Privacy Policy

Blockchain technology, also known as distributed ledger technology (or simply “DLT”), is at the core of our Services. Blockchains are decentralized and made up of digitally recorded data in a chain of packages called “blocks.” The manner in which these blocks are linked is chronological, meaning that the data is very difficult to alter once recorded. Since the ledger may be distributed all over the world (across several “nodes” which usually replicate the ledger), there is no single person making decisions or otherwise administering the system, and there is no centralized place where it is located.

This means that by design, a blockchain’s records cannot be changed or deleted and is said to be “immutable.” This may affect your ability to exercise your rights such as your right to erasure (“right to be forgotten”), or your rights to object or restrict processing, of your personal data. Data on the blockchain cannot be erased or changed. Although smart contracts may be used to revoke certain access rights, and some content may be made invisible to others, it is not deleted.

Certain information is public by nature, including your wallet address, on-chain transaction history, token balances, and trading positions. This information is visible to anyone on the Internet due to the nature of the blockchain, whether or not they have an account with us. Public blockchain data may also be accessed, indexed, or reshared through APIs, analytics platforms, or third-party services. Our analytics Services aggregate and present publicly available blockchain data. We process such data on the basis of our legitimate interests in providing blockchain analytics services. We do not attempt to identify the natural persons behind wallet addresses that are not linked to Datadash accounts, and we do not require separate consent to index or display data that is inherently public by design of the blockchain.

In certain circumstances, in order to provide our Services (such as wallet-based authentication, on-chain analytics, or facilitating non-custodial trades), it will be necessary to reference or process certain personal data, such as your wallet address, from the blockchain. When you execute trades through our interface, the resulting transactions are written to the blockchain by your wallet — we do not custody your funds or execute transactions on your behalf.

We treat wallet addresses as personal data when they are linked to your account or can otherwise be used to identify you. Even where a wallet address alone may appear pseudonymous, we recognize that linking it to account information (such as your email or authentication credentials) renders it identifiable personal data under applicable law.

In most cases, ultimate decisions to (i) transact on the blockchain using your wallet address, as well as (ii) share the public key relating to your wallet address with anyone (including us) rests with you.

If you want to ensure your privacy rights are not affected in any way, you should not transact on blockchains as certain rights may not be fully available or exercisable by you or us due to the technological infrastructure of the blockchain. The blockchain is available to the public and any personal data shared on the blockchain will become publicly available.

Third-Party Wallet Connections

Certain features of the Services may require you to connect a compatible third-party digital wallet. By using such wallet, you agree that your interactions with the wallet are governed by the applicable wallet provider’s terms and privacy policy. Wallets are not maintained, supported by, or affiliated with Datadash FZCO. We expressly disclaim any and all liability for actions arising from your use of third-party wallets, including actions relating to the use or disclosure of personal information by such wallet providers.

When you connect your wallet to our Services through a third-party authentication provider, we may receive information from that provider about you and your wallet, including your wallet address and authentication status. We will use such information in accordance with this Policy. Information shared with the third-party provider is governed by its own privacy policy.

As per our Terms of Service, individuals under the age of 18 are not permitted to use the Services. As such, we do not knowingly collect, solicit, or maintain personal data from anyone under the age of 18 or knowingly allow such persons to register for the Services.

In the event that we learn that we have collected personal data from an individual under age 18, we will use commercially reasonable efforts to delete that information from our database. Please contact us if you have any concerns. If you are a parent or guardian and become aware that your child has shared personal data with our Services, please contact us so that we may remove such data. Note that we cannot delete information stored on public cryptographic blockchains.

Information You Provide Directly

We collect the content, communications, and other information you provide when you use our Services, including when you create an account, initiate the use of the Services, create or share content, and message or communicate with others. This information may include, but is not limited to:

• Email address
• Wallet address(es)
• Display name or username
• Profile information you choose to provide
• Financial information related to your trading activity (e.g., positions, order history, profit and loss)

Information Used to Verify Your Identity

If required to help us verify your identity, you may provide us with verification documents or information as may be necessary to comply with applicable anti-money laundering, counter-terrorism financing, and know-your-customer laws and regulations. By providing verification information and documents, you also provide us information within those records, which may include characteristics of protected classifications like your age, national origin, and citizenship.

