borglife.ai — privacy notice

> TL;DR (human-readable, not legally binding)

• The default Borglife path does not pass through us. Talisman → public RPC → chain. No name, no email, no identity documents, no identity verification, and often no involvement by us at all. We are a controller only for data we actually handle (see §1).
• What we collect. Only what you voluntarily give us — email if you write to us or claim a founding-50 slot; basic web logs (IP, user-agent) when you visit the site; wallet addresses when you interact with our infrastructure; whatever you put into a Borg, a Bounty, or a message.
• What we never collect. Seed phrases (ever, by anyone, period). Private keys. Government-issued identity documents. Biometric data. Payment-card or bank-account data. Behavioural ad-targeting data.
• We minimise on purpose. Less data means less for us to protect, less to leak, and less that can be compelled. This is a design choice.
• Blockchain is public and forever. Wallet addresses, transactions, Borg lineage, badges — all on-chain, all permanent. We can't delete what's on-chain. That's the technology, not a choice.
• Your rights. Access, rectification, erasure (off-chain only), restriction, objection, portability, complaint to the FDPIC. See §9.
• Where your data goes. An EU-based infrastructure provider that hosts what we run; our professional advisors when strictly necessary; public authorities only when required by law. We do not sell or share with advertisers. See §6.
• International transfers. Where practicable, processors sit in Switzerland or the EEA. If any sit outside, we use Swiss-FDPIC- and EU-recognised safeguards (SCCs, adequacy decisions, DPF) — see §7.
• We are never a custodian. Your keys, your assets, your control. We don't hold or move your funds.
• Contact. info@borglife.ai for any data-protection question.

> 01 Scope & controller

This Privacy Notice describes how Swiss Choice GmbH, a Swiss limited liability company with its registered seat at Feusisberg (Höfe district, Canton Schwyz, Switzerland) ("Swiss Choice", "we", "our", "us"), processes personal data in connection with the borglife.ai website, the borglife plugin, the off-chain Borglife infrastructure (matching, indexing, oracle/verifier services), and our communications with you (collectively, the "Service").

This Notice forms part of, and is to be read together with, the Borglife Terms & Conditions. Defined terms used here have the meaning given to them in the Terms unless otherwise stated.

We are the data controller only for personal data that we actually collect, store, or otherwise handle, as described in this Notice and where we determine the purposes and means of that processing. Where another controller is identified (see §13 for the controller / processor allocation between us and Sponsors), that allocation prevails. Where we do not collect or store personal data about you — for example, where you interact with the Borglife protocol via Talisman and a public RPC endpoint without using a touchpoint we operate — there is no controller relationship between you and us in respect of that interaction. Our data-protection contact is info@borglife.ai.

This Notice applies to processing governed by the Swiss Federal Act on Data Protection (FADP) and, where applicable, the EU General Data Protection Regulation (GDPR) in respect of EEA-resident data subjects to whom we direct the Service.

GDPR Article 27 — operational assessment. Where GDPR applies to our processing of personal data of EEA-resident data subjects, we have assessed the Article 27(2)(a) exemption as currently applicable, on the following operational grounds (each tied to the data-minimization architecture described in this Notice and in §16 of the Terms): (i) participation in the on-chain Borglife protocol requires only a self-custodial wallet connection, not personal data, and most user interaction does not pass through our off-chain infrastructure at all (see §1 above and §13.3); (ii) the processing of EEA-resident personal data through our own infrastructure is currently narrow, opt-in, and low-volume (voluntarily emailing us, joining a mailing list, requesting the whitepaper, contacting support, or visiting borglife.ai), within the EDPB's notion of "occasional" processing under Guidelines 3/2018; (iii) special-category data is an absolute exclusion under §2.1; and (iv) the resulting processing is unlikely to result in a risk to the rights and freedoms of natural persons, both because of (i)-(iii) and because data subjects can unsubscribe or request deletion at any time, after which we retain nothing about them beyond the narrow retention windows in §8.

We will actively monitor whether EEA-directed processing through our infrastructure remains within the Article 27(2)(a) scope. If EEA-directed processing becomes regular or systematic in the EDPB sense — for example, through sustained, non-trivial EEA-targeted website / frontend / indexer / oracle / plugin processing or through the materialisation of risks to data subjects above the low-risk threshold — we will, before continuing such processing (other than during a short good-faith transition period), either (a) appoint an Article 27 representative, or (b) restrict EEA-facing access at the off-chain access layer to keep processing within the structural exemption. In either case, this Notice will be updated under §17.

