PRIVACY POLICY — Trustless DAO LLC — Feemaker.io — Last Updated: May 8, 2026

This Privacy Policy (this “Policy”) describes how Trustless DAO LLC, a non-profit DAO limited liability company organized under the laws of the Republic of the Marshall Islands, with its registered address at 852 Lagoon Road, Majuro, Marshall Islands MH 96960 (“Trustless DAO,” “we,” “us,” or “our”), collects, uses, discloses, and otherwise processes information in connection with your access to and use of the Feemaker.io platform, including any associated websites, interfaces, APIs, smart contract integrations, and related services (collectively, the “Service”). This Policy should be read together with our Terms of Use. Capitalized terms used but not otherwise defined herein have the meanings assigned to them in the Terms of Use.

1. Privacy-by-Design and Non-Custodial Architecture

Trustless DAO is committed to a privacy-by-design approach. The Service is designed as a non-custodial software interface that enables users to interact directly with public blockchain networks and third-party decentralized protocols, without requiring the creation of traditional user accounts, the submission of identity documentation, or the routine collection of personally identifying information as a condition of accessing the core functionality of the Service.

This architecture distinguishes the Service materially from custodial financial institutions, centralized exchanges, or conventional web platforms. Trustless DAO generally does not possess the ability to independently access, recover, freeze, transfer, reverse, or control user assets or blockchain-level activity. The Service is structured to minimize the collection and retention of personal information wherever reasonably practicable, consistent with the operational, security, and legal requirements of maintaining a functioning non-custodial infrastructure.

By using the Service, you acknowledge that public blockchain networks are inherently transparent systems, that transaction-related information recorded on-chain may be accessible to third parties indefinitely, and that Trustless DAO does not control and cannot alter the content of any public distributed ledger.

2. Information We May Process

2.1 Information Voluntarily Provided by You

You may voluntarily provide information to us when contacting us for support, submitting technical inquiries, reporting issues, or otherwise communicating with us in connection with the Service. Such information may include your name, email address, wallet address, and the contents of your communications. Trustless DAO does not require users to create accounts or provide identity documentation in order to access the primary functionality of the Service.

2.2 Blockchain and Wallet Information

When you use the Service, you may interact with public blockchain networks through self-custodied wallet software or other third-party technologies that you independently operate and control. Blockchain networks maintain permanent, immutable public records of transactions, wallet addresses, token balances, smart contract interactions, and related on-chain activity. Trustless DAO does not create, own, or control blockchain networks or the data recorded on them.

In connection with providing the Service, we may access, display, process, transmit, or associate publicly available blockchain information relating to wallet addresses and transactions initiated through or in connection with the Service. Wallet addresses and transaction-related information may, in certain circumstances and under certain legal frameworks, constitute personal data or personal information, and we treat them as such for purposes of this Policy.

Blockchain activity is inherently public and transparent. You acknowledge that transactions conducted through public blockchain networks are visible to any participant in or observer of the applicable network, may be permanently recorded on public ledgers outside the control of any single party, and may potentially be associated with your identity by third parties—including through the use of blockchain analytics tools, data aggregators, or other means—regardless of the privacy practices of Trustless DAO. You should not expect transactions, wallet addresses, or other on-chain activity to remain private or anonymous.

2.3 Automatically Collected Technical Information

When you access or interact with the Service, limited technical information may be automatically collected by our systems or third-party infrastructure providers. Such information may include internet protocol (IP) address, browser type and version, device characteristics, operating system information, referring URLs, access times, and general usage metrics. IP addresses may constitute personal data under applicable law and are treated as such.

This information is used solely for legitimate operational purposes, including maintaining the security and integrity of the Service, diagnosing and resolving technical issues, preventing abuse, fraud, sanctions evasion, and unlawful activity, ensuring system reliability and performance, and protecting the rights, assets, and security of Trustless DAO, its users, and the broader ecosystem. Trustless DAO does not use automatically collected technical information to build individualized consumer marketing profiles or to engage in targeted behavioral advertising.

