# Latch Introduction Latch is a blockchain interoperability protocol designed to unify yield, liquidity, and chains. By building a unified crypto UX, we are committed to accelerating the adoption of the on-chain financial system. #### **Why Go On-chain?** The on-chain financial system powered by decentralized blockchain and crypto offers unique values (vs. traditional finance): * Open and permissionless on a global scale * More transparent * More efficient * Trust-minimizing #### **The Problem** However, navigating through the on-chain financial system is quite complex and unintuitive. The ever-increasing numbers of chains, tokens, and assets are fragmenting the user & developer experiences. #### **The Solution** To address fragmentation issues and achieve interoperability, the Latch Protocol is building on liquid staking/re-staking, cross-chain liquidity management, and intent settlement infrastructures. Our first product is Smart Savings built on Gravity Chain, aiming to achieve: * **Omni-chain Yield:** Deposit your idle tokens on any chain, select a preferred vault, and earn yields & points with ease * **On-demand Liquidity:** Unlock liquidity to your staked savings on all chains instantly * **Universal Balance:** Enjoy a unified savings balance that can be spent on all chains, and in all supported dApps More features to come in future iterations. Stay tuned for updates. # Yields & Points Aggregation #### **On-chain Yields** Marked by Ethereum’s successful transition from Proof-of-Work (”PoW”) to Proof-of-Stake (”PoS”), we are witnessing the birth of a robust on-chain yield market, and the explosion of yield-bearing assets leveraging multiple sources of yields on-chain, including staking & re-staking yields, lending yields, RWA yields, and their combinations. For example, Ethena provides a combination of yields from: * Ethereum PoS yield * Lending yield from funding perpetual futures positions A lot of Defi projects are coming up with yield vaults to aggregate multiple sources of yields. #### **Airdrops and Points Are Another Source of Yield** In addition, more and more projects are adopting airdrop and point systems to reward early eco-system contributors. The Points are expected to turn into tokens after their TGE. For example, Eigenlayer Restakers via Ether.Fi have received multiple rounds of airdrops, including: * Altlayer Airdrop * Omni Airdrop * Ether.Fi Airdrop Season 1 * Eigen Stakedrop Season 1 * And more AVSs (Actively Validated Services powered by Eigenlayer) are expected to provide rewards to restakers in the future Thus the airdrops and points create another source of meaningful yield for Latch users. #### **All-in-One APY Aggregation** While all these yields, airdrops, and points are great, it could be troublesome to track, manage and calculate. Latch helps you aggregate all of them in one place, to track and manage your overall returns easily. Latch also helps you calculate the overall expected APY, factoring into points and future airdrops, by sourcing pre-market trading data from leading platforms (e.g. Pendle). Once the airdrop points have turned into claimable tokens, you will have the option to simply add the airdrops to your Latch balance, or to claim the tokens to your wallet. # On-demand Omni-chain Liquidity #### Unlock Liquidity to Your Staked Positions Crypto staking is often subject to a waiting period (usually 7-14 days) when you unstake. To address this issue, we see a lot of liquid staking protocols that allow users to swap out instead of waiting for withdrawal. However, swapping out usually comes with friction, as the LSD/LRT tokens on DEX are generally trading at a discount to the original token. For example, swapping [ether.fi](http://ether.fi)’s weETH to ETH comes at a 0.3% friction, compared to withdrawing weETH from the protocol. The liquidity solution offered by Latch helps minimize that friction, by aggregating all liquidity sources, including providing omni-chain liquidity on its own. #### Aggregating Liquidity There are multiple sources of liquidity providers: * Latch offering certain omni-chain liquidity quota * LSD/LRT (e.g. [Ether.fi](http://Ether.fi), Ethena) players providing liquidity to support their LSD/LRT token pegging * Users contributing liquidity for LP yield * Partner dApps contributing liquidity for improved UX Leveraging the cross-chain intent settlement, both on-chain liquidity (e.g. DEX & Bridges) and off-chain liquidity (CEX) can be aggregated, to maximize transaction efficiency. #### Use Cases for On-demand Omni-chain Liquidity Transactions in crypto space are usually very time-sensitive: waiting to withdraw tokens from LSD/LRT protocols could have huge opportunity costs. We all want to get instant liquidity whenever and wherever we want. By offering Omni-chain Liquidity, Latch facilitates various use cases: * Refuel gas fees on any chain * Buy NFT/Memecoins instantly on any chain * Use Latch balance to spend directly in dApps * … And a lot more to come! # Cross-chain Intent Settlement #### What is Intent? While the buzzword “intent” may sound abstract, it actually is a simple idea to free users from the obscure blockchain technicalities. An “intent” is a message signed by a user to express ‘what’ is to be done instead of ‘how’ to do it. For example, when I want to use my $5 worth of MATIC on Polygon to exchange for $5 worth of USDT on Base, instead of signing and executing several steps of swapping & bridging by myself, I can just sign one intent: “Any one that sends my address $5 worth of USDT on Base, can take my $5 worth of MATIC on Polygon.” Such that I can outsource the entire execution task to professionals who can process these cross-chain transactions more efficiently. #### Building on Gravity Chain's Cross-chain Intent Settlement Infrastructure While this solution sounds intuitive enough, the challenging part is how do we settle this intent securely due to its cross-chain nature. Different blockchains don’t really “talk” to each other, and they have different states and finality rules → thus hard to synchronize for settlement. To achieve Cross-chain Intent Settlement (”CCIS”), we will be building on Gravity Chain, which is a high-performance blockchain with native support of CCIS, featuring: * Safer consensus & faster finality, leveraging PoS consensus and restaking * Efficient ZKP verification for cross-chain communication * High throughput with cost efficiency Gravity Chain will iron out the synchronization issues of different blockchains and act as the unified settlement layer.
