Last Updated: October 28, 2021
The website available at https://gearbox.fi and the Gearbox Application (app) accessible at https://app.gearbox.fi (with temporary beta accessible at https://app.gearbox.fi) (collectively, “Platform”) are provided by GearBox Protocol Limited, a company incorporated under the laws of the British Virgin Islands with its registered office address at Intershore Chambers, PO Box 4342, Road Town, Tortola, VG1110 British Virgin Islands (“we”, “our”). With respect to personal data collected on the Platform we are acting as a data controller.
In this Privacy Notice we explain how your personal data is collected and processed. Personal data or personal information means any information directly or indirectly identifies you as an individual.
We make our best efforts to process personal data in accordance with the applicable data protection legislation (the “Applicable data protection legislation”) which particularly depends on where you are located. If you have any questions regarding processing of your personal data, do not hesitate to contact us via the contact details provided below.
Name: Gearbox Protocol Limited, a company incorporated in the British Virgin Islands Address: c/o Intershore Chambers, PO Box 4342, Road Town, Tortola, VG1110 British Virgin Islands Email: [email protected]
What information we collect
As a general rule, we try not to collect any personal information. If we collect personal data, we strive to comply with the data minimisation principle, meaning that we endeavour to process as little personal data as possible.
We do not collect or process any personal data when you access and browse the Platform without using its functionality. The Platform does not use any analytical, marketing, statistical cookies or any other similar tracking technologies that are not necessary to run the Platform. If we start using cookies or similar tracking technologies that are not necessary for the functioning of the Platform, we will ask your prior consent.
In order to enable you to use certain functionality of the Platform, we process the public blockchain address of your digital wallet (the “Address”) and information about certain blockchain transactions that are associated with the Address (“Transactions”).
We collect and process your Address when you connect your digital wallet to the Platform. The information regarding the Transaction is collected by us from the data available on the public blockchains.
While processing the Address and Transactions we cannot identify you as an individual, therefore, this data is not personal. However, under the Applicable data protection legislation if such data is combined with certain other data, it may be considered personal information. We will update this Privacy Notice once and if we are able to identify you as an individual.
We may also collect certain data if you reach us via the contact details indicated on the Platform. In this case we may collect and process certain information related to your request, such as email address, name, or any other data you choose to provide us.
How we use the information
We use the Address and information about Transactions to ensure the operation of the Platform and to enable you to use certain functionality of the Platform. If and to the extent that the Address and information about your Transactions are deemed personal data, the legal basis for the processing is the necessity for the performance of a contract between you and us.
The purpose for processing your personal data when you contact us is to respond to your inquiry and the legal basis is legitimate interest to do the same.
We do not sell your data. However, we may pass your information to our third-party service providers and subcontractors for the purposes of and if it is necessary to provide the Platform and related services to you. These service providers may include, for instance, support teams and hosting service providers. We may also disclose your data if we are under a duty to disclose or share your data in order to comply with a legal obligation.
Please also consider the features of the blockchain data processing described below.
Your information and blockchain
Please kindly note that the Address and information related to the Transactions will be used within a decentralised blockchain network: essentially, you enter this data to the blockchain using your digital wallet each time you make a blockchain transaction or interact with blockchain smart-contracts via the Platform. We do not control nor operate blockchain networks. This means that due to the structure of the blockchain network certain rights or abilities may be limited. It also means that your Address and information regarding your Transactions are publicly available to any person who has access to the blockchain. Please be aware that any transaction within the blockchain network is irreversible and information put into the blockchain cannot be deleted or changed.
How long we process your data
Since we cannot identify you as an individual using your Address and information related to the Transactions, we do not have any storage limitation. Also note that due to the nature of the blockchain, such information may be accessed and viewed by us or any third party at any time. As for any other personal information that we store, we process it until it is necessary for the purposes it was collected.
According to the Applicable data protection legislation, you may have the following rights:
- to request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
- to request correction (rectification) of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected;
- to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law;
- to object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
- to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (1) if you want us to establish the data’s accuracy, (2) where our use of the data is unlawful but you do not want us to erase it, (3) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims, (4) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Note that due to the structure of the blockchain network we may not be able to exercise this right in full;
- to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Also note that the data available on the blockchain network may be collected and structured by you at any time;
- to withdraw consent at any time where we are relying on consent to process your personal data. Note that currently we do not rely on your consent to process your personal data;
- not to be subject to a decision based solely on automated processing of data, including profiling, which produces legal effects concerning you or similarly significantly affecting you;
- to file a complaint with a relevant supervisory authority in case we violate your rights or obligations imposed on us under the Applicable data protection legislation. Relevant supervisory authority will particularly depend on where you are located or where your rights were violated.
Please note that due to the nature of the processing operation, we may not be able to exercise certain rights that you may have pursuant to the Applicable data protection legislation. When interacting with a blockchain we may not be able to ensure that your personal data is deleted, corrected, or restricted. This is because the blockchain is a public decentralised network and blockchain technology does not generally allow for data to be deleted or changed and certain rights cannot be enforced. In these circumstances, we will only be able to exercise your rights with respect to the information that is stored on our servers and not on a blockchain. If you want to ensure your privacy rights are not affected in any way, you should not transact on public blockchains (such as Ethereum blockchain network) as certain rights may not be fully available or exercisable by you or us due to the technological infrastructure of the blockchain.
In order to exercise your rights as a data subject, we may request certain information or actions from you to verify your identity and confirm that you have the right to exercise such rights.
Children personal data
The Platform is not intended for the use of children (under 18 years old or older, if the country of your residence determines a higher age restriction). We do not knowingly market to, or solicit data from children. We do not knowingly process, collect, or use personal data of children, and in case we receive such data, we will erase it within a reasonable timeframe.
Changes to this Privacy Notice
We keep our Privacy Notice under regular review and may update it at any time. If we make any changes to this document, we will change the “Last Updated” data above. Please review this Privacy Notice regularly.