Privacy Policy

Effective Date: July 26, 2026

This Privacy Policy governs the collection, use, disclosure, and protection of information in connection with The Mark System™, a product of Flavian Systems LLC (“Company,” “we,” “our,” or “us”). This Privacy Policy applies to TheMarkSystem.com, our associated applications, digital services, marketplace, membership features, participation programs, and other services operated by the Company (collectively, the “Platform”).

By accessing or using the Platform, you acknowledge that your information may be collected, used, and disclosed as described in this Privacy Policy. If you do not agree with these practices, you should discontinue your use of the Platform.

1. About The Mark System™

The Mark System™ is a digital ecosystem that brings together verified identity, participation-based rewards, artificial intelligence services, digital credentials, membership features, and an exclusive digital marketplace.

Certain Platform features and services may require additional eligibility requirements, identity verification, account authentication, or possession of an eligible digital credential before access is granted.

This Privacy Policy explains how we handle information associated with these services and the choices available to you regarding your personal information.

2. Age and Identity Verification

Identity verification services provided through Civic or another approved identity verification provider are intended for individuals who are at least eighteen (18) years of age.

Certain Platform features may require successful identity verification before access is granted. These requirements may be implemented to support age eligibility, account integrity, fraud prevention, compliance obligations, and the secure operation of the Platform.

When you use a third-party identity verification service, your information may be collected and processed by that provider in accordance with its own privacy policy and applicable terms.

The Company may receive verification results, eligibility confirmations, or other information necessary to determine whether you qualify for specific Platform features. The information received and retained may depend on the verification method and the requirements of the applicable service.

3. Information We Collect

The information we collect depends on how you access and use the Platform, the features you choose to use, and the information you voluntarily provide.

3.1 Information You Provide

We may collect information that you submit directly to us, including:

Name and other identifying information.
Email address.
Username and account profile information.
Customer support requests and related communications.
Purchase, subscription, and transaction-related information.
Information submitted when participating in Platform activities, campaigns, or services.
Other information you voluntarily provide through the Platform.

You are responsible for ensuring that information you provide is accurate and up to date where necessary for your use of the Platform.

3.2 Wallet and Blockchain Information

If you choose to connect a cryptocurrency wallet or use blockchain-related features, we may collect or process information associated with that wallet, including:

Public wallet address.
Wallet provider or connection information.
Blockchain transaction records relevant to Platform functionality.
Digital credential ownership or eligibility information.
On-chain activity associated with supported Platform services.

Blockchain transactions may be recorded on publicly accessible networks. Information recorded on a public blockchain may remain accessible independently of the Company and may not be capable of being modified or deleted by us.

The Company will never request or store your wallet recovery phrase, private keys, or seed phrase. You are responsible for safeguarding your wallet credentials and authorizing transactions through your chosen wallet provider.

3.3 Identity Verification Information

Where identity verification is required, information may be collected directly by Civic or another approved provider. Depending on the service, the verification process may involve identifying information, age confirmation, identity documents, facial verification, or other information required by that provider.

The Company’s access to such information will depend on the verification arrangement and the information necessary to operate the relevant Platform feature.

We encourage users to review the privacy policies of third-party identity verification providers before submitting information to them.

3.4 Automatically Collected Information

When you access or use the Platform, certain technical and usage information may be collected automatically, including:

Internet Protocol (IP) address.
Browser type and version.
Operating system and device information.
Device identifiers and technical diagnostics.
Language preferences and time zone.
Access dates, timestamps, and session information.
Referring pages and pages visited.
Platform features accessed and interactions performed.

This information helps us understand how the Platform is used, maintain functionality, diagnose technical issues, and support security and fraud prevention efforts.

4. Platform Activity and Participation Data

To operate and improve The Mark System™, we may collect information concerning your interactions with the Platform, including:

Account activity and feature usage.
Marketplace browsing and interactions.
Purchase and transaction history.
Participation in supported activities and promotional campaigns.
Reward eligibility, accrual, and distribution records.
Digital credential and membership-related activity.
Artificial intelligence feature usage and related service interactions.

We may use this information to administer accounts, verify eligibility, calculate and distribute qualifying rewards, investigate suspicious activity, enforce Platform policies, and maintain operational records.

Where appropriate, activity information may be associated with your account, public wallet address, or digital credential.

5. Cookies and Similar Technologies

The Platform may use cookies, pixels, local storage, session technologies, analytics tools, and similar technologies to support its operation.

