Privacy Policy

1. Information We Collect

Information You Provide

• Account and identity information: name, email address, organization name, role, and contact details provided during onboarding.
• KYC/AML documentation: government-issued identification, corporate documentation, and other verification materials required for compliance.
• Financial information: fund structure details, investment parameters, and allocation preferences.
• Communications: messages, support requests, and feedback you send to us.

Information Collected Automatically

• Device and browser information: IP address, browser type, operating system, and device identifiers.
• Usage data: pages visited, features used, transaction history, and interaction patterns.
• Log data: server logs, error reports, and performance metrics.

Blockchain Data

• Wallet addresses associated with your account.
• Onchain transaction data, including transaction hashes, amounts, timestamps, and protocol interactions.
• Yield performance data and portfolio positions across connected DeFi protocols.

2. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve the Platform.
• Process transactions and facilitate interactions with DeFi protocols.
• Generate performance reports, analytics, and audit trails for your fund operations.
• Verify your identity and comply with KYC/AML and other regulatory obligations.
• Communicate with you about your account, platform updates, and support inquiries.
• Detect, prevent, and address fraud, security issues, and technical problems.
• Comply with legal obligations and respond to lawful requests from authorities.

3. Data Sharing and Disclosure

We may share your information with:

• Custody providers: such as Fireblocks, to facilitate secure wallet management and transaction signing.
• KYC/AML providers: third-party identity verification services to meet compliance requirements.
• Fiat on/off-ramp providers: to facilitate conversions between fiat currency and digital assets.
• Service providers: including hosting, analytics, and communication services that assist in operating the Platform.
• Legal and regulatory authorities: when required by law, regulation, or legal process.

We do not sell your personal information to third parties.

4. Security Measures

We implement industry-standard security measures to protect your information, including:

• Encryption of data in transit and at rest.
• Multi-factor authentication and role-based access controls.
• Regular security audits and vulnerability assessments.
• Noncustodial architecture: we do not hold or control private keys or digital assets.

While we take reasonable steps to protect your information, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security.

5. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this policy, comply with legal obligations, resolve disputes, and enforce our agreements. When data is no longer needed, we will securely delete or anonymize it.

Onchain transaction data is immutable and publicly available on the blockchain. We cannot delete or modify information that has been recorded on a public blockchain.

6. Cookies and Tracking Technologies

We may use cookies and similar tracking technologies to collect usage information and improve the Platform. These may include:

• Essential cookies: required for the Platform to function properly, including authentication and session management.
• Analytics cookies: used to understand how visitors interact with the Platform and to improve performance.

You can control cookies through your browser settings. Disabling certain cookies may affect the functionality of the Platform.

7. Third-Party Services

The Platform integrates with third-party services including blockchain networks, DeFi protocols, custody providers, and identity verification services. These services have their own privacy policies and data practices. We encourage you to review their policies.

We are not responsible for the privacy practices of third-party services. Your interactions with these services are governed by their respective terms and policies.

8. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Access: request a copy of the personal information we hold about you.
• Correction: request correction of inaccurate or incomplete information.
• Deletion: request deletion of your personal information, subject to legal retention requirements.
• Portability: request your data in a structured, machine-readable format.
• Objection: object to processing of your personal information for certain purposes.

To exercise these rights, contact us at [email protected]. Note that certain data recorded on public blockchains cannot be modified or deleted.

9. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We take steps to ensure that your data is treated securely and in accordance with this policy regardless of where it is processed.

10. Children's Privacy

The Platform is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child, we will take steps to delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through the Platform or via email. Your continued use of the Platform after changes constitutes acceptance of the updated policy.

12. Contact

If you have questions about this Privacy Policy, please contact us at: [email protected]