Privacy Policy

Last Updated: April 27, 2025

This Privacy Policy describes the privacy practices of Evolve Labs Inc. ("Easy.fun," "we," "us," or "our") and how we handle personal information that we collect through our digital properties that link to this Privacy Policy, including our website (easy.fun) as well as through social media, our marketing activities, webinars, conferences, and other activities described in this Privacy Policy (collectively, the "Service").

1. Personal Information We Collect

We collect information about you directly from you and from third parties, as well as automatically through your use of our Service.

1.1 Information You Provide to Us

You may browse the Service without registering with us or providing personal information; however, certain information is collected from you as described below:

  • Publicly available data such as your digital asset wallet address and public blockchain data, which is only used to provide and improve the Service and to ensure compliance with applicable laws and regulations.
  • Your contact information and other data related to your use of the Service (to the extent that you provide it to us) in connection with survey responses or customer support queries.
  • While not required to access the Service, you may choose to provide us with your email address or social media handle in order to participate in certain promotional activities or to receive additional information related to upcoming product launches or developments.
  • If you choose to utilize email recovery methods available via our service providers, this recovery information is stored on their servers.
  • Communications that we exchange with you, including when you contact us with questions or feedback, post to our communications boards, through social media, or otherwise.
  • 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.
  • If you are providing personal information of third parties to us for specific purposes, you are responsible for ensuring that you have all required permissions and consents (including express consent from such third parties) to provide such personal information to us for such purposes and that our use of such personal information does not violate any applicable law, rule, regulation, or order. If the third party withdraws their consent, you agree to notify us immediately.

    1.2 Information We Collect Automatically

    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:

  • Usage data, such as your browser type and operating system, the web pages that you connect your wallet to, the webpage that led you to our Service, and country-level location information.
  • Device data, such as your computer's or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state, or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.
  • 1.3 Third-Party Sources

    We may receive personal information about you from third-party sources. For example, we may obtain your personal information from third parties, such as publicly available sources and data providers.

    2. How We Use Your Personal Information

    We use the information we collect for the following purposes:

    Provide our services:

  • Communicate with you about your use of our Service and respond to your inquiries
  • Fulfill your orders and for other customer support purposes
  • Provide, operate, and improve the service and our business
  • Provide personalized services:

  • Tailor the content and information that we may send or display to you
  • Offer location customization and personalized help and instructions
  • Personalize your experiences while using the Service
  • Understand your needs and interests, and personalize your experience with the Service and our communications
  • Improve and develop our services:

  • Ensure our service is working as intended
  • Better understand how users access and use our Service, both on an aggregated and individualized basis
  • Make improvements, develop new functionality, and for other research and analytical purposes
  • Marketing and promotional purposes:

  • Send you news, newsletters, special offers, and promotions
  • Conduct contests and sweepstakes
  • Contact you about products or information we think may interest you
  • Assist us in advertising our products on third-party websites
  • Compliance and protection:

  • Enforce any applicable Terms of Use
  • Comply with applicable laws, lawful requests, and legal process
  • Exercise or defend legal claims
  • Detect, prevent, or address fraud, security, or technical issues
  • Protect our property, legal rights, or that of others
  • Comply with law enforcement, regulatory, and tax authority-related requests
  • 3. 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:

    Consent: Where you have provided consent, we may share your information as described at the time of consent.

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

    Affiliates: We may disclose the information we collect from you to our affiliates or subsidiaries.

    Blockchain: Given that blockchain is a public record, the transaction records associated with any transactions you make using the Service will be publicly available on blockchain.

    Business transfers: If we are acquired by or merged with another company, if some or all of our assets are transferred to another company, or as part of a bankruptcy proceeding, or if we are in negotiations for any of these types of transactions, we may transfer the information we have collected from you to counterparties in connection with such transactions.

    Legal purposes: We may disclose information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of any applicable Terms of Use or this Policy, or as evidence in litigation or regulatory investigations in which we are involved in any capacity.

    Aggregate and de-identified information: We may share aggregate or de-identified information about users and their use of the Service with third parties and publicly for marketing, advertising, research, or similar purposes.

    Please note that except as noted above, we will not sell or share your personal information with any third party for their direct marketing purposes without your consent.

    4. Our Use of Cookies and Other Tracking Mechanisms

    We and our service providers use cookies and other tracking mechanisms to track information about your use of our service. We may combine this information with other information we collect from you (and our third-party service providers may do so on our behalf).

    Currently, our systems do not recognize browser "do-not-track" requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies), but such disabling may impair use of the Service.

    4.1 Cookies

    Cookies are alphanumeric identifiers that we transfer to your computer's hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our service, while others are used to enabling a faster log-in process or to allow us to track your activities. There are two types of cookies: Session Cookies: These expire when you close your browser or turn off your computer.

    Persistent Cookies: These remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.

    4.2 Disabling Cookies

    Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Service who disable cookies may not be able to browse certain areas of the Service or use its full functionality.

    4.3 Third-Party Analytics

    We use automated devices and applications, such as Google Analytics, to evaluate usage of our Service. We also may use other analytic means to evaluate the Service. We use these tools to help us improve the service, performance, and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your personal information with these third parties.

    4.4 Third-Party Links

    Our Service may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

    4.5 Security of Your Personal Information

    We have implemented commercially reasonable precautions to protect the information (including your personal information) we collect from loss, misuse, or unauthorized access, disclosure, alteration, or destruction. Please be aware that despite our efforts, no data security measures can guarantee 100% security.

    You should take steps to protect against unauthorized access to your password and your devices (such as your phone and computer). We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

    5. Your Rights Regarding Your Personal Information

    In accordance with Panama's data protection regulations and applicable international standards, you may have certain rights regarding your personal information, including:

  • The right to access, receive a copy of, modify, or delete personal information that you have submitted to us.
  • The right to rectify inaccurate personal information.
  • The right to erasure your personal information in certain circumstances.
  • The right to restrict processing of your personal information.
  • The right to data portability.
  • The right to object to processing your personal information.
  • To exercise these rights, please contact us at [email protected]. We will use reasonable efforts to accommodate such requests to the extent required by law, provided that we may be required to retain personal information to comply with legal obligations, accounting requirements, or for other business purposes. We may request additional information to verify the identity of the requesting party before responding to a request.

    Please note that copies of information that you have updated, modified, or deleted may remain viewable in cached and archived pages of the Service for a period of time.

    6. Your Choices Regarding Marketing Communications

    We may send periodic promotional or informational emails to you. You may opt out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt out of receiving marketing emails about recommendations or other information we think may interest you, we may still send you non-marketing related emails.

    7. Location of Information

    Our service is offered from Panama. We store any information we collect in Panama and other locations where our service providers maintain servers. If you access the Service from outside Panama, you agree to the transfer of your information to Panama and other jurisdictions, which may provide fewer protections for your personal information than your jurisdiction of residence.

    8. Children Under 13

    Our Service is not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.

    9. Do Not Track

    Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit https://www.allaboutdnt.com.

    10. Global Privacy Control (GPC)

    We recognize the Global Privacy Control signal as a valid opt-out mechanism in jurisdictions where applicable.

    11. 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. If required by law, we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the Service. 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.

    12. How to Contact Us

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

    Email: [email protected]

    Evolve Labs Inc. is registered in Panama and complies with Panama's data protection regulations.