# Liquid Staking Overview Latch also utilizes liquid staking solutions to further unlock liquidity, with key elements described below. ### **1. The Liquid Staking Tokens: atUSD / atETH** **What are atUSD and atETH?** These are [ERC-20](https://eips.ethereum.org/EIPS/eip-20) value-accruing tokens representing the user’s Smart Savings position - usually referred to as the “Liquid Staking Token” (“LST”). These tokens represent the user's share of the underlying assets in the Defi vault - atUSD corresponds to the USD stablecoin vault, and atETH corresponds to the ETH vault. Alternatively, you can think them as the “Certificate of Deposit” tokens after you deposit into Smart Savings. **How do atUSD & atETH account for Smart Savings yields?** The Smart Savings yields are distributed to atUSD & atETH holders as these liquid staking tokens keep accruing value from the increasing atUSD/USDT & atETH/ETH exchange rate. The exchange rate represents how much USDT (or ETH) the user can redeem by burning 1 atUSD (or atETH). For example, on Day 1, atUSD/USDT exchange rate is 1:1 (burning 1 atUSD to redeem 1 USDT). On Day 2, when 0.05 yield is realized from the underlying Defi Vault, atUSD/USDT exchange rate is therefore updated to 1:1.05 (burning 1 atUSD to redeem 1.05 USDT). ### 2. Omnichain Deposit / Withdraw / Spend Powered by Gravity The deposit and withdrawal process powered by liquid staking will consist of 2 options: 1) Primary market of minting & burning liquid staking tokens, and 2) Secondary market of buying & selling liquid staking tokens via DEX. The primary market is more suitable for large amounts of deposits & withdrawals, while the secondary market is more efficient for normal day-to-day small deposits and withdrawals. Latch also provides an auto-router function that guides users toward the most efficient path (primary vs. secondary). **Deposit Process** * Primary market: user deposits funds on Ethereum → mint liquid staking tokens on Gravity * Secondary market: user deposits funds on any supported EVM chain → bridge to Gravity → swap to liquid staking tokens on DEX **Withdraw Process** * Primary market: user burns liquid staking tokens on Gravity → start the withdrawal process & waiting period countdown → claim funds on Ethereum (usually T+7 days) * Secondary market: user swaps liquid staking tokens on DEX to USDT or ETH (T+0) → bridge from Gravity to any supported EVM Chain **Spend Process** * In any dApp integrated with Latch (e.g. Galxe), when users need to spend crypto for any transaction (e.g. NFT minting), the dApp will front the money and pay on user’s behalf, and later get reimbursed from the user’s Smart Savings balance, which has pre-authorized Galxe for such reimbursement purpose ### 3. Net Asset Value (”NAV”) **What is Net Asset Value and why do we need it?** The inherent value of the liquid staking tokens (atUSD & atETH) needs to be properly tracked at real-time, to account for the principal capital + yield generated, and distribute the accrued yield to each holder of atUSD & atETH. For example, on Day 1, there are a total of 1,000 atUSD minted (”Total Supply”), which correspond to an underlying Defi Vault valued at US$1,000 (sum of all the Defi assets), then the NAV of each atUSD = NAV of the underlying Defi Vault (US$1,000) / Total Supply of atUSD (1,000) = $1.00. On Day 2, when NAV of the underlying Defi Vault grows to US$1,005, assuming no change to atUSD Total Supply, then NAV of atUSD grows to US$1,005/1,000 = US$1.005, implying a realized yield of 0.5%. The NAV is then used as the exchange rate for primary market minting & burning of atUSD. Such that, on Day 2, depositing US$1.005 will mint you 1 atUSD, and burning 1atUSD will return you US$1.005 back. **How does the market trading price of atUSD & atETH peg to their Net Asset Value?** Following the example above, on Day 2, when NAV of atUSD = US$1.005, the market arbitrage force will push the secondary trading price of atUSD toward its NAV value. * If atUSD trades higher than NAV (e.g. at US$1.01), then the arbitrager can use US$1.005 to mint 1 atUSD, and sells it for US$1.01, thus pocketing a profit of 1.01-1.005 = US$0.005 in real-time, and such selling activities will drive down atUSD price to NAV * If atUSD trades lower than NAV (e.g. at US$1.00), then the arbitrager can buy 1 atUSD for US$1.00, and burn it to redeem back US$1.005 per the NAV rate, thus pocketing a profit of 1.005-1.00 = US$0.005 in real-time, and such buying activities will drive up atUSD price to NAV ### **4. Liquidity Pool for Instant Withdrawal** **Camelot DEX Pool of atUSD/USDT and atETH/ETH on Gravity** atUSD/USDT and atETH/ETH DEX pools have been set up on Camelot DEX on Gravity chain, to facilitate the secondary market deposit and withdrawal process stated above. Size of the DEX pool has been designed to maintain a liquidity ratio of 10% of the underlying Defi Vault TVL. Price ranges of the DEX pool are set dynamically to ensure an acceptable slippage level, together with a rebalancing mechanism to adjust the token ratios in the DEX pool. In the extreme scenarios that all liquidity in the DEX pool has been used up and refills haven’t come in time, the secondary market deposit and withdrawal process may be temporarily unavailable. During such time, for any withdrawal needs, you can either wait for the DEX pool to be refilled and withdraw instantly through the pool (T+0) afterward, or go through the primary market option instead - burning the liquid staking token and claim funds after the waiting period (T+7 days). # Contracts Addresses Addresses for key contracts deployed:
NameAddressesChains
Latch staked USD (atUSD) Contract0xc4af68Dd5b96f0A544c4417407773fEFDc97F58dGravity
Latch staked ETH (atETH) Contract0xc314b8637B05A294Ae9D9C29300d5f667c748baDGravity
USD Vault Proxy 10xa116b4680b52973426B6D2a92DcC972b8DbcB46FETH
ETH Vault Proxy 10x97cA296139f114BF3040Cf05D05c240B770c627EETH
USD Vault Proxy 20x774388454c92FE33e781ab535A5E9d186a4562E7ETH
ETH Vault Proxy 20x774388454c92FE33e781ab535A5E9d186a4562E7ETH
USD Vault Proxy 30x29403B1AC2B745c806e4d4988e4C1B6F4c119b95ETH
ETH Vault Proxy 30x899f88b7c34a01ed0eea2bdb0952bd271ad3245bETH
# Contracts Audit The Smart Contracts deployed are fully audited by SlowMist. You can find the audit report here. {% file src="/files/rmMflSSCnIa7dMtOaYAw" %} {% file src="/files/buS7yIr4h7Ty2E320QRj" %} # How to Deposit Depositing into Latch is easy, follow these instructions below: Choose a vault:
Choose what asset you would like to deposit. Here we will choose to deposit MATIC on Polygon (which will be converted and bridged to ETH).
Select how much of your asset you'd like to deposit.
Confirm transaction!
Then you can easily track your balance, profits and points all in one place in the dashboard! # How to Withdraw Withdrawing funds is simple - just two steps! Read below: Go to your vault, choose how much you'd like to withdraw, and withdraw.
Sign the transaction!
Your tokens withdrawn will be sent to your wallet address within 7 days after requesting withdrawal! The exact wait time is subject to the underlying vault. # How Are the APYs Calculated The APYs are calculated based on the weighted average of the trailing 30 days real yields generated from the underlying yield protocols, including Ethena, Ether.Fi, Pendle, Mellow, Eigenlayer, Symbiotic, etc. # Instant Withdraw vs. T+7 Days Withdraw Crypto staking rules usually implement a lock-up period. For example, for Ether.Fi, withdraw means unstaking the ETH which was restaked to Eigenlayer. The process could in theory take the time to withdraw from Eigenlayer AND from Ethereum validators. In practice, Ether.Fi provides an expedited withdrawal service that normally takes 3-7 days to process. **Latch offers 2 routes for users to withdraw funds:** * Primary Market: Burn LSTs on Gravity → initiate withdrawal and wait for the standard countdown (T+7 days) → claim your funds on Ethereum * Secondary Market: Swap LSTs on a DEX for USDT or ETH (T+0) → bridge back to any supported EVM chain The primary market is ideal for handling large deposits and withdrawals, while the secondary market is more efficient for smaller, day-to-day transactions. This is further accompanied by an auto-router function that guides users toward the most efficient path (primary vs. secondary). In the unlikely event that the DEX pool’s liquidity is exhausted and remains below its functioning levels, the secondary market deposit and withdrawal process may be temporarily suspended. During such times, you have two options for withdrawals: you can wait for the DEX pool to be refilled, allowing for instant withdrawals (T+0), or you can utilize the primary market by burning your liquid staking tokens and claiming your funds after the standard waiting period (T+7). # What are Eigenlayer & LRTs, and their Risks One of the staking vaults Latch will be offering as a place to park your funds is Eigenlayer. If this is your first time hearing about restaking and Eigenlayer, you’re in the right place! Read on to learn more. #### Eigenlayer: Maximizing Staked ETH Potential Traditionally, staking ETH locks up your assets for a period of time in support of network security and consensus. Eigenlayer adds a powerful dimension to this process by enabling "restaking." Simply put, it allows you to use the same staked tokens towards the support of another network security and processing of transactions (Eigenlayers). Terms like double dipping or eating your cake and having it too would be accurate as well. This effectively means you can earn two separate APR’s (the Ethereum staking rate as well