Hopscotch

Version 2026.05-c.
Updated Wednesday, May 6, 2026.

HOPSCOTCH LABS LIMITED, a company incorporated in Ireland under registration number 686139 with its registered office at 10 Earlsfort Terrace, Dublin 2, D02 T380 (“Hopscotch”, “Company”, “we”, or “us”), publishes the Hopscotch software interface (the “Site”, “Website”, “App”, or “DApp”) served within the hopscotch.trade domain and subdomains. The Company is the data controller for the personal information described in this Policy for the purposes of GDPR and UK GDPR.

The Company's Irish registration is retained for purposes of corporate identity only. The Site and App themselves are not offered or made available to residents of the European Union, the European Economic Area, or the United Kingdom, and the Company does not provide crypto-asset services or any other financial services within those territories. However, because the Company is established in the Republic of Ireland, the processing of personal information under this Policy is subject to European data-protection law (including GDPR and UK GDPR), and this Policy extends those rights to all of our users, including U.S. residents.

Nature of the software.

Hopscotch is a neutral, non-custodial software interface. It does not custody user assets, execute trades, operate a marketplace, match counterparties, take possession of funds, or provide escrow, payment, custodial, exchange, brokerage, or other financial services. All settlement occurs on public blockchains via third-party smart contracts that users interact with directly from their own self-custodied wallets. Hopscotch is not a party to, intermediary of, or guarantor of any transaction between users.

This Policy describes the types of information we may collect from you or that you may provide when you visit or interact with the Site and App and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect:

• On this Website.
• In email, text, and other electronic messages between you and this Website.
• Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy.

It does not apply to information collected by:

• Us, offline or through any other means, including on any other website operated by Company or any third party; or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This Policy may change from time to time (see Changes to Our Privacy Policy).

Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information to this Website or on or through any of its features.

If we learn that we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have received any information from or about a child under 13, please contact us at:

We collect several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number, Social Security number, or any other identifier by which you may be contacted online or offline (“Personal Information”);
• That is about you but individually does not identify you; and/or
• About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically, as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and web beacons.
• From third parties, for example, our business partners.

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
• Your search queries on the Website.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk.

Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies)

  A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. For more information about how we use cookies, please refer to our Cookie Policy.

• Flash cookies

  Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.

• Web beacons

  Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or any products or services we offer or provide through it.
• To allow you to participate in interactive features on our Website.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., a legal basis within the meaning of Article 6 of the GDPR) to do so under applicable law. Depending on the specific processing activity, the legal basis we rely on may be: (a) your consent; (b) performance of a contract with you, or steps taken at your request before entering into a contract; (c) compliance with a legal obligation to which we are subject (including U.S. federal and state laws and European data-protection law); (d) protection of your vital interests or those of another natural person; or (e) our legitimate interests (such as operating and securing the software interface, protecting our rights and the rights of other users, and detecting and preventing fraud or abuse) provided that those interests are not overridden by your interests or fundamental rights and freedoms.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of HOPSCOTCH LABS LIMITED's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising

  You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website . If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

We do not control third parties' collection or use of your information to serve interest-based advertising. These third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI's website .

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information .

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: privacy@hopscotch.trade. However, please know we do not currently sell data triggering that statute's opt-out requirements.

U.S. residents in states with comprehensive consumer privacy laws (including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia, as applicable) may have additional rights under their state's statute, which may include the right to know, access, correct, or delete personal information we hold about them, and the right to opt out of targeted advertising, sale, or certain profiling. To exercise any such right, contact privacy@hopscotch.trade. California residents should also review the Supplemental Privacy Statement for California Consumers below.

Because the Company is established in the Republic of Ireland, all users (including U.S. residents) have rights under applicable European data-protection law. These rights may include the right (i) to request access to and obtain a copy of your personal information; (ii) to request rectification or erasure (the “right to be forgotten”); (iii) to restrict the processing of your personal information; (iv) to object to processing based on our legitimate interests or for direct marketing; and (v) where applicable, to data portability. You can make such a request by contacting us using the contact details provided in the Contact Information section, below. We will consider and act upon any request in accordance with applicable data-protection laws and within the timelines those laws require (typically within thirty (30) days under GDPR).

Because we rely on immutable, public blockchain networks to effect non-custodial escrow, certain personal data that is committed on-chain (such as a wallet address associated with a transaction) cannot be technically deleted from the underlying ledger. If you exercise your right to erasure, we will delete the personal information we control in our off-chain systems and sever any link between your identity and on-chain identifiers held by us; however, entries already recorded on-chain will remain visible on the public blockchain. We will explain these limitations in our response to any erasure request.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to lodge a complaint with your local data-protection supervisory authority. The supervisory authority for our Irish entity is the Irish Data Protection Commission (dataprotection.ie ). You can find a list of European authorities on the European Commission's website .

If you are located in Switzerland, the contact details for the data-protection authorities are available at this website .

