Privacy Policy - Figment

Privacy Policy

Last Updated: March 3, 2026

Introduction

Figment Inc. and its affiliated entities (collectively, “Figment,” “we,” “our,” or “us”) are committed to protecting your privacy in accordance with all applicable data protection laws. This Figment Global Privacy Policy (“Privacy Policy”) describes the types of information, including personal data, that Figment collects from you or that you may provide when you use our products and services (referred to collectively herein as the “Services”). Services include, but are not limited to, our content on the websites located at www.figment.io, app.figment.io, and docs.figment.io or any other webpages or mobile applications we own, operate or distribute (collectively, the “Website”). This Privacy Policy also explains how Figment and its affiliated entities collect, use, maintain, protect, and disclose your personal data.

Please read this Privacy Policy carefully. By using the Website, you agree to the collection, use, and disclosure of your personal data as described in this Privacy Policy. If any term in this Privacy Policy is unacceptable to you, please do not use the Website or provide any personal data to us.

Residents of the European Union/European Economic Area, California, Colorado, Connecticut, Utah, and Virginia have additional rights: See Appendix A, attached hereto, for additional disclosures, including certain rights, regarding any personal data that we process subject to relevant and applicable data protection legislation.

This Privacy Policy will explain:

1. What Personal Data We Collect

We collect and maintain several types of personal data about visitors to the Website, including both those who view only publicly-available content (“Visitors”) and end users (“Users”) who interact with the Website or our Services. Personal data does not include anonymous data (i.e., information that cannot be associated with or tracked back to a specific consumer, household or device).

a. Personal Data You Provide

We collect personal data that you provide to us directly through the Website and our Services. The personal data we collect from you includes:

Personal Information. When using our Services or the Website, you may be requested to provide us with certain personal information about yourself, such as your first and last name, physical address, email address, company, and/or title. We do not collect any personal information from Visitors when they use the Website unless they provide such information voluntarily.
Wallet Information. When staking Tokens to us, you may need to provide us with certain information related to the digital wallet in which you maintain the Tokens being staked (“Wallet ID”). We will only use your Wallet ID in order to provide our Services to you. We do not share your Wallet ID with any third parties other than for the purpose of providing our Services to you.
Account Information. You may need to register an account with Figment to use certain of our Services. When you register an account with Figment, we may collect information such as your username, email address, password, custodial platform API keys, Wallet IDs, and other similar information you voluntarily provide.
Third-Party Information. We also may combine the personal data that we have collected about you with other information about you obtained from other sources (both online and offline), such as from third parties and public sources.

b. Data We Collect Automatically

As you navigate through and interact with the Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

Device Information. When you use and access the Website, we receive information about your device, such as your IP address and location.
Usage Information. We automatically receive information about your interactions with the Website including details of your visits to the Website, anonymous IDs, traffic data, form submissions, date and time of access, and the resources that you access and use on the Website.

c. Cookies and Other Automated Technologies

The Website uses cookies, analytics tools, and other similar technologies to collect information about your equipment, browsing actions, and patterns to help the Website function effectively, improve our Services, and assist us with our marketing. For more information, please click the cookie icon on the bottom-right corner of your screen.

d. Combination of Information

We may combine the information we receive from and about you, including information you provide to us and information we automatically collect through the Website and Services, as well as information collected from other online sources or from third-party sources to help us tailor our communications to you and to improve the Website and Services.

2. Why We Collect Your Personal Data

Figment may use personal data we collect from you for a variety of reasons, including the following:

To fulfill our contractual obligations to you or your requests for Services or support.
To communicate with you about our Services and other Services that you may request from us or that we may provide.
To process your payments and provide you with invoices for such payments.
To periodically notify you about changes to the Website or any Services we offer.
To market our Website and Services to you, including by communicating with you about upcoming events and managing your participation in these events.
To analyze User behavior, analyze the effectiveness of marketing and communications, and optimize the Website’s performance and our Services.
To maintain, manage, and improve the Website and our Services.
To create and use de-identified, anonymized, and aggregate information that cannot be used to personally identify you.
To help maintain the safety, security and integrity of the Website and our Services.
To operate the Website and perform any Services associated with the Website, including providing you with technical support.
To investigate and respond to suspected illegal activities or fraud.
To enforce this Privacy Policy and any other terms that you have agreed to.
To comply with applicable federal, state, local, provincial, and other laws and regulations and respond to law enforcement requests or other valid legal requests.
To assess or effectuate a sale or purchase of businesses or assets or to assess or effectuate a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event.

