Privacy Policy

This Privacy Policy and Cookies Statement (the “Privacy Policy”) describes how Synchronicity Systems, S.A. (“Synchronicity”), and its affiliated companies (referred to in this document as “we,” “us” or “our”) operate a non-custodial web-based user interface that enables users to interact directly with a decentralized protocol (the “Interface”). This Privacy Policy explains what information we collect through the Interface and our associated website (collectively, the “Site”), how we use and share that information, and the choices you have regarding the foregoing.

BY ACCESSING THE SITE, CONNECTING A WALLET, OR OTHERWISE USING THE INTERFACE, YOU ACKNOWLEDGE THAT YOU HAVE READ AND AGREE TO THIS PRIVACY POLICY AND OUR TERMS OF USE LOCATED AT https://docs.synchronicity.xyz/terms-of-use.

By visiting the Site or connecting a wallet, you consent to the data practices described in this Privacy Policy.

I. Collection of Personal Data

We collect the following categories of information in connection with your use of the Site and the Interface:

• Wallet connection information. When you voluntarily connect a publicly available blockchain wallet address to the Interface, we process that public address to enable wallet connection, surface on-chain positions and activity, and facilitate on-chain interactions you initiate. We do not have access to your private keys or seed phrase and cannot initiate transactions on your behalf.

• Technical and device information. We and our third party service providers may automatically collect limited technical information when you access the Site, such as IP address (which may be truncated or anonymized where configured), browser type, operating system, device type, language preferences, referring URLs, and diagnostic information. We use this information to maintain security, prevent fraud and abuse, measure performance, and debug issues.

• Usage data. We may collect information about your interactions with the Site and Interface, such as pages viewed, features used, links clicked, time and duration of visits, and referral sources. We use this information to operate, maintain, and improve the Interface, including user experience and performance.

• Approximate location data. We may derive coarse location information from IP address or similar signals to enforce geographic restrictions, such as blocking access from jurisdictions where use of the Interface is not permitted under our Terms of Use.

• On-chain data. We may surface publicly available on-chain information associated with your connected wallet, including transaction hashes, amounts, timestamps, positions, and funding or fee activity. On-chain data is public by design and is not controlled by us.

• Cookies and similar technologies. We and our third-party infrastructure and analytics providers may use cookies, pixels, web beacons, and similar technologies (collectively, “Cookies”) to collect and store the types of information described above. Cookies help us authenticate requests, remember preferences, enhance performance and security, and understand how the Site is used. You can manage Cookies through your browser settings; however, disabling certain Cookies may impair Site or Interface functionality.

We do not request or collect from you: name, mailing address, telephone number, date of birth, government ID, proof of address, payment card details, or other traditional personal identifiers to use core Interface features. We do not target or knowingly collect information from individuals under the age of 18.

II. Use of Personal Data

We use the Personal Data that we collect:

• To make our Site and its functionalities more intuitive and easier to use, we use device data, cookies and other information that you may provide. This data is necessary for our legitimate interests in monitoring how our functionalities and Sites are used to help us improve these functionalities and Sites, and the information and tools available on these functionalities and Site.

• To provide relevant marketing including providing you with information about events or services that may be of interest to you. It is necessary for our legitimate interests to process this information in order to provide you with tailored and relevant marketing, updates and invitations.

• To carry out any other business purpose for which the information was collected.

• To post job openings and opportunities on our Site. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us.

We may also use automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information we obtain in this manner may include your device IP address, identifiers associated with your devices, types of devices connected to our services, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of visits to our Site. The information we collect through cookies and similar technologies helps Synchronicity: (1) remember your information so you will not have to re-enter it; (2) understand how you use and interact with our products and website; (3) measure the usability of our products and website and the effectiveness of our communications; and (4) otherwise manage and enhance our products and website, and help ensure they are working properly. We may create aggregated, de-identified and/or anonymized data from your Personal Information and other individuals whose Personal Information we collect. We make Personal Information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Site and promote our business, and to train our artificial intelligence models and for other machine learning purposes; We may also collect transaction-related information (such as preferred means of payment, billing information, billing address, and/or a history of purchases through our Site). Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Site.

