# PRIVACY POLICY
                                                
**[ENTITY NAME] (“[DAO Name]”, “the Organization”, “we”, “us”, “our”)** is a [ENTITY TYPE], incorporated under the laws of [INSERT JURISDICTION].                                                

This Privacy Policy applies to the website [URL] (“Website”) and its associated subdomains (collectively the “Services”). By accessing or using our Services, you acknowledge that you are at least 16 years old and have read, understood, and agree to the collection, storage, use, and disclosure of your personal information as described herewith. If you disagree with the terms of this privacy policy, please do not access the website.                        

In the capacity of a personal data controller, the Organization carries out its activities in strict compliance with the legal requirements regarding the users’ personal data protection. Pursuant to the provisions of Art. 13 and Art. 14 of the **General Data Protection Regulation (GDPR)**, [ENTITY NAME] hereby provides the necessary information regarding the collection and processing of your personal data while using this website.                                

This privacy policy is compliant with the EU General Data Protection Regulation (GDPR), which can be considered a world standard for privacy compliance.                                                 

We reserve the right to make changes to this Privacy Policy at any time and for any reason. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Website, and you waive the right to receive specific notice of each such change or modification. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted.

## 1. Definitions and key terms

For the purposes of this Privacy policy:

- “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union/Member State law or US Federal Law, the controller or the specific criteria for its nomination may be provided for by the respective laws and regulations.
- “Data subject” means a natural person identified or identifiable whose personal data are processed by the controller.
- “IP address” - every device connected to the Internet is assigned a number known as an Internet protocol (IP) address. These numbers are usually assigned in geographic blocks. An IP address can often be used to identify the location from which a device is connecting to the Internet;
- “Personal data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
- “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
- “Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
- “Site“ refers to [ENTITY NAME] website accessible at [URL];
- “You” refers to a person who accesses, views and navigates in the Site;

## 2. Identity and contact details of the Controller 

Controller: [ENTITY NAME]                                                
Contact details: [.......]
                                        
## 3. Categories of collected and processed personal data

The categories of personal data we collect depend on how you interact with us, our services and the requirements of applicable law. Also, if you decide to send emails or other communications to [ENTITY NAME] you may include in those communications some personal data which will therefore be processed by [ENTITY NAME].
The personal information collected from you generally may include:
* Network information regarding transactions, including, among other things, the type of device you use, access times, hardware model, operating system and version, and other unique device identifiers;
* Information about plugins you might be using, included but not limited to those related to the management of cryptocurrency assets and any information provided by them;
* E-mail address;
* Crypto wallet address, including related data used to detect cryptocurrency and NFT holdings.

We may automatically log standard data provided by the browser in use and may include but is not limited to, Internet Protocol (IP) address, browser type and version, geolocation data.

## 4. Purposes and legal basis of processing
                                                
### 4.1 Purposes

[ENTITY NAME] collects and processes your personal data to fulfill your request to become a [ENTITY NAME] user and later to manage your profile.

[ENTITY NAME] collects and processes your personal data in compliance with its statutory obligations. We must ensure our compliance with various legal obligations imposed by relevant legislation – anti-money laundering laws, financial services laws, corporation laws, privacy laws and tax laws. For the purpose of auditing our internal processes, fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft, the usage of stored data is of significant importance. Such obligations and requirements imposed on us necessary personal data processing activities for identity verification, payment processing, compliance with court orders, tax laws or other reporting obligations and anti-money laundering controls.

In case of emails and other communications, [ENTITY NAME] collects and processes your personal data to examine and answer your request.

### 4.2 Legal basis

If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have a legal basis for doing so under applicable EU laws. The legal basis to handle your signup application and later to manage your personal data as a [ENTITY NAME] user as well as to answer to any email or communications is “the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract” pursuant to Article 6, 1(b) GDPR.

## 5. Storage period

[ENTITY NAME] stores your personal data for a reasonable period of time and never for longer than it is absolutely necessary. In establishing contractual relations with you, [ENTITY NAME] stores your personal data throughout the established relations. Normally, the Organization stores your personal data for 5 (five) years, starting from the beginning of the calendar year following the year of termination of the relationship between us. We may store your personal data for a longer period for reporting, tax and accounting purposes, as well as to protect your legitimate interests. After the expiration of the stipulated terms and if there is no other legal basis for the processing of your personal data, the data will be deleted.

## 6. Disclosure and transfer of personal data

In strict compliance with the legal requirements,  [ENTITY NAME] may disclose or transfer your personal data to the following recipients under particular circumstances:

- With service providers - We may share your information with our service providers and vendors to assist us in providing, delivering, and improving the Services. For example, we may share your wallet address with service providers to provide technical infrastructure services, your wallet address with blockchain analytics providers to detect, prevent, and mitigate financial crime and other illicit or harmful activities, and your activity on our social media pages with our analytics provider to learn more about you interaction with the Services and us.
- To comply with our legal obligations - We may share your data in the course of litigation, regulatory proceedings, compliance measures, and when compelled by subpoena, court order, or other legal procedure. We may also share data when we believe it is necessary to prevent harm to our users, our Organization, or others and to enforce our agreements and policies, including our Terms of Service.
- Safety and Security - We may share data to protect against, investigate, and stop fraudulent, unauthorized, or illegal activity. We may also use it to address security risks, solve potential security issues such as bugs, enforce our agreements, and protect our users, the Organization, and the ecosystem.
- Business changes - We may transfer or share data with another entity in the event of a merger, acquisition, bankruptcy, dissolution, reorganization, asset or stock sale, or other business transaction.
- With your consent - We may share your information any other time you provide us with your consent to do so.