> 02 Categories of personal data we process

2.1 What we never collect

The following are absolute exclusions: we do not request them, we do not retain them, and we do not use them. If you nonetheless transmit any such category to us (for example, by attaching it to an email), we will delete or reject it without further use as soon as we identify it; brief incidental receipt during inbox triage does not constitute use or retention. We will not change this exclusion without amending this Notice and notifying you under §17.

• Your seed phrase or private keys. We will never ask for these. If anyone claiming to represent Borglife asks for them, they are attempting fraud.
• Government-issued identity documents (e.g., passports, identity cards, driving licences, residence permits), identity-verification photographs, or any document intended to verify your legal identity.
• Payment-card data, bank-account information, or other fiat-payment instruments. We do not handle fiat payments.
• Biometric data, including biometric identifiers and biometric templates.
• Special-category personal data within the meaning of FADP Art. 5 lit. c / GDPR Art. 9 — including health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric data processed for identification, and data concerning sex life or sexual orientation.

2.2 What we do not require (you may voluntarily provide)

For participation in the on-chain Borglife protocol, we require only a wallet connection. We do not require — and from your wallet alone we cannot derive — any of the following. You may, however, voluntarily provide them in a separate, optional interaction (for example, by emailing us, joining the mailing list, requesting the whitepaper, or contacting support):

• Your name or any other identifying personal name;
• Your residential or mailing address;
• Your email address;
• Your phone number.

From a wallet address alone, we cannot in the ordinary course identify you personally. Wallet pseudonymity is, however, not anonymity — please see §5.

2.3 What we may process when you interact with the Service or voluntarily provide data

The categories below are processed by us only at specific, opt-in touchpoints. Where you do not engage with a given touchpoint, the corresponding category is not processed by us at all and we are not a controller of any data about you in that respect.

• Contact data — email address (only when you write to us, claim a founding-50 slot, request the whitepaper, or join a mailing list); name and other contact details only if you voluntarily provide them.
• Wallet and on-chain identifiers — wallet addresses, transaction hashes, Borg token IDs, lineage and badge identifiers — but only where you connect a wallet to a frontend we operate or call an indexer, RPC, oracle, or relayer we operate. If you interact with the Borglife protocol via Talisman and a public RPC endpoint without going through our infrastructure, we do not see your wallet at all.
• Technical data — IP address, user-agent string, referrer, request timestamps, basic device/browser information, language preference — only when your client makes a request to a server, API, or indexer we operate (e.g., a visit to borglife.ai). If you do not visit our site or call our APIs, we receive no technical data.
• Eligibility, sanctions, and jurisdictional screening — performed in real time at the access layer from IP address, wallet address, and your acceptance representations, only as needed to allow or block access to a touchpoint we operate. The screen covers (a) sanctions screening against UN, EU, OFAC, Swiss SECO, and UK lists; (b) U.S.-person / U.S.-jurisdiction screening to evidence the Reg S exclusion, implemented via IP geolocation, wallet-address heuristics where applicable, and your own click-wrap representation at acceptance (timestamp, wallet signature, Terms version, U.S.-Person acknowledgement); (c) sanctioned-jurisdiction screening (e.g., comprehensive-sanctions territories) by IP geolocation and self-declaration; and (d) age-eligibility (18+) by self-declaration at acceptance. We retain only the minimum record necessary to evidence that the check was performed (see §8); we do not maintain a standalone database of screened users beyond that.
• Communication content — only the content of emails, Discord messages, GitHub issues, or other communications you choose to send to or via channels we operate.
• Bounty / matching data — Bounty descriptions, submissions, criteria, mating-intent fields, and related metadata — only where you choose to use a matching, indexing, or relayer service we operate. Where Bounty discovery and settlement happen peer-to-peer (e.g., via libp2p) or on-chain without our infrastructure, we have no visibility of that data.
• Borg configuration metadata — only where you upload Borg configuration to off-chain infrastructure we operate (e.g., a hosted SOUL/IDENTITY backup, an indexer cache). By default, Borg configuration lives on your own device or on-chain, not on our servers, and we have no copy.
• ProP eligibility and allocation metadata — contribution records (e.g., bounty completions, infrastructure-service metrics, developer contributions), oracle attestations, Merkle commitments, and related operational proofs used to compute Proof-of-Participation allocations under §6.4 of the Terms — only where we operate the relevant ProP infrastructure (oracle, indexer, or ProP operator role).
• Plugin telemetry — only where the borglife plugin is configured to report errors, version, or basic operational metrics back to us. We will identify if and when such telemetry is collected and provide an opt-out; with telemetry off, we receive nothing from your plugin.
• Support & account data — only where you contact support, open a ticket, or otherwise interact with us as part of a support flow.