as the Eigenlayer staking rate) with the same tokens! It is important to note that as Eigenlayer continues its preparation for mainnet you will be earning Eigen Points, which can later be redeemed for rewards. Restakers can choose where their tokens are “restaked” to by allocating ETH to any one of the AVS (actively validated services) each with its own reward and slashing policies (ie, you can lose money). Any AVS could have its own set of points, yields, and airdrops, leading to a dizzying amount of possibilities! Websites like StakingRewards have a convenient dashboard, allowing you to view all AVS’ and compare them in one glance: #### **LRTs: Liquid Restaking Tokens** When you restake your ETH to Eigenlayer through Liquid Restaking Players (e.g. Ether.Fi), you receive Liquid Restaking Tokens (LRTs, eETH is Ether.Fi's LRT token). These tokens represent your position within the restaking system and serve as a means to continue accruing staking rewards. The "liquid" aspect of LRTs refers to the potential to trade them on decentralized exchanges. #### **Understanding the Risks** As with most crypto technologies, it's important to consider the potential risks involved: * **Smart Contract Risks:** Complex code may contain vulnerabilities, even if thoroughly audited. * **Market Volatility:** The fluctuating price of LRTs is subject to broader crypto market conditions, while typically having less liquidity then the underlying asset (which leads to price premiums). * **Slashing Penalties:** In extreme cases, if the services your restaked ETH supports violate the validating rules, a portion of your stake could be lost as a penalty. As listed above, each AVS you choose to restake with also has their own slashing conditions as well. * **Rug pull:** While we are more familiar with the term rug pull for pump and dump memecoins, there are cases of yield farms being rug pulls as well. # What is Ethena, and its Risks Another popular yield vault is Ethena, an exciting protocol enabling the internet bond. How exactly does it work? Just like in our explainer for Eigenlayer, we start with the base asset in its natively staked form - so staked Ethereum. This means that it is securing the Ethereum blockchain and already receiving rewards. Instead of restaking, or having that same staked Ethereum be used to secure another network or AVS, Ethena allows you to use staked Ethereum as collateral to mint Ethena’s synthetic dollar, USDe, for which Ethena is at the same time creating a short position on ETH to hedge the ETH/USD price risk. These USDe tokens can then be staked (sUSDe) to generate yield or locked to earn points in Ethena's airdrop campaigns ("Ethena Sats"). Ethena's yield is thus generated from multiple sources: 1. **Ethereum staking yield** 2. **Funding and basis spread** **earned from the delta hedging derivatives positions** 3. **Ethena's airdrop campaign** For further explanation: [Yield Explanation | Ethena Labs](https://ethena-labs.gitbook.io/ethena-labs/solution-overview/yield-explanation) ENA Airdrop and Season 2: Sats Campaign: #### What are the risks? No free cake in life. Let’s talk about the risks that staking with Ethena may have. If you check their docs, they are quite transparent on the risks that USDe bear: 1. Funding Risk - negative funding rates over a long period (affecting the shorts Ethena makes when you mint USDe to maintain delta neutrality). 2. Liquidation Risk - risk of an exchange forcibly closing your position when the value of your collateral falls below a certain threshold. 3. Custodial Risk - Ethena has off-exchange settlement providers hold protocol backing assets, so their ability to safely guard assets is a potential risk. 4. Exchange risk - Ethena uses exchanges to perform the shorts, etc. If something were to happen to these exchanges, this could disrupt flow. 5. Collateral risk - Collateral risk is the risk of the value of your collateral dropping below a certain threshold, causing your position to be liquidated. In the context of Ethena, this can happen if the price of the staked asset (stETH) falls significantly compared to the underlying asset (ETH). To learn more visit Ethena docs here: # Terms of Use Effecitve Date: May 29th, 2024 By directly or indirectly accessing or using the Website and/or Services (each, as defined below), including, but not limited to, indirectly linking your Digital Wallet (defined below) to the Services through a site or service operated by a third party, or otherwise using the Website or Services or any portion thereof, you hereby consent to be bound by these terms and conditions (“**Terms**”). These Terms are entered into, and create a legally binding agreement, by and between you, and any organization you are acting on behalf of (“**you**” or “**your**”) and Smart Savings Foundation (“**Latch**”, “**we**,” “**our**,” or “**us**”). We may amend or modify these Terms at any time and for any reason. The amended or modified Terms are effective immediately upon us posting them or otherwise making them available on [latch.io](http://latch.io) (“**Website**”) and by continuing to link your Digital Wallet (as defined below) to our Services, or otherwise use our Services, you agree to such amended or modified Terms. You agree to be responsible for reviewing the Terms and any amendments or modifications thereto. If you do not agree with the Terms, your sole and exclusive remedy is to cease your use of the Services and/or Website. THESE TERMS CONTAIN IMPORTANT INFORMATION, INCLUDING A BINDING ARBITRATION PROVISION AND A CLASS ACTION WAIVER, BOTH OF WHICH IMPACT YOUR RIGHTS AS TO HOW DISPUTES ARE RESOLVED. **1. Definitions.** The definitions for certain defined terms used in these Terms are set out below. Other terms are defined elsewhere in these Terms. 1.1 “**Digital Assets**” means any digital blockchain asset subject to the Services. 1.2 “**Digital Wallet**” means the wallet or similar device or software used to store Digital Assets. 1.3 “**Net Reward**” means the sum of the Rewards minus any Protocol Fees, Service Fees and Transaction Fees. 1.4 “**Rewards**” means any rewards granted by the Supported Staking Protocols, including staking rewards, block rewards, and transaction fees, in each case as actually granted by such Supported Staking Protocols, as applicable. 1.5 “**Protocol Fees**” means any fees charged by the applicable underlying Supported Staking Protocols. 1.6 “**Supported Asset**” means a Digital Asset for which you can use to participate in staking services via the Services. 1.7 “**Supported Staking Protocol”** means a staking, delegation or other validator node or staking smart contract that you can connect to via the Services. 1.8 “**Transaction Fees**” means the aggregate amount of fees prepaid by us on your behalf pursuant to Section 3.3 hereof. **2. Services** 2.1 **The Services**. Subject to these Terms, we offer a set of user interfaces and staking services that allows users to connect to certain third party Supported Staking Protocols for Supported Assets (collectively, the “**Services**”). The Services are strictly offered on a non-custodial basis. You hereby agree and acknowledge that (a) Latch does not at any time hold or custody any assets on your behalf, and (b) Latch solely offers a set of user interfaces for you to interact with third party Supported Staking Protocols, none of which are controlled by Latch. 2.2 **Staking Pools**. Each of the Latch staking pools are single asset and any Supported Assets transferred into such staking pools are staked to a single Supported Staking Protocol. For each Supported Asset, you may choose among multiple Supported Staking Protocols. You may transfer Supported Assets directly into each Latch staking pool, or you may use a third party service, including decentralized exchanges, to convert any Digital Assets that you own into a Supported Asset before they are staked into a Latch staking pool. From time to time, we may also offer a front-end user interface to facilitate connectivity services with third party decentralized services. You agree and acknowledge that your use of such third party services shall be at your own risk and Latch does not bear any responsibility whatsoever for such third party services. 2.2 **License to Access the Services**. Subject to these Terms, we hereby grant you a limited, non-exclusive, revocable, non-transferable, non-sublicensable right and license to access and use the Services for purposes of staking Supported Assets to Supported Staking Protocols accessible via our Services. 2.3 **Blockchain Events**. You acknowledge and agree that the Supported Staking Protocols are independently and separately operated and controlled by third parties. As such, at any time and for any reason, such Supported Staking Protocols may modify their protocols, stake or unstake, bond or unbond your Digital Assets, fork, or implement any other action or change that may impact your Net Rewards, Supported Assets, the Services and/or your access to and use of each of the foregoing (together, a “**Blockchain Event**”). 