Last Updated: February, 2025

This Privacy Policy (“Privacy Policy” or “Policy”) describes how Blade Labs Holdings Pte Ltd. (together with Blade Labs Inc., Blade Foundation Ltd., ZeroH, and our affiliates or subsidiaries, collectively “Blade,” “we,” “us,” or “our”) collects, uses, shares, and stores Personal Data of visitors to our websites at • https://www.bladelabs.io • https://www.bladefoundation.io • https://www.bladegroup.io • https://www.bladewallet.io • https://www.zeroh.io and any other associated sites or mobile applications owned or operated by Blade (collectively, the “Sites”), users of the Wallet and/or Console (formerly “Launchpad”) tools, as well as participants in marketing campaigns, promotions, events, and sales (collectively, the “Services”).

By visiting any of the Sites or engaging with any of our Services, you agree that your Personal Data (defined below) will be handled as described in this Policy. Your use of our Sites or Services, and any dispute over privacy, is subject to this Policy and any associated Terms of Use or services agreements.

If you do not agree with any part of this Privacy Policy, then please do not use the Sites or any of the Services.

1.1 Overview • The Wallet is a non-custodial, self-sovereign Web3 portal that equips individuals to manage digital assets on various distributed ledger networks. Users retain exclusive control over cryptographic keys and digital assets. • The Console (formerly “Launchpad”) is a suite of tools for digital asset management and distribution, supporting NFT creation and distribution, fungible token airdrops, loyalty card programs, and multi-signature wallets. • ZeroH is our embedded, Shariah-compliant finance solution operating under the broader Blade organization. ZeroH leverages distributed ledger and cryptographic techniques to power zero-interest financial services.

1.2 Definitions

Term Definition Data Processing Performing any operation on data, including obtaining, recording, collecting, storing, altering, retrieving, disclosing, transmitting, disseminating, combining, blocking, erasing, or destroying data. Personal Data Any information about an identifiable individual, such as name, date of birth, government ID, contact info, financial information, IP address, wallet ID, or transaction information, as well as metadata associated with blockchain transactions. User An individual who accesses, downloads, or uses the Site, Wallet, Console, or Services.

It is Blade’s policy to comply with all privacy- and data-protection-related regulatory requirements applicable to Blade in connection with the Sites and the Services. This Policy helps Users understand: 1. Information We May Collect About You 2. Justifications for Engaging in Data Processing 3. Who We May Share Your Information With 4. How We Secure Information We Collect 5. How to Access and Control Your Information 6. Your Marketing Preferences 7. International Data Transfers 8. Your Rights if You Are a California Resident 9. Your Rights Under the EU General Data Protection Regulation (“GDPR”) 10. Changes to this Policy 11. How to Contact Us

3.1 Information Collected Directly From You

You can browse certain areas of the Sites without registering or providing personal information. However, we collect certain Personal Data when you: • Sign up for the Wallet, Console, or any other Blade Services. • Provide an email address for newsletters, product updates, or promotional campaigns. • Participate in events, surveys, or promotions. • Submit feedback, inquiries, or customer support requests. • Provide any additional information while interacting with our Sites (e.g., IP address, social media handles, transaction metadata, marketing preferences).

If you submit third-party personal data to us (for example, if you provide an associate’s or customer’s data for a ZeroH finance arrangement), you must have the necessary permissions from that individual and ensure such disclosure is lawful under applicable regulations.

3.2 Information Collected Automatically

We may automatically collect certain technical information when you use the Sites or Services, including: • IP address, domain name, device identifiers, and browser type • The web pages or screens you view, links you click, and referral URLs • Wallet IDs, system fingerprints, DApp referral data (if any) • Cookies and similar tracking technologies (see our separate Cookie Policy for details)

We only process Personal Data when there is a valid legal basis, such as: • Your Consent (e.g., subscribing to marketing emails) • Performance of a Contract (e.g., employment or services agreements) • Compliance with a Legal Obligation • Legitimate Interests (e.g., for fraud prevention, security, or improving our Services), balanced against your rights

We use your Personal Data for reasons including but not limited to: 1. Communications: To respond to inquiries and provide customer service. 2. Personalization: To tailor content, location settings, and site features. 3. Performance & Analytics: To evaluate and improve Services, develop new features, and conduct research. 4. Marketing & Promotions: To send newsletters, special offers, and promotional content (subject to your opt-out preferences). 5. Incident Management: To address bugs, user-reported issues, and provide updates or fixes. 6. Service-Related Updates: To ensure you remain informed about changes in our Sites or Services, including critical notices. 7. Fraud Prevention & Compliance: To detect, investigate, and prevent potential fraud, or to comply with legal obligations. 8. Human Resources & Employment: For job applications, verifications, performance tracking, and team page listings. 9. ZeroH Transactions: If you interact with ZeroH, to manage Shariah-compliant financing arrangements, transaction transparency, and compliance oversight.

We implement commercially reasonable measures to protect your data against loss, misuse, or unauthorized access. Examples include: • Encryption (where feasible) and secure data storage protocols • Access controls and periodic reviews of security measures • User-level security best practices (e.g., enabling 2FA, safeguarding cryptographic keys)

Despite these measures, you are responsible for maintaining the security of your devices, passwords, and cryptographic keys.

You may request to access, obtain a copy of, correct, or delete your Personal Data by contacting us at:

We will fulfill such requests as required by law, though we may retain certain information for legal or business reasons.

You can opt out of marketing or promotional emails at any time by: • Clicking “unsubscribe” in the email footer • Emailing us directly at policies@bladelabs.io

Please note that you cannot opt out of certain transactional or relationship messages (e.g., account notices, security alerts).

If you enable push notifications via mobile apps, you can disable them in your device settings.

Blade operates internationally; data may be transferred within our organization or to third-party service providers in different jurisdictions. We take measures to ensure any cross-border data transfers meet applicable privacy and data protection requirements.

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA), including the right to: 1. Know what personal information we collect, use, or share 2. Request deletion of your personal information 3. Opt out of the “sale” of personal information 4. Not be discriminated against for exercising your rights

To exercise these rights, contact us at:

If you are a resident of the EU or EEA, you have certain data protection rights. These include: • Right to Access: Request copies of your Personal Data. • Right to Rectification: Correct inaccurate or incomplete information. • Right to Object: Object to certain forms of processing. • Right to Restriction: Request restricted processing of your data. • Right to Data Portability: Obtain your data in a structured, machine-readable format. • Right to Withdraw Consent: Revoke consent at any time if we rely on consent.

To exercise these rights, contact us at:

You have the right to lodge a complaint with a local data protection authority if you believe your rights have been violated.

We may update this Privacy Policy from time to time. When we do, we will post the revised version and update the “Last Updated” date at the top. Your continued use of the Sites or Services after any modifications indicates your acceptance of the revised terms.

If you have any questions or concerns regarding this Privacy Policy or wish to make a complaint, please contact us at:

Summary & Next Steps • The attached updated Privacy Policy (dated January 8, 2025) can serve as Blade’s foundational policy. • If ZeroH is fully integrated into Blade’s data flows without extra unique data processing, you can fold ZeroH into this same policy by referencing it alongside the other Blade affiliates. • If ZeroH has distinct Islamic finance compliance obligations or collects user data differently (e.g., extra KYC, financial forms, transaction logs), consider adding an extra “ZeroH” or “Financial Services” section to outline the unique data-handling processes.