# Privacy Policy *Last Updated: October 1, 2025* PrivateBond ## Table of Contents - [Introduction](#introduction) - [Definitions](#definitions) - [Scope](#scope) - [Information We Collect](#information-we-collect) - [How We Use Your Information](#how-we-use-your-information) - [How We Share Your Information](#how-we-share-your-information) - [International Data Transfers](#international-data-transfers) - [Data Security](#data-security) - [Data Retention](#data-retention) - [Your Choices and Rights](#your-choices-and-rights) - [Children's Privacy](#childrens-privacy) - [Changes to This Policy](#changes-to-this-policy) - [Contact Us](#contact-us) ## Introduction Welcome to PrivateBond. We are committed to protecting your privacy and providing transparency about our data practices. This Privacy Policy explains how we collect, use, store, disclose, and protect information when you interact with our website, mobile application, or services (collectively, the "Platform"). By accessing or using the Platform, you consent to the practices described in this Policy. This Policy applies to all users, including those engaging with our blockchain features such as digital wallets, non-fungible tokens (NFTs), smart contracts, and related technologies. If you do not agree with this Policy, please do not use the Platform. We may collect personal information from users worldwide, but our practices are designed to comply with applicable laws, including the General Data Protection Regulation (GDPR) in the European Union and the California Consumer Privacy Act (CCPA) in California. ## Definitions To ensure clarity, here are key terms used in this Policy: - **Personal Information**: Any information that identifies, relates to, or could reasonably be linked with you as an individual, such as wallet addresses or device identifiers. - **Usage Data**: Non-personal information about how you interact with the Platform, such as access times and pages viewed. - **Blockchain Data**: Information recorded on public blockchains, including transaction details and wallet addresses, which is inherently immutable and publicly accessible. - **Processing**: Any operation performed on data, such as collection, storage, use, or disclosure. - **Service Providers**: Third parties we engage to support Platform operations, such as cloud hosting or analytics providers. ## Scope This Policy covers information we collect through the Platform, including via blockchain integrations. It does not apply to: - Information collected by third-party sites or services linked from our Platform (e.g., external wallet providers). - Practices of companies we do not own or control, even if they interact with our Platform. - On-chain data governed by blockchain protocols, which we cannot alter or delete. If you connect third-party services (e.g., a digital wallet), their privacy policies may also apply. ## Information We Collect We collect information in the following categories. We do not collect sensitive personal information such as private keys, seed phrases, or financial details beyond what is necessary for blockchain interactions. 1. **Personal Information**: Provided directly by you or automatically during authentication, including: - Cryptocurrency wallet addresses when connecting for access or transactions. - Contact information if you submit inquiries (e.g., email address). - Any other details you voluntarily provide, such as in feedback forms. 2. **Usage Data**: Automatically collected when you use the Platform, including: - Device information (e.g., IP address, browser type, operating system). - Interaction data (e.g., pages viewed, time spent, content uploads, links generated). - Metadata from blockchain transactions (e.g., timestamps, transaction IDs). - Cookies and similar technologies: We use essential cookies for functionality (e.g., session management) and analytics cookies to understand usage patterns. You can manage cookie preferences via your browser settings. 3. **Blockchain Data**: Publicly visible information inherent to blockchain use, such as: - Wallet addresses and transaction details recorded on the blockchain. - NFT metadata or smart contract interactions. - Note: We do not control or store private keys; all blockchain data is processed non-custodially. We do not collect information about your race, ethnicity, health, or other sensitive categories unless inadvertently included in User Content, which we process automatically without review. ## How We Use Your Information We use your information for the following purposes, based on legal grounds such as your consent, our legitimate interests (e.g., service improvement), or contractual necessity: 1. To operate and maintain the Platform, including authenticating users via wallets, processing and transforming User Content (e.g., watermarking, compression), and generating shareable links. 2. To facilitate blockchain-based features, such as connecting digital wallets, minting or transacting NFTs, and executing smart contracts. 3. To improve our services, analyze usage patterns, develop new features, and conduct internal research (legitimate interest). 4. To comply with legal obligations, respond to law enforcement requests, or enforce our Terms of Service (legal obligation). 5. To communicate with you, such as sending service updates or responding to inquiries (consent or contractual necessity). 6. For security and fraud prevention, including monitoring for suspicious activity (legitimate interest). We do not use your information for automated decision-making that produces legal effects or similarly significant impacts on you. ## How We Share Your Information We share information only as necessary and under strict controls. We do not sell your personal information for monetary or other valuable consideration. We may share with: 1. **Service Providers**: Third parties that help operate the Platform, such as cloud storage providers (e.g., AWS), analytics tools (e.g., Google Analytics), or blockchain nodes. These providers are bound by confidentiality agreements and process data only on our behalf. 2. **Law Enforcement or Regulatory Authorities**: When required by law, subpoena, or to protect our rights, property, or safety, or that of our users or the public. 3. **Public Blockchain Networks**: Blockchain Data is inherently shared with network participants and is publicly viewable. We cannot prevent or control further dissemination. 