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DRAFT FOR LEGAL REVIEW

Privacy Policy

This Privacy Policy explains how neongod LLC, operating the PixelFerry website and waitlist, collects and processes personal data. It currently applies only to the website at pixelferry.app and the associated email waitlist, not to the desktop application.

Effective date:

Current scope

The landing page collects only waitlist email registrations and the consent records needed to prove signup. No analytics, advertising, tracking pixels, session recording, or image uploads are assumed. A revised policy must be published before the app collects additional personal data.

1. Data controller

The controller responsible for your personal data is: neongod LLC Principal address: 447 Broadway, 2nd Floor, New York, NY 10013, United States State of organisation: Wyoming, United States Email: privacy@pixelferry.app EU or EEA representative under Article 27 GDPR: not yet appointed. One will be designated and named here before the beta opens.

2. Personal data we process

WAITLIST REGISTRATION AND EMAIL UPDATES When you join the PixelFerry waitlist, we process: • Your email address • The date and time of registration • The verbatim consent wording you agreed to, and when • The version of the consent wording and Privacy Policy presented to you • The signup source or webpage • A salted, one-way pseudonym derived from your IP address, used to document registration and limit abuse. Your IP address itself is never stored We use this information to register you for the waitlist, confirm your email address, send launch and early-access updates, manage unsubscribe requests, and demonstrate that valid consent was obtained. The legal basis is consent under Article 6(1)(a) GDPR. Providing your email is voluntary. WEBSITE OPERATION AND SECURITY Hosting and infrastructure providers may process limited technical information such as IP address, browser and device type, requested pages, request time, referrer, and error or security data. The legal basis is our legitimate interest under Article 6(1)(f) GDPR in operating and protecting the website. We do not use this information to create marketing profiles.

4. Retention periods

• Waitlist email and registration data: kept as the record of your consent, and deleted when you ask us to erase it. NOTE — there is currently no automated deletion schedule for this data; a retention period will be set before this policy leaves draft. • Website security and server logs: normally no longer than 30 days, unless needed to investigate an incident • Suppression records: minimum information may be retained for up to five years • Compliance records: consent and withdrawal records may be retained for the applicable legal limitation period Information may be retained longer where required by law or needed to establish, exercise, or defend legal claims.

5. Service providers and recipients

We may disclose personal data to providers acting on our instructions: • Website hosting and content delivery: Cloudflare, Inc. (United States), which serves this site and the waitlist API • Bot protection on the signup form: Cloudflare Turnstile, operated by the same provider • Email and waitlist list management, including the confirmation email: Brevo (Sendinblue SAS, France) Providers may process data only for the services they provide and must protect it under appropriate contractual and security obligations. We may disclose information where required by law or needed for legal claims. We do not sell personal data.

6. International transfers

Cloudflare, Inc. is established in the United States, so personal data processed by it is transferred outside the European Economic Area. Brevo (Sendinblue SAS) is established in France. Where data is transferred outside the EEA, we use an applicable safeguard, which may include: • A European Commission adequacy decision • EU Standard Contractual Clauses • The EU-US Data Privacy Framework, where applicable • Additional contractual, organizational, or technical safeguards Contact us for information about the safeguards used.

7. Your rights

Subject to applicable conditions and exceptions, you may have the right to: • Confirm whether we process your data • Request access or correction • Request deletion or restriction • Receive data you provided in a structured, machine-readable format • Withdraw consent at any time • Object to legitimate-interest processing • Object to direct marketing • Lodge a complaint with a data protection authority To exercise rights, contact privacy@pixelferry.app. We normally respond within one month and may request information needed to confirm identity.

8. Complaints

You may complain to the data protection authority where you live, work, or believe an infringement occurred. Hungarian National Authority for Data Protection and Freedom of Information, NAIH 1055 Budapest, Falk Miksa utca 9-11 Hungary We encourage you to contact us first so we can attempt to resolve your concern.

9. Automated decision-making

We do not use waitlist data for automated decision-making or profiling that produces legal or similarly significant effects.

10. Children

The PixelFerry waitlist is not directed to children under 16. If we learn that a child's personal data was collected without valid authorization, we will delete it where required.

11. Security

We use reasonable technical and organizational measures designed to protect personal data against unauthorized access, disclosure, alteration, loss, or destruction. No internet transmission or electronic storage method is completely secure, and absolute security cannot be guaranteed.

12. Changes to this policy

We may update this Privacy Policy when the website, application, providers, or processing activities change. The latest version will be published with an updated effective date. Where a change materially affects consent-based processing, we will request new consent where required.

13. Contact

Questions, requests, and complaints may be sent to: neongod LLC Email: privacy@pixelferry.app Address: 447 Broadway, 2nd Floor, New York, NY 10013, United States