Privacy policy

1. Purposes of processing

The Company records acceptances of the Terms so that it can evidence which wallet accepted which version, and so that a new version can be put to the User for signature before a further deposit.

At present the Company does not process personal information for analytics or advertising. Should the Company later measure use of the Surfaces, it will do so only:

• to determine the country from which the Surfaces are accessed;
• to understand how the Surfaces are used, in order to improve the product.

The Company does not process information for advertising, for building a civil-identity profile, or for sale to third parties.

2. What the Company collects today

The Company does not load a third-party measurement script and does not write a tracking cookie.

When a User signs the Terms in the App, the Company stores the public wallet address, the Terms version, the signed message, the signature, and the timestamp. That record is kept so that the Company can evidence acceptance and ask the User to sign again if the version changes.

The Company does not collect names, dates of birth, government identity documents, email addresses, telephone numbers, residential addresses, source of funds, or any other Know Your Customer data as part of the product. It does not maintain a civil-identity account file for Users.

3. What remains on the User’s device or on-chain

A public wallet address used in the App is processed locally in the browser so that the App can display balances and submit transactions the User approves. The Company does not harvest browsing addresses into a general user directory. The address and the resulting transactions are, independently, public on the blockchain. The Company does not create them and cannot alter or delete them.

A copy of the Terms acceptance may also remain in local storage on the User’s device, so that the App can remember that the current version has already been signed. That local copy is not the Company’s record. The Company’s record is the one described in Section 2.

Connecting a wallet is handled by a third-party connection modal. That provider processes what such a modal ordinarily processes in order to establish the connection. That is not a DeTrade account system.

The Surfaces are hosted on a third-party platform. Serving a page necessarily involves a network request. The host may retain ordinary technical logs. That is a consequence of hosting, not a product registration.

4. What the Company does not collect

The Company will never request a seed phrase or a private key.

The Company does not currently operate identity verification, wallet screening, or sanctions screening as a product feature, and does not ask Users to upload documents.

If a User writes to the Company of their own motion (for example to hello@detrade.fund or on Discord), the Company will see the content of that message. That is correspondence initiated by the User, not data collected through the App.

5. Legal basis

Recording a Terms acceptance is done in order to evidence the agreement and to administer a later change of version. There is at present no analytics processing to ground. If measurement of country and usage is introduced, it will be described in this policy and, where required, made subject to a prior choice by the User.

The Company does not rely on a public-interest task or on official authority. The Company is a private on-chain operator.

If a legal obligation later requires the Company to retain or disclose a record, the Company will do what that obligation requires. That is not a present collection programme. Questions may be sent to hello@detrade.fund.

6. Place of processing and transfers

The Company operates from Panama City, Republic of Panama. Hosting of the Surfaces may take place outside Panama.

On-chain data is processed on public networks, independently of the Company.

7. Retention

The Company does not retain an analytics file. A Terms acceptance is retained for as long as it is needed to evidence that the relevant version was accepted, and for as long as a legal obligation requires.

Local-storage records on the User’s device remain until the User clears them. Clearing the device does not erase the Company’s record.

On-chain data is outside the Company’s control and is not deleted by the Company.

8. Security

The Surfaces are served over TLS. Authentication in the App is effected through the User’s own wallet.

No method of transmission is completely secure. Users remain responsible for their wallet credentials and their devices.

9. Rights of Users

The Company does not currently operate measurement and does not keep a civil-identity file. It does keep Terms acceptances against the wallet address that signed. Subject to applicable law, a User may request:

• confirmation of whether the Company holds a Terms acceptance or other information relating to them, and a copy of what it is able to identify;
• erasure of correspondence the User has sent, so far as the Company still holds it;
• erasure of a Terms acceptance, so far as the Company is not required to keep it as evidence of the agreement;
• a complaint to a competent data-protection authority, where such an authority has jurisdiction.

These rights cannot be used to alter a public blockchain. Requests are to be sent to hello@detrade.fund. They are free of charge and will be handled as soon as reasonably possible.

10. Changes

The Company may amend this policy. The current version is the version published on the Website. Where a change is material, including the introduction of measurement, the Company will endeavour to give notice on the Surfaces.

Users are advised to review this page from time to time.