These technologies may be used to:

Maintain secure sessions and authentication.
Remember user preferences.
Understand traffic and Platform usage.
Improve performance and functionality.
Detect suspicious activity and prevent fraud.
Measure the effectiveness of supported campaigns.
Troubleshoot errors and enhance the user experience.

Where applicable, we may also use industry-standard security technologies, including X.509 digital certificates, to support secure communications, authentication, or related technical functions.

You may be able to control certain cookies through your browser settings or other privacy controls made available by the Platform. Disabling certain technologies may affect the availability or functionality of some features.

Where required by applicable law, we will provide appropriate notices and obtain consent for relevant cookies or similar technologies.

6. How We Use Information

The Company may use collected information for legitimate business and operational purposes, including:

Creating, maintaining, and administering user accounts.
Providing Platform features, products, and services.
Processing purchases and related transactions.
Administering memberships and digital credentials.
Facilitating access to The Mark Exchange™ and other restricted features.
Conducting or confirming identity and age verification.
Determining eligibility for participation programs and rewards.
Calculating and distributing qualifying rewards.
Maintaining security and preventing fraud, abuse, and unauthorized access.
Monitoring compliance with our Terms of Service and other applicable Platform policies.
Providing customer support and responding to inquiries.
Analyzing usage patterns and improving Platform functionality.
Diagnosing technical problems and maintaining system performance.
Communicating service announcements, policy updates, and other relevant notices.
Complying with applicable laws, regulations, legal processes, and enforceable governmental requests.
Establishing, exercising, or defending legal claims where necessary.

We may also use information for other purposes disclosed to you at the time of collection or otherwise permitted by applicable law.

7. Participation Rewards

Eligible users may receive participation rewards through supported Platform activities, subject to applicable eligibility requirements, campaign availability, verification requirements, fraud prevention measures, and the Terms of Service.

Certain qualifying participation rewards may be paid in U.S. dollars (USD). The availability, amount, timing, and eligibility of rewards may vary according to the applicable activity or campaign.

We may process information relating to participation, qualifying events, account eligibility, transaction records, and reward distributions to administer these programs and detect fraudulent or unauthorized activity.

Participation rewards are not guaranteed. The Company does not guarantee that any user will qualify for, earn, or receive a particular reward.

No Guarantee of Earnings or Rewards

Participation in The Mark System does not guarantee that you will earn money or receive rewards, and purchasing a membership or obtaining a verified seal does not guarantee earnings. Any rewards depend on qualifying activity, eligibility, availability, and the applicable program and payout requirements. The Mark System makes no promise of financial gain, trading profits, or future digital asset value.

8. How We Share Information

The Company does not sell your personal information. We may disclose information when reasonably necessary to operate the Platform, provide requested services, protect users, or fulfill legal obligations.

8.1 Service Providers

We may share relevant information with third-party service providers that perform services on our behalf, including:

Payment processors and transaction service providers.
Identity verification providers, including Civic.
Cloud hosting and infrastructure providers.
Analytics and performance monitoring providers.
Fraud prevention and security providers.
Customer support and communications providers.
Other vendors necessary to provide or maintain Platform services.

These providers may process information according to their contractual arrangements with us, their own applicable terms, and relevant legal requirements.

8.2 Platform Partners and Integrated Services

When you choose to use a third-party integration or service offered through the Platform, relevant information may be shared with that provider to enable the requested functionality, confirm eligibility, process transactions, or prevent fraud.

Third-party services may operate under separate privacy policies and terms. The Company does not control the independent privacy practices of third parties acting on their own behalf.

8.3 Legal and Regulatory Disclosures

We may disclose information when we reasonably believe disclosure is necessary to:

Comply with applicable laws, regulations, court orders, or legal processes.
Respond to lawful requests from governmental or regulatory authorities.
Protect the rights, property, or safety of the Company, users, or other individuals.
Investigate suspected fraud, security incidents, or violations of Platform policies.
Establish, exercise, or defend legal claims.

8.4 Business Transfers

If the Company undergoes a merger, acquisition, restructuring, financing, sale of assets, or similar business transaction, information may be transferred as part of that transaction, subject to applicable legal requirements and appropriate safeguards.

8.5 With Your Direction or Consent

We may share information when you direct us to do so, authorize a connection, or otherwise provide consent where required.

