GDPR Policy (EU & UK)

Last updated: September 3, 2025

1. Introduction

This policy applies to individuals residing in the European Union (EU) and the United Kingdom (UK) under the General Data Protection Regulation (GDPR) and the UK GDPR. American Sub N Grill LLC ("the Company") is committed to protecting your personal data and respecting your privacy.

2. Data Controller

The data controller for your personal information is American Sub N Grill LLC, located at 1317 Edgewater Dr STE 3252, Orlando, FL 32804.

3. Legal Basis for Processing Personal Data

We process your personal data on the following legal bases:

  • Consent: Where you have given clear consent for us to process your personal data for a specific purpose (e.g., signing up for our newsletter).
  • Contract: Where processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract (e.g., creating an account to purchase SNGLL tokens).
  • Legal Obligation: Where processing is necessary for us to comply with the law (e.g., conducting KYC/AML checks).
  • Legitimate Interests: Where processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests (e.g., for fraud prevention or network security).

4. Your Data Protection Rights

Under GDPR, you have the following rights:

  • The right to access – You have the right to request copies of your personal data.
  • The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete information you believe is incomplete.
  • The right to erasure – You have the right to request that we erase your personal data, under certain conditions. Please note that data on the blockchain cannot be erased.
  • The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
  • The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
  • The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
  • The right to withdraw consent – You have the right to withdraw your consent at any time where we relied on your consent to process your personal information.

5. International Data Transfers

Your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place, such as Standard Contractual Clauses (SCCs).

6. Data Retention

We will retain your personal data only for as long as is necessary for the purposes set out in our Privacy Policy. We will retain and use your data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

7. How to Exercise Your Rights

If you wish to exercise any of the rights set out above, please contact our Data Protection Officer at:

Email: compliance@sngll.org

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

8. Complaints

You have the right to make a complaint at any time to the supervisory authority for data protection issues in your country of residence.