Privacy Policy

Emotion Insights Corporation (“Emotion Insights,” “we,” “us,” or “our”), the issuer of the Synchtwin token, respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect personal information when you visit www.synchtwin.com, join our Early Adopter Queue, receive communications from us, or otherwise interact with our websites and related services.

Emotion Insights Corporation is a Delaware corporation located in the United States.

1. Scope of This Policy

This Privacy Policy applies to personal information collected through:

• Our websites and online forms;
• The Early Adopter Queue;
• Genesis Raise and potential token presale communications;
• Emails and other communications with us; and
• Related online services that link to this Privacy Policy.

This Policy does not govern the practices of third-party websites, wallet providers, exchanges, payment processors, social media platforms, or other services that we do not control.

2. Information We Collect

Information You Provide

When you join the Early Adopter Queue or contact us, we may collect:

• Your name;
• Your email address;
• Your country or jurisdiction, if requested;
• Your communication preferences;
• Information included in messages you send us; and
• Any other information you voluntarily provide.

Joining the Early Adopter Queue does not require you to purchase tokens and does not create a contract, investment commitment, or guarantee of eligibility.

Information Collected Automatically

When you use our website, we and our service providers may automatically collect limited technical information, such as:

• Internet Protocol address;
• Browser and device type;
• Operating system;
• Approximate location derived from your IP address;
• Pages viewed and actions taken;
• Referring website;
• Date and time of access; and
• Cookie, analytics, and similar technology data.

We may use cookies and similar technologies to operate the website, maintain security, understand site usage, and improve the user experience.

3. How We Use Personal Information

We may use personal information to:

• Register and manage your place in the Early Adopter Queue;
• Send updates about the potential Genesis Raise or token presale;
• Provide information about timing, availability, eligibility, pricing, token bonuses, and participation procedures;
• Respond to questions and requests;
• Confirm and manage communication preferences;
• Maintain and improve our websites and services;
• Detect fraud, misuse, security threats, or technical problems;
• Comply with legal, regulatory, tax, sanctions, or law-enforcement requirements;
• Establish, exercise, or defend legal claims; and
• Support a corporate transaction, such as a financing, merger, acquisition, restructuring, or sale of assets.

We will not use your information to enroll you automatically in a token purchase or to create a purchase obligation.

4. Genesis Raise and Eligibility

Joining the Early Adopter Queue only registers your interest in a potential future offering.

Your queue position may be considered when determining access to early-adopter pricing, token bonuses, or other benefits. However, participation may be subject to:

• Availability;
• Final offering terms;
• Identity or eligibility verification;
• Applicable securities, financial, sanctions, anti-money-laundering, and tax laws;
• Geographic restrictions; and
• Other legal or compliance requirements.

We may later request additional information if you choose to participate in a token sale. Any additional collection will be described in an updated notice or separate transaction-specific privacy notice.

5. Legal Bases for Processing

Where applicable law requires us to identify a legal basis, we process personal information on one or more of the following grounds:

• Consent: You consent to receiving Genesis Raise and related communications.
• Legitimate interests: We have a legitimate interest in managing expressions of interest, operating our website, preventing fraud, securing our systems, and communicating with potential participants.
• Contractual necessity: Processing may become necessary to take steps at your request before entering into a transaction.
• Legal obligation: We may process information to comply with applicable laws and regulatory requirements.

You may withdraw consent to marketing communications at any time by using the unsubscribe link in an email or contacting us. Withdrawal does not affect processing that occurred before consent was withdrawn.

6. How We Disclose Personal Information

We may disclose personal information to:

Service Providers

Vendors that help us operate our website and communications, including providers of:

• Website hosting;
• Cloud storage;
• Email delivery;
• Customer relationship management;
• Analytics;
• Cybersecurity;
• Legal, accounting, and compliance services; and
• Technical support.

These providers may process information only as necessary to perform services for us and subject to appropriate contractual obligations.

Professional and Compliance Advisers

We may disclose information to attorneys, accountants, auditors, consultants, financial institutions, token-administration providers, or compliance vendors when reasonably necessary.

Legal and Safety Purposes

We may disclose information when we believe disclosure is necessary to:

• Comply with law, regulation, legal process, or government request;
• Enforce our terms or protect our legal rights;
• Prevent fraud, security incidents, or unlawful activity; or
• Protect the rights, property, or safety of Emotion Insights, our users, or others.

Business Transactions

Information may be disclosed or transferred in connection with a merger, financing, acquisition, restructuring, bankruptcy, sale of assets, or similar corporate transaction.

7. No Sale of Personal Information

Emotion Insights does not sell your name or email address for money.

We also do not use information submitted through the Early Adopter Queue for unrelated third-party advertising.

Certain privacy laws define “sale” or “sharing” broadly and may treat some advertising or analytics technologies as a sale or sharing even when no money changes hands. If we introduce technologies that trigger such requirements, we will provide any notices and opt-out mechanisms required by law.

8. Marketing Communications

By affirmatively joining the Early Adopter Queue, you request communications concerning the Genesis Raise and related participation opportunities.

