Privacy Policy

Last updated: 30 May 2026

This Privacy Policy describes how HODL LABS - FZCO ("HODL LABS", "we", "us", or "our") handles information collected through our corporate website at hodllabs.org (the "Site"). Each product we operate (such as Privage) has its own, separate privacy policy that governs the data practices of that product.

1. Who we are

HODL LABS - FZCO is a freezone company registered in the United Arab Emirates under IFZA (Dubai Silicon Oasis), trade licence number 45659, with a registered address in Dubai Silicon Oasis, Dubai, United Arab Emirates.

2. Information we collect on this Site

This Site is a static corporate page. It does not require an account and does not contain forms. The information we receive is limited to:

• Basic request metadata (e.g., IP address, user agent, referrer, timestamp) handled by our hosting provider, Cloudflare, for the purpose of delivering the Site and protecting it from abuse.
• Contact information you voluntarily provide when you email us (e.g., via steve@hodllabs.org). We receive whatever you choose to include in your message.
• Analytics information collected through Google Analytics, such as page views, approximate location, device/browser information, referrer, and other usage events used to understand aggregate Site traffic.

We use Google Analytics through Google's gtag.js script. Google Analytics may use cookies or similar identifiers to measure how visitors use the Site. We do not use Google Analytics to collect account information because this Site does not provide accounts. The Site also displays two public posts from X (formerly Twitter), which it fetches as described in "Third-party content" below.

3. Third-party content

The Site displays two public posts from X (formerly Twitter) as testimonials for one of our products. The post content (author name, handle, body text, timestamp) is fetched server-side through our own Cloudflare Worker, which proxies a public metadata API and caches the response at the edge. Your browser does not contact X, Twitter, or any related servers for the post content, and no X/Twitter scripts or cookies are loaded.

Author profile photos on those post cards are loaded as plain images from X's content CDN at pbs.twimg.com. This is a standard image request from your browser; X (X Corp.) will receive your IP address and user-agent as part of that request subject to X's Privacy Policy. No scripts or cookies are involved.

4. How we use information

• To operate, secure, and maintain the Site.
• To understand aggregate Site usage and improve the Site.
• To respond to correspondence directed to us.
• To comply with legal, regulatory, and compliance obligations (e.g., KYC, AML, sanctions screening) where applicable.

5. Sharing

We do not sell personal information. We may share information with:

• Service providers that operate on our behalf (e.g., our hosting provider and analytics provider).
• Professional advisors (e.g., legal, accounting) under appropriate confidentiality.
• Authorities where required by applicable law or a valid legal process.

6. Products we operate

Our products are governed by their own privacy policies. If you use Privage, please refer to its product privacy policy for details on how Privage handles your data. Nothing on this corporate Site grants Privage or any other product rights over your data beyond what that product's own policy permits.

7. Data retention

We retain request logs for a short period for operational and security purposes, and correspondence for as long as necessary to address the matter and comply with our legal obligations.

8. International transfers

We are based in the United Arab Emirates. Service providers we use may process data in other jurisdictions. Where required, we rely on appropriate safeguards for cross-border transfers.

9. Your rights

Depending on where you live, you may have rights to access, correct, or delete personal information we hold about you, or to object to or restrict certain processing. To exercise these rights, contact us at the email below. We may need to verify your identity before acting on your request.

10. Children

This Site is not directed to children under 13, and we do not knowingly collect personal information from children under 13.

11. Changes

We may update this Privacy Policy from time to time. The "Last updated" date above indicates when it was last revised. Material changes will be reflected on this page.

12. Contact

Questions about this Privacy Policy? Email steve@hodllabs.org.