Privacy Policy Effective Date: 21 September 2025 Who We Are SolPad is operated by Techtime-Apps ("we", "us", or "our"). Controller: Techtime-Apps Representative: Daniel Hoefer Contact Email: kontakt@techtime-apps.com Scope This Privacy Policy explains how we process information when you use SolPad, including the non-custodial wallet, token creation utilities, and related features for the Solana blockchain. This Policy applies to our mobile and web experiences. Non-Custodial Design and Your Seed Phrase • SolPad is a non-custodial wallet and launchpad. Your private keys and recovery phrase ("seed phrase") are generated and stored locally on your device. • We do not have access to, and cannot recover, your seed phrase or private keys. If you lose your seed phrase or private keys, your wallet and any associated assets cannot be restored by us. • Always back up your seed phrase securely and never share it with anyone. Information We Process We designed SolPad to minimize personal data processing. Depending on your use of SolPad, we may process: 1) Wallet & On-Chain Information • Public wallet addresses, token balances, and transaction history as publicly available on the Solana blockchain. • No private keys or seed phrases leave your device. • We may query blockchain indexers/providers to display balances, prices, and transaction statuses. 2) Device, Usage, and Diagnostics (if enabled) • App version, device type, OS version, performance metrics, crash logs, and similar technical data to maintain and improve SolPad. • This may be facilitated by third-party processors (e.g., Google Firebase services such as Crashlytics/Analytics) subject to their privacy terms. Where required, we will request your consent. 3) Communication Data • If you contact us by email or via in-app forms, we process your message, email address, and any other information you provide for support and record-keeping. 4) Cookies and Similar Technologies (Web only) • We use strictly necessary cookies to operate the web experience. With your consent, we may use analytics cookies to understand and improve usage. Purposes and Legal Bases (GDPR/UK GDPR) • Provide the Service: To operate the non-custodial wallet and token tools (Art. 6(1)(b) GDPR – contract necessity). • Improve and Secure SolPad: To diagnose, maintain, and enhance performance and security (Art. 6(1)(f) GDPR – legitimate interests). • Compliance: To comply with legal obligations and enforce our Terms (Art. 6(1)(c) GDPR – legal obligation). • Consent-Based Features: For optional analytics or marketing where applicable (Art. 6(1)(a) GDPR – consent). Data Retention • Local Wallet Data: Your keys/seed are stored locally on your device; we do not retain them on our servers. • Support Communications: Retained as long as necessary for the purpose of support and record-keeping, and to comply with legal obligations. • Analytics/Diagnostics: Retained according to our processors' standard retention periods or until you withdraw consent (where consent applies). Sharing and Disclosures We do not sell your personal information. We may share limited information with: • Service Providers/Processors: Infrastructure, analytics, crash reporting, and security providers who process data on our behalf under appropriate data protection agreements (e.g., Firebase services by Google LLC). • Public Blockchain Networks: Interactions with Solana inherently publish transactions and addresses to a public ledger. • Legal and Compliance: Competent authorities or third parties as required by law, court order, or to protect our rights. International Transfers If data is transferred outside your jurisdiction (e.g., to the United States), we rely on appropriate safeguards, such as Standard Contractual Clauses (SCCs), or other lawful transfer mechanisms. Your Rights (GDPR/UK GDPR) Depending on your location, you may have rights to: access; rectification; erasure; restriction; portability; objection; and withdraw consent at any time (without affecting the lawfulness of processing based on consent before its withdrawal). Because on-chain data is public and immutable, erasure requests cannot affect information already recorded on the blockchain. To exercise your rights, contact: kontakt@techtime-apps.com. US State Privacy Disclosures (e.g., CCPA/CPRA) California and certain US state residents may have rights to know, access, delete, correct, and opt out of targeted advertising or certain disclosures. We do not sell personal information. To exercise rights, contact: kontakt@techtime-apps.com. We will not discriminate against you for exercising your rights. Security • We employ industry-standard measures, such as device-secure storage (where available) for keys, encryption in transit (TLS), and access controls. • No method of transmission or storage is 100% secure. You are responsible for securing your device and seed phrase. If your device is compromised, your wallet may be at risk. Children's Privacy SolPad is not directed to children. You must be at least 18 years old to use SolPad. If you believe a minor has provided us with personal data, contact us so we can take appropriate action. Third-Party Links and Services SolPad may link to third-party sites or integrate third-party services (e.g., blockchain providers). Their privacy practices are governed by their own policies; we are not responsible for their practices. Changes to This Policy We may update this Policy from time to time. Material changes will be notified within SolPad or by other appropriate means. Your continued use of SolPad after changes become effective constitutes acceptance of the updated Policy. Contact Techtime-Apps Attn: Privacy Email: kontakt@techtime-apps.com Terms of Use Effective Date: 21 September 2025 