Frostsnap Privacy Policy

Privacy is of utmost importance to us at Stay Frosty Pty Ltd. (hereafter "Frostsnap," "Company," "we," or "our"), particularly due to the high importance of privacy in relation to Bitcoin products.

Frostsnap is committed to protecting your privacy, as well as complying with the Privacy Act 1988 (Cth) (Privacy Act) and other applicable privacy laws and regulations.

This Privacy Policy (Policy) describes how we collect, hold, use and disclose your personal information, and how we maintain the quality and security of your personal information.

Personal Information

“Personal information” refers to any information or opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable. In general terms, this includes information or an opinion that personally identifies you either directly (e.g. your name) or indirectly.

Personal Information We May Collect

The personal information we collect about you depends on the nature of your dealings with us. Some examples of personal information we may collect include: your name, mailing address, email address, phone number.

We may also collect information relating to bitcoin transactions for the purposes of order payments if paid in bitcoin. By using our products, our services may interact with blockchain data servers hosted by us, but we will provide you with the ability to connect to your own server (an Electrum server).

You do not have to provide us with your personal information. Where possible, we will give you the option to interact with us anonymously or by using a pseudonym. However, if you choose to deal with us in this way or choose not to provide us with your personal information, such as through use of a disposable email address, we may not be able to provide you with our services or otherwise interact with you.

How Do We Collect Your Personal Information?

We collect your personal information directly when you: make purchases with us, interact with us online, participate in surveys, attend one of our events, apply for employment with us, or attend an event held by us. In many of these scenarios we may facilitate the ability to interact with us anonymously or pseudonymously where it makes sense to do so.

Collecting Personal Information from Third Parties

We may also collect your personal information from third parties or through publicly available sources, for example: from a business partner who expresses your interest in learning about us or our products or services.

How Do We Use Your Personal Information?

We use personal information for many purposes in connection with our products and services, including the following purposes: management of orders, customer support, product development, internal administrative processes, marketing and research purposes. We analyze use of the products and services to research and improve the services, and to develop new products, including by studying customer demographics and usage of services.

When using your personal information for research and product development, we will make use of deidentified, anonymized, or aggregated data where it makes sense for us to do so.

Disclosure of Personal Information to Third Parties

We may disclose your personal information to third parties in accordance with this Policy in circumstances where you would reasonably expect us to disclose your information. For example, we may disclose your personal information to service providers who assist us in the facilitation of: payment processing, order fulfillment, customer support, or for our own marketing systems.

These third parties may use your personal information only as authorized by us, in a manner consistent with this Privacy Policy, and are explicitly prohibited from using or disclosing your information for any other purpose.

To comply with law, it may be required that we use your personal information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities. In these situations we may elect to notify you of these requests if legally permissible and on the basis that it makes sense for us to do so.

Transfer of Personal Information Overseas

Some of the third-party service providers we disclose personal information to may be based in or have servers located outside of Australia, including in Malaysia where we primarily manage order fulfillment.

Where We Disclose Your Personal Information to Third Parties Overseas

We will take reasonable steps to ensure that data security and appropriate privacy practices are maintained. We will only disclose to overseas third parties if you have given us your consent to disclose personal information to that third-party, including for the facilitation of our services as described in this policy. We will only disclose your information if we reasonably believe that the overseas recipient is subject to a law or binding scheme that is, overall, substantially similar to the APPs; the law or binding scheme can be enforced; or the disclosure is required or authorised by an Australian law or court or tribunal order.

How Do We Protect Your Personal Information?

Frostsnap will take reasonable steps to ensure that the personal information that we hold about you is kept confidential and secure, including by: having established security practices on electronic data security, having a robust physical security of our premises and databases, measures to restrict access to only personnel who need that information to effectively provide services to you, in-house systems that limit the extent of required personal information sharing.

Online Activity

Cookies

Frostsnap may from time to time make use of cookies, a small file of letters and numbers the website puts on your device if you allow it. These cookies may recognise when your device has completed a form, or visited our website(s) before, so we can distinguish you from other users of the website. This improves your experience and the Frostsnap website(s).

We do not use cookies to identify you, just to improve your experience on our website(s). If you do not wish to use the cookies, you can amend the settings on your internet browser so it will not automatically download cookies. However, if you remove or block cookies on your computer, please be aware that your browsing experience and our website’s functionality may be affected.

Analytic Services

Our website may use analytic services to help us better understand visitor traffic, so we can improve our services. Although this data is mostly anonymous, it is possible that under certain circumstances, we may connect it to you.

Direct Marketing

We may send you direct marketing communications and information about our services, opportunities, or events that we consider may be of interest to you if you have requested or consented to receive such communications.

These communications may be sent via email, in accordance with applicable marketing laws, such as the Australian Spam Act 2003 (Cth). You may opt-out of receiving marketing communications from us at any time by following the instructions to “unsubscribe' on any of our marketing emails, or by contacting us using the details set out in the “How to contact us” section below.

Retention of Personal Information

We will not keep your personal information for longer than we need to. In most cases, this means that we will only retain your personal information for the duration of your relationship with us unless we are required to retain your personal information to comply with applicable laws, for example record-keeping obligations. We will transition your personal information offline once we no longer have reasonable purpose to store it on an internet connected device.

How to Access and Correct Your Personal Information

Frostsnap will endeavour to keep your personal information accurate, complete and up to date. If you wish to make a request to access or correct the personal information we hold about you, you should make a request by contacting us and we will usually respond within 10 business days.

Links To Third-Party Sites

Frostsnap website(s) may contain links to websites operated by third parties. If you access a third-party website through our website(s), personal information may be collected by that third-party website. We make no representations or warranties in relation to the privacy practices of any third-party provider or website and we are not responsible for the privacy policies or the content of any third-party provider or website. Third party providers / websites are responsible for informing you about their own privacy practices and we encourage you to read their privacy policies.

Company Transfers

We may transfer or otherwise share some or all of our business or assets, which may include your personal information, in connection with a business transaction (or potential business transaction) such as a corporate merger, acquisition, consolidation, reorganization or sale of assets, or in the event of bankruptcy.

Inquiries and Complaints

For queries or complaints regarding how Frostsnap handles, processes or manages your personal information, please contact us. We strive to provide our customers with comfort when interacting with our services.

It will not always be possible to resolve a complaint to everyone’s satisfaction. If you are not satisfied with our response to a complaint, you have the right to contact the Office of Australian Information Commissioner (at www.oaic.gov.au/) to lodge a complaint.

How to Contact Us

If you have a question or concern in relation to our handling of your personal information or this Policy, you can email us at contact@frostsnap.com

Version 1.0 Effective Date: May 4, 2025