Legal

PRIVACY NOTICE

Last Updated: April 17, 2026

This Privacy Notice describes how Regnum Aurum Acquisition Corp. (“RAAC,” “we,” “us,” “our”) receives, stores, uses, discloses, and otherwise processes information about you, when you access or use our decentralized finance software interface (“RAAC Interface”).

The RAAC Interface operates in a decentralized and permissionless manner. As such, when you connect your wallet (“Wallet Data”) to the RAAC Interface, it remains localized and isolated on your physical device (e.g., through your browser or wallet application), so that, through the RAAC Interface, you can interact directly with the Ethereum protocol (“Ethereum”). No intermediary—including RAAC—will have access to your Wallet Data, unless and until you make a transaction on Ethereum, in which case, once a transaction is complete, a limited amount of your personal information (i.e., that which is part of an applicable “payload” or metadata) may become public or sent to third parties as part of the blockchain’s natural ecosystem, independent of RAAC. RAAC has no control over Ethereum, which has separate privacy and data collection practices, independent from us. For more information on Ethereum’s privacy and data protection practices, we recommend that you review its privacy notice (See Ethereum Privacy Policy).

RAAC may collect your personal information when you use the RAAC Interface to create an account, mint NFTs or stablecoins or make investments or payments, use a part of the RAAC Interface that requires us to verify your identity, communicate with us, or visit our website (raac.io).

RAAC may change this Privacy Notice from time to time. If RAAC makes changes, we will notify you by revising the date at the top of this policy. If we make material changes, we will provide you with additional notice. We encourage you to review this Privacy Notice regularly to stay informed about our information practices and the choices available to you.

COLLECTION OF INFORMATION

The only personal information that is collected or accessible by RAAC is the metadata that helps us ensure the quality and functionality of the RAAC Interface, (e.g., your operating system, browser version, IP address, and other details) and the information you provide to us to utilize the RAAC Interface. Other personal information, such as your payload data, will be part of the Ethereum blockchain, and publicly visible. Your Wallet Data will reside locally on your device—it is not remotely stored in any RAAC database or in the cloud. RAAC does not manage, control, or access your Wallet Data when you make a transaction on Ethereum. Rather, the RAAC Interface interacts directly with Ethereum. For example, if you lose your private key and seed phrase, RAAC cannot remotely restore such Wallet Data. Use of the RAAC Interface is at your own risk. You are responsible for understanding how it functions with respect to your data.

In this section, we describe the categories of personal information that RAAC does collect and the sources of this information.

Information that RAAC Collects Automatically

When you use the RAAC Interface, we automatically collect the following information from your browser:

Device, Usage, and Activity Information: RAAC collects information about how you access and interact with the RAAC Interface, including data about the device and network you use, such as your operating system version, browser version, IP address, and other unique identifiers. RAAC also collects information about access dates and times, related metadata, and other technical data.
Information Collected by Cookies and Similar Tracking Technologies: RAAC uses tracking technologies such as cookies to collect information about your use of RAAC Interface, including the search terms or link that brought you to the RAAC Interface. For more information about the cookies and similar tracking technologies used and the choices available to you, see the Your Choices sections below.

Information You Provide to RAAC

If you use the RAAC Interface to redeem a RAAC NFT for title to property, we may collect information directly from you as part of our Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”) procedures.

If you use a part of the RAAC Interface that requires KYC, the types of information that RAAC collects directly from you include your name, address, email address, wallet address, nationality, date of birth, copies of government-issued identification, proof of address, photographs, online video-based liveness checks, and any other information you choose to provide.

If you request support from us or otherwise communicate with us, we will collect your contact information, including the means of contact you provide (e.g., email address, Discord username, or X username) and any other information you choose to provide.

Information RAAC Collects from Other Sources

We obtain information about you from other sources. For example, we may collect information from identity verification services, blockchain analytics and wallet analytics providers, and oracles. This information includes blockchain addresses, blockchain activity, nationality, and information regarding sanctions compliance.

