Last Updated: April 20, 2026

PRIVACY POLICY

This Privacy Policy applies to the processing of personal information by The Arbitrum Foundation (“Arbitrum Foundation,” “we,” “us,” or “our”) including on our website available at https://alt.gov.arbitrum.foundation and our other online or offline offerings that link to, or are otherwise subject to, this Privacy Policy (collectively, the “Services”).

UPDATES TO THIS PRIVACY POLICY
PERSONAL INFORMATION WE COLLECT
HOW WE USE PERSONAL INFORMATION
HOW WE SHARE PERSONAL INFORMATION
YOUR PRIVACY CHOICES AND RIGHTS
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
RETENTION OF PERSONAL INFORMATION
SUPPLEMENTAL NOTICE FOR EU/UK GDPR
CHILDREN’S PERSONAL INFORMATION
CONTACT US

1. UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Policy on our website, and we may also send other communications.

2. PERSONAL INFORMATION WE COLLECT

We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.

(a) Personal Information You Provide to Us Directly

We may collect personal information that you provide to us.

Wallet Information. In order to use the Services, you will need to connect your digital wallet (a “Wallet”). We and our service providers may collect personal information and details associated with your transactions such as wallet addresses, asset types, and transaction history in connection with the Services. Note that your interactions with third-party wallet services are subject to each Wallet provider’s respective privacy policy, not this Privacy Policy.
Your Communications with Us. We, and our service providers, may collect the information you communicate to us, such as through email.
Interactive Features. We and others who use our Services may collect personal information and voting information that you submit or make available through our interactive features (e.g., messaging features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered “public.”
Governance and Profile Information. We may collect personal information you provide in connection with governance participation, such as delegate profiles, Security Council member or candidate information, biographies, statements, affiliations, and other information submitted through forms or profile features of the Services.

(b) Personal Information Collected Automatically

We may collect personal information automatically when you use the Services.

Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, Internet service provider, and location information (including, as applicable, an approximate location derived from the IP address and precise geo-location information).
Usage Information. We may collect personal information about your use of the Services, such as the pages that you visit, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use the Services.
Cookie Notice (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect personal information through your use of the Services.
- Cookies. Cookies are small text files stored in device browsers.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in emails to understand whether messages have been opened, acted on, or forwarded.
See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

(c) Personal Information Collected from Third Parties

Third-Party Services. We may collect personal information about you from third parties. For example, if you access the Services using a third-party website, application, service, products, or technology (each a “Third-Party Service”), we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings.
Blockchain Information. We may collect personal information that is publicly available on the blockchain.

3. HOW WE USE PERSONAL INFORMATION

We use personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below.

(a) Provide the Services

We use personal information to provide the Services, such as:

Providing access to certain areas, functionalities, and features of the Services;
Communicating with you;
Answering requests;
Sharing personal information with third parties as needed to provide the Services; and
Processing your transaction information.

(b) Improve the Services and Develop New Products and Services

We use personal information to improve the Services and to develop new products and services, such as:

Improving, upgrading, or enhancing the Services.

(c) Operate Our Business

We use personal information to operate our business, such as:

Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
Carrying out analytics;
Creating de-identified and/or aggregated information;
Allowing you to register for events;
Enforcing our agreements and policies; and
Carrying out activities that are required to comply with our legal obligations.

(d) Marketing

We may use personal information in connection with our marketing activities including to tailor and to provide you with marketing communications, promotions, and offers that may interest you.

Some of the ways we market to you include email campaigns and custom audiences advertising.

(e) With Your Consent or Direction

We may use personal information: (i) for other purposes that are clearly disclosed to you at the time you provide the personal information, (ii) with your consent, or (iii) as otherwise directed by you.

We share personal information with third parties for a variety of business purposes, including to provide the Services, to protect us or others, or in connection with a major business transaction such as a merger, sale, or asset transfer, as described below.

(a) Disclosures to Provide the Services

We may share any of the personal information we collect with the categories of third parties described below.