We may need to collect or send some personal information outside of the European Economic Area (EEA). For the transfer of personal data to countries or jurisdictions which are not subject to an adequacy decision granted by the European Commission, we will take measures to comply with our legal obligations and all reasonable safeguards to ensure that your personal data is treated securely and in accordance with this Privacy Policy. For example, we will enter into standard contractual clauses that have been approved by the European Commission.

We do not share your information with any third parties for any marketing purposes whatsoever.

Notwithstanding the foregoing, we do not have full control over information that is stored on a particular blockchain. This information may include transaction data (i.e., purchases, sales, and transfers) related to your blockchain wallet and respective interactions with  [ENTITY NAME] platform. 

Public blockchains are distributed ledgers intended to immutably record transactions across vast networks of computer systems. Many blockchains are open to forensic analysis, which can lead to deanonymization and the unintentional revelation of private financial information, especially when blockchain data is combined with other data. Because blockchains are decentralized or third-party networks that are not controlled or operated by the Organization, we are not able to erase, modify, or alter personal data from such networks.

## 7. Cookie policy

We are using cookies to improve the quality of the client’s experience on the Site. The cookie, a small text file that is stored on the customer’s computer for record-keeping purposes, can be used as an identification card: a cookie is unique to your computer and only the server that gave it to you can read them. Using traffic log cookies, we can identify and monitor what pages are mostly used. This will help us to analyze data about website traffic and later improve our website. Most existing web browsers can automatically receive cookies, but you can change your browser settings and decide whether to accept cookies or not. There is one important characteristic – cookies do not provide websites with personal information (such as email addresses or other information) without your permission. Once you provide a website with personal information, your information can be linked to the data stored in the cookie. You should remember that we will not share your personal information with third parties if we do not have permission from you or if we are not required to do it by law. Our main goal is to make our website as efficient for you as we can. We can personalize your web experience on our website with cookies: we will remember you as an individual and what content was interesting for you, and as a result, we can remove web pages that are not important and offer you the most popular products and services based on your web preferences (for example we may send you promotional emails with information about our new products, new special offers, special deals, etc.)                                
## 8. Your privacy rights

As a data subject under the GDPR, you have the following rights in relation to the personal data you provide:

- The right to be informed – you have the right to receive appropriate transparent information about the processed personal data, the purposes and basis of the processing, the recipients or categories of recipients to whom your personal data has been or will be disclosed, the storage period, as well as any other information about your personal data.
- The right of access – you have the right to access your personal data processed by [ENTITY NAME], as well as to request a copy of the personal data in a structured, commonly used format.
- The right to rectification – you have the right to request rectification of your personal data if it is incomplete, inaccurate or out of date.
- The right to erasure (the right to be forgotten) – you have the right to request the erasure of your personal data under particular circumstances: it is no longer necessary in relation to the purposes for which it was collected; you have withdrawn your consent to the processing, and there is no other legal basis for processing; when your personal data has been unlawfully processed; in the presence of other legal grounds.
- The right to object – you have the right to object to the processing of your personal data.
- The right to restrict processing – you have the right to withdraw your consent to the processing of your personal data by the controller or the processor at any time and free of charge.
- The right to data portability – you have the right to request the transfer of your personal data to another personal data controller when technically feasible.
- Right of protection – you have the right to defend your rights by judicial or administrative means if you believe that your rights as a data subject have been infringed in any way.
- Rights related to automated decision-making and profiling.
                                                                
## 9. Exercising rights related to personal data
                                                                
At any time, you can withdraw your consent or object to the processing of your personal data and exercise your other rights as a data subject. For this purpose, you should send us a notice using one of the contact details provided in this policy.
                                                                
Upon receipt of such a notice, [ENTITY NAME] will provide information regarding the actions taken within one month of receipt. If necessary, this period may be extended by another two months, considering the complexity and number of requests made by one data subject. We will inform you of any extension within one month of receiving the notice, stating the reasons for the extension.
                                                                
[ENTITY NAME] will provide the necessary information in relation to the notice only if the sender has been properly identified. [ENTITY NAME] is not obliged to respond to a notice in the event that it is unable to identify the data subject or his/her credentials. We may request the provision of additional information and documents necessary to confirm the identity and authority of the data subject when there are reasonable concerns.
                                                                
Your questions, comments, requests or complaints regarding this Privacy Policy shall be addressed to [INSERT E-MAIL ADDRESS]
                                                                
If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to the supervisory authority of the place where you reside.
                                
If you are a resident of the United Kingdom and believe we maintain your Personal Data within the scope of the applicable laws relating to personal data in the United Kingdom, you may direct questions or complaints to the UK supervisory authority, the Information Commissioner’s Office. 
                                
## 10. Supplemental Notice for California residents

### 10.1.

This Supplemental Notice for California Residents only applies to our processing of personal data that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal data [ENTITY NAME] has collected about them and whether [ENTITY NAME] disclosed that personal data for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information respectively in Art. 3 “Categories of collected and processed personal data” and Art. 6 “Disclosure and transfer of personal data” of this Privacy Policy.

### 10.2. “Sales” of Personal Information under the CCPA 

For purposes of the CCPA, [ENTITY NAME] does not “sell” personal data, nor do we have actual knowledge of any “sale” of personal data of minors under 16 years of age.

### 10.3. Additional Privacy Rights for California Residents

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth in “Contact Us” below.

Verification. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include confirming the email address associated with any personal information we have about you. If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

California Shine the Light. The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal data (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal data disclosed to those parties.

## 11. Supplemental Notice for Nevada residents

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal data to third parties who intend to license or sell that personal data. You can exercise this right by contacting us as set forth in “Contact Us” below with the subject line “Nevada Do Not Sell Request” and providing us with your email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

## 12. Contact Us

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at: [INSERT E-MAIL ADDRESS]