2.4 Analytics and Infrastructure Providers

Trustless DAO may utilize third-party analytics providers, infrastructure providers, RPC providers, hosting providers, content delivery networks, and similar service providers to support the operation, maintenance, monitoring, and improvement of the Service. Where reasonably practicable, such tools and providers are configured to minimize unnecessary collection or retention of personally identifying information. Users should be aware that such providers may independently collect certain technical information in accordance with their own privacy practices.

3. How We Use Information

Trustless DAO may use the limited information it processes for the following purposes: operating, maintaining, securing, and improving the Service and its technical infrastructure; facilitating interactions with supported blockchain networks and third-party decentralized protocols; monitoring, detecting, investigating, preventing, and responding to fraud, abuse, security incidents, potential sanctions concerns, unlawful activity, and violations of our Terms of Use; complying with applicable legal obligations or responding to lawful governmental requests, to the minimum extent required; communicating with users who contact us regarding support or operational matters; and protecting the rights, property, safety, and security of Trustless DAO, users, third parties, and the public.

Trustless DAO does not sell, rent, or share personal information for cross-context behavioral advertising, and does not use personal information for targeted advertising or commercial profiling purposes.

4. Legal Bases for Processing

To the extent applicable data protection law requires identification of a legal basis for the processing of personal data, Trustless DAO processes personal data on the following bases, as applicable to the relevant processing activity: performance of a contract or pre-contractual steps, where processing wallet addresses and transaction data is necessary to provide the Service; legitimate interests in operating, securing, and improving the Service, preventing fraud and abuse, and maintaining the integrity of the platform, where those interests are not overridden by the rights and freedoms of affected individuals given the limited and predominantly pseudonymous nature of the data involved; compliance with legal obligations, where processing is required by applicable law, regulation, or lawful governmental authority; and user consent, where voluntarily provided for specific processing activities. The foregoing legal bases apply solely to the extent required under applicable law.

5. Sharing and Disclosure of Information

Trustless DAO does not sell or rent your personal information to third parties. We may disclose limited information to vendors, contractors, analytics providers, infrastructure providers, RPC providers, and other service providers that support the operation or security of the Service. In each case, these disclosures are made under strict contractual obligations that limit the use of such information solely to the provision of services on our behalf. We may also disclose information where required by applicable law, regulation, subpoena, court order, or lawful governmental request; where reasonably necessary to investigate or address fraud, abuse, potential sanctions concerns, security incidents, or unlawful conduct; to protect the rights, property, safety, or security of Trustless DAO, the Service, our users, or others; or in connection with a merger, restructuring, reorganization, financing transaction, dissolution, or similar corporate event, subject to appropriate confidentiality obligations.

Because blockchain networks are decentralized public ledgers, information relating to on-chain transactions may remain publicly accessible indefinitely and cannot be recalled, deleted, or restricted by Trustless DAO or any other party.

6. Third-Party Services and Decentralized Protocols

The Service may interact with or provide access to a range of third-party services and technologies, including wallet providers, decentralized protocols, blockchain networks, validators, relayers, APIs, RPC providers, block explorers, analytics providers, liquidity sources, and smart contracts deployed by third parties. Trustless DAO does not own or control such third-party services and is not responsible for their availability, functionality, security, or privacy practices. When you connect a wallet to the Service or initiate a transaction that routes through a third-party protocol, that third party may independently collect data about your wallet address or activity in accordance with its own terms and privacy practices. Your interactions with third-party services are governed by those parties’ own terms and policies, not this Policy.

Additionally, because the Service interacts with public blockchain networks maintained by decentralized networks of independent participants—including validators, miners, node operators, and other infrastructure providers—information transmitted to or recorded on those networks is outside the custody and control of Trustless DAO and is subject to the inherent transparency and immutability of public distributed ledger technology.

7. Data Retention

Trustless DAO retains personal information only for as long as reasonably necessary to fulfill the operational, security, legal, compliance, and dispute-resolution purposes for which it was collected, or as required or permitted by applicable law. In general terms: contact and inquiry data is retained for the duration of the relevant communication and for a reasonable period thereafter, typically no longer than three years, for record-keeping and legal purposes; technical logs and IP address data are retained for up to 90 days for security and operational purposes, unless a longer period is required by applicable law or an ongoing legal matter; and API access logs are retained for up to twelve months for billing, audit, and compliance purposes. When information is no longer required for any of the foregoing purposes, it is deleted or irreversibly anonymized.