Where we rely on your consent to process your personal information, which may be express and/or implied consent depending on applicable law, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. You can withdraw your consent at any time by contacting us using the details in the Contact Information section, below.

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, see our California Statement below.

California's “Shine the Light” law ( Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@hopscotch.trade or write to us at:

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on secure servers.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

By using our interface, you acknowledge that your personal information may be transferred to, stored in, and accessed from multiple countries, including the United States, which may provide different levels of data protection than your home country.

For data processed by the Company (Ireland): When we transfer personal information originating under our EU/Irish obligations to the United States or other regions without an adequacy decision, we do not rely solely on your consent. We mandate strict, legally binding safeguards (including the implementation of Standard Contractual Clauses and Data Processing Agreements with our service providers) to ensure your data remains protected to the standards required by the GDPR.

We retain personal information as required by our enterprise records retention schedule, which varies by Service, business function, country, record classes, and record types. We calculate the retention period based upon the time the personal information is needed to: (a) fulfill the purposes described in this Privacy Statement, (b) meet the timelines required or recommended by regulators, professional bodies, or associations, (c) comply with applicable laws, legal holds, and other legal obligations (including contractual obligations), and (d) comply with your requests.

It is our policy to post any changes we make to our Privacy Policy with a notice that the Privacy Policy has been updated on the Website home page and App login. If we make material changes to how we treat our users' Personal Information, we will notify you through a notice on the Website home page and App login. The date this Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Policy to check for any changes.

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

This Supplemental Privacy Statement for California Consumers under CCPA/CPRA (“California Statement”) supplements our Privacy Statement and further explains required disclosures about how we collect, disclose, and sell the personal information of California consumers and the rights that California consumers may have under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA/CPRA”) where we act as a business under CCPA/CPRA.

When we use the term “personal information” in this California Statement, we are using that term as CCPA/CPRA defines it, which generally means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. However, personal information does not include publicly available, de identified, or aggregate consumer information (which are all defined in CCPA/CPRA).

In general, the categories of personal information we collect, sources of that information, business and commercial purposes for why we collect and use it, and who we share it with, as well as our personal information retention practices, are as outlined in our Privacy Statement.

California law, however, requires we restate some of this information for specific categories that are defined in CCPA/CPRA. The type of personal information we collect and how we handle that personal information, including if we share or sell that personal information, depends on how you are specifically interacting with us and which Services you are inquiring about. In general, we may have collected, disclosed for a business purpose, and shared the following categories of personal information and sensitive personal information from California consumers within the last twelve (12) months:

If you are a California consumer, you may have one or more of the following rights under CCPA/CPRA:

• Right to confirm we process your personal information and, if so, to request we disclose to you: (1) the categories of personal information we collected about you; (2) the categories of sources from which the personal information is collected; (3) the business or commercial purpose for collecting, selling, or sharing personal information; (4) the categories of third parties to whom we disclose personal information; and (5) the specific pieces of personal information we have collected about you.
• Right to access (which may include a portable copy), correct, complete, or delete specific pieces of personal information we hold about you.
• Right to limit our use and disclosure of your sensitive personal information.
• Right to opt-out of the sale of personal information, as sale is defined under CCPA/CPRA.
• Right to opt-out of the sharing of personal information, as sharing is defined under CCPA/CPRA.
• Right not to receive discriminatory treatment for exercising your rights under CCPA/CPRA.
• Additionally, California Civil Code Section 1798.83 may permit you the right to request information regarding the personal information about you we disclose to third parties for the third parties' direct marketing purposes.

To make a request and/or opt-out of the sale and sharing of personal information, you can contact us by emailing privacy@hopscotch.trade.

Please provide us with enough information to verify your identity. We will use information you provide to us to verify your request. If we cannot initially verify your identity, we may request additional information to complete the verification process, such as, for example, a copy of your driver's license and/or a recent utility or credit card bill. You can designate an agent to make a request on your behalf by either: (1) having your agent send us a letter, signed by you, certifying that the agent is acting on your behalf and showing proof that they are registered with the California Secretary of State; or (2) by you and the agent executing and sending us a notarized power of attorney stating that the agent is authorized to act on your behalf. Please note that we may still require you to verify your identity before we process a request submitted by your agent.

IMPORTANT: These rights are not absolutely guaranteed and there are several exceptions where we may not have an obligation to fulfill your request. We are only required to honor these rights to the extent that we act as a business/controller under CCPA/CPRA and the requested rights have been granted and apply to you under CCPA/CPRA. Please consult CCPA/CPRA to determine what rights may be available to you and when access to these rights is limited. You may appeal an adverse decision on your requests by emailing or writing to us; and you have the right to lodge a complaint to the California Attorney General if you are not satisfied with our responses to your requests or how we manage your personal information. However, we encourage you to first contact us so we can address your concerns directly.

This California Statement was last updated on May 6, 2026.