3. How We Disclose Your Personal Data

Figment will only grant access to personal data on a need-to-know basis. Figment discloses the personal data we collect from and about you to the following categories of third parties:

Affiliates and Agents. We may share your personal data within the Website, to our affiliates, agents, employees, contractors, consultants, and other agents who require such information to assist us.
Service Providers. We may share your personal data with third-party service providers that perform services on our behalf.
Business and Marketing Partners. We may share your personal data with business and/or marketing partners.
Social Media or External Websites. Our Website contains links to independent social media websites or other websites.
Government or Law Enforcement. We may use your information to comply with any court order, law, or legal process.
Successors. We may share your personal data with a potential or actual buyer or other successor in the event of a merger or sale.

4. How We Protect Your Personal Data

We have implemented appropriate technical, physical, and organizational measures to protect personal data. Unfortunately, no method of transmission over the Internet or method of electronic storage is 100% secure.

5. How Long We Keep Your Personal Data

We retain your personal data to fulfill the purposes for which it is collected, or as required by applicable laws and regulations.

6. Your Rights With Regard To Your Personal Data

We have created the following mechanisms to provide you with control over your personal data:

Opt-Out From Marketing Communications. You can opt out of receiving our marketing communications.
Cookies. The means by which you can refuse cookies through your web browser vary from browser-to-browser.

Depending on your local law, you may have certain rights regarding personal data we have collected about you.

7. Third-Party Websites

The Website and email messages from us may contain links to third-party websites, which may have privacy policies that differ from our own. Figment encourages you to read the privacy policies and terms of use of these websites.

8. Children’s Privacy

We do not knowingly collect personal data from children under the age of 16. If you believe that a child under the age of 16 has provided personal data to us, please contact us.

9. How to Contact Us

If you have additional questions about this Privacy Policy or the practices described herein, you may contact us at:

Email: legal@figment.io

Postal Address: 545 King Street West, Toronto, Ontario, M5V 1M1

APPENDIX A – ADDITIONAL REGION-SPECIFIC DISCLOSURES

Residents of the European Union/European Economic Area, California, Colorado, Connecticut, Utah, and Virginia have additional rights.

11. Additional Information for Residents of the European Union/European Economic Area

If you live in the European Union (the “EU”) or the European Economic Area (the “EEA”), the following additional disclosures apply to your personal data that we process.

Lawful Bases of Processing

You have provided us with your consent to do so.
Processing is necessary for the performance of a contract.
Processing is necessary for us to comply with a legal obligation.
We have a legitimate interest in processing your personal data.

International Data Transfers

We may transfer, use and/or store your personal data outside the EU/EEA, including to or in the United States and other countries.

12. Additional Information for Residents of California

A.Disclosures of Your Personal Information for a Business Purpose

We collect the following categories of personal information from California residents for the following business purposes:

Category of Personal Information Collected	Categories of Sources of Collection	Business or Commercial Purpose for Use	Categories of Third Parties with whom Personal Information is Shared
Identifiers	Directly from you	Register an account	Affiliated companies
Commercial Information	Directly from you	Payments relating to Services	Business partners
Internet Activity Information	Collected automatically	Research/development	Government or law enforcement
Professional Information	Directly from you	Marketing and analytics	Business partners
Geolocation Data	Directly from you	Marketing and analytics	Government or law enforcement
Inferences	Directly from you	Marketing and analytics	Marketing or analytics service providers

B.Sale or Sharing of Personal Information

We do not sell, trade, or rent the personal information of California residents to third parties.

C.Your California Privacy Rights

If you are a California resident, the California Consumer Privacy Act (“CCPA”) provides you with specific rights regarding your personal data.

D.How to Exercise Your California Privacy Rights

To exercise your California privacy rights, please submit a verifiable consumer request to us by either visiting our online portal or emailing us at legal@figment.io.

13. Additional Information For Residents of Colorado, Connecticut, Utah, and Virginia

For eligible residents of Colorado, Connecticut, Utah and Virginia, you have rights with respect to the personal information that we collect about you.

14. Additional Information for Residents of Singapore

If you are a resident of Singapore, we process your personal data in accordance with the Personal Data Protection Act 2012 (“PDPA”).

15. Additional Information for Residents of Japan

If you are a resident of Japan, we process your personal information in accordance with the Act on the Protection of Personal Information (”APPI”).