Privacy Policy

THRESHOLDS.TRADE ("Thresholds," "we," "us," or "our"). This Privacy Policy explains how Thresholds collects, uses, discloses, stores, and otherwise processes personal information in connection with the Thresholds managed mining operations service ("MMaaS"), including related websites, dashboards, communications, support channels, and associated services (collectively, the "Service"). 1. Scope This Privacy Policy applies to personal information we process in connection with your use of the Service, your communications with us, and our business operations. It does not apply to third-party websites, services, wallets, payment providers, infrastructure providers, or platforms that we do not control, even if they are linked to or used alongside the Service. 2. Personal Information We Collect Depending on how you interact with the Service, we may collect the following categories of personal information: (a) Account and contact information, such as your name, organization name, email address, phone number, mailing address, and account identifiers. (b) Billing and transaction information, such as invoices, billing contact details, payment status, subscription records, tax-related information, and transaction metadata. Thresholds may use third-party payment processors and may not store full payment card details. (c) Service and support information, such as plan selections, operational requests, tickets, messages, exported reports, preferences, and communications history. (d) Technical, device, and log information, such as IP address, user-agent, browser type, approximate geolocation derived from IP, timestamps, referrers, session events, authentication events, and security logs. (e) Operational and audit information, such as account changes, support actions, notices sent, administrative events, and other records reasonably necessary to operate, secure, troubleshoot, document, and improve the Service. (f) Information you choose to provide, such as materials sent through contact forms, support requests, email, or other communications. 3. How We Use Personal Information We may use personal information for the following purposes: (a) to provide, administer, maintain, and improve the Service; (b) to create and manage accounts and customer records; (c) to process orders, subscriptions, invoices, and payments; (d) to provide support, troubleshooting, and operational communications; (e) to monitor performance, detect incidents, prevent fraud, and protect the security and integrity of the Service; (f) to generate logs, records, and exports relevant to service delivery and dispute handling; (g) to comply with legal, regulatory, tax, accounting, and contractual obligations; (h) to enforce our Terms of Service and other applicable policies; and (i) to communicate updates, notices, and other information relevant to your account or our business relationship. 4. Legal Bases Where applicable law requires a legal basis for processing, we rely on one or more of the following: performance of a contract, taking steps at your request prior to entering a contract, legitimate interests, compliance with legal obligations, and consent where consent is required by law. 5. How We Share Personal Information We may disclose personal information: (a) to service providers, contractors, and subprocessors that help us operate the Service, including hosting, communications, analytics, support, infrastructure, payment, security, and administrative vendors; (b) to professional advisors such as lawyers, accountants, insurers, and auditors where reasonably necessary; (c) to governmental, regulatory, law enforcement, or judicial authorities where we believe disclosure is required or appropriate under applicable law, legal process, or to protect rights, safety, property, or the integrity of the Service; (d) in connection with a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar transaction, subject to customary confidentiality safeguards; and (e) with your direction or consent. Thresholds does not sell personal information in the ordinary sense of selling customer lists for unrelated third-party marketing. If applicable law uses a broader statutory meaning of "sale" or "sharing," your rights may depend on that law and the facts of the disclosure. 6. Cookies and Similar Technologies We may use cookies, local storage, session tokens, and similar technologies to keep you signed in, remember settings, maintain security, analyze service usage, and improve functionality. You may be able to manage cookies through your browser or device settings, but disabling certain technologies may affect service availability or functionality. 7. Data Retention We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Service, maintain records, resolve disputes, enforce agreements, prevent fraud, satisfy legal obligations, and preserve backups. Retention periods vary depending on the type of information, the sensitivity of the data, the reason it was collected, operational necessity, and applicable legal requirements. We may delete, de-identify, anonymize, or aggregate information when it is no longer reasonably required. 8. Security We use reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, and disclosure. However, no method of transmission, storage, or security control is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining credential security, using strong authentication practices, and notifying us promptly of suspected unauthorized access or compromise. 9. International and Cross-Border Processing Thresholds and its providers may process or store personal information in jurisdictions other than your own. As a result, personal information may be subject to the laws and lawful access requirements of those jurisdictions. Where required by applicable law, we use appropriate measures for cross-border transfers. 10. Your Rights and Choices Depending on the law that applies to you, you may have rights to request access to, correction of, deletion of, or information about our handling of your personal information, and in some cases rights relating to portability, restriction, objection, or withdrawal of consent. These rights are not absolute and may be limited by law, security requirements, technical feasibility, privilege, fraud prevention concerns, or legitimate business and recordkeeping needs. To make a request, use the contact form. We may take reasonable steps to verify your identity before acting on your request. 11. Children The Service is not directed to children, and Thresholds does not knowingly collect personal information from children in connection with the Service. 12. Third-Party Services The Service may interact with third-party websites, infrastructure, wallet software, payment providers, communications platforms, or other services. Thresholds is not responsible for the privacy practices of third parties, and you should review their applicable terms and privacy notices separately. 13. Changes to This Privacy Policy We may update this Privacy Policy from time to time. Material changes will be reflected by an updated effective date and, where required by law, communicated by reasonable means before they take effect. Your continued use of the Service after the effective date of a revised Privacy Policy constitutes acknowledgment of the updated Policy. 2026-03-25