qBitTensor Labs

PRIVACY POLICY

Last Updated: April 2, 2026

Effective Date: April 2, 2026

qBitTensor Labs LLC ("qBitTensor Labs," "Company," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, store, and safeguard your personal information when you access or use our products, services, platforms, applications, tools, APIs, software, websites, and related offerings (collectively, the "Services"), including but not limited to the Enigma competition platform ("Enigma").

By accessing or using the Services, you agree to the practices described in this Privacy Policy and our Terms of Use (available at ). If you do not agree, please do not use the Services.

1. Information We Collect

We collect the following categories of information to provide, secure, and improve our Services:

1.1 Information You Provide

Account Information: Name, email address, username, password or authentication credentials, organization or affiliation, job title, and country of residence.

Billing Information: Organization name, billing address, tax identifiers, and billing contact details (e.g., name, email, phone number).

Payment Information: Payment method type (e.g., card brand, last four digits), transaction history (e.g., amount, date, purchase type), and billing contact information. We do not store full payment card numbers; payment processing is handled by PCI-compliant third-party processors.

Cryptocurrency Wallet Information: Wallet addresses, transaction hashes, and related blockchain identifiers you provide for prize claims or other purposes in connection with Enigma or the Bittensor network.

Communications: Support requests, helpdesk tickets, emails, chat messages, survey responses, and marketing preferences (e.g., opt-in/opt-out choices).

Customer Data and Submissions: Any data, content, files, code, or information you upload, submit, store, or process through the Services, including code submissions to Enigma challenges. Please note that all code and materials submitted to Enigma are assigned to qBitTensor Labs pursuant to our Terms of Use and the Enigma Rules.

1.2 Information We Collect Automatically

Technical Data: Device type, operating system, browser type, screen resolution, hardware specifications, IP address, language preferences, time zone, diagnostic logs, and crash reports.

Usage Data: Feature utilization, pages visited, click patterns, session duration, API calls, performance metrics, referral URLs, interaction data, and Enigma competition activity (e.g., submission timestamps, validation results).

Cookies and Tracking Technologies: We use cookies, web beacons, pixels, and similar technologies for: (a) essential functionality (login, session management); (b) analytics and performance monitoring; (c) preference storage; and (d) marketing and advertising (with your consent where required). You can manage cookie preferences through your browser settings or our cookie preference tools where available.

Blockchain Data: Publicly available information from the Bittensor network and other blockchains related to your interactions with the Services, including transaction records, wallet activity, and subnet participation data.

1.3 Information from Third Parties

We may receive information about you from third-party sources, including identity verification services, analytics providers, marketing partners, public databases, blockchain explorers, social media platforms (if you choose to connect), and business partners. We may combine this information with other data we collect.

2. How We Use Your Information

We use the information we collect for the following purposes:

Providing Services: To operate, deliver, maintain, and improve the Services (including Enigma), including account management, authentication, challenge validation, prize distribution, and customer support.

Billing and Payments: To process transactions, manage subscriptions, distribute prizes, and handle billing inquiries.

Security: To detect, prevent, and respond to fraud, abuse, cheating, security incidents, and technical issues.

Communications: To send service-related notices, respond to your inquiries, and provide updates about the Services.

Marketing: To send promotional materials and newsletters, subject to your marketing preferences and applicable law. You may opt out at any time.

Research and Development: To analyze usage patterns, conduct research, and develop new features, products, and services.

Competition Integrity: To validate submissions, detect cheating or rule violations, resolve disputes, and maintain the fairness and integrity of Enigma competitions.

Legal Compliance: To comply with applicable laws, regulations, legal processes, and governmental requests, including tax reporting and sanctions compliance.

Aggregated Data: To create aggregated, anonymized, or de-identified data sets for analytics, benchmarking, and other lawful purposes. Such data is no longer personal information.

2.1 Legal Basis for Processing (EEA/UK Users)

If you are located in the European Economic Area (EEA), the United Kingdom, or another jurisdiction that requires a legal basis for processing personal information, we rely on the following bases:

Contractual Necessity: Processing necessary to provide the Services you requested.

Consent: Where you have given explicit consent, such as for marketing communications or non-essential cookies. You may withdraw consent at any time.

Legal Obligations: Processing necessary to comply with applicable laws and regulations.

Legitimate Interests: Processing necessary for our legitimate business interests (e.g., security, fraud prevention, competition integrity, service improvement), provided your rights are not overridden.

3. How We Share Your Information

We may share your information in the following circumstances:

Service Providers: With third-party vendors who perform services on our behalf, including hosting, analytics, payment processing, customer support, email delivery, and security. These providers are contractually required to protect your information and may only use it for the purposes we specify.

Blockchain Networks: Certain information (such as wallet addresses and transaction data) may be recorded on the Bittensor network or other blockchains. Blockchain transactions are publicly visible and immutable. qBitTensor Labs cannot control, modify, or delete information once recorded on a blockchain.

Legal Compliance: When required by law, regulation, subpoena, court order, or governmental request, or when we believe disclosure is necessary to protect the rights, safety, or property of qBitTensor Labs, our users, or others.

