Privacy Policy

DIGITAL ASSET SETTLEMENT NETWORK LLC & TASSAT GROUP INC.

Effective Date: February 2025

This Privacy Policy explains how Digital Asset Settlement Network LLC and its subsidiaries (“DASN”) and Tassat Group Inc. and its subsidiaries (“Tassat” and together with DASN, “we,” “us,” “our”) collect, use, disclose, and otherwise processes personal information in connection with your access and use of the Lynq website located at www.lynq.network, the Tassat website located at www.tassat.com, the Tassat API Portal located at http://developer.lynq.com (collectively, the “Websites”), Tassat’s proprietary settlement platform (the “Platform”) and the services you may access through the Websites and Platform (collectively, “Services”), including, but not limited to, transaction and settlement services available to registered users on the Platform, whether accessed through the Websites, API, or otherwise.

This Privacy Policy does not address our privacy practices relating to job applicants, employees and other employment-related individuals, nor information that is not subject to applicable privacy laws (such as deidentified or publicly available information). This Privacy Policy is also not a contract and does not create any legal rights or obligations not otherwise provided by law.

By visiting our Websites, accessing the Platform, and/or registering to use our Services, you are acknowledging this Privacy Policy, and accept the accompanying Terms of Use, and, if applicable, the agreement between DASN and the institution at which you are employed or on whose behalf you will be accessing the Platform or Services (your “Institution”), as applicable, all of which form the “Agreement”. Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use.

Our Role in Processing Personal Information.

Data protection laws sometimes differentiate between “controllers” and “processors” of personal information. A “controller” determines the purposes and means (the why and how) of processing personal information. A “processor,” which is sometimes referred to as a “service provider,” processes personal information on behalf of a controller subject to the controller’s instructions.

This Privacy Policy describes our privacy practices where we are acting as the controller of personal information. However, this Privacy Policy does not cover or address how our customers may process personal information when they use our Services, or how we may process personal information on their behalf in accordance with their instructions where we are acting as their processor. As a result, we recommend referring to the privacy notice of the customer with which you have a relationship for information on how they engage processors, like us, to process personal information on their behalf. In addition, we are generally not permitted to respond to individual requests relating to personal information we process on behalf of our customers, so we recommend directing any requests to the relevant customer.

Information We Collect.

In the course of operating the Websites and the Platform, and providing the Services, we will collect (and/or receive) the following types of information.

Personal Information Provided by Individuals
- Contact Information. While it is not necessary to register in order to visit the Websites, some of the Services available through the Websites and use of the Platform, may require you to be a registered user (“Registered User”). In connection with any registration process, you or your Institution may need to provide certain contact information such as your name, firm name, and work email address, and work phone number (collectively, “Contact Information”).
  Contact Information may be collected for purposes that include administering your access and use of any Services for which you are registered, securely identifying you when you log into a Service, delivering Service-related notifications, providing customer support, and complying with applicable laws and regulations.
- Customer Information. Additional information about yourself that you voluntarily provide to us, such as and mailing list opt-in and opt-out information. We use this information primarily to provide you with our products and services, to facilitate your requests, and to improve our products and services.
Personal Information Automatically Collected
- Information About Your Device and Network. Information that we automatically collect when you use the Websites and Platform, such as the device from which you access the Websites or Platform, your IP addresses, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Websites or Platform you visit, and similar information concerning your use of the Websites or Platform;
- Information About the Way Individuals Use Our Services and Interact With Us.
  - From Cookies. Information that we collect using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. We use cookies to help us collect other information and to enhance your experience using the Websites and Platform. If you do not want the Websites or Platform to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this. However, if you decide not to accept cookies from us, the Websites or Platform may not function properly.
  - From Third Party Analytics. We may use one or more third-party analytics services (such as Google Analytics) to evaluate your use of the Websites and Platform, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Websites or Platform and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. By accessing and using the Websites or Platform, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Websites or Platform, as the case may be.
    Below is a list of analytics providers that we use; however, such list may be subject to change based on how we wish to understand the user experience. You may use the accompanying links to learn more about such providers and, if available, how to opt-out from their analytics collection.
    For Google Analytics, please visit: https://support.google.com/analytics/answer/6004245?hl=en

How we Use and Share Personal Information.

