Effective date: November 19, 2025
Contact: legal@structure.fi
Applies to: Marketing/landing pages at structure.fi that link to this policy.
Does not apply to: The Structure web app, API, or MCP server (those will have a separate in‑app notice).

1) Who we are

Structure Financial Inc. (“Structure,” “we,” “us,” “our”) is the controller for personal data processed on this landing page.

Registered address: Craigmuir Chambers, Road Town, Tortola VG 1110, British Virgin Islands
Privacy & security contact: legal@structure.fi

2) Scope & geographic coverage

This policy applies worldwide, except in countries or regions subject to sanctions or embargoes under laws applicable to us and our service providers (for example, measures administered by the U.S. OFAC, UK, EU, UN, or other competent authorities) as updated from time to time. We do not intentionally make the site available to, or process personal information of, individuals in those sanctioned countries/regions or other locations where access would be unlawful.

Note: When our web app/API/MCP is live, we will publish a separate in‑app privacy notice. This document is landing‑page only.

3) What we collect on the landing page

Information you provide

• Email address when you join the early‑access list.

Information collected automatically

• Basic technical and security information from your browser/device (e.g., IP address, user‑agent, timestamps, page requested, and referrer) for site operation and abuse prevention. We may infer country‑level location from IP for security and sanctions compliance.

Not collected on the landing page

• No wallet connection and no wallet addresses.
• No KYC checks.
• No AI/LLM prompts or content.
• We do not store private keys or seed phrases anywhere.

We do not run analytics tools, session replay, or advertising/retargeting pixels on the landing page today, and we do not set non‑essential cookies.

4) How we use your information (purposes & legal bases)

EU/UK legal bases shown in parentheses.

• Send early‑access updates and product news you requested (consent). Unsubscribe anytime via any email or legal@structure.fi.
• Operate, secure, and debug the site; prevent fraud/abuse; comply with sanctions controls (legitimate interests; legal obligation where applicable).
• Comply with law and enforce our terms (legal obligation / legitimate interests).

We do not use landing‑page data for profiling, targeted advertising, or automated decisions producing legal or similarly significant effects.

5) Cookies & similar technologies

We do not use non‑essential cookies, analytics, session replay, or advertising pixels on the landing page. Our hosting/CDN (Cloudflare) may set strictly necessary cookies for security/performance. Because we only use essential cookies, a cookie‑consent banner (CMP) is not shown. If that changes, we will update this policy and implement any required consent flows.

6) Sharing your information

We disclose landing‑page data only to:

• Service providers (processors) acting on our instructions (e.g., Cloudflare for CDN/WAF/hosting).
• Legal/safety recipients where required by law or necessary to protect rights, security, and compliance (including sanctions).

We do not sell or “share” personal information for cross‑context behavioral advertising under U.S. state privacy laws.

7) International transfers

We may transfer personal data internationally (for example, to the United States) in connection with our providers. Where required, we use appropriate safeguards (e.g., European Commission Standard Contractual Clauses and the UK Addendum) to protect personal data transferred outside your jurisdiction.

8) Data retention

• Email signups (marketing): retained for as long as legally permissible and necessary for the purposes described above (e.g., to send you updates and to maintain suppression/opt‑out records), and to comply with law, prevent abuse, and protect our services. If you unsubscribe, we will stop marketing to you, but we will keep a minimal record of your email on a suppression list to honor your opt‑out.
• Security/HTTP logs: kept for up to 24 months (earlier deletion where feasible), unless needed longer to investigate security issues or comply with law.

We delete or anonymize personal data when no longer needed for the purposes above, subject to legal retention obligations.

9) Security

We implement administrative, technical, and organizational measures appropriate to the risk (including protections provided by Cloudflare) to help safeguard personal data. No method of transmission or storage is 100% secure.

10) Your privacy rights

EU/UK (GDPR/UK GDPR)

You have rights to access, rectify, erase, restrict or object to processing, and data portability. Where processing relies on consent (e.g., email updates), you may withdraw consent at any time. You can also lodge a complaint with your local supervisory authority.

United States (including California)

Depending on your state, you may have rights to know/access, delete, and correct personal information, and to appeal a denial of your request. We do not sell or share personal information and do not use or disclose sensitive personal information for purposes that require a “right to limit.” If we ever introduce ad tech, we will provide an opt‑out of sale/share and honor Global Privacy Control (GPC) where required.

Submitting a request (all regions): email legal@structure.fi describing your request. We verify by confirming control of your email (and may request limited additional information where allowed by law).
Appeals (U.S. states where applicable): If we deny your request, reply with “Appeal” and we will review again.

11) Your choices

• Unsubscribe from emails: use the unsubscribe link in any message or email legal@structure.fi.
• Browser controls: you can block cookies; however, we rely only on strictly necessary hosting/security cookies on the landing page. We do not respond to legacy Do Not Track signals.

12) Children

The site is intended for adults (18+) and is not directed to minors.

13) About our app & on‑chain data (for clarity)

This policy covers only the marketing site. Our app uses wallet‑based sign‑in and we do not store private keys or seed phrases. Actions executed via DEXs through our app are public on‑chain, just as if you used the DEX directly. App‑specific details will appear in a separate in‑app privacy notice and do not apply to this landing page.

14) Changes to this policy

If we make material changes, we will display an in‑site banner and update the Effective date above.

15) Contact us

Email: legal@structure.fi
Postal: Structure Financial Inc., Craigmuir Chambers, Road Town, Tortola VG 1110, British Virgin Islands