PRIVACY POLICY

1. “Personal data” (or “personal information” as the case may be) means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you, as defined under applicable Data Protection Legislation. For clarity, blockchain data such as wallet addresses and transaction hashes may be publicly available by design. Where we associate such on-chain data with identifiable off-chain information (such as an email address), that combined dataset may constitute Personal Data.

2. Capitalised terms in this Privacy Policy shall have the meaning given to them in the Terms, unless the context requires otherwise.

3. We may revise this Privacy Policy from time to time without any prior notice. By continuing to access and/or use our Platform or Services, you are deemed to acknowledge and accept such changes to this Privacy Policy.

4. In order to access and/or use the Platform and our Services, you may be required to provide us and we may collect the following categories of personal information:

1. User Account Information (if applicable): If you connect or link your social media profile to the Platform, we will collect such details relating to your social media profile which may include name, username, handles or email addresses.
2. Wallet Information: Details of your Digital Wallet (such as the wallet address) when you create or connect your Digital Wallet with the Platform.
3. User Onboarding Information: information submitted for onboarding, eligibility checks, compliance verification, or KYC (if applicable).
4. Communications Data: Information contained in support requests, surveys, feedback, or community messages.
5. Internet Activity Information: When you visit, use, or interact with the Platform or Services, the following information may be created and automatically logged in our systems:
   1. Device Information: The manufacturer and model, operating system, IP address and unique identifiers of the device, as well as the browser you use to access the Service. The information we collect may vary based on your device type and settings.
   2. Usage Information: Information about how you use our Platform, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.
   3. Email Open/Click Information: We may use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.
6. Transaction and Blockchain Data: When you interact with the Platform, including initiating or authorising Digital Asset transactions, making Transaction Requests, interacting with the Vault Feature or otherwise using Digital Assets, we may process publicly available blockchain data such as transaction hashes, wallet addresses, asset types, amounts, timestamps and network identifiers.

5. We generally do not collect your personal data:

1. if you are just visiting or browsing the Platform without connecting or linking your Digital Wallets;
2. unless it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided consent (whether written or by conduct) to the collection and usage of your personal data for those purposes; or
3. collection and use of personal data without consent is permitted or required by the Data Protection Legislation or other laws. We will seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

6. We may collect and use your personal data for any or all of the following purposes:

1. performing obligations in the course of or in connection with allowing you access or use of our Platform and Services;
2. verifying your digital wallet or identity, where we are required to do so (whether by law or otherwise);
3. provision of the Platform and Services, including to:
   1. provide, operate, maintain, and secure the Platform or Services;
   2. create, maintain, and authenticate your User Account; and
   3. initiating, routing, or facilitating Digital Asset transactions;
4. processing payments for Platform Transactions;
5. marketing and advertising purposes, including to send you direct marketing communications as permitted by law, and notify you of special promotions, offers and events by email and other means;
6. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
7. managing your relationship with us;
8. contacting you in respect of any matters relating to your Platform Transactions;
9. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
10. any other purposes for which you have provided such information;
11. transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether within or outside your jurisdiction of residence; and
12. any other incidental business purposes related to or in connection with the above.

7. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).

8. We may disclose your personal data described above to third parties or in specific situations without further notice to you, unless required by applicable law. Such disclosures may occur in the following instances:

9. Your personal data may be made publicly available in certain instances, including when you:

1. make any social media posts with your social media accounts which we may repost or share on our own social media platforms.

10. For the purposes of registration, verification or provision of any of our Services, we may rely on third parties who may collect, use, disclose or process your personal data for their own purposes, and without our involvement or reference to us. We are not liable or responsible for the collection, use, disclosure or processing of your personal data by such third parties.

11. We may deploy one or more of the following technologies to collect Internet Activity Information in order to enhance your user experience, understand how you interact with our Services, and improve our offerings:

You may refer to our Cookies Notice and Policy as set out at https://rise.trade/cookies for more information.

12. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to us at the contact details provided below.

13. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within fourteen (14) days of receiving it.

14. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue to grant you access and/or use of our Platform and Services and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us via email.

15. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.

16. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request via email to us at the contact details provided below.

17. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

18. We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the Data Protection Legislation).

19. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have or will implement appropriate administrative, physical and technical safeguards. These include limiting the collection of personal data, enforcing strong authentication and access controls (such as secure password practices and restricting data access to a need-to-know basis), encrypting data, maintaining up-to-date antivirus protection, regularly updating our operating system and other software, securely erasing storage devices before disposal, applying web security measures against risks, and conducting regular security reviews and testing.

20. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures. However, no security measures are failsafe and we cannot guarantee the security of your personal data. You use the Platform and our Services at your own risk.

21. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is up-to-date, complete and accurate, please update us if there are changes to your personal data via email at the contact details provided below. Failure to do so may affect or impact your continued use of our Platform and/or Services.

22. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

23. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

24. We generally do not transfer your personal data to countries outside of your country of origin or Panama. However, we may be required to do so in order to complete the fulfilment of your Platform Transaction (for example, if we were to facilitate a registration for an event held outside of your country).

25. Apart from as stated in the paragraph above, we will obtain your consent for the transfer of any personal data to countries outside of your country of origin or Panama and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the Data Protection Legislation.

26. Where required, we rely on adequacy decisions, standard contractual clauses, or other lawful transfer mechanisms.

27. If you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, you may contact us by this email:

Email Address: info@riselabs.xyz