Submetrik is a product of Senthora Labs AD, a company registered in Bulgaria with company number 208932097, registered address 168 Tsar Boris III Blvd, Andromeda Business Center, 2nd Floor, Office 23A, Ovcha Kupel District, Sofia, Bulgaria ("Senthora Labs", "we", "us", "our").

We are the data controller for the personal data described in this policy.

For any privacy question or to exercise your rights, contact us at privacy@submetrik.com.

This policy explains how we handle personal data when you:

• visit submetrik.com and our other web pages;
• join our early access list;
• contact us by email or through our support channels;
• use the Submetrik mobile application, once it is released (Section 7).

What we collect: your email address, the date and time you signed up, your IP address at the moment of signup, the referral or campaign source that brought you to us (for example a UTM parameter or a referral link), and — if you take part in our referral programme — the number of people who joined using your link and your position in the queue.

Double opt-in: after you submit your email, we send you a confirmation link. We only add you to the list once you click it. If you do not confirm within 48 hours, we delete the unconfirmed record.

How long we keep it: until you unsubscribe or ask us to delete your data, or until 24 months after the launch of the application, whichever comes first. Unconfirmed signups are deleted after 48 hours.

Withdrawing consent: every email we send contains an unsubscribe link. You can also email us at privacy@submetrik.com. Withdrawing consent does not affect the lawfulness of what we did before you withdrew it.

We use Plausible Analytics to understand how visitors use our website, which pages they read and which campaigns bring them to us.

Plausible does not use cookies, does not track individuals across websites and does not collect or store personal data or personally identifiable information. It produces aggregated statistics only, and the data is processed and stored within the European Union.

Legal basis: our legitimate interest (Article 6(1)(f) GDPR) in understanding how our website performs.

We use only strictly necessary cookies — small files required for the website to work, for example to remember that you have already joined the early access list, to carry your referral code from the link you clicked to the signup form, and to protect our forms against automated abuse. These cookies do not require your consent under Article 5(3) of the ePrivacy Directive.

We do not use advertising, profiling or third-party tracking cookies, and we do not use cookie-based analytics. For this reason we do not display a cookie consent banner.

We do not sell your personal data, and we do not share it for advertising purposes. We share it only with service providers who process it on our behalf, under a written data processing agreement:

We may also disclose personal data where we are required to do so by law, or where necessary to establish, exercise or defend legal claims.

International transfers. Most of our providers process data inside the European Economic Area. Where a provider processes personal data outside the EEA — currently our waitlist provider, which is based in the United States — we rely on the European Commission's Standard Contractual Clauses together with additional technical and organisational safeguards. You may request a copy of the safeguards in place by emailing privacy@submetrik.com.

This section describes how the Submetrik mobile application will handle data. It applies from the date the application is released and will be updated before release with the final details.

Submetrik is a non-custodial wallet. Your private keys and recovery phrase are generated and stored on your own device. We never receive, store or have access to them. We cannot access, move, freeze or recover your funds, and we cannot restore your wallet if you lose your recovery phrase.

We do not receive or store the identity documents you provide to these third parties, unless expressly stated at the time.

Children. Submetrik is not intended for anyone under 18 and we do not knowingly process the data of children.

Under the GDPR you have the right to:

• access the personal data we hold about you;
• rectify inaccurate data;
• erase your data ("right to be forgotten");
• restrict or object to our processing, including direct marketing;
• data portability — receive your data in a machine-readable format;
• withdraw consent at any time, where processing is based on consent;
• lodge a complaint with a supervisory authority. In Bulgaria this is the Commission for Personal Data Protection (Комисия за защита на личните данни), 2 Prof. Tsvetan Lazarov Blvd, Sofia 1592, www.cpdp.bg. You may also complain to the authority in your own country of residence.

To exercise any of these rights, email privacy@submetrik.com. We will respond within one month.

Note that we cannot delete data recorded on a public blockchain, because we do not control those networks.

We apply appropriate technical and organisational measures to protect personal data, including encryption in transit, access controls and regular review of our providers. No system is completely secure, but we take these obligations seriously and will notify you and the supervisory authority of a personal data breach where the law requires it.

We may update this policy as the product develops — in particular before the application is released. We will post the updated version on this page and change the "last updated" date. If the changes are significant, we will notify you by email.

Senthora Labs AD, company number 208932097

Represented by Zhivko Yuriev Atanasov, Legal Representative and Member of the Board of Directors

168 Tsar Boris III Blvd, Andromeda Business Center, 2nd Floor, Office 23A, Ovcha Kupel District, Sofia, Bulgaria

privacy@submetrik.com