III. Marketing Choices

You have control regarding our use of Personal Data for direct marketing. In certain markets, you will need to expressly consent before receiving marketing. In all markets, you can choose to not receive marketing communications at any time. If you no longer wish to receive marketing communications from Synchronicity, or remain on a mailing list to which you previously subscribed, or receive any other marketing communication, please follow the unsubscribe link in the relevant communications or contact us as specified below.

IV. How we share your information

• With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;

• In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation;

• If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of us or any third-party;

• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company;

• With your consent or at your direction; and

• We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

V. Artificial Intelligence

Artificial intelligence (“AI”) technologies, such as those provided by our AI platform providers, OpenAI, Anthropic, Google, and AWS are used to operate the chat and/or user input/prompt features that you can use to communicate with us and/or input your prompts and other data through the Site or Interface. WE ADVISE AGAINST SHARING PERSONAL INFORMATION IN CHATBOT INTERACTIONS.

VI. Legal Bases For Processing (For EEA and other Users)

Specific provisions for EU-residents: This Section VI applies to you, if you are from the European Union. Synchronicity adopted the following provisions, to comply with the EU 2016/679 Directive General Data Protection Regulation (“GDPR”), pursuant to which Synchronicity will be considered as a “Data Controller” with respect to our use of Personal Information of resident of the European Union.

Legal Basis. We base our processing of any personal data as “Data Controllers” based on the following lawful grounds: Synchronicity relies, primarily, on your consent to the terms of this Privacy Policy as a legal basis for processing:

A. any Personal Information related to you or communicating any other promotional material

B. may collect and use your Personal Information when it is necessary for one of the legitimate uses set out in Section II above, which we believe are not overridden by your fundamental rights.

C. may process your Personal Information to comply with a legal obligation and to protect our users’ vital interests. If, at any time, you wish to exercise your rights in accordance with the provisions provided by law (including as provided under this Section and Section XII of this Privacy Policy) you may send us an email to [email protected] and request: to access your Personal Information together with information about how, and on what basis, such information is being processed. Should you desire to receive such information in a different format than the one that was provided to you, you can contact us via [email protected] and we shall use commercially reasonable efforts to accommodate your request, if applicable; rectify any of the Personal Information being held when such information is inaccurate; to delete or restrict access to your Personal Information in limited circumstances as described under the GDPR. Please note that if we need to delete any Personal Information related to you, as per your request, it can take time until we completely delete residual copies of such data from our servers and backup systems.

D. to withdraw your consent to the processing of your Personal Information. However, please note that exercising this right will not affect the lawfulness of any previous processing activities based on consent that was lawfully obtained before its withdrawal.

E. to obtain and reuse your Personal Information for your own purposes across different services, as part of your right to data portability.

Please note that you have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the European Economic Area (“EEA”). If you have any concerns with respect to our methods of processing any Personal Information related to you, or if you wish to withdraw your consent, for any reason, kindly let us know by sending an email to [email protected]. If you reside in a country from the European Economic Area, then, by agreeing to the terms of this Privacy Policy, you agree to Synchronicity sharing your Information outside of the European Economic Area. These transfers are subject to special rules under data protection laws. If this happens, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice is to use ‘standard data protection clauses’ which have been approved by the European Commission for such transfers. Synchronicity shall not charge you for requesting to exercise any of the aforementioned rights.

Please also note that we cannot change, edit or delete information that is stored on a public blockchain.

VII. Transfer of Personal Data To Other Countries

We may transfer your Personal Data to countries outside of your country of residence, including, but not limited to the European Economic Area (“EEA”), as well as the United States, where Synchronicity offices and some of its IT systems are located. Personal Data is not processed outside of the countries listed in this Privacy Policy.

