Privacy Notice

1. Introduction

This Privacy Notice ("Notice") is issued by Titan Network, an exempted company with limited liability incorporated in the Cayman Islands ("Titan," "we," "us," or "our"), and explains how we collect, use, store, share, and protect personal data when you download, install, access, or use the Titan application software (including the Titan Desktop Application, the Titan Browser Extension, and the Titan Agent), the Titan Platform, related dashboards, wallets, and web interfaces, and any other associated services (collectively, the "Services").

Titan Network may operate through, or in conjunction with, its affiliates and related entities. References to "Titan," "we," "us," or "our" in this Notice refer to Titan Network as the data controller responsible for your personal data in connection with the Services, and where the context permits, its affiliates and related entities.

This Notice is issued in accordance with the Data Protection Act (As Revised) of the Cayman Islands (the "DPA") and its associated regulations and guidance. Where the Services are used by individuals located in jurisdictions with additional or more stringent data protection requirements (including, without limitation, the European Union General Data Protection Regulation ("GDPR"), the UK General Data Protection Regulation ("UK GDPR"), or other comparable frameworks), we endeavour to comply with the applicable requirements of those frameworks to the extent reasonably practicable.

By using the Services, you acknowledge that you have read and understood this Notice. By installing, launching, or otherwise running the Application in any form on any device, you expressly consent to the collection and processing of your personal data as described in this Notice, including device data, resource contribution data, and network telemetry. This consent is deemed granted in full upon the first installation or launch of the Application and remains in effect for the duration of the Application's presence on your device. If you do not agree with the practices described in this Notice, please do not use the Services.

2. Data Controller

For the purposes of the DPA and other applicable data protection laws, the data controller responsible for your personal data is:

If you have any questions about how we process your personal data or wish to exercise your rights under applicable data protection laws, please contact us at the details set out above or as described in Section 13 below.

3. Personal Data We Collect

We may collect and process the following categories of personal data about you:

3.1 Information You Provide to Us

• Account registration data: email address, username, and password or authentication credentials.
• Wallet information: public cryptocurrency wallet addresses (e.g., Solana, Titan Chain, or compatible wallets) that you link to your Account for receiving Rewards.
• Communications: information you provide when you contact our support team, participate in surveys, submit bug reports, or communicate with us via email, Discord, Telegram, or other channels.
• Identity verification data: where required by applicable law or where Titan elects to implement risk-based KYC and sanctions-screening procedures, we may collect identity documents, proof of address, or other verification information.
• Referral data: information about users you invite to the Platform through referral or invitation programmes.

3.2 Information Collected Automatically

• Device information: device type, model, operating system, browser type and version, unique device identifiers, hardware specifications (CPU, GPU, RAM, storage capacity), and virtualisation capabilities.
• Network and connectivity data: IP address, geolocation data (at the country and region level), internet service provider information, network configuration, port status (e.g., UPnP status), and bandwidth metrics.
• Resource contribution data: bandwidth usage, storage allocation and usage, compute cycles contributed, node uptime, task execution metrics, Resource Contribution Value (RCV), and related performance data.
• Application usage data: login events, session duration, feature interactions, crash reports, error logs, and diagnostic data.
• Blockchain and transaction data: on-chain transaction records, token balances, staking activity, reward history, and wallet activity associated with your Account. Note that blockchain transactions are inherently public and immutable.
• Cookies and similar technologies: we use cookies, local storage, and similar tracking technologies on our website and Platform to collect usage analytics, remember user preferences, and improve our Services. See Section 10 for details.

3.3 Information from Third Parties

• Blockchain networks: publicly available transaction data from the Titan Chain, Solana, and other supported blockchain networks.
• Analytics providers: aggregated and anonymised analytics data from third-party analytics services.
• Referral sources: information from users who refer you to the Services.

4. Purposes of Processing and Legal Bases

We process your personal data for the following purposes, relying on the legal bases set out below:

5. Data Sharing and Disclosure

We may share your personal data with the following categories of recipients:

5.1 Affiliates

We may share personal data with our affiliates and related entities for the purposes described in this Notice, including operational support, network management, and compliance activities (including sanctions screening).

5.2 Service Providers

We engage third-party service providers to perform functions on our behalf, including hosting, cloud infrastructure, analytics, customer support, identity verification (KYC/sanctions screening), and email delivery. These service providers are contractually required to process personal data only on our instructions and in accordance with applicable data protection laws.