2.4 **Changes to the Services**. We reserve the right to modify, alter or otherwise change the Services from time to time by adding, deleting, or otherwise modifying features or functionality to improve your experience, comply with applicable regulations and/or laws or for any other reason or purpose. We further reserve the right to (i) discontinue any feature of the Services or any portion thereof at any time, including, without limitation, discontinue to support any Supported Asset, or Supported Staking Protocol, or other services, or (ii) remove any content from the Services at any time, in each case for any reason in our sole discretion and without notice to you. You specifically acknowledge and agree that we are not (a) responsible for such modifications, changes, content removals, or (b) liable for any loss of value of your Digital Assets or loss of Net Rewards that may result directly or indirectly from any such changes or any Blockchain Event. **3. Rewards; Fees** 3.1 **Rewards**. Your use of the Services may result in a Net Reward that is issued by the applicable Supported Staking Protocol and either (a) transferred to the Digital Wallet address where your Supported Assets originated or is otherwise used by you in connection with the Services (the “**Originating Wallet**”), or (b) eligible to be claimed by you using the Originating Wallet. You acknowledge that (i) such Net Rewards may be issued in the same denomination as the Supported Assets, (ii) any estimates or projections of Rewards or Net Rewards, as applicable, are not a guarantee, (iii) we will never ask for and you should never provide to us the private key for your Originating Wallet or any other wallet, (iv) we are not responsible for the loss of your private key or your inability to access (a) your Originating Wallet, or (b) any resulting Net Rewards that may be stored or claimable therein, and (v) you assume responsibility for ensuring the proper use of the correct and valid address of your Originating Wallet(s), and that your Originating Wallet supports and is otherwise compatible with the applicable Supported Asset and Supported Staking Protocol. You specifically acknowledge and understand that your Net Rewards may be subject to a bonding/unbonding, locking/unlocking, claim or other delay period or mechanism by a Supported Staking Protocol that may render your Net Rewards and/or Supported Assets unavailable and/or subject to other restrictions imposed and controlled by such Supported Staking Protocol (collectively, “**Protocol Restrictions**”). 3.2 **Services** **Fees**. In consideration for granting you a limited license to access and use our Services, you hereby agree that we may charge a service fee (a “**Service Fee**”). Any such Service Fee may be transferred to us directly by the applicable Supported Staking Protocol. 3.3 **Transaction Fees**. Latch further provides a service whereby users who wish to transact using their Galxe Smart Savings Balance can request us to pre-pay any transaction or gas fees on behalf of such user on the Ethereum, Solana, and other blockchains, as the case may be. You agree that upon your request we may agree to do so in our sole discretion. In the event that we pay any Transaction Fees on your behalf, you agree that upon your withdrawal of any Supported Assets from a Latch Staking Pool, we may deduct the U.S. dollar equivalent value of such Transaction Fees from the amount of Supported Assets that you may withdraw from such staking pool. You further agree that in the event that the aggregate amount of Transaction Fees exceed the amount that you are eligible to withdraw from any Latch staking pools, we reserve the right (at our discretion) to seek compensation via legal and other remedies. Please note that third parties, such as Galxe Wallet, have their own Terms of Service/Use (or equivalent thereof) and Privacy Policies associated with their products/services. Prior to accessing or using such third party products/services in connection with our Services, you are responsible for reviewing, agreeing to and complying with their respective Terms of Service/Use (or equivalent thereof) and Privacy Policies. **4. Termination** 4.1 **Termination**. In the event that you breach these Terms or if we reasonably determine that action is necessary or advisable under applicable law, we may terminate or suspend your right to use or otherwise access the Services with or without notice to you. Such termination or suspension shall be a non-exclusive remedy for your breach of these Terms and we reserve the right to pursue any and all additional remedies that may be available to us. We may also terminate or suspend the Services in whole or in part for whatever reason and at any time. Notwithstanding the foregoing, you acknowledge and agree that termination of these Terms may be subject to other terms and conditions maintained and enforced by Supported Staking Protocols or other third parties. 4.2 **Effects of Termination**. In the event of any termination or suspension pursuant to Section ‎4.1 or otherwise, the Services will immediately cease. Termination or suspension of the Services may require you or us to complete certain additional tasks that comprise part of the Services, including, but not limited to, your compliance with certain Protocol Restrictions. The performance of such tasks shall be at our discretion and you disclaim any responsibility or obligation that we may have to perform such tasks. 4.3 **Survival**. The following Sections shall survive termination of these Terms: Section ‎3.2 (Fees), ‎3.3 (Transaction Fees), Section ‎4.2 (Effects of Termination), Section ‎5 (Intellectual property), Section ‎7 (Disclaimer), Section ‎8 (Limitation of Liability), and Section ‎‎9 (Indemnification). ‍**5. Intellectual property** 5.1 **Ownership**. As between you and us, we own all rights, title, and interest in and to the Services and Website and any modifications, improvements, adaptations, enhancements, derivates thereto and any intellectual property rights related thereto, including, but not limited to, patent rights, trademark rights, copyrights, and trade secret rights and any other intellectual property and/or industrial rights recognized anywhere in the world. 5.2 **No Other Right**. Except for the limited license granted to you in Section ‎2.2, we do not grant or convey to you by implication, waiver, estoppel or otherwise any license to, any right, title, or interest in and to our intellectual property rights in or to the Services and Website or any other products, software or technology shared or made available by us under or in connection with these Terms. 5.3 **No Reverse Engineering; Restrictions**. You agree not to, directly or indirectly, (i) copy modify, reproduce, reverse engineer, decompile, disassemble, or otherwise attempt to discern the source code or any other proprietary information or materials related to the Services or the Website; (ii) use the Services or Website to (a) build a competitive product, software or other technology that could be used to offer similar services as to those offered hereunder, (b) engage in activity that seeks to defraud us or any other person or entity, including but not limited to, providing any false, inaccurate or misleading information in order to unlawfully obtain the property of another, or (c) engage in activity that breaches these Terms; (iii) interfere with the Services or Website, their security, network and the operability of any of the foregoing; or (iv) introduce, post, or upload, (a) bugs, time bombs, time locks, traps, trojan horses, or (b) any other harmful code or software that can corrupt or damage data, storage media, programs, equipment, or any hardware used in connection with the Services or Website. **‍6. YOUR REPRESENTATIONS, WARRANTIES AND COVENANTS; ACKNOWLEDGMENT OF RISKS** 6.1 **Your Representations and Warranties**. You represent, warrant and covenant that: (i) the organization or entity you may be acting on behalf of is duly organized, validly existing, and in good standing under its jurisdiction of organization and has the right to enter into these Terms; (ii) you have all requisite power and authority to, and no other proceedings on its part are necessary to, execute and deliver these Terms; (iii) your performance of your duties and obligations under these Terms and in connection with your use of the Services and Website shall comply with all applicable laws, rules, and regulations; (iv) you and the organization or entity you may be acting on behalf of are not (a) located, incorporated or otherwise established in, or a citizen or resident of any state, country or other jurisdiction that is designated by the U.S. Secretary of State as a country supporting international terrorism, or to which U.S. nationals cannot lawfully engage in transactions as designated by the Office of Foreign Assets Control (“**OFAC**”), including Cuba, Crimea, Luhansk and Donetsk regions of Ukraine, Democratic People’s Republic of Korea, Iran and Syria, (b) a person found on the OFAC Specially Designated Nationals, Blocked Persons List, or any other consolidated prohibited persons list as determined by any applicable governmental authority (including any such list maintained by the government of the United Kingdom and/or British Virgin Islands), (c) a person identified as a terrorist organization on any other relevant lists maintained by any governmental authority, or (d) a senior foreign political figure, or an immediate family member or close associate of a senior foreign political figure; (v) you are of legal age in the jurisdiction in which you reside and have the full legal authority and right (a) to be bound to these Terms, and (b) to bind the organization or entity you may be acting on behalf of to these Terms; (vi) you have the right, title, and interest in and to the Supported Assets used by you in connection with the Services; (vii) you have all the rights and requisite authority to submit or otherwise provide your Digital Assets, data or any other materials you provide under and in connection with these Terms; (viii) any