In addition to the primary purposes for using personal information described above, we may also use personal information we collect to:

Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to facilitate payment for our services, or to deliver the services requested;
Manage our organization and its day-to-day operations;
Communicate with you, including via email, texts, and/or telephone calls;
Facilitate the relationship we have with you and, where applicable, the company you represent;
Create and maintain accounts for our users;
Verify your identity and entitlement to our services;
Develop, operate, improve, maintain, protect, and provide the features and functionality of our services;
Create aggregated or de-identified information that cannot reasonably be used to identify you, which information we may use for purposes outside the scope of this Privacy Policy;
Test, enhance, update, and monitor the products and services, or diagnose or fix technology problems;
Help maintain and enhance the safety, security, and integrity of our property, products, services, technology, assets, and business;
Defend, protect, or enforce our rights or applicable contracts and agreements (including our Terms of Use), as well as to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
Detect, prevent, investigate, or provide notice of security incidents or other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of DASN, Tassat and others;
Facilitate business transactions and reorganizations impacting the structure of our business;
Comply with contractual and legal obligations and requirements;
Fulfill any other purpose for which you provide your personal information, or for which you have otherwise consented.

Our Disclosure of Personal Information.

a.) Parent Companies and Subsidiaries. We may share some or all of your personal information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us in connection with product development.

b.) Aggregated Data. In an ongoing effort to better understand our users, our Platform and Websites, we might analyze the Information in aggregate form in order to operate, maintain, manage, and improve the Platform and Websites. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and services to current and prospective business partners and to other third parties for other lawful purposes.

c.) Service Providers. We may use third parties to provide certain Websites and Platform related services, such as maintenance services, hosting services or development services. These other companies will have access to your Information only to the extent necessary for such third party service providers to perform the duties for which it has been retained by DASN or Tassat, as applicable, and to the extent permitted by law.

d.) Employers. If you are accessing any Service offered through the Websites or Platform as a Registered User of an Institution, we may provide your Institution with any and all of your personal information.

e.) Legal and Contractual Compliance. We may disclose your information to government or law enforcement officials, regulatory agencies or other third parties (such as attorneys or regulatory service providers), as necessary (in our sole discretion) to (i) comply with applicable laws or regulations, (ii) cooperate with governmental or law enforcement investigations, (iii) respond to legal claims or processes, (iv) protect the safety and legal rights of the public or any individual, (v) detect, prevent or remedy any suspected fraud, market manipulation or illegal, tortious or wrongful activity; or (vi) enforce applicable terms to which you are bound.

f.) Business Transfers. As we develop our businesses, we may sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.

Accessing and Modifying Personal Information and Communication Preferences.

If you are a Registered User of any Services, you may make changes to your personal information, such as updating your user preferences, by logging onto your user account, navigating to the “Support” menu and requesting the Platform administrator to make your changes. If you are not a Registered User and wish to review, update or correct any of your personal information, or “opt out” from any Websites or Platform functionalities, you may contact DASN at support@lynq.network or Tassat at support@tassat.com. If you are updating or correcting personal information or submitting a request for review of personal information in your capacity as an administrator, on behalf of Registered Users at your Institution, you represent that you have full authorization to provide this information to us. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases.

How We Protect Your Information.

We implement reasonable security measures designed to protect your Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Websites may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Children.

The Websites, Platform and Services are not intended for children under eighteen (18) years of age. Neither DASN nor Tassat markets any products or services to children under eighteen (18) years of age or knowingly collect any information from children under eighteen (18) years of age through the Websites, Platform or Services. If you are under 18, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide us personal information without their permission. If you have reason to believe that a child under the age of 18 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Nevada Privacy Rights.

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Although we do not currently sell personal information of Nevada residents (as defined under Nevada law), you can exercise this right by contacting DASN at support@lynq.network or Tassat at support@tassat.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.

Third Party Websites and External Links. Our Websites and Platform may contain links to websites with which we have no affiliation or relationship (“External Links”). We have no control over the privacy practices or the content of any of our business partners, advertisers, sponsors, or other websites to which we provide links. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any such External Sites. Neither DASN nor Tassat is, nor will be, responsible for the privacy practices or security of any such websites, and we urge you to read their privacy policies carefully.

Do Not Track. We do not respond to “Do Not Track” settings or other related mechanisms at this time.

Changes to Our Privacy Policy.

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time, and will post any changes on the Websites and Platform as soon as they go into effect. By accessing the Websites, Platform, and/or Services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

Contact Us.

If you have questions or comments about our privacy practices, please contact DASN via email at legal@lynq.network or Tassat at legal@tassat.com.