> 03 Sources of personal data

Where we process personal data, the sources are:

• Voluntarily from you — when you choose to email us, claim a founding-50 slot, request the whitepaper, join the mailing list, contact support, or otherwise provide data to us. None of this is required for participation in the on-chain Borglife protocol (see §2.2).
• Automatically through your interactions with our touchpoints — basic technical data (IP, user-agent, request timestamps) when your client makes a request to a server, API, or indexer we operate; equivalent telemetry from the borglife plugin where applicable. If you do not interact with a touchpoint we operate, we receive nothing automatically.
• From the public blockchain — wallet addresses, transactions, and on-chain artefacts are observable on-chain by anyone (us included). We may index, cache, or display them where we operate the relevant indexer or frontend; we do not proactively monitor on-chain activity beyond what our infrastructure requires.
• From third parties — sanctions-list providers, fraud-prevention services, and similar service providers, only at the moment of a real-time eligibility check; rarely, from public sources or other participants.

The default Borglife user path does not pass through our off-chain infrastructure. If you operate Talisman, sign transactions locally, broadcast via a public RPC endpoint, and never interact with a frontend, indexer, oracle, relayer, or communication channel we operate, we do not collect or store personal data about you through our own infrastructure. (Our design of the Borglife protocol may still engage controller-style responsibilities under data-protection law for the schema-level design choices that determine what data is recorded on-chain — see §1.)

> 04 Purposes & legal bases

Where we process personal data, we do so for the following purposes, on the following legal bases under FADP Art. 31 and GDPR Art. 6.

The table shows, for each purpose, the categories of data that may be used if and to the extent we actually hold them. Most categories are collected only when you voluntarily provide them (see §2); where we do not hold a category, the corresponding processing does not occur.

Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal. Where processing is based on legitimate interests, you have the right to object on grounds relating to your particular situation (see §9).

> 05 Blockchain data & the right to erasure

Public blockchains such as Polkadot and Asset Hub are by design distributed, public, pseudonymous, and effectively immutable. Once a transaction is confirmed, neither we nor any other single party can delete or rewrite it. Wallet addresses, transaction history, Borg lineage, badges, and Bounty interactions are part of the chain's permanent record.

This has practical consequences for your data-protection rights:

• Where personal data is recorded on-chain (typically a wallet address linked to your activity), the right to erasure (FADP Art. 32(1) / GDPR Art. 17) and the right to rectification (FADP Art. 32(1) / GDPR Art. 16) cannot be effected against the chain itself.
• We will, however, honour erasure and rectification of any off-chain personal data we hold about you (e.g., email, support tickets, indexer caches, telemetry), subject to legal-retention exceptions.
• Where we cache or index on-chain data on our servers, we will remove the cached copy on request, but the underlying on-chain record will remain on the public chain.
• Pseudonymity is not anonymity. A wallet address can in many cases be linked to a person through external information; you should treat on-chain activity as effectively public.

By choosing to use a public blockchain, you accept these structural limits on data-protection rights as against the chain itself. This is a property of the technology, not a choice we make.

> 06 Recipients & sub-processors

To the extent we share personal data, we share it only with parties that have a need to receive it and that are bound by adequate contractual and technical safeguards. The current scope of recipients is deliberately narrow:

• An EU-based infrastructure / hosting provider — for the operation of borglife.ai and any backend infrastructure operated by us. The provider acts as our processor under GDPR Art. 28 / FADP Art. 9 with appropriate contractual safeguards. They do not have logical access to application-layer data; their processing is limited to the infrastructure operations inherent in providing hosting (including the handling of network traffic and IP addresses contained therein).
• Professional advisors — lawyers, accountants, auditors — only where strictly necessary, and only when they receive personal data in their capacity as independent controllers (subject to professional confidentiality and applicable data-protection law).
• Public authorities — only where required by law (court order, regulatory request, sanctions enforcement, tax authority demand).
• Successors — in the event of a corporate transaction (merger, acquisition, asset sale, restructuring), where the recipient is bound by equivalent or stricter data-protection obligations.