9. Data Retention

We retain information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including providing Platform services, maintaining account records, processing transactions, administering rewards, preventing fraud, resolving disputes, and meeting legal or regulatory obligations.

Retention periods may vary depending on the type of information, the nature of the service, account status, applicable legal requirements, and the need to preserve records for security or legitimate business purposes.

When information is no longer reasonably necessary for these purposes, we may delete it, anonymize it, or securely dispose of it, subject to applicable law and technical limitations.

Information recorded on public blockchains may remain publicly accessible even when associated information held by the Company is deleted.

10. Data Security

The Company implements commercially reasonable administrative, technical, and organizational safeguards designed to protect information against unauthorized access, disclosure, alteration, loss, or destruction.

These safeguards may include access controls, authentication measures, secure communications, system monitoring, and other protections appropriate to the nature of the information and the services provided.

However, no electronic transmission, storage system, or security measure can be guaranteed to be completely secure. Accordingly, we cannot guarantee absolute security.

You are responsible for maintaining the security of your account credentials, passwords, connected devices, and cryptocurrency wallets. You should never disclose your private keys, seed phrases, or wallet recovery phrases.

11. Third-Party Websites and Services

The Platform may contain links to, or integrations with, third-party websites, applications, payment services, identity verification providers, wallet providers, and other external services.

Your use of those services may be governed by separate terms and privacy policies. The Company is not responsible for the privacy, security, or data handling practices of independent third parties.

We encourage you to review the applicable policies before providing information to any third-party service.

12. Your Privacy Rights and Choices

Depending on your location and applicable law, you may have rights concerning your personal information, which may include the right to:

Request access to certain personal information we maintain about you.
Request correction of inaccurate personal information.
Request deletion of certain personal information.
Request a copy of eligible information in a portable format.
Object to or request restrictions on certain processing activities.
Withdraw consent where processing is based on consent.
Opt out of certain marketing communications.
Lodge a complaint with an appropriate data protection authority.

These rights are subject to applicable legal conditions and exceptions. Certain records may need to be retained to satisfy legal obligations, complete transactions, prevent fraud, resolve disputes, or maintain the integrity of the Platform.

We may need to verify your identity before processing a privacy request. You may submit a request through the Platform’s designated contact channel.

13. Children's Privacy

The Platform's identity verification features provided through Civic or another approved identity verification provider are intended for individuals aged eighteen (18) or older.

Features subject to age or identity restrictions may not be accessed until the applicable requirements have been satisfied.

We do not knowingly seek to collect personal information from children in violation of applicable law. If you believe a child has provided personal information to the Company in circumstances where such collection is not permitted, please contact us so that we can review the matter and take appropriate action.

14. International Data Processing

The Company and its service providers may process or store information in jurisdictions other than the jurisdiction in which you reside.

Where information is transferred across borders, we will take steps required by applicable law to support appropriate protection of that information.

The privacy protections and legal requirements applicable in another jurisdiction may differ from those in your place of residence.

15. Changes to This Privacy Policy

The Company reserves the right to revise, update, or amend this Privacy Policy from time to time to reflect changes in Platform functionality, business operations, service providers, legal requirements, or data handling practices.

Updates will be published on this page with the revised effective date, where appropriate.

Your continued use of the Platform following the effective date of a revised Privacy Policy will be subject to the revised policy to the extent permitted by applicable law. Where additional notice or consent is legally required, we will provide it.

We encourage you to review this page periodically to remain informed about our privacy practices.

16. Contact Information

For questions, concerns, or requests relating to this Privacy Policy or the handling of your personal information, please contact the Company through the designated contact channel available at TheMarkSystem.com.

Flavian Systems LLC

The Mark System™

Website: https://TheMarkSystem.com

Android Advertising and Pangle

The Mark System Android application uses Pangle to provide optional rewarded video advertisements. When the Android application is used, Pangle and its service providers may process the device advertising identifier, Internet Protocol address, IP-derived approximate location, device and application information, advertising interactions, advertising data, and diagnostic or performance information. This information is used to deliver and measure advertisements, limit ad frequency, detect invalid traffic and fraud, maintain security, and comply with applicable requirements.

Rewarded advertisements are optional and are shown only after the user chooses to watch one. The application respects Android advertising-ID controls. If a user deletes the Android advertising identifier, the application does not attempt to reconnect the replacement value to information derived from the deleted identifier. Pangle processes information under its own privacy terms at https://www.pangleglobal.com/privacy.