Parties and Acceptance These Terms of Use (the "Terms") govern your access to and use of SolPad and related services. SolPad is provided by Techtime-Apps ("we", "us", or "our"). By accessing or using SolPad, you agree to be bound by these Terms. If you do not agree, do not use SolPad. Eligibility You must be at least 18 years old and capable of forming a binding contract to use SolPad. You are responsible for complying with all applicable laws in your jurisdiction. Non-Custodial Architecture and Seed Phrase • SolPad is a non-custodial Solana wallet and launchpad. You control your private keys and recovery phrase ("seed phrase"). • We do not control, store, or have access to your seed phrase or private keys and cannot recover them. If you lose your seed phrase, your wallet and assets cannot be restored by us. • You are solely responsible for safeguarding your seed phrase and device. Anyone with access to your seed phrase can control your assets. Services and Features • Wallet: Create/import a non-custodial wallet, view balances, and send/receive assets on supported Solana networks (e.g., Mainnet, Devnet). • Token Tools: Create and manage SPL tokens on supported networks. Tokens minted on Devnet have no real-world monetary value. • Pricing and Market Data: Market and price information shown in SolPad is for convenience only and may be delayed, inaccurate, or incomplete. • Third-Party Integrations: SolPad may rely on third-party providers (e.g., RPC nodes, indexers, analytics, cloud hosting). Availability and accuracy depend on those providers. Prohibited Conduct You agree not to use SolPad to: • Violate any law or regulation, including sanctions, securities, AML/KYC, and anti-fraud laws. • Infringe others' rights, or engage in deceptive, harmful, or abusive activity (including phishing, malware, or spam). • Create or distribute tokens that are illegal, infringing, misleading, or designed to defraud. • Interfere with or disrupt SolPad, networks, or services. We may, at our discretion, suspend or terminate access for violations. Fees and Taxes • Network Fees: You are responsible for all blockchain network (gas) fees. • Platform/Service Fees: SolPad may charge fees for certain features. We may update fees at any time; changes apply prospectively. • Taxes: You are solely responsible for any taxes related to your use of SolPad and blockchain transactions. Risk Disclosure Using blockchain technology involves significant risks, including but not limited to: • Irreversibility of transactions and potential loss of assets due to errors in addresses or amounts. • Market volatility and potential total loss of value. • Software, hardware, or network failures; congestion; chain reorganizations and forks. • Smart contract vulnerabilities and third-party service outages. • Phishing, social engineering, or compromise of your device. You acknowledge and accept these risks and agree that you use SolPad at your own risk. No Investment, Legal, or Tax Advice SolPad is for utility and informational purposes only. We do not provide investment, legal, or tax advice. Decisions you make using SolPad are your own responsibility. No Warranties SOLPAD IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. WE DO NOT WARRANT THAT SOLPAD WILL BE ERROR-FREE, SECURE, OR UNINTERRUPTED. Limitation of Liability TO THE MAXIMUM EXTENT PERMITTED BY LAW, IN NO EVENT SHALL WE BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, OR ANY LOSS OF PROFITS, DATA, OR GOODWILL, ARISING OUT OF OR RELATED TO YOUR USE OF SOLPAD, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. OUR AGGREGATE LIABILITY FOR ANY CLAIMS RELATING TO SOLPAD SHALL NOT EXCEED THE GREATER OF: (A) THE AMOUNT YOU PAID TO US FOR SOLPAD IN THE 3 MONTHS PRECEDING THE CLAIM; OR (B) EUR 100. Indemnification You agree to indemnify, defend, and hold harmless Techtime-Apps, its affiliates, and their respective officers, directors, employees, and agents from any claims, damages, losses, liabilities, costs, and expenses (including reasonable attorneys' fees) arising from your use of SolPad, your violation of these Terms, or your violation of any rights of another. Compliance; KYC/AML We reserve the right to request information reasonably necessary to comply with applicable laws (e.g., sanctions, AML/KYC). Failure to provide requested information may result in suspension or termination. Suspension and Termination We may suspend or terminate your access to SolPad at any time for any reason or no reason, including for actual or suspected violations of these Terms or legal requirements. Governing Law and Venue These Terms and any dispute or claim arising out of or in connection with them shall be governed by the laws of Germany, without regard to conflict-of-laws principles. The exclusive venue for disputes shall be the courts of Berlin, Germany, unless mandatory consumer protection laws in your country of residence provide otherwise. Electronic Communications and Notices You consent to receive notices and communications electronically within SolPad or via email. Legal notices to us should be sent to: kontakt@techtime-apps.com. Severability; Assignment; Entire Agreement If any provision of these Terms is held invalid, the remainder shall continue in full force. You may not assign these Terms without our prior written consent. These Terms constitute the entire agreement between you and us regarding SolPad and supersede all prior understandings. Changes to the Terms We may update these Terms from time to time. Material changes will be notified within SolPad or by other appropriate means. Your continued use of SolPad after changes become effective constitutes acceptance of the updated Terms. Contact Techtime-Apps Attn: Legal Email: kontakt@techtime-apps.com