Because blockchain transaction data is recorded on immutable public distributed ledgers outside the custody or control of Trustless DAO, we are unable to delete, modify, anonymize, or restrict access to information recorded on-chain, and requests for erasure cannot be fulfilled with respect to such data.

8. Data Security

Trustless DAO implements reasonable technical and organizational safeguards designed to protect information under our control against unauthorized access, misuse, alteration, or disclosure. These measures include encryption of data in transit, access controls on internal systems and infrastructure, and ongoing security monitoring. The non-custodial architecture of the Service means that we do not hold or have access to users’ private keys, seed phrases, or digital assets, which materially limits the risk profile of any security incident involving systems operated by Trustless DAO.

No system, network, or technology can be guaranteed to be completely secure, and no data transmission over the internet is immune from interception or unauthorized access. You acknowledge and agree that your use of the Service and any transmission of information to or through the Service occurs at your own risk. If you become aware of a security vulnerability or incident relating to the Service, we encourage you to notify us promptly at sales@feemaker.io. In the event of a personal data breach likely to result in risk to affected individuals, we will take steps to notify relevant authorities and, where required, affected users, in accordance with applicable law.

9. International Processing of Information

Trustless DAO is organized under the laws of the Republic of the Marshall Islands. Information we process in connection with the Service may be transferred to, stored in, or processed in jurisdictions other than your jurisdiction of residence, including jurisdictions where data protection standards differ from those of your home jurisdiction. To the extent applicable law imposes requirements on such transfers—including the requirement to implement standard contractual clauses, binding corporate rules, or other recognized transfer mechanisms—Trustless DAO takes reasonable measures designed to process information in a manner consistent with those requirements. Users in the European Economic Area or United Kingdom should refer to Section 10 below for additional information.

10. Your Rights Relating to Personal Data

To the extent provided under applicable law (such as the GDPR, UK GDPR, or CCPA/CPRA), you may have certain rights relating to personal data we hold about you. These include the right to request access to, correction of, deletion of, restriction of processing of, or portability of your personal data. Where processing is based on legitimate interests, you have the right to object. Where processing is based on consent, you have the right to withdraw that consent at any time. Requests to exercise these rights should be submitted to sales@feemaker.io with the subject line “Data Rights Request.” We will respond within the timeframe required by applicable law (generally 30 days) and may need to verify your identity before processing your request. There is no charge for responding to requests unless they are manifestly unfounded or excessive. Because the Service operates on a substantially pseudonymous basis and Trustless DAO does not maintain traditional user accounts, we may not possess sufficient information to associate on-chain data with a specific individual. Certain requests, particularly those relating to blockchain-based information, may be technically impossible to fulfill. This limitation applies specifically to data recorded on a public blockchain; where we hold off-chain data (such as email correspondence or server logs), we will make reasonable efforts to fulfill valid requests. If you believe our response to a request is inadequate, you have the right to lodge a complaint with a supervisory authority. EEA Residents: You may contact the data protection authority of your Member State. UK Residents: You may contact the Information Commissioner’s Office (ico.org.uk). Other Jurisdictions: You may have similar rights to contact your local regulator. We encourage you to contact us directly in the first instance so that we may attempt to resolve your concerns.

11. Additional Information for EEA and UK Residents

Trustless DAO is not established in the European Economic Area (EEA) or the United Kingdom (UK). We do not maintain physical offices, employees, or proprietary server infrastructure within those jurisdictions, nor do we intentionally target the Service toward residents of those regions. Whether the EU General Data Protection Regulation (GDPR), the UK GDPR, or related frameworks apply to Trustless DAO is a fact-specific inquiry; accordingly, nothing in this Policy constitutes an admission that such laws apply to our operations or any specific processing activity.