assets, including Supporting Assets used by you in connection with the Services is not encumbered or restricted in any manner that would prohibit compliance with these Terms; (ix) you own or otherwise have the right to access and use the Originating Wallet(s) used in connection with the Services; (x) you understand that the continued ability to provide the Services is dependent on many elements and you understand the risk involved with use of the Services, Website and Supported Staking Protocols; (xi) you and the organization or entity you may be acting on behalf of are in compliance with all applicable laws and regulations; (xii) you will not intentionally use the Services to commit or perpetrate any form of fraud or other violations of law and these Terms; (xiii) your use of the Services shall not cause us to be in violation of applicable U.S. federal or state or non-U.S. laws or regulations, including, without limitation, anti-money laundering, economic sanctions, anti-bribery or anti-boycott laws or regulations, the U.S. PATRIOT Act, or the various statutes, regulations and executive orders administered by OFAC (“**OFAC Regulations**”) or any applicable laws, rules and regulations which apply in the British Virgin Islands, including the Proceeds of Criminal Conduct Act and the Anti-Money Laundering Regulations. (xiv) None of the Supported Assets used by you in connection with the Services relate in any way to (i) the government of any country designated by the United States, the British Virgin Islands or other governmental authority as a country supporting international terrorism, (ii) property that is blocked under any OFAC Regulations or that would be blocked under OFAC Regulations if it were in the custody of a U.S. national, (iii) persons to whom U.S. nationals cannot lawfully export services, or with whom U.S. nationals cannot lawfully engage in transactions under OFAC Regulations, (iv) the government of any country that has been designated as a non-cooperative country or designated by the U.S. Secretary of the Treasury or other governmental authority as a money laundering jurisdiction or (v) directly or indirectly, any illegal activities. (xv) you and the organization or entity you may be acting on behalf of have not been convicted of, or agreed to enter into a pretrial diversion or similar program in connection with the prosecution of, a criminal offense involving theft, dishonesty, breach of trust, money laundering, the illegal manufacture, sale, distribution of or trafficking in controlled substances, or substantially equivalent activity in a domestic, military, or foreign court; (xvi) you are solely responsible for the security, custody and control of any Originating Wallets; (xvii) you will not use the Services or Website in a manner that infringes, misappropriates or otherwise violates the intellectual property rights and privacy rights of any third party; (xviii) you are not subject to any restriction or prohibition that would limit or prohibit your use of the Service or Website in accordance with these Terms; (xix) the Supported Assets used by you in connection with the Services are not derived from, and do not otherwise represent the proceeds of, any activities done in violation or contravention of applicable law or regulations; and (xviii) you will not use the Services or Website in any manner that violates applicable law or regulations. 6.2 **Acknowledgment of Risk**. You understand and agree that (i) the Website and Services facilitate access to Supported Staking Protocols, the use of which has many inherent risks and (ii) cryptographic and blockchain-based systems have inherent risks to which you are exposed when using the Website and Services. You further represent that you have a working knowledge of the usage and intricacies of blockchain-based Digital Assets and that you acknowledge and understand that (a) your use of the Services exposes you to considerable risk of loss; (b) you may not earn any Net Rewards; (c) the operation of the Services and any resulting Net Rewards, if any, depends on the Supported Staking Protocols and other services provided by third parties whom we do not control or which no single identifiable person or entity controls, and as such, it may be difficult or impossible to recover any Digital Assets provided to such Supported Staking Protocols if such Digital Assets are lost or stolen; (d) Digital Assets and staking programs, including the Supported Staking Protocols are new technologies that currently face uncertain and evolving regulatory requirements in many jurisdictions; (e) the value of any Supported Assets may fluctuate and be highly volatile at any time, and the value of the Supported Assets may be insufficient to pay for any Transaction Fees; and (e) one or more such jurisdictions may, in the future, adopt laws, regulations or directives that affect one or more Supported Assets and/or Supported Staking Protocols and that may result in sudden changes (x) to the Services or (y) in connection with your Rewards or Supported Assets. For the avoidance of doubt, we specifically disclaim any liability for any losses or damages you experience in connection with any of the foregoing and you agree to assume full responsibility for all of the risks of accessing and using the Website and Services. **7. DISCLAIMER.** THE SERVICES, WEBSITE, AND ANY OTHER PRODUCTS, SOFTWARE OR TECHNOLOGY PROVIDED BY US HEREUNDER IS PROVIDED “AS IS” AND “AS AVAILABLE,” AND WE DO NOT MAKE ANY REPRESENTATIONS OR WARRANTIES WITH RESPECT TO THE SAME OR OTHERWISE IN CONNECTION WITH THESE TERMS, AND HEREBY DISCLAIM ANY AND ALL EXPRESS, IMPLIED, OR STATUTORY WARRANTIES, INCLUDING, WITHOUT LIMITATION, ANY WARRANTIES OF NON-INFRINGEMENT, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AVAILABILITY, ERROR-FREE OR UNINTERRUPTED OPERATION, AND ANY WARRANTIES ARISING FROM A COURSE OF DEALING, COURSE OF PERFORMANCE, OR USAGE OF TRADE. WE FURTHER DISCLAIM ANY LIABILITY INCLUDING, BUT NOT LIMITED TO, ANY LOSSES RESULTING FROM OR IN CONNECTION WITH SLASHING PENALTIES AND TRANSACTION FEES. WE FURTHER EXPRESSLY DISCLAIM ALL LIABILITY OR RESPONSIBILITY IN CONNECTION WITH THIRD PARTY SERVICES. NOTHING HEREIN NOR ANY USE OF THE SERVICES IN CONNECTION WITH THIRD PARTY SERVICES CONSTITUTES OUR ENDORSEMENT, RECOMMENDATION OR ANY OTHER AFFILIATION OR WITH ANY THIRD PARTY SERVICES. LATCH WILL NOT BE RESPONSIBLE OR LIABLE TO YOU FOR ANY LOSS AND TAKES NO RESPONSIBILITY FOR, AND WILL NOT BE LIABLE TO YOU FOR, ANY USE OF THE SERVICES, INCLUDING BUT NOT LIMITED TO ANY LOSSES, DAMAGES OR CLAIMS ARISING FROM (I) USER ERROR SUCH AS FORGOTTEN PASSWORDS, INCORRECTLY CONSTRUCTED TRANSACTIONS, OR MISTYPED WALLET ADDRESSES; (II) SERVER FAILURE OR DATA LOSS; (III) BLOCKCHAIN NETWORKS, CRYPTOCURRENCY WALLETS OR CORRUPT FILES; (IV) UNAUTHORIZED ACCESS TO SERVICES OR (V) ANY THIRD PARTY ACTIVITIES, INCLUDING WITHOUT LIMITATION THE USE OF VIRUSES, PHISHING, BRUTEFORCING OR OTHER MEANS OF ATTACK. **8. LIMITATION OF LIABILITY.** EXCEPT FOR ACTS OF WILLFUL MISCONDUCT OR FRAUD, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, UNDER NO CIRCUMSTANCE AND REGARDLESS OF THE NATURE OF ANY CLAIM SHALL WE BE LIABLE UNDER THESE TERMS TO YOU FOR ANY CONSEQUENTIAL, INDIRECT, INCIDENTAL, SPECIAL, EXEMPLARY, PUNITIVE OR ENHANCED DAMAGES OR LOST PROFITS, INTEREST, ATTORNEYS’ FEES, COMPUTER FAILURE OR MALFUNCTION, DATA LOSS, LOSS OF GOODWILL, OR REVENUE ARISING OUT OF RELATING TO, OR IN CONNECTION WITH THESE TERMS. TO THE EXTENT OUR LIABILITY IS NOT ALREADY EXCLUDED BY THE FOREGOING SENTENCE, OUR AGGREGATE LIABILITY UNDER OR IN CONNECTION WITH THESE TERMS SHALL OTHERWISE BE LIMITED TO AN AMOUNT EQUAL TO ONE HUNDRED U.S. DOLLARS ($100). **9. INDEMNIFICATION** You shall and hereby agree to indemnify, defend and hold us and our representatives, officers, directors, employees, successors and assignees harmless from and against any losses suffered by us arising from (i) your breach of these Terms, (ii) a breach of your representations and warranties and/or covenants made hereunder, (iii) your use of the Services or Website in violation of these Terms, (iv) your infringement, misappropriation, or violation of the rights of any other person or entity, (v) any content, materials, or information (in any form or medium) that you submit, post, upload, provide, contribute, or make available (or authorize or instruct us to do so) through the Services or Website, and (vi) violation of any law or applicable regulation. If you are obligated to indemnify us, we have the right to control any action if we want and you cannot settle any action without our consent, unless the settlement is only for money damages which you entirely pay. ‍**10. MISCELLANEOUS** 10.1 **Governing Law.** These Terms shall be governed by and construed in accordance with the laws of Panama, without regard for choice of law provisions thereof. 10.2 **Severability**. If any provision of these Terms or the application thereof to any person or circumstance is held invalid or unenforceable to any extent, the remainder of these Terms and the application of that provision to other persons or circumstances is not affected thereby, and that provision will be enforced to the greatest extent permitted by applicable laws. 10.3 **Waiver**. No waiver of any right under these Terms will be of any effect or binding upon anyone unless such waiver is in writing and is signed by an authorized representative of the party so waiving such right. No delay or failure of any party in exercising any right hereunder and no partial or single exercise of any such right will be deemed of itself to constitute a waiver of such right or other rights hereunder. 