Roburna Builders — Privacy Policy

The information we collect depends on how you interact with Roburna Builders.

We may collect the following categories of information:

• information you provide when applying to the Program;
• founder and team information;
• project and business information;
• social media and professional profile information;
• communications and correspondence;
• information relating to your participation in the Program;
• information relating to events, activities, or opportunities associated with the Program;
• information about how you use the Roburna Builders website and Services; and
• technical information collected automatically when you access the website.

We seek to collect information that is relevant and reasonably necessary for the purposes described in this Privacy Policy.

When you apply to or participate in Roburna Builders, you may provide information about yourself and members of your team.

This may include:

• full name;
• professional role or title;
• email address;
• contact information;
• professional background;
• technical or entrepreneurial experience;
• location or country;
• information about your role in a project;
• professional profiles;
• portfolio or previous work; and
• other information you choose to provide as part of your application or participation.

If you provide information about another individual, such as a co-founder or team member, you should ensure that you are authorized to provide that information and that the individual has been appropriately informed where required by applicable law.

Roburna Builders may use founder and team information to evaluate applications, communicate with applicants and Builders, administer the Program, facilitate relevant introductions, and carry out other purposes described in this Privacy Policy.

Applications may require information about the project you are building or proposing to build.

This may include:

• project name;
• project description;
• website;
• product information;
• technical information;
• development stage;
• business model;
• ecosystem or blockchain integrations;
• project goals;
• information about the project team;
• pitch decks or other submitted materials;
• repositories or development resources;
• project metrics or traction information; and
• other information you choose to submit.

Project information may be used to evaluate applications, understand the needs of Builders, provide appropriate Program support, facilitate relevant opportunities, and administer the Program.

You should not submit confidential, proprietary, or highly sensitive information unless it is reasonably necessary for your application or participation and you understand how the information may be used.

Roburna Builders does not assume that information submitted through an application is confidential merely because it is submitted through the Program.

Where you require specific confidentiality protections, those protections should be established through an appropriate separate agreement before confidential information is disclosed.

As part of an application or Builder profile, you may provide links to websites and online profiles, including:

• X or other social media profiles;
• LinkedIn;
• GitHub;
• project websites;
• professional portfolios;
• community profiles; and
• other publicly accessible online resources.

We may use these links to evaluate applications, understand your professional or project background, communicate with you, administer the Program, or showcase accepted Builders and projects where appropriate.

Information available publicly on third-party platforms may also be accessible to us independently of your application.

Roburna Builders does not control the privacy practices of those platforms. You should review the privacy policies of the relevant third-party services to understand how they process your information.

We may collect and retain information contained in communications between you and Roburna Builders.

This may include communications through:

• email;
• application forms;
• support channels;
• community platforms;
• direct messages;
• events or Program activities; and
• other communication channels used for Program-related purposes.

We may use this information to:

• respond to requests;
• communicate about applications;
• administer participation;
• provide Program support;
• maintain appropriate records;
• improve the Program;
• address complaints or concerns; and
• protect the security and integrity of the Program.

Where permitted by applicable law, we may also send Program updates, announcements, newsletters, or other communications that may be relevant to Builders and the wider Roburna ecosystem.

Where applicable law requires consent for certain marketing communications, we will obtain that consent.

You may unsubscribe from marketing communications at any time using the unsubscribe mechanism provided in the communication or by contacting us.

Roburna Builders may publicly showcase accepted Builders and projects as part of operating and promoting the Program.

Depending on the circumstances, this may include:

• Builder or founder names;
• project names;
• project descriptions;
• project logos;
• project websites;
• publicly available social profiles;
• publicly available project information;
• Builder photographs or biographies where appropriately provided;
• project milestones or achievements; and
• other information that has been made public by the Builder or that you have authorized us to use.

We may use this information on:

• the Roburna Builders website;
• Roburna or Roburna Builders social media accounts;
• newsletters;
• announcements;
• ecosystem updates;
• presentations;
• events;
• case studies; and
• other Program-related communications.