Disclosures to the Blockchain. Aspects of the Services may be hosted on or interact with the blockchain. Where you use aspects of the Services that are hosted on or interact with the blockchain, information about your interactions and/or transactions will be shared with the applicable blockchain network and may be accessible to third parties due to the nature of the blockchain protocol.
Service Providers. We may share personal information with service providers that assist us with the provision of the Services. This may include, but is not limited to, service providers that provide us with hosting services, customer service, AI or machine learning services, analytics, marketing services, IT support, and related services. These Service Providers are generally processors acting on our instructions to the extent we are acting as data controller. Additionally, a Service Provider may use your personal data where it is necessary for compliance with a legal obligation to which it is directly subject. The Service Provider, in respect of this specific use of personal data acts as a data controller.
Other Users You Share or Interact With. The Services may allow users to share personal information or interact with other users of the Services.
Third-Party Services You Share or Interact With. The Services may link to or allow you to interface with, interact with, share information with, direct us to share information with, access, and/or use a Third-Party Service.

Any personal information shared with a Third-Party Service will be subject to the Third-Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.

Business Partners. We may share your personal information with business partners we work with to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.

Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners.

Affiliates. We may share your personal information with our corporate affiliates.
Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies on our Services to collect personal information regarding your activities and your device (e.g., IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this personal information (and similar information collected from other services) to tailor and deliver personalized ads to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising,” “personalized advertising,” or “targeted advertising.”

(b) Disclosures to Protect Us or Others

We may share your personal information and related information with external parties if we, in good faith, believe doing so is required or appropriate to comply with law enforcement requests, national security requests, or other government requests; comply with legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual unauthorized or illegal activity.

(c) Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be shared, sold, or transferred as part of such a transaction.

5. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are described below.

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will not be able to opt out of certain communications (e.g., communications regarding the Services or updates to 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 we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies. 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, the Services may not work properly.
The online advertising industry also provides mechanisms that may allow you to opt out of receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative, the Digital Advertising Alliance, and the European Digital Advertising Alliance.
Please note you must separately opt out in each browser and on each device.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

Request Access to or Portability of Your Personal Information;
Request Correction of Your Personal Information;
Request Deletion of Your Personal Information;
Request Restriction of or Object to Our Processing of Your Personal Information; and
Withdraw Your Consent to Our Processing of Your Personal Information. Please note that your withdrawal will take effect only for future processing and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below.

We will process such requests in accordance with applicable laws.

If your personal information is subject to the applicable data protection laws of the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe that our processing of your personal information violates applicable law.

6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. These countries may or may not have adequate data protection laws as defined by the data protection authority in your country.

If we transfer personal information from the European Economic Area, Switzerland, and/or the United Kingdom to a country that does not provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

7. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Policy for as long as you use the Services, or as long as necessary to fulfill the purpose(s) for which it was collected, or as long as necessary to pursue our business purposes.

To determine the appropriate retention period for personal information, we may consider applicable legal requirements; the amount, nature, and sensitivity of the personal information; certain risk factors; the purposes for which we process your personal information; and whether we can achieve those purposes through other means.

This Supplemental Notice for EU/UK GDPR applies only to our processing of personal information that is subject to the EU or UK General Data Protection Regulation.

In some cases, providing personal information may be a requirement under applicable law, a contractual requirement, or a requirement necessary to enter into a contract. If you choose not to provide personal information in cases where it is required, we will inform you of the consequences at the time of your refusal to provide the personal information.

Arbitrum Foundation’s processing of your personal information may be supported by one or more of the following lawful bases:

Privacy Policy Section	Lawful Basis: Performance of a Contract (i.e., to provide the Services to you)	Lawful Basis: Legitimate Interest	Lawful Basis: Consent	Lawful Basis: For Compliance with Legal Obligations
Section 3A: Provide the Services	✔	✔	✔	✔
Section 3B: Improve the Services and Develop New Products	✔	✔	✔	✔
Section 3C: Operate Our Business	✔	✔	✔	✔
Section 3D: Marketing		✔	✔
Section 3E: With Your Consent or Direction	✔	✔	✔

9. CHILDREN’S PERSONAL INFORMATION

The Services are not directed to children under 18 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe that your child has uploaded personal information to the Services in violation of applicable law, you may contact us as described in “Contact Us” below.

10. 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: info@arbitrum.foundation.