If you communicate with us via third-party platforms (e.g., Discord, X, LinkedIn, Fuul, Magic Eden) we will collect from such third-parties, your username, avatar, chat history, and content of the communications you send to us, including blockchain addresses and nationality.

RAAC works with zk.me to conduct zero-knowledge KYC and AML. When you provide information to zk.me, RAAC does not collect, store, or access it. Rather, zk.me provides RAAC with a cryptographic proof verifying that you meet the criteria required to use the RAAC Interface. The information you provide to zk.me is subject to their own privacy policy: https://www.zk.me/web-privacy-policies.

RAAC works with Hypernative and TRM Labs to provide blockchain and wallet analytics. For example, we may collect wallet addresses, as well as Office of Foreign Assets Control and sanctions status. Information collected by Hypernative and TRM Labs is subject to their own privacy policies: https://www.hypernative.io/privacy-policy and https://www.trmlabs.com/policies/privacy-policy.

Information RAAC Derives About You

RAAC may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address to ensure you are not accessing the services from a blocked or sanctioned country.

USE OF INFORMATION

RAAC uses the information we collect or derive about you to verify your identity, report suspicious activity, and to process and fulfill your requests to mint, sell, purchase, lend, invest, or collateralize NFTs or stablecoins.

We also use the information we collect to:

Draft and deploy (including setting up vaults for) smart contracts;
Create and assist in the redemption of RAAC Tokens for investors;
Establish and manage smart contracts for liquidity, lending, and stability pools;
Provide, maintain, and improve the RAAC Interface and its services;
Assist in auctioning or liquidating applicable NFTs from borrowers who default;
Develop new products and services;
Personalize your experience;
Monitor and analyze trends, usage, and activities in connection with the RAAC Interface;
Detect, investigate, respond to, and help protect against security incidents and other malicious, deceptive, fraudulent, or illegal activity, and help protect the rights and property of RAAC and others;
Comply with legal and financial obligations; and
Create de-identified and aggregate data that cannot reasonably be linked to you.

DISCLOSURE OF INFORMATION

We disclose information about you as described in this Privacy Notice and below to:

Vendors and Service Providers. We share personal information with our vendors and service providers who perform services on our behalf, such as companies that assist us with identity verification, liveness checks, fraud prevention, and analytics.
Other Layer 2 Service Providers. RAAC provides information, such as that related to your applicable RAAC Tokens, other cryptocurrency or blockchain transaction information, or RAAC NFTs when you direct us to do so.
The Public through the Ethereum Protocol: The RAAC Interface publishes information to the Ethereum protocol in order to establish RAAC NFTs or other tokens or conduct transactions there. In this scenario, the associated personal information in the payload and metadata will be publicly viewable.
Law Enforcement Authorities and Individuals Involved in Legal Proceedings. RAAC will provide information to law enforcement in response to a request for information if we believe that disclosure is required by any applicable law, regulation, or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
To Protect the Rights of RAAC and Others. RAAC provides information to our legal advisors or law enforcement if we believe it is necessary to protect the rights, property, and safety of RAAC, our users, the public, or others.
Professional Advisors. RAAC provides information that may include your personal information to our legal, financial, insurance, and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
Corporate Transactions. RAAC provides information in connection with, or during negotiations of, certain corporate transactions, including a merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
Others With Your Consent or at Your Direction. RAAC may provide information to third parties when we have your consent or you direct us to do so.

YOUR CHOICES

Cookies and Similar Tracking Technologies

RAAC uses cookies and similar tracking technologies, as described above.

You can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect some of the functionality of our services, such as remembering your preferred language or enabling your participation in the reward points program.

UNITED KINGDOM, SWITZERLAND, AND THE EUROPEAN ECONOMIC AREA

Legal Basis for Processing

When you interact directly with Ethereum or use RAAC Interface to store information on the protocol, you are putting your information onto the protocol yourself, and RAAC is neither controlling nor processing your Wallet Data.