10.4 **No Third-Party Beneficiaries**. The provisions hereof are solely for the benefit of the parties and are not intended to, and will not be construed to, confer a right or benefit on any other person. 10.5 **Assignment**. You shall not assign or transfer (whether by operation of law or otherwise) these Terms (or any rights or obligations hereunder) to a third party. 10.6 **Force Majeure**. No party will be held liable or responsible to any other party nor be deemed to have breached these Terms for failure or delay in fulfilling or performing any provision hereunder when such failure or delay results from causes beyond the reasonable control of the affected party, which may include embargoes, acts of war (whether declared or not), insurrections, riots, civil commotions, acts of terrorism, strikes, lockouts or other labor disturbances, pandemics, epidemics or acts of God (a “**Force Majeure Event**”). The affected party will notify the other parties of such Force Majeure Event as soon as reasonably practical and will make every reasonable effort to mitigate the effects of such Force Majeure Event. 10.7 **External Sites and Third-Party Content**. The Website may contain links to third-party websites or content (“**External Sites**”). Such External Sites are provided solely as a convenience to you and not as an endorsement by us of the content on such External Sites. The content of such External Sites is developed and provided by others. You should contact the site administrator or webmaster for those External Sites if you have any concerns regarding such links or any content located on such External Sites. We are not responsible for the content of any linked External Sites and do not make any representations regarding the content or accuracy of materials on such External Sites. You should take precautions when (i) interacting with such External Sites, or (ii) downloading files from all websites to protect your computer from viruses and other destructive programs. If you decide to access linked External Sites, you do so at your own risk. 10.8 **Exclusive Forum**. Any dispute, controversy or claim arising out of or relating to these Terms, or the breach, termination or invalidity thereof, shall be settled solely by binding, individual arbitration in accordance with the BVI IAC Arbitration Rules. The number of arbitrators shall be one. The place of arbitration shall be Road Town, Tortola, British Virgin Islands, unless the Parties agree otherwise. The language to be used in the arbitral proceedings shall be English. Prior to initiating arbitration, you and we must first attempt in good faith to resolve any such dispute, controversy or claim informally. Accordingly, neither you nor us may start a formal arbitration proceeding for at least sixty (60) days after one party notifies the other party of a claim in writing. 10.9 **Class Action Waiver**. Notwithstanding anything to the contrary contained herein, any arbitration pursuant to these Terms must be on an individual basis. As a result, you may not join or consolidate claims in an arbitration by or against any other person, or litigate in court or arbitrate any claims as a representative or member of a class or private attorney general action. 10.10 **Contact Information**. For any inquiries or questions, please contact # Privacy Policy Last Updated: May 29th, 2024 Smart Savings Foundation (“**Latch**,” “**we**,” “**us**,” and “**our**”) provides a set of user interfaces and staking services that allows users to connect to certain third party supported staking protocols. We respect your privacy and are strongly committed to keeping secure any information we obtain from you or about you. This Privacy Policy describes our practices with respect to personal data (“**Personal Data**”) that we collect from or about you when you use our applications and services (collectively, “**Services**”) or when you visit our website at [latch.io](http://latch.io) (the “**Website**”). This Privacy Policy does not apply to content that we process on behalf of customers of our business offerings. **1. A Summary of The Policy** **Personal Data we collect** – We collect most of the Personal Data related to you through the login processes to our Services and your engagement with our website. **The purposes of use of the Personal Data** – We collect Personal Data related to you for various business purposes as further detailed in ‘The purposes of use of your Personal Data’ section of this privacy policy. **How we share Personal Data with third parties** – We share information with our service providers as necessary to facilitate our business. We will share information when we change our corporate structure, and we will share the information with our affiliated entities. **Your Privacy Choices and Rights** You may opt-out of our mailing lists and terminate your use of our website. **Security of your information** - We implement technical and organizational measures to secure your Personal Data from loss, misuse, unauthorized access or disclosure, alteration or destruction. **Cross-border data transfer** – We use cloud-based services to store and process data in Amazon Web Services servers located in the United States and will store data at additional sites, at our discretion, in accordance with applicable laws. **Aggregated and analytics information** - Aggregated data is not identifiable. We use standard analytical tools for legitimate business purposes. **Specific provision for EEA, UK and Swiss residents** – If we process Personal Data related to you when you are in the European Economic Area (“**EEA**”), further terms apply to our processing in relation to your rights as a data subject under EEA data protection laws. **U.S. State Law Disclosures** – If you are a resident of certain U.S. states, you are entitled to specific privacy rights. **Children’s information** - The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect Personal Data from children. **Data retention and deletion** – We retain different types of Personal Data for different periods, depending on the purposes for processing the information, our legitimate business purposes as well as pursuant to legal requirements. **Changes to this privacy policy** – We will update this privacy policy from time to time after giving proper notice. Read more. Contact us – Please contact us at: **2. Personal Data We Collect** The categories of Personal Data we collect and process depend on how you interact with us, our Services and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below. **A. Information You Provide to Us Directly** We collect the following Personal Data that you provide to us. **Galxe Login ID**. When you login to our Services, we collect your Galxe account information, including your name, email address, Galxe ID, wallet addresses, Galxe Web3Score associated with your Galxe ID, as well as any related social media account information such as Twitter, Discord, Github, Telegram, etc.. **User Content**. When you use our Services, we collect Personal Data as part of the Services such as your transaction history, wallet addresses, staking information, gas fees and transaction fee information, and or feedback that you provide to us (“**Content**”). **Surveys**. We may contact you to participate in surveys from time to time. If you decide to participate, you may be asked to provide certain information which may include Personal Data. **Sweepstakes or Contests**. If we offer a sweepstake or contest, we will collect certain Personal Data such as your name and e-mail address if you participate in such sweepstake or contest. Note that in some jurisdictions, we are required to publicly share information of sweepstakes and contest winners. **Website visitors** When you contact us via the Website, for example to get a demo of our Services or to subscribe to our newsletter, or for any other reason, we will receive and process any Personal Data that you provide to us, such as your name, phone number and email address. In addition, we will collect any Personal Data that you will provide to us while communicating with us. * **Interactive Features**. We and others who use our Services may collect Personal Data that you submit or make available through our interactive features (e.g., collaboration tools, messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide on the public sections of these features will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. * **Business Development and Strategic Partnerships**. We collect Personal Data from individuals and third parties to assess and pursue potential business opportunities. **B. Information Collected Automatically** The following Personal Data is collected automatically when you use our Services and our Website, using cookies and similar tracking technologies (“**Technologies**”): Your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and internet service provider. We also collect information regarding your use of our Services and Website, such as pages that you visit before, during and after using our Services and Website, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services and Website. In addition, we collect information that other people provide about you when they use our Services, including information about you when they tag you. We use such cookies and similar tracking technologies to process the above mentioned Personal Data to make it easier for you to log-in and to facilitate the Website and Services activities, to