4. **Business Transfers**: In the event of a merger, acquisition, or asset sale, your information may be transferred as part of the transaction, subject to similar privacy protections. We do not share with advertisers or for marketing purposes without your explicit consent. ## International Data Transfers If you are located outside the United States, your information may be transferred to and processed in the US or other countries where our service providers operate. We ensure appropriate safeguards, such as Standard Contractual Clauses (SCCs) approved by the European Commission, to protect data in compliance with GDPR and similar laws. ## Data Security We implement industry-standard security measures to protect your information, including: - Encryption for data in transit (e.g., HTTPS) and at rest where feasible. - Access controls, firewalls, and regular security audits. - Non-custodial handling of blockchain assets to minimize risks. However, no system is 100% secure. Due to blockchain's transparency, certain data (e.g., wallet addresses, transaction histories) is publicly visible and cannot be removed or altered once recorded. We cannot guarantee absolute security against breaches, hacks, or unauthorized access. If a security incident occurs, we will notify affected users as required by law. ## Data Retention We retain information only as long as necessary for the purposes outlined above or as required by law: - Personal Information: Retained for the duration of your account plus up to 7 years for legal compliance (e.g., tax records). - Usage Data: Retained for 24 months for analytics, then anonymized. - Blockchain Data: Indefinitely on the blockchain, as it is immutable and not under our control. You can request deletion of data we control (see "Your Choices and Rights" below). ## Your Choices and Rights We empower you to control your data, subject to blockchain limitations: - **Access and Portability**: Request a copy of your Personal Information in a structured, machine-readable format. - **Correction/Rectification**: Update inaccurate or incomplete information. - **Deletion/Erasure**: Request deletion of data we control (e.g., "right to be forgotten" under GDPR). Note: Blockchain Data cannot be deleted. - **Restriction/Objection**: Object to or restrict processing for certain purposes, such as analytics. - **Withdraw Consent**: Where processing relies on consent, withdraw it at any time (this may limit service access). - **Opt-Out of Cookies/Analytics**: Manage via browser settings or contact us. - **CCPA-Specific Rights (for California Residents)**: Opt-out of sales (though we do not sell data), request disclosure of categories shared, and non-discrimination for exercising rights. To exercise these rights, contact us at [Contact Email]. We respond within 30-45 days, depending on the request's complexity. Verification may be required. For blockchain data, we can only disassociate it from our systems where possible. ## Children's Privacy Our Platform is not intended for individuals under 18 years old. We do not knowingly collect Personal Information from children. If we learn we have collected such data, we will delete it promptly. Parents or guardians who believe their child has provided information should contact us immediately. ## Changes to This Policy We may update this Policy to reflect changes in our practices or legal requirements. We will post revisions on the Platform with an updated "Last Updated" date and, for material changes, notify you via email or in-app notice. Continued use after changes constitutes consent. Review this Policy periodically. ## Contact Us For questions, concerns, or to exercise your rights, please contact our Data Protection Officer at: support@privatebond.io # Cookie Usage We use cookies to ensure the proper functioning of our Platform and to comply with jurisdictional requirements. Cookies are small text files stored on your device when you visit our website or use our services. Below, we describe the types of cookies we use, their purposes, and how you can manage them. We only use cookies that are strictly necessary for the operation of the Platform, and therefore, we do not display a cookie consent popup. ### Types of Cookies We Use 1. **Session Cookies** - **Purpose**: Session cookies are essential for enabling core functionality of the Platform, such as maintaining your login session and ensuring seamless navigation during your visit. These cookies are temporary and are deleted from your device when you close your browser. - **Data Processed**: These cookies may process limited personal information, such as a session identifier, which is necessary to authenticate your access and provide a consistent user experience. - **Duration**: Temporary, deleted upon closing your browser. 2. **Geoblocking Cookies** - **Purpose**: Geoblocking cookies are essential for enforcing jurisdictional restrictions by identifying your geographic location, ensuring compliance with applicable laws and regulations regarding content access. These cookies help us restrict access to the Platform in jurisdictions where it is not permitted. - **Data Processed**: These cookies process your IP address to determine your approximate location. This information is used solely for geoblocking purposes and is not stored beyond the duration of your session. - **Duration**: Temporary, deleted upon closing your browser. ### Why We Use These Cookies We use session and geoblocking cookies because they are strictly necessary to provide the services you request and to comply with legal requirements. These cookies do not track your behavior for marketing or analytics purposes, nor do they collect sensitive personal information beyond what is required for their essential functions. ### Managing Cookies You can control or disable cookies through your browser settings at any time. Most browsers allow you to block or delete cookies, but doing so may prevent you from accessing certain features of the Platform, as these cookies are essential to its operation. For instructions on managing cookies, please refer to your browser's help or privacy settings (e.g., in Chrome, Firefox, Safari, or Edge). We do not use non-essential cookies, so no additional opt-out mechanisms are provided. ### Contact Us If you have questions about our use of cookies or this Privacy Policy, please contact us at support@privatebond.io