
• Rectification: to have inaccurate data corrected or incomplete data completed.
• Erasure: to have your data deleted in certain circumstances.
• Restriction and objection: to restrict or object to certain processing.
• Portability: to receive your data in a commonly used format and have it transmitted to another controller.
• Withdraw consent: where we rely on consent, at any time, without affecting processing already carried out.
• Complain: to your local data protection authority.

To exercise any of these rights, contact us using the details below. We may need to verify your identity before acting on a request.

Note that we cannot alter, delete, or reverse data that has been written to a public blockchain, because that is outside our control.

Children

The Program is not intended for anyone under 18. We do not knowingly collect personal data from anyone under 18. If you believe we have, please contact us and we will delete it.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we make a material change, we will update the “Last updated” date above and, where appropriate, tell you by other means. Changes take effect when posted.

Contact us

If you have any questions about this Privacy Policy or how we handle your personal data, you can reach the team through our Telegram community at gate.2factor.finance.

Registered

This Program is operated by Fragments Inc., registered in Delaware, with its registered office at 1647 W. Temple Ave #309, Los Angeles CA 90026.

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