Information Collected Automatically

We collect information about how you use our Services, such as the types of content you view or engage with; the features you use; the actions you take; the cohorts, insights, or analytics views you create; trades you initiate or execute through our interface; and the time, frequency, and duration of your activities.

Information About Transactions

If you use our Services to execute trades or other on-chain transactions, we collect information about those transactions, including transaction hashes, token amounts, market identifiers, and associated wallet addresses. Because our Services are non-custodial, we do not have access to your private keys or direct control over your funds.

Information Others Provide About You

We also receive and analyze content, communications, and information that other people provide when they use our Services.

Correspondence

If you contact us, we will collect and retain the content of the communications we have with you and any personal data contained within, including the email address you used to contact us.

We, and our partners, use cookies and similar technologies to give you the best possible content and experience. Cookies are used to remember you and to collect information about how you interact with the Services. If you have an account with the Services, we may link this usage data with other information. You may have the option to either accept or refuse these cookies. If you choose to refuse, you may not be able to use some portions of the Services.

We may also use web beacons, clear gifs, pixel tags, and similar tracking technologies to collect usage data about how you interact with the Services. These technologies may be used in conjunction with cookies to understand usage patterns, diagnose technical issues, and improve the Services.

Because recognition of the Do Not Track (DNT) HTTP header is not standardized, the Services do not currently recognize or respond to DNT signals.

We collect information from and about the computers, phones, and other web-connected devices you use that interact with our Services, and we combine this information across different devices you use.

Information we obtain from these devices includes:

• Device operations: information about operations and behaviors performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).
• Identifiers: unique identifiers, device IDs, and other identifiers.
• Network and connections: information such as the name of your mobile operator or ISP, language, time zone, IP address, connection speed, and in some cases, information about other devices that are nearby or on your network.
• Cookie data: data from cookies stored on your device, including cookie IDs and settings.
• Location information: we may derive approximate location information from your IP address for fraud prevention, regulatory compliance, and analytics purposes.

When using the Services, we may collect and process personal data. The data will be stored in different instances. We collect and use this information to provide you the Services and to debug issues and provide support.

• On the Blockchain the following data may be referenced or processed:
  • Addresses of externally owned accounts
  • Transactions made (including trades executed through our interface)
  • Token balances, trading positions, and portfolio data

The data on the blockchain is publicly available by design. Given the technological design of the blockchain, this data will become public and it will not likely be possible to delete or change the data at any given time.

• In our web servers, we may store the following data:
  • Wallet addresses of externally owned accounts
  • Log data
  • Internet protocol address (“IP address”)
  • User-created content (cohorts, insights, saved views)
  • Error and performance telemetry

We use the information we have (subject to choices you make) as described below and to provide and support the Services.

Legal Basis for Processing

We process your personal data on the following legal bases:

• Contractual necessity— to provide, operate, and maintain the Services you have requested, including executing trades through our non-custodial interface and delivering analytics features.
• Legitimate interest— to improve our Services, conduct internal analytics, ensure platform security, and detect and prevent fraud, where such interests are not overridden by your rights.
• Consent— for marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Legal obligation— to comply with applicable anti-money laundering, tax, regulatory, and law enforcement requirements. We may also process geolocation and wallet data to determine whether you are a restricted person under our Terms of Service or applicable sanctions laws.

Provide, Personalize, and Improve Our Services

We use the information we have to deliver our Services, including to personalize features and content.

• Product research and development: We use the information we have to develop, test, and improve our Services, including by conducting surveys and research, and testing and troubleshooting new products and features.

Provide Measurement, Analytics, and Other Business Services

We use the information we have (including your activity on our Services) to understand the types of people who use our Services and how people interact with our platform.

Promote Safety, Integrity, and Security

We use the information we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Services, and promote safety and security.

Communicate With You

We use the information we have to send you marketing communications, communicate with you about our Services, and let you know about our policies and terms. We also use your information to respond to you when you contact us.

Automated Processing

We may use automated processing to analyze publicly available trading patterns, generate analytics, and classify wallets into cohorts. These analyses are informational in nature and do not produce legal or similarly significant effects on individuals. No automated decisions are made that restrict access to the Services.