5.3 Blockchain Networks

Certain data, including public wallet addresses and transaction records, is inherently recorded on public blockchain networks (including the Titan Chain and Solana). Once data is recorded on a public blockchain, it becomes publicly available and immutable. Titan cannot control access to or deletion of data on public blockchains.

5.4 Enterprise Clients

In the ordinary course of operating the Titan Network, we may share aggregated, anonymised, or pseudonymised data about resource availability, network performance, and service quality metrics with enterprise Clients who consume resources from the Network. We do not share your personal data (such as your name, email address, or precise location) with enterprise Clients without your explicit consent, except as required by law.

5.5 Legal, Regulatory, and Sanctions Disclosures

We may disclose your personal data where we reasonably believe disclosure is necessary to: (i) comply with applicable law, regulation, legal process, or governmental request; (ii) comply with applicable sanctions regimes; (iii) enforce our Terms of Use or our rights under any agreement; (iv) detect, investigate, or prevent fraud, security breaches, or illegal activity; or (v) protect the rights, property, or safety of Titan, its users, or the public.

5.6 Business Transfers

In the event of a merger, acquisition, reorganisation, bankruptcy, dissolution, or similar transaction affecting Titan, your personal data may be transferred to the acquiring entity or successor. We will use reasonable efforts to ensure that any such transferee agrees to honour this Notice.

5.7 With Your Consent

We may share your personal data with third parties where you have provided your express consent to such sharing.

6. International Data Transfers

The Titan Network is a globally distributed decentralised network operating across 100+ countries. By using the Services, you acknowledge and consent to the transfer of your personal data to recipients located in jurisdictions outside the Cayman Islands, including jurisdictions that may not provide the same level of data protection as your home jurisdiction.

Where personal data is transferred to jurisdictions outside the Cayman Islands, we take reasonable steps to ensure that appropriate safeguards are in place, including: (i) entering into data processing agreements incorporating standard contractual clauses or equivalent transfer mechanisms approved by relevant data protection authorities; (ii) ensuring that recipients are subject to data protection laws providing an adequate level of protection; or (iii) relying on other lawful transfer mechanisms permitted under applicable law.

You further acknowledge that the decentralised and distributed nature of the Titan Network means that device metadata, resource contribution data, and network telemetry may be processed by Titan Harbor nodes and infrastructure located in various jurisdictions globally. While Titan implements technical and organisational measures to protect data in transit and at rest, the inherent nature of decentralised infrastructure means that not all data processing can be confined to a single jurisdiction.

7. Data Retention

We retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, as described in this Notice, unless a longer retention period is required or permitted by law. The specific retention periods we apply are as follows:

• Account data: retained for the duration of your Account and for a period of three (3) years after Account closure or last activity, to comply with legal, regulatory, and audit requirements.
• Device and resource contribution data: retained in identifiable form for the duration of your active participation in the Network, and in aggregated or anonymised form thereafter for analytical and statistical purposes.
• Transaction and blockchain data: data recorded on public blockchains is immutable and cannot be deleted. Off-chain transaction records are retained for five (5) years from the date of the relevant transaction.
• Communications and support data: retained for two (2) years from the date of the most recent communication.
• Identity verification and sanctions screening data: retained for the period required by applicable law and our internal compliance policies, which is typically five to seven (5–7) years from the date of the relevant verification or the termination of the relationship.
• Cookies and analytics data: retained for the periods described in Section 10.

When personal data is no longer required, we will securely delete or anonymise it in accordance with our data retention policies and applicable law.

8. Data Security

We implement appropriate technical and organisational measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include, without limitation:

• Encryption of personal data in transit (TLS/SSL) and at rest.
• Access controls limiting access to personal data to authorised personnel on a need-to-know basis.
• Regular security assessments, vulnerability testing, and code audits.
• Use of virtualisation and containerisation technologies (including VMs, Docker, WASM sandboxes, and QEMU-KVM) to isolate user device resources from third-party workloads.
• Network security measures including firewalls, intrusion detection, and monitoring.
• Incident response procedures for identifying, reporting, and remediating data breaches.

While we use commercially reasonable efforts to protect your personal data, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee the absolute security of your personal data, and any transmission of personal data is at your own risk. You are responsible for maintaining the security of your Account credentials, private keys, and wallet seed phrases.