However, when RAAC controls and/or processes your personal information as described in this Privacy Notice, we do so in reliance on the following lawful bases:

Categories of Personal Information	Legal Basis for Processing
Information collected and processed for identity verification	Contract necessity: as necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract, for example when you agree to the terms of service and use the RAAC Interface; Legitimate interest: as necessary for the RAAC’s legitimate interests to verify your identity and ensure that RAAC can lawfully onboard you to use the RAAC Interface and its respective services; Legal Compliance: as necessary for compliance with a legal obligation, for example financial regulatory laws that require RAAC to “know our customer” and verify that users are not sanctioned parties or from a sanctioned jurisdiction where RAAC would be legally obligated to refuse to provide services
Information collected and processed to obtain iREET or stablecoins, or to redeem iREET or RAAC NFTs	Contract necessity: as necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract, for example when you want us to convert your real-property assets into an NFT or your fiat currency into stablecoins; Legitimate interest: as necessary for the RAAC’s legitimate interests to ensure that RAAC can lawfully assist you in obtaining NFTs, iREET, or stablecoins; Legal Compliance: as necessary for compliance with an applicable legal obligation
Information collected and processed to secure a loan from the RAAC ecosystem	Contract necessity: as necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract, for example when you want us to use your RAAC NFTs as collateral to secure a loan; Legitimate interest: as necessary for the RAAC’s legitimate interests to ensure that RAAC can lawfully assist you in securing a loan against your NFT collateral; Legal Compliance: as necessary for compliance with an applicable legal obligation
Information collected and processed to participate in an RAAC liquidity, lending, or stability pool	Contract necessity: as necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract, for example when you want us to invest or make a deposit in an RAAC pool to receive RAAC Tokens; Legitimate interest: as necessary for the RAAC’s legitimate interests to verify your financial assets and issue you RAAC Tokens; Legal Compliance: as necessary for compliance with an applicable legal obligation
Device Usage and Activity Information	Legitimate interest: as necessary for the RAAC’s legitimate interests to provide, maintain, and improve RAAC Interface, and conduct data analytics
Information Collected by Cookies and Similar Tracking and Analytics Technologies	Legitimate interest: as necessary for the RAAC’s legitimate interests to provide, maintain, and improve the RAAC Interface, and conduct data analytics; Consent
Data Collected from Oracles	Contract necessity: as necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract, for example when you want to use the RAAC Interface’s smart contracts functionality; Legitimate interest: as necessary for the RAAC’s legitimate interests to ensure that RAAC can lawfully assist you in creating and selling NFTs and to operate RAAC Interface; Legal Compliance: as necessary for compliance with an applicable legal obligation
Information RAAC Derives, such as inferences about your approximate location based on your IP address	Legal Compliance: as necessary for compliance with an applicable legal obligation

Data Subject Rights

With respect to your personal information that RAAC controls or processes, you have the right to (1) access your personal information, including in a portable format, (2) request erasure of your personal information, and (3) request correction of inaccurate personal information. In addition, you may have the right to (4) object to certain processing or (5) request restriction of certain processing. To exercise any of these rights, please contact us at admin@raac.io.

If you have a concern about RAAC’s processing of personal information, we encourage you to contact us as your first step. However, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the European Union: https://edpb.europa.eu/about-edpb/board/members_en

For individuals in the UK: https://ico.org.uk/global/contact-us/

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

International Transfers

Where applicable, RAAC takes steps, where necessary, to ensure that your personal information receives an adequate level of protection (by putting in place appropriate safeguards, such as contractual protections) or ensures that we can rely on an appropriate derogation under data protection laws. Where relevant, you may request access to any safeguard which we use to transfer your personal information outside of the European Economic Area, the United Kingdom, or Switzerland (although we may need to redact data transfer agreements for confidentiality reasons).

Data Retention

To the extent personal information is collected by RAAC during the onboarding process and/or the tokenization process, that data may be stored for up to 12 months, or for as long as necessary to carry out the purposes for which it was originally collected and for other business purposes explained in this Privacy Notice.

CONTACT US

If you have questions about this Privacy Notice, please contact RAAC’s Data Protection Officer: admin@raac.io