Privacy Policy

1. Overview

This Privacy Policy describes how Monark Technologies, LLC (“Company,” “we,” “us,” or “O2”), a Pennsylvania limited liability company, collects, uses, and protects information in connection with the O2 protocol and related services.

O2 does not collect personally identifiable information (PII) or business-sensitive information beyond what is required for regulatory compliance, platform security, and the provision of services. We do not collect data for advertising, marketing profiling, or resale.

2. Information We Collect

KYC and AML Documentation. To comply with applicable anti-money laundering (AML) and know-your-customer (KYC) regulations, we may require participants to provide documentation and information including but not limited to:

• Entity formation documents, certificates of good standing, and organizational charts
• Identification of beneficial owners, authorized signatories, and controlling persons
• Government-issued identification of authorized representatives
• Source of funds documentation and accredited investor or qualified purchaser certifications
• Information necessary for OFAC and sanctions screening

Transaction Data. We collect onchain transaction data related to your use of the O2 protocol, including wallet addresses, transaction hashes, collateral deposits, credit positions, and hedge allocations. This data is necessary for protocol operations, position management, and audit purposes. Onchain transaction data is inherently public on the blockchain.

Communications. We collect the content of communications you send to us, including emails to access@o2.credit and conversations with the Ask O2 assistant.

Technical Data. We automatically collect limited technical information when you access the platform, including IP address, browser type, device information, and access timestamps. This data is used solely for platform security, abuse prevention, and infrastructure monitoring.

3. How We Use Information

We use collected information exclusively for the following purposes:

• Verifying participant identity and eligibility in compliance with KYC/AML requirements
• Conducting ongoing AML monitoring, sanctions screening, and suspicious activity reporting as required by law
• Facilitating protocol operations, including credit positions, collateral management, and hedge execution
• Communicating with participants about their positions, account status, or material protocol changes
• Maintaining platform security and preventing unauthorized access or abuse
• Complying with legal obligations, regulatory requests, and audit requirements

We do not use your information for marketing, behavioral profiling, targeted advertising, or any purpose unrelated to the provision of services and regulatory compliance.

4. Information Sharing

We do not sell, rent, or trade your information. We may share information only in the following circumstances:

• Service providers: With third-party vendors who assist in KYC/AML screening, identity verification, or platform infrastructure, subject to confidentiality obligations and data processing agreements
• Legal compliance: When required by law, subpoena, court order, or regulatory request, or when necessary to comply with applicable AML reporting obligations
• Protocol counterparties: Transaction data that is necessary to facilitate credit positions, to the extent required for protocol operations
• Protection of rights: When necessary to enforce these terms, protect the Company’s rights, or prevent fraud or security threats

5. KYC/AML Data Handling

KYC and AML documentation is treated with the highest level of sensitivity. We implement the following safeguards:

• KYC documents are stored in encrypted, access-controlled systems with audit logging
• Access to KYC data is restricted to authorized compliance personnel only
• KYC data is retained for the minimum period required by applicable law (typically five years after the termination of the business relationship, or as otherwise required by applicable regulations)
• We do not use KYC data for any purpose other than regulatory compliance and eligibility verification

6. Data Security

We implement reasonable technical and organizational measures to protect information, including encryption in transit and at rest, access controls, and regular security assessments. However, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

7. Data Retention

We retain information for the minimum period necessary to fulfill the purposes described in this policy and to comply with legal and regulatory obligations. Specifically:

• KYC/AML records are retained as required by applicable anti-money laundering regulations
• Transaction records are retained for the duration required by applicable financial recordkeeping requirements
• Technical logs are retained for a reasonable period for security purposes and then deleted
• When information is no longer required, it is securely deleted or irreversibly anonymized

8. Cookies and Tracking

The O2 platform uses only essential cookies required for platform functionality and security. We do not use third-party advertising cookies, tracking pixels, or behavioral analytics tools. We do not participate in cross-site tracking or advertising networks.

9. Third-Party AI Services

The Ask O2 assistant is powered by third-party artificial intelligence services. Conversations with the assistant are transmitted to and processed by these services to generate responses. You should not share sensitive financial information, private keys, wallet seed phrases, or confidential business information through the assistant. The Company is not responsible for the data handling practices of third-party AI providers.

10. Onchain Data

Transactions executed through the O2 protocol are recorded on public blockchain networks. Onchain data, including wallet addresses and transaction details, is publicly accessible and cannot be deleted or modified by the Company. This is an inherent characteristic of blockchain technology. You acknowledge that your onchain activity may be visible to third parties.

11. International Considerations

The Company operates from the United States. If you access the platform from outside the United States, your information may be transferred to and processed in the United States, which may have different data protection standards than your jurisdiction. By using the platform, you consent to this transfer.

12. Your Rights

Subject to applicable law and regulatory retention requirements, you may have the right to:

• Request access to the personal information we hold about you
• Request correction of inaccurate information
• Request deletion of information that is not subject to mandatory retention requirements
• Receive a copy of your information in a portable format

To exercise these rights, contact us at the address below. Note that we may be unable to delete information that we are required to retain under AML or other regulatory obligations.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. Material changes will be communicated through the platform or via email to registered participants. Continued use of the platform after changes are posted constitutes acceptance of the updated policy.

14. Contact

For privacy-related inquiries or to exercise your data rights, contact us at access@o2.credit.

Monark Technologies, LLC
A Pennsylvania Limited Liability Company