Sixpence Privacy Policy

Date of last revision: 25 May 2026

This Privacy Policy ("Policy") describes how Sixpence ("we", "us", or "our") collects, uses, discloses, and protects personal data of users ("you", "your") who access or use our website, browser extension, application, and related services (collectively, the "Services"). This Policy is intended to comply with the General Data Protection Regulation ("GDPR") and the California Consumer Privacy Act ("CCPA").

By accessing or using our Services, you acknowledge that you have read, understood, and agree to the terms of this Policy.

1. Definitions

• Personal Data: Any information relating to an identified or identifiable natural person.
• Processing: Any operation or set of operations performed on personal data, whether or not by automated means.
• Controller: The natural or legal person which determines the purposes and means of the processing of personal data.
• Processor: A natural or legal person which processes personal data on behalf of the controller.

2. Data Collection and Use

End-Users

We do not collect, share, or sell any personal data from end users of our Services. This includes, but is not limited to, names, addresses, email addresses, browsing history, website URLs visited, or any other information that could be used to identify you personally. The only exception is the possible storage of IP addresses in an anonymized, non-personally identifiable form to prevent abuse of our Services. If you do not consent to this, you may opt out or discontinue use of our Services.

The Sixpence browser extension may share unutilized bandwidth and computing resources with authorized partners as described in our Terms and Conditions. This functionality does not require collection of your personal browsing data, browsing history, or other personally identifiable information.

Voluntary Support Communications

If you choose to contact us for support or feedback, you may voluntarily provide information such as your email address and message content. We use this information solely to respond to your inquiry and improve our Services. We do not use it for marketing or sell it to third parties.

Business Partners

Organizations that contract with Sixpence to use the network may be required to provide certain information, including:

• Email Address: For communication, account management, and contractual purposes.
• Organization and Technical Information: As necessary to maintain the integrity, security, and proper functioning of the Sixpence ecosystem.

This information is used exclusively to ensure the integrity, security, and proper functioning of the Sixpence network. It is not shared with unrelated third parties or used for purposes unrelated to delivering the Services.

3. Legal Basis for Processing (GDPR)

We process personal data only where we have a legal basis to do so under applicable law, including:

• With your consent;
• To fulfill contractual obligations;
• To comply with legal obligations;
• To protect the vital interests of you or others;
• For legitimate interests, provided these do not override your rights and freedoms.

4. Browser Extension

The Sixpence browser extension may request permissions necessary to operate across websites and facilitate bandwidth and resource sharing in the background. Such permissions are required for the extension to function as intended. The extension does not collect, share, or sell users' browsing data, browsing history, or other personal data from end users.

5. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, to comply with legal obligations, resolve disputes, and enforce our agreements. When personal data is no longer required, it will be securely deleted or anonymized.

6. International Data Transfers

Your personal data may be transferred to, and processed in, countries other than your country of residence. Where such transfers occur, we ensure appropriate safeguards are in place to protect your personal data in accordance with applicable data protection laws.

7. Data Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, disclosure, alteration, or destruction. Your data may be used to determine liability in case of suspected cyber, tax, or other crimes against the service, as permitted by law.

Business partners and users who voluntarily contact us may need to provide certain personal data to receive specific services (e.g., support responses, account management, or partner onboarding). Without such data, we may not be able to provide those services.

8. Cookies and Tracking Technologies

We do not use cookies or similar tracking technologies to collect personal data from end users. If this changes, we will update this Policy accordingly and provide appropriate notice and choices as required by law.

9. Your Rights

Under the GDPR, you have the right to:

• Access your personal data;
• Rectify inaccurate or incomplete personal data;
• Erase your personal data (right to be forgotten);
• Restrict or object to the processing of your personal data;
• Data portability;
• Withdraw consent at any time (where processing is based on consent);
• Lodge a complaint with a supervisory authority.

Under the CCPA, California residents have the right to:

• Know what personal data is collected, used, disclosed, or sold;
• Request deletion of personal data;
• Opt out of the sale of personal data (we do not sell personal data);
• Non-discrimination for exercising your rights.

To exercise any of these rights, please contact us as described in the "Contact Us" section below. We will respond to your request in accordance with applicable law.

10. Children's Privacy

Our Services are not directed to children under the age of 16. We do not knowingly collect personal data from children under 16. If you believe that a child has provided us with personal data, please contact us and we will take steps to delete such information.

11. Changes to This Privacy Policy

We reserve the right to modify, update, or revise this Policy at any time in our sole discretion. Any changes will be effective immediately upon posting of the revised Policy on our website. We will provide notice of material changes through the Services or other appropriate means. Your continued use of the Services following any changes constitutes acceptance of the revised Policy. We encourage you to review this Policy periodically for any updates.

Last updated: May 27, 2026

12. Contact Information and Privacy Inquiries

For questions, concerns, or requests regarding this Privacy Policy, our privacy practices, or the exercise of your rights under applicable law, please contact us through the following means:

• Email: yuchen@jomo.network

We will respond to privacy inquiries and requests in accordance with applicable law and within reasonable timeframes.

13. Governing Law and Jurisdiction

This Privacy Policy shall be governed by and construed in accordance with the laws of Delaware, without regard to conflict of law principles. Any disputes arising under this Policy shall be subject to the exclusive jurisdiction of the courts of Delaware.

By accessing or using the Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree to this Policy, you must discontinue use of the Services immediately.