PHANTOM OF THE OPERA POLICY

Valley of New Angels LLC (VONA) receives all cryptocurrency payments, transfers, and deposits on behalf of parent holding company Poltergeist LLC. 

VONA accepts privacy‑focused cryptocurrency payments to protect the anonymity and security of artists, producers, labels, A&R representatives, and other clients. All transactions and holdings are conducted using self‑custodial wallets; Neither VONA nor Poltergeist store client funds on third‑party exchanges. We record and report transaction information as required by applicable tax and reporting laws while seeking to preserve client privacy consistent with those obligations. Clients who pay with cryptocurrency are registered internally by the generic designation “Artist” without personal identifiers. If a client provides an email via projectvona.net, that email will be deleted from our systems within 72 hours after service completion. VONA minimizes collection and retention of personally identifiable information related to cryptocurrency transactions and implements reasonable technical and administrative safeguards to protect anonymity. However, we cannot guarantee that third parties, authorities, or others will be unable to trace payments, wallets, or metadata to an individual. 

VONA will not assist private parties in de-anonymization efforts and will only disclose information when compelled/forced by valid legal process. VONA is not responsible for tracing or identification by external parties or for security breaches on client devices, wallets, or services outside our control. Services are one‑time transactions; after completion and settlement, VONA’s obligations end unless otherwise agreed in writing. If a client voluntarily reveals their identity or links themselves to a transaction, the seller is not responsible for resulting consequences. VONA may amend this policy at any time; material changes will be posted on projectvona.net.

VONA Cryptocurrency & Confidentiality Policy (“Phantom of the Opera Policy”)
Effective Date: 8 – 20 – 2025

Last Revised: 8 – 20 – 2025

1. Purpose and Scope:
1.1 • This Policy sets forth VONA’s practices, obligations, and limitations concerning the acceptance, handling, retention, reporting, and confidentiality of cryptocurrency payments and related client information. It applies to all persons and entities that transact with VONA using cryptocurrency (each, an “Artist” or “Client”) and to VONA personnel, contractors, agents, and affiliates involved in receiving, recording, storing, or otherwise processing such transactions.

2. Definitions:
• “Cryptocurrency” — digital assets, tokens, or coins used for payment, including, without limitation, privacy‑focused coins.
• “Self‑custodial Wallet” — a cryptocurrency wallet under the control of VONA or the Client where private keys are held outside of third‑party custodial exchanges.
• “Identifying Information” — any information that could reasonably be used to identify an individual, including but not limited to name, physical address, government identification numbers, email address, telephone number, or IP address.
• “Service Completion” — the point at which VONA has fulfilled the contracted service and the related cryptocurrency transaction is finalized.

3. Acceptance and Handling of Cryptocurrency
3.1 • Payment Methods. VONA accepts payment in specified cryptocurrencies as posted on VONA’s website. VONA may, in its sole discretion, add or remove accepted cryptocurrencies at any time.

3.2 • Custody and Storage. VONA conducts all cryptocurrency transactions and maintains holdings using self‑custodial wallets under VONA’s control. VONA does not maintain client funds on third‑party custodial exchanges except where expressly required and disclosed.

3.3 • Transaction Records. VONA will maintain internal transaction records reasonably necessary for accounting, auditing, tax reporting, and compliance with applicable laws. Such records will avoid unnecessary Identifying Information; clients will be referred to and registered in internal records by the generic designation “Artist” unless additional information is required by law or a separate, signed agreement.

4. Privacy, Anonymity and Data Retention
4.1 • Minimal Data Collection. VONA collects the minimum personal data necessary to provide services and comply with applicable legal obligations.

4.2 • Email and Contact Data. If a Client elects to provide an email address via VONA’s website (projectvona.net) or otherwise, VONA will retain such email only for the period necessary to complete the requested service and for up to 72 hours following Service Completion, after which the email will be deleted from active systems. Backups or archival processes may retain residual copies for a commercially reasonable period consistent with VONA’s backup retention practices and legal obligations; however, VONA will take commercially reasonable measures to purge such data promptly where practicable.

4.3 • Non‑identification in Records. Except where lawfully required otherwise, VONA’s internal systems will not associate transactions with personal identifiers beyond the designation “Artist.”

5. Legal Compliance and Reporting
5.1 • Compliance with Law. VONA will comply with applicable national and international tax, reporting, and regulatory requirements, including obligations to report transaction information to tax authorities or other government entities as required by law. VONA will endeavor to reconcile its privacy practices with applicable legal obligations in a manner that preserves client anonymity to the extent legally permissible.

