PRIVACY POLICY

This Privacy Policy explains how 54 Projects LLC ("54 Projects", "we", "us"), the developer and operator of Mazipan OS, collects, uses, shares and protects personal information when you visit mazipanos.com or use the Mazipan OS platform (together, the "Platform").

Mazipan OS is an institutional platform used by organizations such as project sponsors, capacity buyers, escrow agents, insurers, lenders, equipment suppliers, contractors and their advisors. The personal information we handle is mostly business contact and account information about the people who act for those organizations. Confidential commercial information that organizations place on the Platform is also governed by the agreements under which they participate, such as the Platform Participation terms and any non-disclosure agreements.

1. Information We Collect

Information you give us

• Registration and access requests: name, organization, title or role, business email address, telephone number, participant category, and any information you include in your request.
• Account and onboarding information: details of the organization you represent, your role within it, and documents or information provided during onboarding.
• Platform activity: information you or your organization enter or upload in a workspace, such as capacity declarations, reservation details, project documents, messages and approvals, together with records of who created, viewed, shared or changed them.
• Correspondence: messages you send us by email or through contact and inquiry forms.

Information collected automatically

• Technical and security information: IP address, browser and device type, pages requested, date and time of access, and sign-in events. This is processed by our hosting and infrastructure providers to deliver the Platform, keep it secure and investigate misuse.
• Sign-in storage: when you sign in, our authentication service stores a session token in your browser so you stay signed in. This is strictly necessary for the Platform to work and is not used for advertising.
• Website analytics: on our public pages we use Cloudflare Web Analytics, a privacy-focused service that counts page visits without cookies and without tracking individual visitors. It is not used inside signed-in workspaces.

We do not use advertising or cross-site tracking cookies.

2. How We Use Information

• To review access requests, create and manage accounts, and verify that users act for the organizations they represent.
• To operate the Platform: publishing capacity declarations, supporting reservations, enabling workspaces, and sharing information with the participants your organization chooses.
• To maintain records of Platform activity, including audit and access records, so that participants can rely on the integrity of transaction records.
• To communicate with you about your account, Platform changes, and the projects and transactions you are involved in.
• To secure the Platform, prevent fraud and misuse, and troubleshoot problems.
• To comply with legal, regulatory and contractual obligations, and to establish, exercise or defend legal claims.

3. How Information Is Shared

We do not sell personal information, and we do not share it for advertising. We share it only as follows:

• With other participants, as directed: Mazipan OS is built so that each organization works in its own workspace and sees only what is shared with it. Information you or your organization share with a project, a counterparty or a service provider on the Platform is visible to them under those permissions.
• With service providers: companies that host, secure and support the Platform for us, including Google Cloud and Firebase (hosting, database, storage and authentication), Cloudflare (website analytics and network services) and email delivery providers. They may use the information only to provide their services to us.
• Within our group: with affiliates of 54 Projects where needed to operate the Platform. Some projects listed on Mazipan OS are sponsored by an affiliate of 54 Projects; such projects are labeled on the Platform and treated under our Conflicts of Interest Policy, and affiliated sponsors do not receive other participants' information except as those participants share it through the Platform.
• For legal reasons: where required or permitted by law, including to regulators, courts or law enforcement, or to protect the rights, property or safety of 54 Projects, Platform participants or others.
• In a business transaction: in connection with a merger, financing, reorganization or sale of all or part of our business, subject to confidentiality protections.

4. Retention

We keep account information while your account is active. Records of Platform activity, including reservation, escrow, project and audit records, are kept for as long as needed to support the transactions they relate to and to meet legal, regulatory, accounting and contractual record-keeping requirements. Correspondence and access requests are kept for as long as needed to respond and maintain ordinary business records. We then delete or anonymize information.

5. Security

The Platform is served over encrypted connections, and access to workspaces is controlled by sign-in and role-based permissions. We take reasonable technical and organizational measures to protect information, but no system is completely secure. Please notify us promptly at privacy@mazipanos.com if you believe your account has been compromised.

6. International Transfers

54 Projects is based in the United States, and the Platform is hosted on infrastructure that may process information in the United States and other countries. Data protection laws there may differ from those in your country. Where required, we rely on appropriate safeguards for these transfers, such as the European Commission's Standard Contractual Clauses.

7. Your Choices and Rights

You may ask us to access, correct or delete personal information we hold about you, or to stop contacting you, by emailing privacy@mazipanos.com. Some information may need to be kept where it forms part of transaction or audit records that other participants rely on, or where the law requires it; in that case we will explain what we can and cannot do. We may need to verify your identity before responding.

European Economic Area and United Kingdom

54 Projects LLC is the controller of personal information processed through the Platform, except where a participant organization determines how its own users' information is used, in which case that organization is responsible for it. We process personal information to perform our agreements with participants, on the basis of our legitimate interests in operating a secure and reliable institutional platform, to comply with legal obligations, and with consent where the law requires it. You have the right to access, correct, erase, restrict or object to processing of your personal information, to data portability, and to withdraw consent at any time, and you may complain to your local data protection authority.

California residents

We collect the categories of personal information described above, namely identifiers, professional information and internet activity, for the purposes described in this policy. We do not sell personal information or share it for cross-context behavioral advertising. To the extent California law applies, you may request to know, correct or delete the personal information we hold about you, and we will not discriminate against you for making a request.

8. Children

The Platform is intended for institutional and professional users and is not directed to children.

9. Changes to This Policy

We may update this policy from time to time. We will post the updated version on this page with a new date and, where changes are significant, notify registered users.

10. Contact

For privacy questions or requests, contact privacy@mazipanos.com. Mazipan OS is developed and operated by 54 Projects LLC.