Third parties may collect or receive certain information about you and/or your use of the Services to provide content or functionality, or to measure and analyze performance, in or through the Services. These third parties fall into the following categories:

• Authentication and wallet providers– to enable account creation, login, and wallet connection
• Hosting and infrastructure providers– to serve, deploy, and maintain the Services
• Error monitoring and performance providers– to detect, diagnose, and resolve technical issues
• Content delivery and security providers– to protect the Services from malicious activity and deliver content efficiently
• Analytics providers– to understand usage patterns and improve the Services
• Blockchain infrastructure providers– to read from and interact with public blockchains

Each of these third-party service providers operates under its own privacy policy and terms of service. We encourage you to review their respective policies. For a current list of our third-party service providers, please contact us at the email provided in this policy.

The Services may contain links to third-party websites, applications, or services. We do not control the information collection practices of any third-party service. Any information you provide to a third party is governed by that party’s privacy policy, not ours, and we cannot guarantee the safety or privacy of your information on third-party platforms.

The Services may retain the information we gather about you for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law.

To request that information collected about you be deleted, please contact us at the email provided in this policy. A valid request must include sufficient information to identify your personal data. Note that we cannot delete information stored on public cryptographic blockchains.

The Services only share information about you with others as follows:

• We do not sell your personal information to third parties.
• We may transfer your personal data to a third party as a result of a business combination, merger, asset sale, reorganization, or similar transaction, or to governmental authorities when we reasonably believe it is required by law or appropriate to respond to legal process.
• We will share your information with third-party companies, organizations, or individuals if we have a good faith belief that access, use, preservation, or disclosure of your information is reasonably necessary to detect or protect against fraud or security issues, enforce our terms of use, meet any enforceable government request, defend against legal claims, or protect against harm to our legal rights or safety. In any such event, and to the extent legally permitted, we will notify you and, if there are material changes in relation to the processing of your data, give you an opportunity to consent to such changes.
• To operate the Services, we share information about you as needed with our service providers, including information technology consultants, advisors, and our affiliates. We only share information to the extent it is required to fulfill our obligations to you and to regulators, and to operate the Services.
• We routinely share information with companies closely related to us — our “affiliates” — for certain purposes under this policy. Our affiliates will be entitled to enjoy our rights under this Privacy Policy and we will be responsible for our affiliates’ conduct related thereto.
• We may share aggregated or de-identified information, which cannot reasonably be used to identify you.

Depending on your location, you may have certain rights regarding your personal information under applicable data protection laws, including:

• Access to your personal information
• Correction of inaccurate or incomplete information
• Deletion of your personal information (subject to blockchain immutability limitations described in Section 1)
• Restriction of processing of your personal information
• Data portability
• Objection to processing
• Withdrawal of consent where processing is based on consent, without affecting the lawfulness of prior processing

To exercise these rights, please contact us using the details provided in the “Contact Us” section. Please note that, prior to any response to such request, we may require you to verify your identity. In addition, we may have valid legal reasons to refuse your request and will inform you if that is the case.

These rights may be limited by law. Such limitations may apply, for example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interests, or where we are required by law to retain your personal data.

If you wish to stop receiving marketing or promotional communications or to opt out of use of your information for the purposes described in this policy, please follow the opt-out instructions, such as clicking “Unsubscribe” (or similar opt-out language), in those communications. You can also contact us at the email below to opt out. Despite your indicated email preferences, we may send you service-related communications, including notices of any updates to our terms of service or this policy.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

No method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security. Any transmission of personal information is at your own risk.

We may transfer your personal information to countries other than the one in which you live. When we do, we deploy appropriate safeguards as required by applicable law, which may include Standard Contractual Clauses (SCCs), adequacy decisions, or binding contractual commitments, to ensure your data is protected in accordance with this policy and applicable law.

This Policy takes into account the requirements of the UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection and general privacy principles.

Individuals located in the European Union and the United Kingdom may have rights under the EU General Data Protection Regulation 2016/679 and the UK General Data Protection Regulation, respectively. You may file a complaint with the data protection supervisory authority in the EEA country in which you live or work, or with the UK Information Commissioner’s Office, as applicable.

This Privacy Policy shall be governed by and construed in accordance with the laws of the United Arab Emirates. The Services are operated from the UAE and are not intended to subject the operator to the laws or jurisdiction of any state, country, or territory other than the UAE, except as required by applicable law.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice. Check this page for the latest version.

Your continued use of the Services following the posting of changes to this Privacy Policy will be deemed your acceptance of those changes. If you do not agree to the revised policy, please discontinue use of the Services.

If you have comments or questions about the privacy policies of the Services, please contact us at contact@datadash.xyz.