If you access the Site or Interface from outside the jurisdiction where our servers are located, you consent to the transfer and processing of your information in accordance with this Privacy Policy and at your own risk, recognizing that the level of protection in such jurisdictions may be different from that of your home jurisdiction.

VIII. How We Protect Your Information

Protecting your information is important to us. We maintain administrative, technical and physical safeguards designed to protect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use of Personal Data.

IX. How Long We Retain Your Information

We strive to keep your Personal Data only for the period of time needed for legitimate business purposes. In certain circumstances, however, legal or regulatory obligations may require us to retain records for a longer time than we otherwise would.

X. Children’s Information

The Site and Interface are not directed to individuals under the age of 18, and we do not knowingly collect personal information from individuals under the age of 18. If you believe that an individual under the age of 18 has provided us with personal information, please contact us, and we will take appropriate steps to delete such information where feasible.

XI. Your Rights

If you are resident in countries with applicable data privacy laws you have the right, subject to certain exceptions, to request a copy of the Personal Data we are processing about you, to require that any incomplete or inaccurate Personal Data is amended, to request that we delete your Personal Data (although we may not be able to delete certain data due to legal or other obligations), to object to the use of your Personal Data or to withdraw consent. You may also have a right to lodge a complaint with the local data protection authority if you believe that we have not complied with the applicable data protection laws. You may also contact us to address and resolve concerns you may have about our use of your Personal Data. Please contact us at [email protected].

XII. Modifications To This Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

You can see when this Privacy Policy was last updated by checking the last updated date displayed at the top of this Privacy Policy. It is your responsibility to check the last updated date.

XIII. Third-Party Services, Applications, and Websites

Certain third-party services, websites, or applications you use, or navigate to or from our Site or made available by using our Site may have separate user terms and privacy policies that are independent of this Privacy Policy. We are not responsible for the privacy practices of these third-party services or applications. We recommend carefully reviewing the user terms and privacy policy of each third-party service, website, and/or application prior to use.

XIV. Data Security

Our Security Safeguards. We have established commercially reasonable safeguards to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration and destruction, but we cannot guarantee that your information will never be disclosed in a manner inconsistent with this Privacy Policy (e.g., as a result of unauthorized acts by third parties that violate applicable law, or our or our affiliated providers’ policies). Please be aware that despite our efforts, no data security measures can guarantee 100% security.

Your Obligations. You may log in to your account using third-party credentials or by connecting a digital asset wallet. We may use authentication technologies to register or authenticate you and enable you to use the Site. You are responsible for preventing unauthorized access to your account and Personal Information by appropriately safeguarding all credentials and access methods associated with your use of the Site, including passwords, private keys, seed phrases, recovery codes, and access to your computer, device, and browser, and by logging out or disconnecting your wallet when you have finished using the Site. We are not responsible for any lost, stolen, or compromised credentials or access methods, or for any unauthorized activity conducted through your account or connected wallet.

XV. Governing Law

This Privacy Policy shall be construed in accordance with and governed for all purposes by the substantive laws of the British Virgin Islands without regard to conflicts of law provisions. The exclusive jurisdiction for all disputes will be in the British Virgin Islands, and you and the Company each waive any objection to such jurisdiction and venue.

XVI. Additional Disclosures for an On-Chain, Non-Custodial Interface

• No custody; no private key access. We do not control, hold, or have access to your private keys, seed phrase, or funds. You are solely responsible for securing your wallet and private keys. Transactions you initiate are authorized by you and are broadcast to and settled by the relevant blockchain network.

• Public nature of blockchains. Transactions on public blockchains are inherently transparent and may be viewed by anyone. Please carefully consider what information you choose to associate with your public wallet address.

• Indexing and display. To display balances, positions, fills, and related activity, we or our service providers may query public blockchain data or indexers associated with your connected wallet address. This information is already publicly available and is surfaced to you for convenience.

Contact Us

If you have any questions about this Privacy Policy, please contact us via [email protected].