You may unsubscribe at any time by:

• Clicking the unsubscribe link in an email; or
• Contacting us at privacy@emotioninsights.com

We may still send non-promotional messages reasonably necessary to respond to your request, confirm an unsubscribe request, provide security notices, or communicate about an existing transaction.

Email marketing consent should be freely given, specific, informed, and capable of being withdrawn. The signup checkbox should therefore remain unchecked by default, and each marketing email should include a functional unsubscribe option.

9. Cookies and Analytics

We may use:

• Essential cookies required for site functionality and security;
• Preference cookies that remember your settings;
• Analytics tools that help us understand website use; and
• Similar technologies used to measure communication effectiveness.

Where required, we will request consent before placing non-essential cookies.

You may be able to manage cookies through your browser settings or a cookie-management tool made available on our website. Blocking cookies may affect website functionality.

10. International Data Transfers

Emotion Insights is based in the United States. If you access our services from outside the United States, your information may be transferred to, stored in, and processed in the United States and other countries where our service providers operate.

Those countries may have privacy laws that differ from the laws of your country.

Where required, we will use appropriate safeguards for international transfers, such as contractual protections, recognized transfer mechanisms, or other legally permitted safeguards. We will not claim participation in the EU-U.S. Data Privacy Framework unless Emotion Insights has completed the required certification.

11. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, including to:

• Maintain the Early Adopter Queue;
• Send requested communications;
• Document consent and communication preferences;
• Meet legal, tax, accounting, and compliance obligations;
• Resolve disputes; and
• Enforce agreements.

Unless a longer period is legally required or reasonably necessary, we expect to retain Early Adopter Queue signup information until the earlier of:

1. 24 months after the Genesis Raise concludes or is abandoned;
2. Your verified deletion request; or
3. The point at which the information is no longer reasonably needed.

We may retain limited suppression-list information, such as your email address and unsubscribe status, to ensure that we honor your communication preference.

12. Your Privacy Rights

Depending on where you live, you may have the right to:

• Request access to personal information we hold about you;
• Ask us to correct inaccurate information;
• Request deletion of your information;
• Restrict or object to certain processing;
• Withdraw consent;
• Request a portable copy of certain information;
• Opt out of certain sales, sharing, targeted advertising, or profiling;
• Appeal our response to a privacy request; and
• Lodge a complaint with a privacy or data-protection authority.

Individuals covered by the GDPR may have rights of access, correction, deletion, restriction, portability, objection, and protections relating to certain automated decisions.

California residents may have rights to know, delete, and correct personal information, opt out of qualifying sales or sharing, limit certain uses of sensitive information, and receive equal treatment for exercising their rights, where the CCPA applies.

To exercise a privacy right, contact:

Email: privacy@emotioninsights.com
Subject Line: Privacy Request

Please include your name, email address, country or state of residence, and the nature of your request. We may take reasonable steps to verify your identity before completing a request.

Authorized agents may submit requests where permitted by law. We may require evidence of authorization and may ask you to verify your identity directly.

We will respond within the period required by applicable law. GDPR-covered requests generally must be addressed without undue delay and ordinarily within one month.

13. Automated Decision-Making

We do not currently use information submitted through the Early Adopter Queue to make decisions based solely on automated processing that produce legal or similarly significant effects.

Queue position, jurisdiction, legal eligibility, and availability may be considered in determining whether a person receives an opportunity to participate. Any final eligibility determination may also require human review and additional compliance information.

14. Data Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information from unauthorized access, loss, misuse, alteration, or disclosure.

However, no internet transmission or electronic storage method is completely secure, and we cannot guarantee absolute security.

We seek to collect only information reasonably necessary for the stated purpose, restrict access appropriately, and dispose of information when it is no longer needed. These practices are consistent with current FTC data-security guidance.

15. Children and Minors

The Early Adopter Queue and any potential token offering are intended only for adults who have reached the age of legal majority in their jurisdiction.

Our services are not directed to children under 13, and we do not knowingly collect personal information from children under 13.

We may impose a higher minimum age, such as 18 or 21, for participation in any future offering. Joining the queue does not establish that a person satisfies the age or eligibility requirements for a token purchase.

If you believe a child has provided information to us, contact us at privacy@emotioninsights.com.

16. Third-Party Links and Services

Our website may link to third-party websites or services. Those third parties have their own privacy practices, and we are not responsible for their policies or conduct.

You should review the privacy notice of any third-party service before providing information to it.

17. Changes to This Privacy Policy

We may update this Privacy Policy periodically.

When we make changes, we will revise the “Last Updated” date. If changes materially affect how we use previously collected information, we will provide additional notice or obtain consent where required by law.

18. Contact Us

Questions, requests, or concerns about this Privacy Policy may be directed to:

Emotion Insights Corporation
312 W 2nd St Unit #A1616
Casper, WY 82601
United States

Email: privacy@emotioninsights.com

Website: www.synchtwin.com or www.emotioninsights.com

You may also have the right to submit a complaint to the data-protection authority in the country where you live or work.