Business Transfers: In connection with a merger, acquisition, reorganization, bankruptcy, asset sale, or similar transaction, your information may be transferred to the acquiring entity. We will provide notice of any such transfer.

With Your Consent: When you direct us to share information with a third party or provide explicit consent.

Aggregated/De-Identified Data: We may share aggregated or de-identified data that cannot reasonably be used to identify you.

We do not sell your personal information to third parties. We may share aggregated and/or anonymized data from which all personal identifiers have been removed.

4. Your Privacy Rights

Depending on your location, you may have the following rights under applicable data protection laws:

Access: Request a copy of the personal information we hold about you.

Correction: Request correction of inaccurate or incomplete personal information.

Deletion: Request deletion of your personal information, subject to legal or operational exceptions. Please note that information recorded on a blockchain cannot be deleted by qBitTensor Labs.

Restriction: Request that we limit the processing of your personal information in certain circumstances.

Portability: Request your personal information in a structured, commonly used, machine-readable format.

Objection: Object to processing of your personal information based on our legitimate interests.

Opt-Out of Marketing: Unsubscribe from marketing communications at any time via the unsubscribe link in emails or by contacting us.

Cookie Preferences: Manage or disable cookies through your browser settings or our cookie preference tools.

4.1 U.S. State Privacy Rights

Residents of certain U.S. states (including California, Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, and others with applicable privacy laws) may have additional rights, such as: the right to know what personal information is collected and how it is used; the right to opt out of targeted advertising, “sale,” or “sharing” of personal information; the right to non-discrimination for exercising privacy rights; and the right to appeal a denial of a privacy request. To exercise these rights, contact us using the information in Section 10.

4.2 Exercising Your Rights

To exercise any of these rights, please contact us at the email address provided in Section 10. We will respond to verified requests within the timeframe required by applicable law. We may require identity verification before processing your request.

5. Data Retention

We retain personal information only as long as reasonably necessary to fulfill the purposes for which it was collected, provide the Services, comply with legal obligations, resolve disputes, enforce agreements, and protect our legitimate interests. When we no longer need personal information, we will securely delete or anonymize it. Specific retention periods depend on the nature of the data, the purpose of processing, and applicable legal requirements. Please note that: (a) data recorded on blockchain networks is immutable and cannot be deleted by qBitTensor Labs; and (b) all code and materials submitted to Enigma are assigned to and owned by qBitTensor Labs pursuant to our Terms of Use and the Enigma Rules, and will be retained indefinitely as qBitTensor Labs’ property.

6. Security

We implement reasonable technical, administrative, and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption, access controls, monitoring, incident response procedures, and regular security assessments. However, no method of transmission over the Internet or method of electronic storage is 100% secure, and we cannot guarantee absolute security. You are responsible for maintaining the security of your account credentials and cryptocurrency wallet private keys.

7. International Data Transfers

Your personal information may be transferred to, stored in, and processed in the United States or other countries that may have different data protection laws than your country of residence. By using the Services, you acknowledge and consent to such transfers. Where required by applicable law, we use appropriate safeguards for cross-border transfers, such as Standard Contractual Clauses approved by the European Commission, or other lawful transfer mechanisms.

8. Children’s Privacy

The Services are not intended for children under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child, we will take steps to delete that information promptly. If you believe we have collected information from a child, please contact us immediately.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the Services, or applicable law. For material changes, we will provide notice by email, through the Services, or by posting a prominent notice on www.qbittensorlabs.com. Your continued use of the Services after the effective date of any updated Privacy Policy constitutes your acceptance of the changes. We encourage you to review this Privacy Policy periodically.

10. Contact Us

For questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

qBitTensor Labs LLC

Website:

Email: bob@quantumrings.com

For data protection inquiries from EEA/UK residents, please include “Data Protection Request” in the subject line of your communication.

11. Additional Disclosures

11.1 Do Not Track

Some browsers transmit “Do Not Track” (DNT) signals. Because there is no industry-standard interpretation of DNT signals, we do not currently respond to them. We will update this Privacy Policy if we adopt a standard for responding to DNT signals in the future.

11.2 Third-Party Links and Services

The Services may contain links to third-party websites, applications, or services, including blockchain explorers, the Bittensor network, and other decentralized platforms. This Privacy Policy does not apply to those third parties. We encourage you to review the privacy policies of any third-party services you access. We are not responsible for the privacy practices of third parties.

11.3 Blockchain Transparency

Blockchain networks are inherently transparent. Transactions on the Bittensor network and other blockchains are publicly visible and permanently recorded. qBitTensor Labs does not control the blockchain and cannot delete, modify, or restrict access to on-chain data. You should be aware that your wallet addresses and transaction history may be publicly viewable.

11.4 Automated Decision-Making

We may use automated tools and algorithms to process information in connection with the Services, including automated validation of Enigma competition submissions. Where automated decision-making produces legal effects or similarly significant effects on you, you may have the right to request human review, express your point of view, and contest the decision, subject to applicable law and the Enigma Rules.