analyze performance and marketing activities, and to personalize your experience. We also use standard analytics tools as described in the Section titled “Aggregated and analytics information” of this privacy policy. See Section 5 below to understand your choices regarding these Technologies. **C. Information Collected from Other Sources** We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings. **3. The Purposes of Use of The Personal Data** We use the Personal Data we collect for all of the following purposes: To provide you with our Services and Website, including: * To manage your information and accounts; * To provide access to certain areas, functionalities, and features of our Services and Website; * To provide customer or technical support; and * To communicate with you about your account, activities on our Services, and policy changes. * To pursue our legitimate interests such as direct marketing, research and development (including marketing research),network and information security, and fraud prevention; * To detect security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecute those responsible for that activity; * To measure interest and engagement in our Services and Website; * Short-term, transient use, such as contextual customization of ads; * To improve, upgrade or enhance our Services; * To develop new products and Services; * To ensure internal quality control and safety; * To authenticate and verify individual identities; * To debug, identify and repair errors within our Services; * To perform audits and other compliance activities; * To enforce our agreements and policies; and * To comply with our legal obligations. * Subject to your consent, if such is required under applicable law, to send you e-mails or other messages and/or newsletters about us or our Services, including through one of our service providers. At any time, you can unsubscribe from our mailing list by clicking on the unsubscribe link on the message. We will process, use, retain and share Personal Data solely for the purposes described in this privacy policy and only when reasonably necessary and proportionate to achieve such purposes for which such information was collected and processed. To the extent relevant and possible, we will make efforts to maintain Personal Data accurate, complete and up to date. **4. How We Share Personal Data With Third Parties** We disclose Personal Data related to you to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below. We only allow these third parties to use it as necessary to fulfill the purposes for collecting the Personal Data under this privacy policy and under strict conditions. **A. Sharing with third parties to provide our Services** The categories of third parties with whom we share Personal Data are described below. * **Service Providers**. To assist us in meeting business operations needs and to perform certain services and functions, we provide Personal Data to vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, email communication software, and web analytics services, among others. Pursuant to our instructions, these parties will access, process, or store Personal Data only in the course of performing their duties to us. * **Other Latch Users at Your Direction**. When you use the Services, including the Services’ interactive features, you may direct us to share certain information with other Latch users. This information can include Personal Data about yourself and details about your work and your use of the Services. * **Share Content with Friends or Colleagues**. Our Services offer various tools and functionalities. For example, from time to time we may allow you to share certain information about your use of the Services on social media such as Twitter. From time to time you may also provide information about your friends or colleagues through our referral services, which allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. * **Affiliates**. We share your Personal Data with our company affiliates, meaning an entity that controls, is controlled by, or is under common control with Latch, for our administrative purposes including activities such as IT management, for them to provide services to you, or to support and supplement the Services we provide. **B. Sharing with third parties to protect us or Others** We will disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. In addition, we will disclose or use users' Personal Data to defend or enforce our legal rights and in accordance with any applicable law. **C. Disclosure in the Event of Merger, Sale, or Other Structural Change** If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider (together, a “**Structural Change**”), Personal Data relating to you may be sold or transferred as part of the Structural Change, provided that the receiving entity will comply with this policy. **5. Your Privacy Choices And Rights** * Email Communications. At any time, you can opt-out of our mailing list by clicking the unsubscribe link found at the bottom of the email. Note that you will continue to receive transaction-related emails regarding Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms of Service or this Privacy Policy). * “Do Not Track.” Do Not Track (“**DNT**”) is a privacy preference that users can set in certain web browsers. Please note that our Services and website do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. * Cookies and Interest-Based Advertising. Cookies are small text files that can be used by websites to make a user's experience more efficient. Our website uses cookies.We use cookies to personalize content and ads, to provide social media features and to analyze our traffic. Our site uses different types of cookies. Some cookies are placed by third party services that appear on our pages. We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services. The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies we need your permission. You can at any time change or withdraw your consent on our website. Your consent applies to the following domains: [latch.io](http://latch.io). You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada. Please note you must separately opt out in each browser and on each device. **6. Security of Personal Data** We take steps to ensure that Personal Data is treated securely and in accordance with this Privacy Policy. We have put in place appropriate physical, technical and organizational controls to safeguard and secure Personal Data related to you from loss, misuse, unauthorized access or disclosure, alternation or destruction. These measures provide industry standard security. However, no system is 100% secure, and we cannot guarantee or warrant that the Services or our website will be immune from cyber-attacks, malicious activities, malfunctions, honest mistakes or other types of abuse and misuse. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure. **7. Cross-Border Data Transfers** We are a global company with headquarters in Singapore. We therefore transfer Personal Data outside of the country it was collected in or outside of the EEA to the United States. All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, Singapore, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard Personal Data relating to you consistent with the requirements of applicable laws. If our use of the Personal Data is governed by laws restricting the transfer of personal information to other countries that do not provide an adequate level of protection to the Personal Data, we will use appropriate safeguards, in particular, by way of entering into appropriate contractual agreements with the relevant recipients, or by adhering to equivalent data transfer regulations to protect the security and confidentiality of such personal information. When we transfer Personal Data outside the EEA, the United Kingdom (the “**UK**”), and Switzerland, we make use of the standard contractual data protection clauses, which have been approved by the European Commission, to safeguard the transfer of information we collect from the EEA, the UK, and Switzerland. **8. Aggregated and Analytics Information** We use standard analytics tools like Google Analytics to learn about how you and other users use our Website and Services, how we should improve your user experience and which improvements we should prioritize. In order to find out how Google uses data when you use their services you can visit: . We will use additional or other analytics tools, from time to time, in support of our Services-related activities and operations. The privacy practices of these tools are subject to their own privacy policies. We use anonymous, statistical or aggregated information and will share it with our partners for legitimate business purposes. It has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that we or others can associate specifically to you. **9. Specific provision for EEA, UK and Swiss residents** Under the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“**GDPR**”), we are considered a data controller with respect to the Services we provide to you. If you are a resident of a territory in the EEA, the UK, or Switzerland, we base our processing of Personal Data as a data controller on the following lawful grounds: * Performance of a contract with you when we provide and maintain our Services. When we process your account information, Content, and technical information solely to provide our Services to you, this information is necessary to be able to provide our Services. If you do not provide this information, we may not be able to