Privacy Policy

Privacy Policy Effective: as of the date set forth in the platform record. 1. Scope. This Privacy Policy describes how Nuvion Energy DAO LLC ("Nuvion," "we," "our") collects, uses, discloses, and safeguards personal information processed through the Nuvion participation environment, including the public website, the gated participation environment, and any related applications, APIs, or communications (collectively, the "Platform"). 2. Information We Collect. We collect information that you provide directly to us — including identifying information (name, email, address, jurisdiction of residence), profile information (role, organization, area of interest), authentication credentials, accreditation and eligibility documentation, agreement acceptance records, optional wallet addresses, and any messages you send to us. We also collect technical information automatically — including device, browser, IP address, log data, session identifiers, and usage telemetry — and information from third-party identity, accreditation, sanctions-screening, and KYC/AML providers engaged in the eligibility review process. 3. How We Use Information. We use personal information to operate and secure the Platform; to verify investor eligibility under Rule 506(c) of Regulation D and other applicable jurisdictional requirements; to administer per-project Special Purpose Vehicles ("SPVs"), agreements, and participation records; to communicate with you about your account, the review process, and projects you have joined; to comply with legal, regulatory, audit, recordkeeping, tax, and reporting obligations; to detect, prevent, and respond to fraud, abuse, sanctioned activity, and security incidents; and to improve the Platform and develop new features. 4. Legal Bases for Processing. Where processing is governed by law that requires a legal basis, we rely on (i) performance of a contract between you and Nuvion, (ii) compliance with a legal obligation, (iii) our legitimate interests in operating, securing, and improving the Platform, and (iv) your consent where required. 5. How We Share Information. We do not sell personal information. We share personal information with service providers that act on our behalf under written contract — including hosting, identity, accreditation, KYC/AML, sanctions screening, electronic signature, payments, analytics, and customer support — and only for the purposes for which we engaged them. We may also share information with our affiliates, with the Texas-licensed operating entity that executes field work, and with the SPVs you elect to participate in, in each case strictly as needed to administer the relationship. We may disclose information when legally compelled, in connection with a corporate transaction, or to protect rights, safety, or the integrity of the Platform. 6. Wallet Addresses and On-Chain Activity. If you elect to link a wallet, we record the wallet address, ownership-proof signatures, and any on-chain interactions associated with your participation. On-chain activity is, by its nature, public and permanent; we cannot remove on-chain records. Off-chain references to your wallet address are retained as part of audit logs and participation records. 7. International Transfers. Personal information may be processed in jurisdictions other than your own, including the United States. Where required, we rely on appropriate transfer mechanisms or contractual safeguards. 8. Retention. We retain personal information for the duration of your relationship with the Platform and for the periods required by applicable law, regulation, audit, tax, and recordkeeping obligations, after which we securely delete or anonymize it. Certain records — including agreement acceptances, accreditation evidence, and on-chain references — are retained for the longer of regulatory minimums or the lifecycle of the related project. 9. Security. We use administrative, technical, and physical safeguards designed to protect personal information against loss, misuse, unauthorized access, alteration, and disclosure. No system is perfectly secure, and we cannot guarantee absolute security. 10. Your Rights. Subject to applicable law and our recordkeeping obligations, you may request access to, correction of, or deletion of your personal information; object to or restrict certain processing; request portability; and withdraw consent where processing is based on consent. We will respond within the period required by law. Some requests may be limited where compliance, audit, sanctioned-party, or anti-fraud obligations require continued retention. 11. Cookies and Similar Technologies. We use cookies and similar technologies for authentication, security, preferences, and analytics. You can control cookies through your browser; disabling certain cookies may affect Platform functionality. 12. Children. The Platform is not directed to children under sixteen, and we do not knowingly collect information from them. If you believe a child has provided information, contact us so we can delete it. 13. Changes. We may update this Privacy Policy. The current version, version identifier, and effective date are shown on this page. Material changes will be communicated through the Platform or by email where appropriate. 14. Contact. For privacy questions or requests, contact privacy@nuvionenergy.com.