5.2 • Legal Process and Compelled Disclosure. VONA will not voluntarily disclose Identifying Information to third parties, except (a) as required by binding legal process, such as a valid court order, subpoena, or other lawful demand; (b) to protect VONA’s rights or property; or (c) to prevent fraud or illegal activity where disclosure is necessary and lawful. If compelled by lawful process, VONA will comply to the extent required by law and will notify the Client of such process where permitted and practicable, unless prohibited by law or court order.

6. Limitations of Anonymity; No Guarantee of Non‑Tracing
6.1 • No Absolute Anonymity. VONA provides tools and practices intended to enhance Client privacy; however, VONA makes no representations or warranties, express or implied, that any transaction is, or will remain, anonymous or untraceable. External parties, including blockchain analytics companies, service providers, hosting providers, or government authorities, may possess or obtain technical means to link transactions, wallet activity, or metadata to particular individuals.

6.2 • No Assistance in Deanonymization. VONA will not assist private parties, third‑party investigators, or other non‑governmental entities in efforts to deanonymize or identify Clients. VONA expressly disavows any obligation to aid in such efforts unless compelled by lawful process.

6.3 • Client Responsibility. Clients are solely responsible for the security of their own devices, wallets, and any actions they take that could reveal their identity (including, but not limited to, publishing transaction details or otherwise linking transactions to identifiable information).

7. Scope of Services and Post‑Completion Relationship
7.1 • One‑Time Transaction Nature. Unless otherwise set forth in a written agreement signed by VONA and the Client, VONA’s services related to any specific transaction are one‑time in nature. Upon Service Completion and settlement of the related cryptocurrency transaction, VONA’s contractual obligations with respect to that service terminate, subject only to any surviving provisions expressly stated in the applicable service agreement or required by law.

7.2 • No Ongoing Monitoring or Liability. After Service Completion, VONA will have no duty to monitor Client conduct, prevent disclosure by the Client, or otherwise act on behalf of the Client with respect to subsequent uses or disclosures of work product or transactional information.

8. Representations, Warranties and Disclaimers
8.1 • No Guarantee of Legal Compliance by Client. Clients represent and warrant that they will not use VONA’s services for unlawful purposes. VONA expressly disclaims liability for Clients’ unlawful acts or for any consequences arising from Clients’ voluntary disclosure of their identity.

8.2 • Disclaimer of Certain Warranties. EXCEPT AS EXPRESSLY PROVIDED IN A WRITTEN AGREEMENT BETWEEN VONA AND A CLIENT, VONA MAKES NO WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR WARRANTIES REGARDING THE ABSOLUTE ANONYMITY, SECURITY, OR NON‑TRACEABILITY OF ANY TRANSACTION.

9. Indemnification and Limitation of Liability
9.1 • Indemnification. Clients will indemnify, defend, and hold harmless VONA and its officers, directors, employees, agents, and affiliates from and against any claims, losses, liabilities, damages, costs, and expenses (including reasonable attorneys’ fees) arising out of or relating to Client’s use of VONA’s services, breach of this Policy, or unlawful conduct.

 9.2 • Limitation of Liability. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, VONA’S AGGREGATE LIABILITY ARISING OUT OF OR RELATING TO THIS POLICY OR ANY TRANSACTION SHALL NOT EXCEED THE AMOUNT PAID BY THE CLIENT FOR THE APPLICABLE SERVICE. IN NO EVENT SHALL VONA BE LIABLE FOR SPECIAL, INCIDENTAL, EXEMPLARY, PUNITIVE, OR CONSEQUENTIAL DAMAGES.

10. Security Measures:
VONA will implement commercially reasonable administrative, technical, and physical safeguards designed to protect transactional data and limited client information from unauthorized access, disclosure, alteration, or destruction. Clients acknowledge that no security measures are perfect or impenetrable.

11. Amendments:
VONA may amend this Policy at any time. Material changes will be published on VONA’s website with the effective date. Continued use of VONA’s services following posting of amendments constitutes acceptance of the amended Policy.

12. Governing Law and Dispute Resolution:
This Policy is governed by the laws of Pennsylvania. Any dispute arising under or in connection with this Policy shall be resolved in the competent courts of Pennsylvania, unless the parties mutually agree to alternative dispute resolution.

13. Miscellaneous
13.1 • Severability. If any provision of this Policy is held invalid or unenforceable, the remaining provisions shall remain in full force and effect.

13.2 • Entire Agreement. This Policy, together with any written service agreement between VONA and a Client, constitutes the entire understanding regarding the subject matter herein and supersedes prior agreements and understandings.

Contact For questions regarding this Policy, please contact: contact@projectvona.net
End of Policy.