We will not intentionally publish information that you have clearly identified to us as confidential unless we have a lawful basis to do so or are otherwise permitted or required by applicable law.

Acceptance into the Program does not necessarily mean that every piece of information submitted in an application will be made public.

Where a particular use requires your consent or another form of authorization under applicable law, we will obtain the appropriate authorization before making that use.

Roburna Builders distinguishes, where reasonably possible, between information intended for public presentation and information submitted privately for Program administration.

Public information

Information that you intentionally publish publicly, such as a project website, public GitHub repository, public social-media profile, or publicly announced project information, may already be accessible to others.

Roburna Builders may reference or link to publicly available information when evaluating, administering, or showcasing a Builder or project, subject to applicable law.

Private information

Information submitted privately through an application, communication, or other Program process is generally used for the purposes described in this Privacy Policy and is not automatically published.

However, private information may be disclosed where necessary to operate the Program, provide services, comply with legal obligations, protect the rights and safety of Roburna or others, or where you have otherwise authorized the disclosure.

You should carefully consider what information you submit through the Program.

We may use personal information for the following purposes:

Program administration

To:

• receive and evaluate applications;
• determine eligibility;
• communicate application decisions;
• administer Builder participation;
• maintain Program records;
• provide relevant resources and support; and
• manage Program activities.

Builder and project support

To understand the needs, objectives, and development stage of Builders and projects so that we can provide relevant resources, introductions, guidance, or opportunities.

Communications

To communicate with applicants, Builders, founders, team members, partners, and other Program participants.

Program development

To understand how the Program is being used and identify ways to improve its resources, processes, services, and overall experience.

Community and ecosystem development

To facilitate appropriate connections between Builders and relevant members of the broader Roburna ecosystem, which may include partners, service providers, mentors, investors, developers, community members, or other organizations.

Where an introduction involves sharing personal information with another party, we will do so in accordance with applicable law.

Publicity and showcasing

To feature accepted Builders and projects as described in this Privacy Policy and any additional authorization or agreement that applies.

Security and fraud prevention

To:

• protect the security of the website and Program;
• detect and prevent abuse, fraud, or unauthorized activity;
• investigate security incidents;
• enforce applicable terms and policies; and
• protect Roburna, Builders, users, and other persons.

Legal and regulatory purposes

To comply with applicable legal obligations, respond to lawful requests, establish or defend legal claims, and protect our rights and interests.

Where privacy laws such as the GDPR apply to our processing of personal information, Roburna Builders will rely on an appropriate legal basis for each processing activity.

Depending on the circumstances, these may include:

• your consent;
• taking steps at your request before entering into an agreement or performing an agreement with you;
• compliance with a legal obligation;
• our legitimate interests, where those interests are not overridden by your rights and freedoms; or
• another lawful basis permitted by applicable law.

Where we rely on consent, you may withdraw your consent where permitted by applicable law.

Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

Roburna Builders may use third-party providers to operate and support the Program.

These may include providers of:

• website hosting;
• cloud infrastructure;
• application and form management;
• email and communications;
• analytics;
• security;
• file storage;
• authentication;
• customer or community support; and
• other operational services.

These providers may process personal information on our behalf where necessary to provide their services.

The specific third parties used by Roburna Builders may change over time as the Program develops.

Third-party websites, social networks, wallets, repositories, communication platforms, and other services that you access through links or integrations are generally governed by their own privacy policies.

Roburna Builders does not control the privacy practices of independent third parties.

You should review the relevant third party's privacy policy before providing information or using its services.

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

• evaluate and administer applications;
• manage Builder participation;
• provide Program services;
• maintain appropriate records;
• communicate with applicants and Builders;
• comply with legal obligations;
• resolve disputes;
• enforce agreements; and
• protect the security and integrity of the Program.

The length of time information is retained may depend on:

• the nature of the information;
• the purpose for which it was collected;
• whether you are an applicant, current Builder, or former Builder;
• legal or regulatory requirements;
• legitimate business needs; and
• whether the information is relevant to an ongoing dispute or legal matter.

