Privacy Policy

This Privacy Policy ("Policy") describes how Refractor, Inc. ("Lore," "we," "our," or "us") collects, uses, discloses, and otherwise processes personal information in connection with your use of our website located at https://www.lore.xyz and any related content, services, products, features, functionality, or other online platforms (collectively, the "Services"). This Policy does not apply to personal information processed in connection with employment or recruitment activities.

For purposes of this Policy, "personal information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked (directly or indirectly) to an individual. Personal information does not include aggregated or de-identified information that is maintained in a form that cannot reasonably be associated with or linked to an individual.

We collect personal information directly from you, automatically through your use of the Services, and from third-party sources. The categories of personal information we collect include:

• Identifiers and Contact Information, such as your name, email address, and social media handles (e.g., Twitter, Discord, Telegram).
• Account Information, including your public blockchain address (wallet ID), profile photo, username, and other information you provide when you register for an account.
• Fund Participation Information, such as transactions, deposits, proposals, and voting activity.
• Inquiry and Communications Data, including information submitted through our contact forms, emails, chatbots, or other communications.
• Marketing and Newsletter Preferences, including your email address and any preferences or interests you disclose.
• Event and Meeting Information, including RSVP and registration data and, in some cases, audio/video recordings of Lore-hosted sessions.
• Employment Application Information, including job application submissions and related materials if you apply for a position at Lore.

We, and our third-party service providers, may automatically collect the following categories of information through your use of the Services:

• Device Information and Technical Identifiers, such as IP address, browser type, operating system, referral/exit URLs, device identifiers, and activity logs.
• Usage Data, including page views, interaction with features, time spent, and clickstream behavior.
• Location Information, inferred from IP address or browser metadata.
• Cookies and Similar Technologies, such as web beacons, pixel tags, and local storage.

You can manage cookie preferences through your browser settings. Disabling cookies may affect functionality of certain features.

We may obtain personal information from:

• Wallet Providers, when you connect a crypto wallet, including MetaMask, WalletConnect, Coinbase Wallet, or Phantom.
• Analytics and Tracking Tools, including Mixpanel, Hotjar, Google Analytics, Google Tag Manager, Addressable, and Metabase.
• Social Media Platforms, including public posts or information linked through Twitter, Discord, and Telegram.
• Third-Party Integrations, such as blockchain analytics services and vendor platforms used for user insights or onboarding.
• Legacy Systems, including data (e.g., email addresses) imported from Prysm.xyz or Lore Collective.

We use personal information for the following business and commercial purposes:

• Provide and maintain the Services;
• Create and manage user accounts and profiles;
• Authenticate users and enable access to shared funds and portfolios;
• Enable participation in transactions, proposals, and voting;
• Display public activity feeds, leaderboards, fund pages, and profiles;
• Communicate with users, including for customer support and responding to inquiries;
• Send marketing and promotional messages (where permitted);
• Send service-related notifications (e.g., account activity, proposal updates) on an opt-in basis;
• Monitor, evaluate, and improve the Services;
• Conduct research and develop new features;
• Comply with legal and regulatory obligations;
• Detect, investigate, and prevent fraudulent or malicious activity;
• Enforce our Terms of Service and other legal rights.

We may disclose your personal information to the following categories of recipients:

• Public Blockchain Participants, as your wallet ID and onchain activity may be recorded on public ledgers.
• Other Users, for example via fund pages, group feeds, or profile visibility.
• Service Providers, including vendors that assist with hosting, analytics, infrastructure, authentication, communications, and development.
• Marketing Partners, who help us conduct campaigns, measure performance, and manage contact preferences.
• Affiliates, including our parent company and subsidiaries.
• Professional Advisors, such as auditors and legal counsel.
• Government Authorities or Law Enforcement, when required to comply with legal obligations or lawful requests.
• In Connection with Business Transactions, such as mergers, acquisitions, financings, or asset sales.
• With Consent, when you instruct or explicitly authorize us to do so.

We do not sell your personal information or share it with third parties for their independent marketing purposes.

We retain personal information for as long as necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law. Due to the immutable nature of blockchain systems, some data (e.g., wallet IDs, transactions) may not be deleted even upon request.

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information under our control. However, no system is 100% secure, and we cannot guarantee the security of your personal information.

• Access and Correction: You may request access to and correction of your personal information.
• Email Preferences: You may unsubscribe from marketing emails at any time using the link provided. Transactional messages and legal notifications may still be sent.
• Cookie Controls: Manage cookies through browser settings or via available opt-out tools.
• Analytics and Interest-Based Ads: Opt out via NAI or DAA.
• Contact: Email hello@lore.xyz with requests related to your data.

The Services are not intended for individuals under the age of 13, and we do not knowingly collect personal information from children. If we learn that a child has provided us personal information, we will delete it.

Our Services may link to third-party websites or integrate third-party tools. We are not responsible for the privacy practices of those third parties. You should review their policies separately.

We do not actively market to users in the EU, UK, or other jurisdictions with extraterritorial data protection laws. However, if you access our Services from outside the U.S., your information may be transferred to, stored, and processed in the United States.

• California: Residents may request information about data shared for direct marketing (Shine the Light). Email hello@lore.xyz.
• Nevada: Residents may opt out of future data sales (though we do not currently sell data). Email hello@lore.xyz.

We may update this Policy from time to time. When we do, we will revise the “Last Updated” date. If material changes are made, we will notify users through the Services or by email.

If you have questions or concerns regarding this Privacy Policy or our practices, please contact us at:
Refractor, Inc.
Email: hello@lore.xyz