Communication platforms you choose to contact us through (e.g., Discord, GitHub) are not our sub-processors; they are independent controllers governed by their own privacy notices for the relationship between you and that platform. Off-chain matching, indexing, oracle, verifier, relayer, and ProP operator / allocation roles are operated by us directly during the bootstrap phase and are not third-party recipients.

Any new category of recipient (for example, a dedicated email-delivery provider, a third-party sanctions-screening API, or analytics tooling) will be added to this list by amendment to this Notice before deployment, in line with §17.

We do not sell personal data, and we do not share personal data with advertisers or data brokers.

> 07 International transfers

Switzerland and the EEA benefit from mutual adequacy. Where practicable, we prefer recipients and sub-processors located within Switzerland or the EEA.

If and when a recipient or sub-processor is located in a country that does not benefit from a Swiss FDPIC adequacy decision or a European Commission adequacy decision, we rely on appropriate safeguards including, as relevant:

• The European Commission's Standard Contractual Clauses (SCCs) (Decision 2021/914) and, where applicable, the Swiss FDPIC SCCs;
• The EU-US Data Privacy Framework and the Swiss-US Data Privacy Framework, where the receiving organisation is certified;
• Supplementary technical and organisational measures (such as encryption in transit and at rest, pseudonymisation, and access controls) on top of the contractual safeguards;
• Your explicit consent, where strictly necessary and where no other safeguard is available.

You may request a copy of the relevant safeguards by contacting us at info@borglife.ai, subject to redactions necessary to protect commercial confidentiality and the rights of others.

> 08 Retention

Where we hold personal data, we retain it only as long as necessary for the purposes for which it was collected and any subsequent compatible purposes, plus any retention period required by law.

The periods below apply only to data we actually hold. If we never received a category from you, no retention applies for it.

Indicative periods:

• Email correspondence — typically up to 3 years from last interaction, unless retention is required for legal claims or compliance;
• Mailing-list contacts — until you unsubscribe, plus a short period to honour the unsubscribe and to evidence consent;
• Web logs (IP, user-agent) — typically up to 90 days for security and abuse mitigation, longer where required for incident investigation;
• Transient screening logs (the moment-of-access sanctions/jurisdictional/age check) — the minimum record (timestamp, outcome, version of the screening rules) needed to evidence that the real-time check was performed; typically up to 12 months;
• Acceptance and eligibility-evidence records (the click-through proof — timestamp, wallet address and signature, Terms / License / Privacy Notice version, U.S.-Person and other eligibility acknowledgments) — retained for the duration of your use of the Service plus a reasonable period to defend regulatory and contract-formation challenges; typically up to 10 years, aligned with the limitation period for contract claims under Swiss CO Art. 127;
• Indexer / matching caches — for the operational lifetime of the cache; deleted on rotation;
• Plugin telemetry / error reports — typically up to 12 months;
• ProP allocation records (contribution records, oracle attestations, Merkle commitments, allocation computations, audit trails relevant to a participant's ProP entitlement) — retained for the operational lifetime of the relevant ProP epoch plus the dispute / audit window applicable to that epoch, and thereafter as required to defend disputes, audits, or legal claims (typically aligned with Swiss CO Art. 127 limitation periods);
• Legal-claim evidence — for the duration of any actual or reasonably anticipated dispute and the relevant limitation periods (Swiss CO Art. 127 — 10 years; Art. 128 — 5 years for specific claims).
• On-chain data — permanent, as a property of the blockchain (see §5).

When the retention period ends, we delete or anonymise the data, unless legal obligations require continued retention.