provide our Services to you. * Our legitimate interests in protecting our Services from abuse, fraud, or security risks, or in developing, improving, or promoting our Services. This may include the processing of account information, Content, and Technical Information. * Your consent when we ask for your consent to process your Personal Data for a specific purpose that we communicate to you. You have the right to withdraw your consent at any time. * Compliance with our legal obligations when we use your Personal Data to comply with applicable law or when we protect our or our affiliates’, users’, or third parties’ rights, safety, and property. At any time, you can contact our privacy team at: and request to exercise your rights in accordance with the provisions provided bylaw: * You are entitled to access the Personal Data that we keep about you together with information about how and on what basis the Personal Data is being processed and to rectify when such information is inaccurate. If you find that the Personal Data related to you is not accurate, complete or updated, then please provide us the necessary information to correct it. * You can contact us if you want to withdraw your consent to the processing of Personal Data related to you. Exercising this right will not affect the lawfulness of processing based on consent before its withdrawal. * You are entitled to request to delete or restrict access to Personal Data related to you in limited circumstances as described under the GDPR, subject to certain exceptions. If we need to delete Personal Data related to you following your request, it can take time until we completely delete residual copies of Personal Data related to you from our active servers, from our backup systems, and from third parties (as described in section 4). If you exercise one (or more) of the above-mentioned rights, in accordance with the provisions under applicable law, you are entitled to request to be informed that third parties that hold Personal Data related to you, in accordance with this privacy policy, will act accordingly. * You are entitled to request the transfer of Personal Data related to you in accordance with your right to data portability. * You are entitled to object to the processing of Personal Data related to you, for example in relation to direct marketing. * You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you. * You have the right to obtain a copy of or access to safeguards under which Personal Data related to you is transferred outside of the EEA. * You have a right to lodge a complaint with a data protection supervisory authority. Note that when you send us a request to exercise your rights, we will need to reasonably authenticate your identity and location. We will ask you to provide us credentials to make sure that you are who you claim to be and will further ask you questions to understand the nature and scope of your request. We will look into your inquiry and make good-faith efforts to respond promptly. Where we process Personal Data as part of the Services, as a data processor of our users, we are committed to assist our data controllers to fulfill the above mentioned rights under the GDPR. If you have any concerns about the way we process Personal Data related to you, you are welcome to contact our privacy team at: . **10. U.S. State Law Disclosures** Several U.S. states have enacted privacy laws to grant new privacy rights to their residents. To the extent provided for by local law and subject to applicable exceptions, individuals may have privacy rights in relation to their Personal Data including the following: * Access their information * Correct their inaccurate information * Opt out if a business “sells” their information, uses or shares it for certain advertising purposes, or profiles them to make decisions with legal or similarly significant effects * Be notified about a business’s data practices * Nondiscrimination for exercising their privacy rights * Delete their personal information The following table provides additional information about the categories of Personal Data we collect and how we disclose that information. You can read more about the categories of Personal Data we collect in “Personal Data we collect” above, how we use Personal Data in “The purposes of use of the Personal Data” above, and how we retain Personal Data in “Data Retention and Deletion” below. | Category of Personal Data | Disclosure of Personal Data | | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------- | | Identifiers (e.g., name, alias, email address, unique personal identifier, online identifier, IP address, account name, or other similar identifiers) | We disclose this information to our affiliates, vendors and service providers, law enforcement, and parties involved in a Structural Change. | | Commercial information (e.g., information regarding products or services purchased, obtained, or considered) | We disclose this information to our affiliates, vendors and service providers, law enforcement, and parties involved In a Structural Change. | | Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding your interactions with our Services and Website) | We disclose this information to our affiliates, vendors and service providers. law enforcement, and parties Involved in a Structural Change. | | Geolocation Data | We disclose this information to our affiliates, vendors and service providers, law enforcement, and parties Involved in a Structural Change. | | Personal information described in Cal. Civ. Code §1798.80(e)(such as your name) | We disclose this Information to our affiliates, vendors and service providers, law enforcement, and parties Involved in a Structural Change. | We don’t “sell” Personal Data or “share” Personal Data for cross-contextual behavioral advertising (as those terms are defined under applicable local law). We also don’t process sensitive Personal Data for the purposes of inferring characteristics about a consumer. **Exercising Your Rights.** To the extent applicable under local law, you can exercise privacy rights described in this section by submitting a request to: **Verification.** In order to protect your Personal Data from unauthorized access, change, or deletion, we may require you to verify your credentials before you can submit a request to know, correct, or delete Personal Data. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Data and proof of residency for verification. If we cannot verify your identity, we will not be able to honor your request. **Authorized Agents.** You may also submit a rights request through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity and submit proof of your residency with us. Authorized agent requests can be submitted to . **Appeals.** Depending on where you live, you may have the right to appeal a decision we make relating to requests to exercise your rights under applicable local law. To appeal a decision, please send your request to **Additional Privacy Rights for California Residents** California Shine the Light. California Civil Code Section 1798.83 permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Data (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Data disclosed to those parties. **11. Children’s Information** The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect Personal Data from children. If you learn that your child has provided us with Personal Data without your consent, you may contact us as set forth below. If we learn that we have collected a child’s Personal Data in violation of applicable law, we will promptly take steps to delete such information. **12. Data Retention And Deletion** We retain different types of Personal Data for different periods, depending on the purposes for processing such information, our legitimate business purposes as well as pursuant to legal requirements under the applicable laws. We will maintain your contact details, to help us stay in contact with you. At any time before or after the termination of the Services, you can contact our privacy team at: , and request to delete your contact details. Note that we may retain your details without using them unless necessary and for the necessary period of time, for legal requirements and proceedings, and that we will not retain the Personal Data related to you for any longer than reasonably necessary for purposes described in this privacy policy. We will keep aggregated non-identifiable information without limitation, and to the extent reasonable we will delete or de-identify potentially identifiable Personal Data, when we no longer need to process the information. In any case, as long as you use the Services, we will keep information about you, unless applicable law requires us to delete it. **13. Changes to This Privacy Policy** From time to time, we will need to update this privacy policy. If the updates have minor, if any, consequences, they will take effect 7 days after we post a notice on the Services’ platform and/or our website, or after we send you the notice through email or through the Services. Substantial changes will be effective 30 days after we initially posted our notice. Changes to this privacy policy are effective as of the stated “last updated” date. Continuing to use the Services or our website after the new privacy policy takes effect means that you agree to the new privacy policy. Note that if we need to adapt the privacy policy to legal requirements, the new privacy policy will become effective immediately or as required. **14. Contact Us** If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at: