Effective Date: 08/08/2025

StoneBit Ltd., a company incorporated under the laws of the British Virgin Islands (“Pebbles,” “we,” “our,” or “us”), is committed to protecting the privacy of individuals who access and use our services. This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information when you use the Pebbles application, website, and any associated services (collectively, the “Services”).

By accessing or using our Services, you consent to the collection and use of your information in accordance with this Privacy Policy. If you do not agree with the practices described herein, you should not use the Services.

1. Information We Collect

a. Information You Provide to Us:

• Profile information (e.g., usernames, avatars, bios)

• Email address used for social login

• Communications with support

b. Information We Automatically Collect:

• Public blockchain data associated with your connected wallet (e.g., wallet address, transaction history)

• Technical data (e.g., IP address, browser type, operating system, device type)

• Usage data (e.g., access times, feature usage, page interactions)

c. Third-Party Sources:

• On/off-ramp data (e.g., KYC status, transaction metadata) from providers like Meld

• Analytics tools to understand user behavior and improve the Services

We do not collect private keys or seed phrases. Pebbles is a self-custodial platform.

2. How We Use Your Information

We use the collected information to:

• Provide, maintain, and improve the Services

• Facilitate peer-to-peer transactions and tipping

• Support account login and user identification

• Analyze user interactions and platform engagement

• Detect, investigate, and prevent fraud and other illegal activities

• Comply with legal obligations

• Communicate with users and provide support

3. Legal Basis for Processing (EEA/UK Users)

If you are located in the European Economic Area or the United Kingdom, we rely on the following legal bases:

• Your consent

• Performance of a contract

• Compliance with a legal obligation

• Legitimate interests, such as fraud prevention and service improvement

4. Sharing of Information

We may share your information with:

• Third-party service providers such as:

  • AWS (cloud infrastructure)

  • Firebase (authentication and database services)

  • Cloudflare (security and content delivery)

  • MongoDB Atlas (data storage)

• Law enforcement or regulatory authorities if required by applicable law

• Affiliates and successors in the event of a business transfer

We do not sell personal data to third parties.

5. International Transfers

The Services are operated from and governed by the laws of the British Virgin Islands. By using the Services, you understand that your information may be transferred to and processed in jurisdictions outside your own, including but not limited to Southeast Asia, North America, and Europe, which may not offer the same level of data protection as your jurisdiction. We take appropriate measures to safeguard your data in accordance with applicable laws.

6. Your Rights

Depending on your location, you may have the following rights:

a. European Union and United Kingdom (GDPR):

• Right to access your data

• Right to correct inaccurate data

• Right to delete your data (right to be forgotten)

• Right to data portability

• Right to object or restrict certain processing

b. Singapore and Malaysia (PDPA):

• Right to access and correct personal data

• Right to withdraw consent for data use

c. Canada (PIPEDA):

• Right to access and amend personal data

• Right to know how personal data is used and shared

Users may request corrections to their personal data through in-app functionality where applicable.

To exercise your rights, please contact us at official@pebbles.cash. We may require you to verify your identity before processing your request.

7. Data Retention

We retain information as long as reasonably necessary for the purposes described in this policy, including for legal, accounting, or reporting requirements. Wallet addresses and transaction records may be retained to comply with regulatory obligations.

8. Security

We implement reasonable safeguards to protect the information we collect, including the use of AWS, Cloudflare, and Firebase for secure infrastructure. However, no security measure is completely foolproof. You are responsible for safeguarding access to your wallet.

9. Children’s Privacy

The Services are not directed to children under the age of 13 (or equivalent minimum age in relevant jurisdictions), and we do not knowingly collect personal data from children.

10. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you through the Services or by other means. Your continued use of the Services constitutes your acceptance of the revised Privacy Policy.

11. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us at:

📧 official@pebbles.cash

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