WEBSITE AND PORTAL PRIVACY POLICY

Last updated: 06 October 2025.

Midnight TGE Ltd. (“Midnight”, “we”, “our”, “us”) is committed to protecting and respecting your privacy. We are a company established in the British Virgin Islands with a registered office at Craigmuir Chambers, Road Town, Tortola, VG, 1110, BVI.

This Website and Portal Privacy Policy (“Privacy Policy”) applies to all personal data collected through any website managed by Midnight , NIGHT Portal, and in connection with any services we provide to you (collectively, the “Website”).

In this Privacy Policy, we describe how we collect, use, store and share your personal data and what rights you have in relation to it. If there are any terms in this Privacy Policy that you do not agree with, please discontinue access and use of our Website.

Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your personal data with us.

  • If you reside in the European Economic Area (the “EEA”) or the United Kingdom (the “UK”), please refer to the “EEA/UK Addendum” below in addition to this Privacy Policy.
  • If you reside in the United States (the “US”), please refer to the “US Addendum” below in addition to this Privacy Policy.
  • If you reside in Japan, please refer to the “Japan Addendum” below in addition to this Privacy Policy.

1. Collection of Personal Data

Midnight collects the following types of personal data:

Information you provide:

  • Public blockchain addresses, signed messages, and related personal data which you may choose to provide to us (“blockchain personal data”). This information is required to enable us to fulfil our contract with you.
  • Name and email address (“contact data”) where you opt-in to receive updates on our services available on the Website or marketing communications or choose to contact us and/or exercise your rights.
  • Any personal data you choose to provide when you use our chatbot, including contact data and blockchain personal data (“chat data”).

Information we collect automatically:

  • Data collected via cookies or similar tracking technologies (“cookies data”).
  • IP addresses, date and time of requests, device information, browser type, pages accessed, and security information (“usage data”).

Information we receive from third parties:

  • We may receive personal data about you from certain third parties providing services to us, such as sanctions-related personal data and/or token value data, where required (“sanctions or token data”).

2. Use of Personal Data

Midnight uses your personal data for the following purposes:

  • To allow you to participate in the features of the Website such as the airdrops of the NIGHT tokens.
  • To provide you with support, updates and/or marketing content.
  • To gather analysis or valuable information to improve the Website.
  • To comply with legal obligations, protect our rights, and prevent wrongdoing.

3. Retention of Personal Data

We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We also retain certain cookies and usage data for internal analysis purposes.

4. Disclosure of Personal Data

Midnight will disclose your personal data as necessary, or as required or permitted by applicable laws to the following categories of recipients:

  • Service providers and vendors.
  • When you request us to share certain information with third parties.
  • With professional advisors such as auditors or law firms.
  • With regulators, law enforcement agencies, and public authorities.
  • With our affiliates for administrative and marketing purposes.
  • In connection with business transactions or reorganisations.

5. Security of Personal Data

We use reasonable technical and organisational methods to safeguard your information, but acknowledge that data transmissions over the internet are not 100% secure.

6. Links To Other Websites

The Website may contain links to other websites, products or services that are not operated by Midnight. We have no control over and assume no responsibility for their content or privacy policies.

7. Changes To This Privacy Policy

We may update this Privacy Policy from time to time and will inform you of changes as required by law.

8. Data Controller and Data Privacy Contact

Midnight TGE Ltd. is the controller of your personal data processed under this Privacy Policy. .

EEA/UK Addendum

This addendum complements the Privacy Policy and addresses specific requirements under EEA and UK privacy laws.

US Addendum

This US Addendum complements the Privacy Policy and addresses specific requirements under the California Consumer Privacy Act (CCPA) and other US state privacy laws.

Japan Addendum

This addendum complements the Privacy Policy and addresses specific requirements under Japanese data protection law (APPI).