> 09 Your rights as a data subject

Subject to applicable law, you have the following rights in respect of personal data we process about you:

• Right of access (FADP Art. 25 / GDPR Art. 15) — to obtain confirmation of whether we process your personal data and, if so, a copy and the related information.
• Right to rectification (FADP Art. 32(1) / GDPR Art. 16) — to have inaccurate or incomplete data corrected (subject to the on-chain limits in §5).
• Right to erasure (FADP Art. 32(2)(c) / GDPR Art. 17) — to have your data deleted in defined circumstances (subject to on-chain limits and our legal-retention exceptions).
• Right to restriction (GDPR Art. 18) — to have processing restricted in defined circumstances.
• Right to object (FADP Art. 30 / GDPR Art. 21) — to processing based on legitimate interests, on grounds relating to your particular situation; and at any time to processing for direct marketing.
• Right to data portability (GDPR Art. 20) — to receive personal data you have provided in a structured, commonly used, machine-readable format and to transmit it to another controller, where processing is based on consent or contract and is carried out by automated means.
• Right to withdraw consent (GDPR Art. 7(3)) — at any time, without affecting the lawfulness of processing carried out before withdrawal.
• Right not to be subject to a solely-automated decision with legal or similarly significant effects (GDPR Art. 22) — see §12.
• Right to lodge a complaint with a competent supervisory authority — see §11.

> 10 How to exercise your rights

To exercise any of the rights in §9, contact us at info@borglife.ai. We may need to verify your identity before responding — typically by asking you to send the request from the email address we already have on file, or to sign a verification message with the wallet whose data is the subject of the request.

We will respond within 30 days of receiving a verifiable request, unless the request is complex or numerous, in which case we may extend by up to 60 additional days and inform you of the extension and the reasons.

Exercising your rights is free of charge. If a request is manifestly unfounded or excessive, we may charge a reasonable fee or refuse to act, and we will explain our reasoning.

> 11 Right to lodge a complaint

You have the right to lodge a complaint with a competent supervisory authority. In particular:

• Switzerland. Federal Data Protection and Information Commissioner (FDPIC) — https://www.edoeb.admin.ch.
• EEA. Your local data-protection authority. A list is maintained by the European Data Protection Board at edpb.europa.eu.

We would appreciate the opportunity to address your concerns directly first; please consider contacting us at info@borglife.ai before lodging a formal complaint.

> 12 Automated decision-making & profiling

We do not currently make decisions producing legal or similarly significant effects on you that are based solely on automated processing in the sense of GDPR Art. 22.

We use automated processing for limited operational purposes only — for example, sanctions-screening, basic anti-abuse heuristics, and rate-limiting. Where any such processing materially affects your access to the Service, a human review is available on request.

Note that the Borglife smart contracts execute deterministically on-chain. The contracts are not profiling within the meaning of GDPR; they are software executing rules on data you choose to submit. The economic, social, and reputational consequences of on-chain activity follow from those rules, not from any opaque decision by us about you personally.

> 13 Sponsors, Bounties & controller roles

13.1 Controller-role allocation

Different processing of personal data in connection with Bounties involves different controller roles. Each role is allocated as follows:

• (a) Our infrastructure — we are the sole controller. For the operation of the off-chain matching, indexing, oracle, verifier, relayer, and ProP operator / allocation infrastructure that supports Bounties and the protocol's Proof-of-Participation rewards, and for related website / plugin telemetry, eligibility, sanctions, and jurisdictional screening, security and abuse mitigation, ProP eligibility and allocation metadata processing, and aggregate analytics. Purposes and means of this processing are determined by us alone.
• (b) Bounty content — the Sponsor is the controller; we act as processor. The Sponsor decides what personal data to include in a Bounty and the purposes of its processing (which Borg the Bounty targets, what work is sought, how submissions are evaluated, how long to retain, to whom the output is communicated). Where we process Bounty content on the Sponsor's behalf for the purposes of matching, indexing, or relaying, we act as a processor under GDPR Art. 28, under the standard processor terms set out in §8.4 of the Terms & Conditions (which operate as the data-processing agreement between Sponsor as controller and us as processor) and any separate written DPA agreed with the Sponsor under §8.4.
• (c) Sponsor's downstream use — the Sponsor is an independent controller. For any further use the Sponsor makes of Bounty submissions, outputs, or related personal data outside the Borglife protocol (including reuse, internal retention, marketing, or onward transfer to third parties). We have no role and no responsibility for this processing.

To the extent we process operational metadata derived from Bounty processing for our own purposes — including infrastructure operation, abuse detection, fraud prevention, security, and aggregate analytics — that processing falls under (a), and we act as a separate controller for those purposes (not as a joint controller with the Sponsor).

