Halliday Privacy Policy

Last updated: September 25, 2026

This Privacy Policy for Halliday International Inc., ("Halliday", "Company", "we", "us" "our") describes how we collect, use and disclose information about users of the Halliday websites (including https://www.halliday.xyz, https://dashboard.halliday.xyz, and https://demo.halliday.xyz), and any related content, tools, applications, programs, orchestration, front end, messaging, features, protocols, wallets, and functionality offered on or through our Website or application (collectively, the "Features"). For the purposes of this Privacy Policy, "you" and "your" means you as the user of the Features.

Please read this Privacy Policy carefully. Halliday is committed to being transparent about any data we collect in connection with your use of the Features. This Privacy Policy is incorporated into and forms part of our Terms of Use (located at https://www.halliday.xyz/legal/terms-of-use), and your use of the Features is governed by those Terms of Use. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Privacy Policy to check for any updates.

We may update this Privacy Policy from time to time at our discretion, including in response to changing legal, technical, or business developments. If we make changes to this Privacy Policy, we will update the last revised date, post the updated version on our website, and take any other steps necessary to comply with applicable law. Should you not agree with the revised terms of this Privacy Policy, do not continue to use the Features.

1. HOW WE COLLECT AND USE INFORMATION ABOUT YOU

Depending on the requirements of the financial institutions and other service providers whose products and services are accessible through the Features (each, a "Third Party Provider"), Halliday may pass through information that includes name, address, date of birth, national identification numbers (such as social security number), identity documentation, email address, IP address, wallet address, and other similar information ("Pass Through Information") to enable that Third Party Provider to comply with their own legal, regulatory, compliance, or contractual obligations. Halliday passes this information through solely for that purpose and does not use it to improve or develop the Features or for marketing or promotional purposes. The Third Party Provider determines what information it requires and the legal basis on which it collects and uses that information. It collects that information under its own terms of use, privacy policy, and data consents, which you accept with that Third Party Provider. Halliday transmits the information at the Third Party Provider’s direction and does not independently determine what information is collected or how it is used. Where a Third Party Provider is subject to Know Your Customer or anti-money laundering requirements, the information it requires is collected in order to satisfy those legal obligations and is not optional; if you do not provide it, you may not be able to use that Third Party Provider’s services.

Halliday maintains relationships with third party data processing vendors ("Data Processing Vendors") for the purposes of passing through the Pass Through Information to Third Party Providers, including those Third Party Providers that set their own data collection requirements due to applicable law (such as Know Your Customer or anti-money laundering compliance requirements).

Data Processing Vendors support identity verification, compliance screening, and payment and transaction functionality in connection with the Features. Where a Third Party Provider requires it, Halliday may pass through your Pass Through Information to that provider solely to enable that Third Party Provider to perform those services and to meet its own legal, regulatory, compliance, or contractual obligations. Halliday does not analyze or use Pass Through Information for its own purposes, including to improve or develop the Features or for marketing or promotional purposes. Each Third Party Provider and Data Processing Vendor processes the information it receives in accordance with its own privacy policy, which we encourage you to review. Our current Data Processing Vendors include SumSub and Basis Theory, among others (as integrated from time to time). Our current Third Party Providers include Noah, Banxa, and Coinbase, among others (as integrated from time to time). Their privacy policies are available at the following links and via their public websites:

• Sum & Substance Ltd. (UK) (SumSub): https://sumsub.com/privacy-notice/

• Basis Theory Inc.: https://basistheory.com/resources/privacy-policy

• Noah US Inc. (and related parties): https://noah.com/en/privacy-notice

• Banxa Holdings Inc. (and related parties): https://banxa.com/wp-content/uploads/2025/02/Privacy-and-Cookies-Policy-1-July-2024-Banxa.pdf

• Coinbase Inc. (and related parties): https://www.coinbase.com/legal/privacy

Additionally, some aspects of the Features may require you to provide certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these Features.

