IMPOSSIBLE LABS PRIVACY POLICY

Last Updated: March 22, 2026

This privacy policy ("Privacy Policy") governs how we, Impossible Labs Ltd. (together, "Impossible Labs", "we", "our" or "us") use, collect and store Personal Data we collect or receive from or about you ("you") in connection with the https://pearlresearch.ai/ (the "Master Website"), and its subdomains, https://compute.pearlresearch.ai (the "Mining Website"), https://compute.pearlresearch.ai/wallet (the "Wallet Web"), and https://explorer.pearlresearch.ai therein (together, the "Subdomains" and together with the Master Website, the "Website") and the services provided within our platform (the "Services").

Please read this Privacy Policy carefully, so you can understand our practices and your rights in relation to personal data. "Personal Data" or "Personal Information" means any information that can be used, alone or together with other data, to uniquely identify any living human being and any information deemed as Personally Identifiable Information by privacy laws. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

1. What information we collect, why we collect it, and how it is used
2. How we protect and retain your Personal Data
3. How we share your Personal Data
4. Additional information regarding transfers of Personal Data
5. Your privacy rights
6. Use by children
7. Interaction with third party products
8. Analytic tools
9. Specific provisions applicable under California privacy law
10. Contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Specific Personal Data we collect	Why is the Personal Data collected and for what purposes?	Legal basis (GDPR only, if applicable)	Consequences of not providing the Personal Data
When you browse, and/or visit our Website and Services
Cookies, analytic tools, and log files For more information, please read our cookies policy - https://compute.pearlresearch.ai/cookie-policy	To enable the operation of the Website To review or improve the usage and operations of our Website To analyze trends To administer the Website To track users' movement and preferences around the Website for various purposes, including for marketing communications	Legitimate interest (e.g., essential cookies required for the operation of the Website and the Services); or Consent	Certain non-essential Website and Services features may not be available
When you make use of, or interact with, our Website (e.g., when you contact us)
Full name Email address Any free text that you choose to provide – please avoid using free text to provide Personal Data about you or others	To process and answer questions To provide support (e.g., to solve problems, bugs or issues)	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. respond to your request)	Cannot process and answer questions Cannot provide support (e.g., to solve problems, bugs or issues)
When you make use of, or interact with, the Services within the Web Wallet and Mining Website (e.g., when you create an account, log in, use the Services etc.)
Email address Phone number To the extent that you register via your Google account, we receive the approved information from Google Wallet address (including without limitation, the wallet name) Any other information that you decide to provide us with	To be able to create an account To be able to log in To be able to enjoy features To be able to use the Services (e.g., mining cryptographic tokens via the Services, connecting your wallet) To comply with legal obligations or protect the rights, privacy, and safety of our users, ours and/or third parties	Processing is necessary for the performance of a contract to which the data subject is party Legitimate interest (e.g., to improve Services) Where necessary to comply with a legal obligation (e.g., to prevent fraud, illegal activity, or misuses of the Services)	Cannot create an account Cannot log in Cannot enjoy all the features Cannot provide or maintain the Services Cannot comply with legal obligations or protect the rights, privacy, and safety of our users, ours and/or third parties Cannot optimize the results of the Services for you
Payment details	For processing payments To be able to attribute the payment to you For other payment-related purposes, such as accounting, billing, or tax purposes	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. to process your payment) Where necessary to comply with legal obligations (e.g., accounting or tax laws)	Cannot charge you and therefore cannot provide you with paid-for features Cannot attribute the payment to you
When you interact with us on our social media profiles (e.g., Twitter/X, Discord)
Full name Email address Company name Job position Any other information that you decide to provide or supply us with	To answer your questions To establish a connection or discussion	Depending on the context, legitimate interest (e.g., to answer your questions and/or establish a connection) or consent	Cannot answer your question Cannot establish a connection/ discussion

Finally, please note that some of the abovementioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. "Anonymous Information" means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

2. HOW WE PROTECT AND RETAIN YOUR INFORMATION

2.1. Security.

We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

2.2. Retention of your Personal Data.

Your Personal Data will be stored until we delete the record and we proactively delete it or you send a valid deletion request, please note that in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually. Regarding retention of cookies, you can read more in our cookie policy - https://compute.pearlresearch.ai/cookie-policy.

3. HOW WE SHARE YOUR PERSONAL DATA

In addition to the recipients described above, we may share your Personal Data as follows:

With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies.
To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order. We may use or disclose the information we collect in order to ensure that our users are complying with all applicable aspects of our policies;
We may disclose information with our lawyers, accountants, auditors and other professional advisors where necessary to obtain legal or other advice or otherwise protect and manage our business interests;
We may use or disclose the Personal Data to investigate, prevent, or take action regarding illegal activities, suspected fraud, cybersecurity threats, situations involving potential threats to the physical safety of any person, violations of this policy, or as otherwise required or allowed by law and regulations;
If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;
In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or
Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
If you want to receive the list of the current recipients of your Personal Data, please make your request by contacting us at support@pearlresearch.ai.

4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

4.1. Internal transfers.

Transfers within the Impossible Labs group will be covered by an internal processing agreement entered into by members of the Impossible Labs group (an intra-group data processing agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to.

4.2. External transfers.

Where we transfer your Personal Data outside of EU/EEA (for example to third parties who provide us with services), we will generally obtain contractual commitments from them to protect your Personal Data.

5. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT

5.1. Rights.

The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

5.1.1. You have a right to access Personal Data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
5.1.2. You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;
5.1.3. You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;
5.1.4. You have the right to object, to or to request restriction, of the processing;
5.1.5. You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
5.1.6. You have the right to object to profiling;
5.1.7. You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
5.1.8. You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
5.1.9. You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

5.2.

You can exercise your rights by contacting us at support@pearlresearch.ai. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

6. USE BY CHILDREN

We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), please do not enter the Website or use the Services. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at support@pearlresearch.ai.

7. INTERACTION WITH THIRD PARTY PRODUCTS

We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a "Third Party Service"). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

8. ANALYTIC TOOLS/COOKIES

8.1. DataDog.

The Services uses "DataDog" to collect information about your use of the Services for the purpose of monitoring and securing your use in the Services. DataDog collects information such as: browser name, browser language and browser version; device brand, device model, device type; continent, country, city, geo location; internet/domain provider; operation system's name and version User, email and internal user ID; session's actions, errors, events and session record; IP address. Further information is available at: https://www.datadoghq.com/legal/msa/ and https://www.datadoghq.com/legal/privacy/.

8.2. Stripe.

We use Stripe for payment, analytics, and other business services. Stripe collects identifying information about the devices that connect to its services. Stripe uses this information to operate and improve the services it provides to us, including for fraud detection. You can learn more about Stripe and read its privacy policy.

8.3. Mixpanel.

We use Mixpanel for product analytics to understand how users interact with the Services. Mixpanel collects information such as: device information, browser type, IP address, pages visited, actions taken, and usage patterns. This information helps us improve and optimize the Services. You can learn more about Mixpanel and read its privacy policy.

8.4. We reserve the right to remove or add new analytic tools.

9. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

9.1. California Privacy Rights.

California Civil Code Section 1798.83 permits our customers who 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 support@pearlresearch.ai. Please note that we are only required to respond to one request per customer each year.

10. CONTACT US

10.1. If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at support@pearlresearch.ai.