9. Your Rights

Subject to applicable law (including the DPA and, where applicable, the GDPR or UK GDPR), you may have the following rights in relation to your personal data:

• Right of access: You have the right to request confirmation as to whether we are processing your personal data and, if so, to request access to and a copy of the personal data we hold about you.
• Right to rectification: You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
• Right to erasure ("right to be forgotten"): You have the right to request that we delete your personal data in certain circumstances, such as where it is no longer necessary for the purposes for which it was collected. Please note that we may be unable to delete data recorded on public blockchains, as such data is immutable.
• Right to restriction of processing: You have the right to request that we restrict the processing of your personal data in certain circumstances.
• Right to data portability: Where processing is based on consent or a contract and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.
• Right to object: You have the right to object to processing of your personal data where the processing is based on our legitimate interests. We will cease processing unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms.
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
• Right to lodge a complaint: You have the right to lodge a complaint with the Ombudsman of the Cayman Islands or with the data protection authority in your jurisdiction of residence.

To exercise any of these rights, please contact us at the details set out in Section 13. We will respond to your request within the timeframe required by applicable law (generally within 30 days). We may request reasonable identification information to verify your identity before processing your request.

10. Cookies and Tracking Technologies

Our website and Platform use cookies and similar technologies (including local storage, web beacons, and pixel tags) to collect information about your browsing behaviour and preferences. The types of cookies we use include:

• Strictly necessary cookies: essential for the operation of our website and Platform. They enable core functionality such as security, session management, and authentication. These cookies cannot be disabled.
• Performance and analytics cookies: collect information about how you interact with our website, including pages visited, links clicked, and error messages encountered. We use this information to improve the performance and usability of our Services. We may use third-party analytics providers such as Google Analytics for this purpose.
• Functional cookies: enable enhanced functionality and personalisation, such as remembering your language preferences or display settings.

We do not use advertising or behavioural targeting cookies on our website or Platform.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Services.

11. Children's Privacy

The Services are not directed at, and are not intended for use by, individuals under the age of eighteen (18) or the age of legal majority in their jurisdiction, whichever is greater. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child without appropriate parental or guardian consent, we will take steps to delete such data promptly. If you believe that we may have collected personal data from a child, please contact us at the details set out in Section 13.

12. Changes to this Notice

We may update this Notice from time to time to reflect changes in our practices, the Services, or applicable law. When we make material changes to this Notice, we will notify you by posting the updated Notice on the Platform and/or within the Application, and by updating the "Last Updated" date at the top of this Notice. Where required by applicable law, we will obtain your consent to material changes. We encourage you to review this Notice periodically. Your continued use of the Services after any changes constitutes your acceptance of the updated Notice.

13. Contact Us

If you have any questions, comments, or concerns about this Notice, our data practices, or if you wish to exercise your rights under applicable data protection law, please contact us at:

If you are located in the European Economic Area or the United Kingdom and have concerns about our processing of your personal data that we are unable to resolve, you also have the right to lodge a complaint with the supervisory authority in the EU Member State or UK country where you reside, where you work, or where the alleged infringement took place.

For residents of the Cayman Islands, complaints may also be directed to the Ombudsman of the Cayman Islands.

14. Supplemental Terms for Specific Jurisdictions

To the extent that specific data protection laws of your jurisdiction impose additional or different requirements, the following supplemental terms shall apply and, in the event of any conflict, shall prevail over the general terms of this Notice:

14.1 European Economic Area and United Kingdom

If you are located in the EEA or the UK, the GDPR or UK GDPR (as applicable) applies to our processing of your personal data. The legal bases for processing are as set out in Section 4 above. Where processing is based on legitimate interests, our legitimate interest is the operation, maintenance, and improvement of the Titan Network and the prevention of fraud and misuse. You have the right to object to processing based on legitimate interests at any time. For international transfers from the EEA or UK, we rely on standard contractual clauses approved by the European Commission or the UK Information Commissioner's Office (as applicable), or other appropriate safeguards under Chapter V of the GDPR.

14.2 Cayman Islands

If you are located in the Cayman Islands, the DPA applies to our processing of your personal data. We process personal data in accordance with the principles set out in the DPA, including processing personal data fairly, lawfully, and in a transparent manner; collecting personal data for specified, explicit, and legitimate purposes; and ensuring that personal data is adequate, relevant, and not excessive in relation to the purposes for which it is processed.

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