When personal information is no longer required, we will take reasonable steps to delete it or otherwise dispose of it in accordance with applicable law.

Information that has been intentionally made public, including information appearing on public websites or third-party platforms, may continue to be accessible after your participation in the Program ends.

Roburna Builders takes reasonable technical and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, loss, destruction, or other unauthorized processing.

Depending on the nature of the information and the Services involved, these measures may include:

• access controls;
• authentication;
• encryption where appropriate;
• secure hosting and infrastructure;
• monitoring and logging;
• restricted access to personal information;
• organizational safeguards; and
• procedures for responding to security incidents.

No method of electronic transmission or storage can be guaranteed to be completely secure.

You are also responsible for taking reasonable precautions when sharing information with Roburna Builders and when using third-party services connected to the Program.

Depending on your location and the privacy laws applicable to you, you may have certain rights regarding your personal information.

These may include:

• the right to access personal information we hold about you;
• the right to request correction of inaccurate information;
• the right to request deletion of personal information, subject to applicable exceptions;
• the right to request restriction of certain processing;
• the right to object to certain processing;
• the right to withdraw consent where processing is based on consent;
• the right to receive certain information in a portable format;
• the right to opt out of certain forms of sale or sharing of personal information where applicable; and
• the right to lodge a complaint with a relevant data-protection or privacy authority.

The availability and scope of these rights depend on applicable law.

Certain rights may be subject to legal limitations or exceptions.

For example, information that has already been lawfully made public may not always be capable of complete removal from the internet or from third-party platforms.

To exercise an applicable privacy right, contact us using the information provided below.

We may need to verify your identity before responding to certain requests in order to protect personal information from unauthorized disclosure.

Roburna Builders may use service providers, infrastructure, technologies, or other resources located in countries other than the country where you reside.

As a result, personal information may be transferred to or processed in other jurisdictions.

Where applicable law imposes requirements on international transfers of personal information, Roburna Builders will use appropriate safeguards or other lawful transfer mechanisms.

For individuals protected by the GDPR, this may include an adequacy decision, appropriate contractual safeguards, or another legally recognized transfer mechanism.

The distributed nature of blockchain technology can create additional international-data considerations where blockchain-related information is processed across multiple jurisdictions. Current EDPB guidance specifically identifies international transfers and the involvement of multiple blockchain participants as factors that should be considered when assessing blockchain-related processing.

The Roburna Builders Program may interact with or reference blockchain-based projects, wallets, applications, and services.

Where you voluntarily provide a wallet address as part of your application, Builder profile, project information, or Program participation, we may associate that wallet address with information you have provided to us.

Wallet addresses and public blockchain identifiers may be publicly visible on the applicable blockchain.

Depending on the circumstances, a wallet address may constitute personal information where it can reasonably be linked to an identifiable individual.

Roburna Builders does not generally require or collect private keys, seed phrases, or recovery phrases for participation in the Program.

You should never provide a private key, seed phrase, or recovery phrase to Roburna Builders or anyone claiming to represent us.

You should also consider carefully whether to associate a personal identity with a public blockchain address, as information recorded on public blockchains may remain accessible and may not be capable of being deleted or modified.

Roburna Builders seeks to avoid intentionally placing unnecessary personal information on public blockchain networks.

The Roburna Builders Program is intended for individuals who are legally able to participate in the Program under applicable law.

We do not knowingly collect personal information from children in circumstances where such collection is prohibited by applicable law.

If you believe that a child has provided personal information to us inappropriately, please contact us so that we can review the matter and take appropriate action.

We may update this Privacy Policy from time to time to reflect changes to the Program, our information practices, technology, or applicable legal requirements.

When we make changes, we will update the "Last Updated" date at the beginning of this Privacy Policy.

Where required by applicable law, we may provide additional notice or obtain consent before implementing material changes.

We encourage you to review this Privacy Policy periodically.

This Privacy Policy is effective as of [Effective Date].

By continuing to use the Roburna Builders Services after an updated Privacy Policy becomes effective, you acknowledge the updated policy to the extent permitted by applicable law.