13.2 Exercising your rights

You may exercise the rights described in §9:

• against us — for processing under (a), and for any processing of operational metadata under (b) where we act as a separate controller;
• against the relevant Sponsor — for processing under (b) (where the Sponsor is the controller and we are its processor), and for the Sponsor's independent processing under (c).

Where we act as a processor under (b), data-subject requests are most effectively directed to the relevant Sponsor as controller; we will assist the Sponsor in responding to the extent required by GDPR Art. 28(3)(e). If you are unsure who to contact, write to info@borglife.ai and we will route your request appropriately.

13.3 Paths that do not use our infrastructure

Where you participate in Bounties without using matching, indexing, oracle, verifier, or relayer infrastructure that we operate (for example, peer-to-peer discovery via libp2p with on-chain settlement), we have no visibility of and no operational role in the relevant Bounty processing, and no processing relationship — controller or processor — arises between you and us through our own infrastructure for that processing. (Our protocol-design choices may still engage controller-style responsibilities for the schema-level design — see §1.)

> 14 Children

The Service is not directed to children and the Terms restrict participation to persons aged 18 or older. We do not knowingly collect personal data from children. If you believe a child has provided personal data to us, please contact info@borglife.ai and we will delete it without undue delay.

> 15 Security

Data minimization is our primary security control. What we do not collect cannot be lost, leaked, subpoenaed, or compelled. The non-custodial, no-account, real-time-screen-only architecture described in §1, §2, and §3 substantially reduces the personal-data attack surface relative to a typical web service.

For the limited categories of personal data we do hold (see §2.3), we implement appropriate technical and organisational measures to protect them against unauthorised access, alteration, disclosure, or destruction, taking into account the state of the art, the costs of implementation, and the nature, scope, context, and purposes of processing.

No method of transmission over the internet or storage is fully secure. Your seed phrase and private keys are your responsibility alone — we never request, store, or have access to them. Please see §5 of the Terms.

If we become aware of a personal-data breach, we will assess the risk to your rights and freedoms and, where required by law, notify the competent supervisory authority — under GDPR Art. 33, without undue delay and where feasible within 72 hours of becoming aware of the breach, and under FADP Art. 24, as soon as possible. Where the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly without undue delay (GDPR Art. 34 / FADP Art. 24 para. 4).

> 16 Cookies, analytics & local storage

The borglife.ai website does not currently deploy analytics, advertising, profiling, or cross-site tracking cookies, and does not use third-party tracking SDKs.

Where the Service uses cookies or browser local-storage mechanisms, they are strictly necessary to deliver the functionality you requested (for example, to record that you have accepted the Terms during a click-wrap acceptance flow). Strictly necessary cookies do not require consent under the Swiss FADP, and are exempt from the consent requirement of Article 5(3) of the ePrivacy Directive 2002/58/EC (as transposed in EEA Member States) for EEA users.

If that changes — for example, if we later deploy analytics, performance, or advertising cookies — we will request your consent in advance via a cookie banner, identify the categories and purposes, and allow you to refuse or selectively accept.

You can manage cookies through your browser settings.

> 17 Changes to this notice

We may amend this Notice from time to time. The "Effective" date at the top will be updated for any amendment, and where reasonably practicable we will also give notice on the website or by email where you have previously provided one.

Material changes (privacy posture) — including any change to the categories of personal data we process, the legal bases we rely on, the controller / processor allocation in §13, the international-transfers position in §7, the retention windows in §8, the §2.1 absolute exclusions, or the Article 27(2)(a) framing in §1 — will be treated as material privacy-posture changes for the purpose of §22 of the Terms & Conditions. Consistent with that section, continued access to touchpoints we operate after the effective date of a material privacy-posture change will be gated on a fresh affirmative click-wrap acceptance of the amended Notice; the amended Notice will not be applied to your processing on the basis of mere continued use.

Non-material changes — clarifications, formatting fixes, contact-information updates, cross-reference corrections, sub-processor-name changes that do not alter the underlying allocation, and similar — take effect on the new Effective date and continued use of the Service constitutes acceptance of those non-material amendments.

> 18 Contact

For any data-protection question or to exercise your rights, please contact us at info@borglife.ai.