Privacy Policy

2. Information We Collect

2.1 Information You Provide

• Wallet Addresses: Public blockchain addresses you connect to the Platform.
• Communications: Messages, support requests, or feedback you submit.
• Identity Information: If required for compliance (KYC/AML), we may collect government IDs, proof of address, and related documentation.
• Transaction Data: Details of transactions you execute through the Platform.

2.2 Automatically Collected Information

• Device Information: Hardware model, operating system, browser type, unique device identifiers.
• Log Data: IP addresses, access times, pages viewed, referring URLs.
• Location Data: Geographic location derived from IP address or other means.
• Cookies and Tracking: See our Cookie Policy.

2.3 Blockchain Data

Blockchain transactions are publicly visible. We may collect and analyze public blockchain data related to wallets interacting with our smart contracts.

2.4 Third-Party Sources

We may receive information from blockchain analytics providers, identity verification services, and other third parties to prevent fraud and ensure compliance.

3. How We Use Your Information

3.1 Primary Uses

• Provide, maintain, and improve the Platform and Services
• Process transactions and send related information
• Verify identity and prevent fraud, money laundering, or illegal activity
• Comply with legal obligations and respond to legal requests
• Enforce our Terms of Service and protect our rights

3.2 Additional Uses

• Analyze usage patterns and optimize Platform performance
• Develop new features, products, and services
• Send promotional communications (with opt-out options)
• Personalize your experience
• Any other purpose disclosed at the time of collection

3.3 Broad Processing Rights

The Company reserves the right to use collected information for any lawful purpose consistent with this Policy, including purposes not specifically enumerated herein.

4. Information Sharing and Disclosure

4.1 Service Providers

We share information with third-party service providers who perform services on our behalf, including hosting, analytics, customer support, and identity verification.

4.2 Legal Requirements

We may disclose information if required by law, court order, subpoena, or government request, or if we believe disclosure is necessary to protect our rights, property, or safety, or that of others.

4.3 Business Transfers

In connection with a merger, acquisition, reorganization, or sale of assets, your information may be transferred as a business asset. We will notify you of any such transfer via the Platform.

4.4 Affiliates

We may share information with our affiliates, subsidiaries, and related companies for purposes consistent with this Policy.

4.5 Consent

We may share information with your consent or at your direction.

5. International Data Transfers

The Company is based in the British Virgin Islands. Your information may be transferred to, stored, and processed in any country where we or our service providers operate, including countries that may have different data protection laws than your country of residence.

BY USING THE PLATFORM, YOU CONSENT TO THE TRANSFER OF YOUR INFORMATION TO COUNTRIES OUTSIDE YOUR COUNTRY OF RESIDENCE, INCLUDING THE BRITISH VIRGIN ISLANDS AND OTHER JURISDICTIONS.

Where required, we implement appropriate safeguards for international transfers, but we cannot guarantee the security of data during transmission.

6. Data Retention

We retain information for as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. Factors influencing retention include:

• Duration of your relationship with us
• Legal obligations requiring data retention
• Statute of limitations for potential claims
• Ongoing disputes or litigation
• Business needs and legitimate interests

Blockchain data is permanent and cannot be deleted by the Company.

7. Your Rights and Choices

7.1 Access and Correction

You may request access to or correction of your personal information by contacting us at the address below. We may require identity verification before processing requests.

7.2 Deletion

You may request deletion of your information, subject to legal retention requirements. Note that blockchain data cannot be deleted.

7.3 Marketing Opt-Out

You may opt out of marketing communications by following unsubscribe instructions or contacting us directly.

7.4 Limitations

We may decline requests that are unreasonable, repetitive, require disproportionate effort, or jeopardize the privacy of others. Exercise of rights may affect your ability to use the Platform.

8. Security

We implement reasonable administrative, technical, and physical safeguards to protect information. However, NO METHOD OF TRANSMISSION OR STORAGE IS 100% SECURE. We cannot guarantee absolute security of your information.

You are responsible for maintaining the security of your wallet, private keys, and access credentials. The Company is not liable for unauthorized access resulting from your failure to protect these.

9. Children's Privacy

The Platform is not intended for individuals under 18 years of age. We do not knowingly collect information from minors. If we become aware of such collection, we will delete the information promptly. If you believe a minor has provided us information, please contact us immediately.

10. Do Not Track

The Platform does not respond to "Do Not Track" (DNT) signals. We may continue to collect information as described even if your browser transmits a DNT signal.

11. Third-Party Links and Services

The Platform may contain links to third-party websites or services. We are not responsible for their privacy practices. We encourage you to review their privacy policies before providing any information.

12. Additional Rights for EEA/UK Users

If you are located in the European Economic Area or United Kingdom, you may have additional rights under the GDPR, including:

• Right to data portability
• Right to restrict processing
• Right to object to processing
• Right to lodge a complaint with a supervisory authority

Our legal basis for processing includes consent, contract performance, legitimate interests, and legal compliance. Contact us for specific inquiries.

13. Automated Decision-Making & AI

13.1 Use of Automated Systems

The Platform may use automated decision-making systems, including artificial intelligence (AI) and machine learning (ML) algorithms, for various purposes including but not limited to:

• Fraud detection and prevention
• Risk assessment and scoring
• Identity verification (KYC/AML)
• Transaction monitoring and analysis
• Content personalization and recommendations
• Customer support automation
• Geolocation and access control

13.2 Profiling

We may create profiles based on your behavior, transactions, and other data to assess risk, prevent fraud, and personalize your experience. Such profiling may affect your access to certain features or services.

13.3 Human Review

While automated decisions may be made without human intervention, you may request human review of significant automated decisions by contacting us. We reserve the right to determine what constitutes a "significant" decision.

14. Lawful Basis for Processing (GDPR Article 6)

For users in the European Economic Area and United Kingdom, we process personal data based on the following legal grounds:

• Consent (Art. 6(1)(a)): Where you have given explicit consent for specific processing activities.
• Contract (Art. 6(1)(b)): Processing necessary for the performance of our contract with you (the Terms of Service).
• Legal Obligation (Art. 6(1)(c)): Processing necessary to comply with our legal obligations, including KYC/AML requirements.
• Legitimate Interests (Art. 6(1)(f)): Processing necessary for our legitimate interests (fraud prevention, security, service improvement) where not overridden by your rights.

To withdraw consent or object to processing, contact us at the address below. Withdrawal may affect your ability to use the Platform.

15. Data Portability Limitations

While you may have rights to data portability under certain laws, the following limitations apply:

• Blockchain data is publicly available and not subject to portability requests.
• Data processed for security, fraud prevention, or legal compliance may be excluded.
• We may provide data in a format of our choosing that is commonly used and machine-readable.
• Requests may be subject to identity verification and may take up to 30 days to fulfill.
• We may charge a reasonable fee for manifestly unfounded or excessive requests.

17. Contact & Registered Agent

For privacy-related inquiries, contact:

For data subject access requests (DSAR), please email dpo@freed.finance with "DSAR Request" in the subject line. We will respond within the timeframe required by applicable law.