# Privacy Policy

**Effective Date:** 01-04-2025
**Jurisdiction:** Abu Dhabi Global Market (ADGM), United Arab Emirates
**Language:** English (official version)

Version: V1.3

This Privacy Policy describes how Chill Airways (“we”, “us”, or “our”) collects, uses, discloses, and safeguards personal data in connection with our websites, platforms, applications, and services (collectively, the “Services”). By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your information as described.

This policy complies with key international data protection laws, including:
- EU General Data Protection Regulation (GDPR)
- California Consumer Privacy Act (CCPA)
- UAE Personal Data Protection Law (Federal Law No. 45 of 2021)
- Canadian Personal Information Protection and Electronic Documents Act (PIPEDA)
- China’s Personal Information Protection Law (PIPL)

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## 1. Information We Collect

### a. Information You Provide Directly
- Email address (e.g., for whitelist signups or communications)
- Wallet address (for blockchain-based services, rewards, or access)
- User-generated content (e.g., community posts, support tickets)

### b. Information We Collect Automatically
- Device information (IP address, browser type, operating system)
- Usage data (pages visited, session length, referral source)
- Cookie and tracking data (with user consent where required)

### c. Information from Third Parties
- Social platforms (e.g., Instagram, Tik-Tok, Discord, X, Telegram handles if connected)
- Third-party analytics tools (e.g., Google Analytics, WalletConnect)

We do not intentionally collect or process any sensitive personal data such as race, religion, biometric data, or health information.

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## 2. How We Use Your Information

We use your personal information for the following purposes:
- To provide access to the Services
- To personalize your experience and content
- To enable community engagement and DAO voting features
- To deliver communications and platform updates
- To comply with legal, regulatory, or contractual obligations
- To detect, investigate, and prevent security incidents or fraud
- To enforce our Terms and Conditions

We may aggregate and anonymize personal data for analytics or ecosystem optimization. Aggregated data is not considered personal data under applicable laws.

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## 3. Lawful Basis for Processing

Depending on the type of data and jurisdiction, our legal bases include:
- Email: Consent
- Wallet address: Contract performance or legitimate interest
- IP/device data: Legitimate interest, security
- DAO voting and rewards: Public interest or governance-related access

These are in line with GDPR, PDPL, and other applicable frameworks.

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## 4. Sharing and Disclosure of Data

We do not sell or rent your personal information.

We may share your data with:
- Service providers and technology partners (under confidentiality agreements)
- Regulatory authorities or law enforcement (as required by law)
- Legal or compliance consultants (for audits or investigations)
- Other users, if part of a public DAO vote or governance action (wallet addresses only)

We work with third-party processors to deliver the Services (e.g., analytics, cloud hosting, communications tools). All such parties are contractually obligated to process data securely and only for permitted purposes.

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## 5. Data Transfers and International Access

Your data may be transferred to, stored in, or processed in jurisdictions outside of your home country, including the United Arab Emirates, European Union, United States, or others.

Where applicable, we implement safeguards (e.g., Standard Contractual Clauses) to ensure your data is protected under relevant legal standards.

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## 6. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy or to comply with legal, regulatory, tax, or accounting obligations. When no longer needed, your data is securely deleted or anonymized.

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## 7. Your Rights

Depending on your jurisdiction, you may have the following rights:
- Access to your personal data
- Correction of inaccurate or outdated data
- Deletion of your data (“right to be forgotten”)
- Restriction or objection to data processing
- Data portability
- Withdrawal of consent (where processing is based on consent)
- Filing a complaint with your data protection authority

To exercise these rights, please contact us at **privacy(@)chillairways.com**.

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## 8. Cookies and Tracking Technologies

We use cookies, beacons, scripts, and similar technologies to enhance user experience, analyze traffic, and enable certain functionality.

You may set your browser to refuse or delete cookies. Where required, we ask for your consent before using non-essential cookies.

Users may withdraw consent at any time via in-platform settings, unsubscribe links, or by emailing privacy(@)chillairways.com. You may also manage cookie preferences directly through your browser or device settings.

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## 9. Automated Decision-Making

Where Chill Airways uses automated systems to evaluate eligibility or access rights (e.g., for DAO voting weight, reward access, or regional exclusions), such decisions are based on transparent rules and do not result in legal or financial consequences.

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## 10. Children’s Privacy

Our Services are not intended for use by individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware of any such data, we will take steps to delete it immediately.

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## 11. Security Measures

We implement industry-standard technical, administrative, and organizational measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. These include:
- HTTPS encryption
- Secure wallet connection protocols
- Role-based access controls
- Data minimization and storage security

However, no system is 100% secure. Use of our Services is at your own risk.

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## 12. Data Protection Officer

Chill Airways has appointed a data protection lead responsible for ensuring compliance. For escalated concerns, please contact **privacy(@)chillairways.com** and request contact with the Data Protection Officer.

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## 13. Changes to This Policy

We reserve the right to amend this Privacy Policy at any time. Any material changes will be posted on our website and may be communicated via email or app notification. Continued use of the Services after changes implies acceptance.

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## 14. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy, please contact:

**Chill Airways**
Email: **privacy(@)chillairways.com**
Jurisdiction: Abu Dhabi Global Market (ADGM)

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*This Privacy Policy is designed to comply with international data protection frameworks and the legal requirements of the Abu Dhabi Global Market (ADGM). It is subject to regular review and updates to reflect changes in regulatory guidance and industry best practices.*