We may also obtain information about you from other sources, including third parties through which you choose to share information with us, such as when interacting with us through social media (e.g., Discord, Twitter or Medium), third party service providers who help us process or supplement the information you have provided including to help us comply with applicable laws, and other publicly available sources. Any information that we receive about you from outside sources will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for their policies or practices.

In addition, our website, like most websites, uses third party tools, including cookies, pixels and other tracking technologies ("Tracking Technologies"), to provide and enhance the performance of our Features, facilitate and enhance user experience, and measure aggregate usage and performance of our websites. We do not use Tracking Technologies as it relates to Pass Through Information, and we do not combine Tracking Technologies data with Pass Through Information. The information we collect through Tracking Technologies includes: details of the devices used to access our website, such as language, unique device identifier, browser type, device type, and operating system information; IP address; approximate geolocation; date and time stamps, such as the date and time you first accessed the Features; and other information regarding your interaction with the Features, such as your activity while browsing the Website (e.g., whether you played a video, performed a search, downloaded a file, submitted a webform, etc.) number of page views, scrolling behavior, outbound clicks, clickstream data and log data. We may associate this information with your account (if you have a registered account) or the device you use to access the Features.

In addition to the specific uses of information described above, we may use certain of the above information to provide, improve and develop the Features and our product offerings, including as we describe in our Terms of Use, to comply with any applicable legal obligations, to enforce any applicable terms of service, to protect or defend the Features, our rights, the rights of our users, or others, for the purpose of combatting fraud, or to otherwise operate our business. Halliday does not use Pass Through Information, or any other sensitive personal information (including date of birth, social security number, or identity documentation), to improve or develop the Features, to train or improve any machine learning or artificial intelligence models, or for marketing, advertising, or profiling purposes. Further, we may also aggregate and de-identify information that we collect for our own purposes so that it is no longer reasonably associated with an identified or identifiable natural person, and may then use that aggregated or de-identified data for any lawful purpose. We do not aggregate, de-identify, derive data from, or otherwise create new data sets from Pass Through Information.

2. HALLIDAY’S ROLE

Where Halliday passes through your information to a Third Party Provider, the Third Party Provider (not Halliday) determines what categories of information are collected, the purposes for which that information is used, how long it is retained, and which vendors are engaged to process it. Halliday facilitates the transfer of that information at the Third Party Provider's direction and does not make those determinations independently.

Because the Third Party Provider determines how Pass Through Information is retained and handled, requests to access, correct, or delete Pass Through Information should be directed to the relevant Third Party Provider using the contact details in the relevant privacy policies linked above. If you contact us instead, we will forward your request to the relevant Third Party Provider and assist it in responding. Requests relating to information that Halliday collects for its own purposes (such as your email address, wallet address, or information collected through Tracking Technologies) should be directed to Halliday as described in the "Your Privacy Choices and Rights" section below.

3. HOW WE SHARE INFORMATION

In addition to the pass-through described above, we may share information that we collect for our own purposes with other third parties in the following circumstances:

• With vendors and service providers who support our business, including cloud storage providers, security vendors, and with professional advisors such as auditors, law firms or accounting firms.

• With our affiliates or otherwise within our corporate group.

• To enforce any applicable terms of use, and to ensure the safety and security of Halliday and our users.

• To comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.

• In connection with an asset sale, merger, bankruptcy, or other business transaction.

The disclosures described above do not apply to Pass Through Information, which is transmitted only to the relevant Third Party Provider and designated Data Processing Vendors.

4. DATA RETENTION

We retain information that we collect for our own purposes for as long as necessary to provide the Features, to comply with our legal and regulatory obligations, to resolve disputes, and to enforce our agreements, after which we delete or de-identify it. Pass Through Information is retained by the relevant Third Party Provider and the Data Processing Vendors in accordance with their own retention policies and legal obligations.