To the extent any applicable data protection law affords residents of the EEA or UK rights with respect to personal data—including rights to access, rectify, restrict, or object to certain processing activities—those rights may be exercised by contacting us as described in Section 10. We will evaluate and respond to any such request in good faith and in accordance with our legal obligations as we understand them. Requests may be submitted to sales@feemaker.io with the subject line “Data Rights Request.”

Where personal data originating in the EEA or UK is transferred internationally in circumstances where applicable law requires a transfer mechanism, Trustless DAO will we endeavor to work with providers to implement appropriate safeguards consistent with those requirements. Residents of the EEA who believe their rights under applicable law have not been respected may contact the data protection supervisory authority of their Member State. UK residents may contact the Information Commissioner’s Office (ico.org.uk). We encourage users to contact us directly in the first instance so that we have the opportunity to address any concern.

12. Additional Information for California Residents

This Section supplements the rest of this Policy for consumers who are residents of the State of California, pursuant to the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020 (collectively, “CCPA/CPRA”). In the event of any conflict, this Section prevails for California residents.

Categories of personal information collected. In the preceding twelve months, we have collected the following categories of personal information as defined under Cal. Civ. Code § 1798.140: identifiers, including wallet addresses, IP addresses, and email addresses if voluntarily provided; internet or electronic network activity information, including browsing activity on the Service and API usage data; approximate geolocation data derived from IP addresses; and commercial information, consisting of transaction data associated with use of the Service. We do not collect sensitive personal information as defined under CCPA/CPRA.

No sale or sharing. Trustless DAO does not sell personal information for monetary or other valuable consideration and does not share personal information for cross-context behavioral advertising, in each case within the meaning of Cal. Civ. Code § 1798.140.

Consumer rights. California residents have the right to know what personal information we have collected about them and how it has been used and disclosed; the right to request deletion of personal information, subject to certain exceptions (including, without limitation, our inability to delete information recorded on public blockchain networks); the right to correct inaccurate personal information; and the right not to receive discriminatory treatment for exercising any CCPA/CPRA right. To submit a verifiable consumer request, please contact us at sales@feemaker.io with the subject line “CCPA Privacy Request.” We will respond within 45 days of receipt, or notify you in writing if additional time is required, up to a maximum of 90 days total. Authorized agents submitting requests on behalf of a California consumer must provide appropriate proof of authorization.

Financial incentives. Trustless DAO does not offer financial incentives or price differentials in exchange for the collection, retention, or sale of personal information.

13. No Confidential or Fiduciary Relationship

Your use of the Service and any communications with Trustless DAO do not create any fiduciary, confidential, advisory, agency, or special relationship between you and Trustless DAO. Nothing in this Policy or in the Service creates any obligation on the part of Trustless DAO to act in your interest or treat your interactions with the Service as confidential in nature, except for the specific data protection obligations expressly stated in this Policy or as required by applicable law.

14. Children’s Privacy

The Service is not directed to individuals under the age of eighteen (18) years, and Trustless DAO does not knowingly collect personal information from children. In the United States, Trustless DAO does not knowingly collect personal information from children under the age of thirteen (13) without appropriate parental or guardian consent, consistent with the Children’s Online Privacy Protection Act. If you believe that we may have inadvertently collected personal information from a minor, please contact us at sales@feemaker.io and we will take prompt steps to investigate and, where appropriate, delete such information.

15. Changes to This Policy

Trustless DAO reserves the right to modify or update this Policy at any time. When we make material changes, we will update the “Last Updated” date at the top of this Policy and, where reasonably practicable, provide notice through the Service or other appropriate channels. Your continued use of the Service following any such update constitutes your acknowledgment of, and agreement to be bound by, the revised Policy. We encourage you to review this Policy periodically.

16. Contact Information

Questions, requests, or other communications regarding this Policy or the data practices described herein may be directed to:

Trustless DAO LLC

Attention: Data Privacy

852 Lagoon Road

Majuro, Marshall Islands MH 96960

Email: sales@feemaker.io (subject line: “Privacy Policy” or “Data Rights Request,” as applicable)

Website: https://www.feemaker.io