5. YOUR PRIVACY CHOICES AND RIGHTS

Depending on where you live, you may have rights under applicable privacy laws with respect to personal information that Halliday collects for its own purposes. These may include the right to request access to that information, to request that it be corrected or deleted, to request a copy of it in a portable format, and to appeal a decision we make about your request. You may exercise these rights by emailing us at privacy@halliday.xyz. We will verify your request before responding and will not discriminate against you for exercising any of these rights. As described above, requests relating to Pass Through Information should be directed to the relevant Third Party Provider; if you send such a request to us, we will forward it and assist the Third Party Provider in responding.

Halliday does not sell personal information, and does not share personal information for cross-context behavioral advertising, as those terms are defined under applicable United States state privacy laws. Halliday does not collect, use, or disclose sensitive personal information (including date of birth, social security number, and identity documentation) for any purpose other than transmitting it to the relevant Third Party Provider at that Third Party Provider’s direction, and does not use it to infer characteristics about you. You may also control Tracking Technologies as described in the "Cookies and Other Tracking Technologies" section below.

6. COOKIES AND OTHER TRACKING TECHNOLOGIES

Do Not Track Signals

Your browser settings may allow you to transmit a "Do Not Track" signal when you visit various websites. Like many websites, our website is not designed to respond to "Do Not Track" signals received from browsers. To learn more about "Do Not Track" signals, you can visit http://www.allaboutdnt.com/.

Cookies and Other Tracking Technologies

You may control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Features, including any portal features and general functionality, to work incorrectly.

Most browsers accept cookies automatically. However, you may be able to configure your browser settings to use the Features without some cookie functionality. You can delete cookies manually or set your browser to automatically delete cookies on a pre-determined schedule. For example, in the Chrome menu bar, select: More → Settings → Privacy and security → Cookies and other site data → See all cookies and site data, where you can choose to allow or block all or certain cookies, and choose to clear cookies when you quit Chrome. In addition, to opt out of Tracking Technologies, please email privacy@halliday.xyz.

7. SOCIAL FEATURES

Certain aspects of the Features may permit you to initiate interactions between the Features and third-party Features or platforms, including those that allow you to click and access Halliday's pages on certain third-party platforms (e.g., Discord and Twitter) and from there to "share" or "retweet" our content on those platforms. Use of these social features may entail a third party's collection and/or use of your data. If you use these features or similar third-party services, information you post or otherwise make accessible may be publicly displayed by the third-party service you are using. Both Halliday and the third party may have access to information about you and your use of both the Features and the third-party service. For more information on third-party websites and platforms, see below.

8. THIRD PARTY WEBSITES AND LINKS

We may provide links third-party websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible the privacy or security of these sites, including the accuracy, completeness, or reliability of their information. Information you provide on public or semi-public venues, including information you share on third-party social media platforms (such as Facebook or Instagram) may also be viewable by other users of the Features and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on the Features. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of personal information by third parties. Any information submitted by you directly to these third parties is subject to that third party's privacy policy.

9. CHILDREN'S PRIVACY

Children under the age of 18 are not permitted to use the Features, and we do not seek or knowingly collect any personal information from children under 18 years of age. If we become aware that we have unknowingly collected information from a child under 18 years of age, we will make commercially reasonable efforts to delete such information from our systems and to notify any Third Party Provider or Data Processing Vendor to which it was transmitted. If you are the parent or guardian of a child under 18 years of age who has provided us with their personal information, you may contact us using the below contact information to request that it be deleted.

10. DATA SECURITY

Please note that any information you send to us electronically, while using the Features or otherwise interacting with us, may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable, and we cannot guarantee "perfect security." Any information you transmit to us you do at your own risk.

11. HOW TO CONTACT US

Should you have any questions about our privacy practices or this Privacy Policy, please email us at privacy@halliday.xyz. General questions about the Features may also be sent to support@halliday.xyz.