Privacy Policy
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Privacy Policy for Felix
Last Updated: 30 October 2024
Introduction
1.1. This Privacy Policy details how Felix (“we,” “us,” “our,” or the “Platform”) collects, processes, shares, and safeguards information about users (“Users” or “You”) interacting with or using our Platform. We respect your privacy and are dedicated to protecting your Personal Data and Blockchain Data in accordance with applicable data protection laws.
1.2. Definitions: Unless expressly defined herein, all capitalised terms in this Privacy Policy are as defined in the Platform’s General Terms and Conditions (“T&Cs”). By accessing or using the Platform, you confirm your understanding of and consent to, the data practices outlined in this Privacy Policy. If you disagree with this Policy, please discontinue use of the Platform.
Definitions
2.1. For clarity, the following terms are defined as follows:
2.1.1. Platform: Felix’s digital ecosystem, including its user interface and smart contract infrastructure, facilitates decentralised finance (DeFi) transactions, including borrowing, collateral management, and token redemptions.
2.1.2. Personal Data: Information that can identify an individual, either alone or combined with other data, as defined by relevant data protection laws.
2.1.3. Blockchain Data: Information related to blockchain transactions, including wallet addresses, transaction IDs, and timestamps, is recorded on the blockchain.
2.1.4. Third-Party Wallet Providers: Independent wallet services (such as MetaMask) that allow Users to interact with blockchain-based services on the Platform.
2.2. These definitions are aligned with the T&Cs, ensuring that terms are consistent across all documents governing your use of the Platform.
Information We Collect
Felix collects several types of information necessary to provide our services, enhance the user experience, comply with legal obligations, and ensure the security of the Platform.
3.1. Information Provided by Users
3.1.1. Blockchain Wallet Information: To use the Platform, Users must connect a compatible blockchain wallet. We do not store private keys or access wallet contents; however, wallet addresses and transaction data may be recorded to execute transactions and facilitate Platform interactions.
3.1.2. User Preferences and Settings: Some Platform features allow Users to set preferences, such as notifications for collateral thresholds or redemption alerts. This information is stored in association with the User’s wallet address.
3.1.3. User Communications: When you contact our support team, we collect the communication details, including your email address, name, and message content. This information helps us respond to inquiries and improve our customer service.
3.2. Automatically Collected Information
3.2.1. Blockchain Data: Due to the transparency of blockchain networks, all transactions (e.g., borrowing, redemptions) conducted on the Platform are visible on the public blockchain. This includes wallet addresses, transaction timestamps, and transaction-specific details, which are immutable and beyond the Platform’s control.
3.2.2. Usage Data: We collect technical data automatically when you access the Platform, including browser types, device types, operating systems, IP addresses, page views, and timestamps. This information is de-identified where feasible and used to monitor and improve Platform performance.
3.2.3. Cookies and Similar Technologies: We may use cookies or similar technologies to enhance Platform navigation, remember User preferences, and analyze trends. You may adjust browser settings to control cookie preferences, though this may affect the usability of certain Platform features.
3.3. Information from Third-Party Sources
3.3.1. Third-Party Wallet Providers: When you connect a third-party wallet to the Platform, limited data is shared with us (e.g., your wallet address) to facilitate access. We advise reviewing the privacy practices of any third-party wallet provider, as we are not responsible for the data handling practices of these providers.
How We Use Your Information
The Platform uses collected data for various essential purposes, as outlined below:
4.1. Service Provision and Platform Management
4.1.1. Facilitating Transactions: Wallet and transaction data are processed to execute and verify transactions on the Platform, such as collateral deposits, redemptions, and loan repayments.
4.1.2. User Experience Optimization: Usage data is analysed to improve Platform performance, tailor user interfaces, and introduce new features based on user demand and technical insights.
4.1.3. Maintaining Security: We process data to detect and mitigate security risks, unauthorised access attempts, and other malicious activity. This includes monitoring for suspicious activity to protect User assets and Platform integrity.
4.1.4. Customer Support and Communication: Communication data enables us to address inquiries, provide support, resolve technical issues, and enhance the overall User experience.
4.2. Legal and Regulatory Compliance
4.2.1. Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF): Certain data may be processed in line with regulatory requirements to monitor for suspicious activity and report where legally required.
4.2.2. Compliance and Risk Management: We process data to manage financial, operational, and legal risks, ensuring the Platform remains compliant with applicable laws and minimising exposure to liabilities or reputational harm.
4.3. Research and Analytics
4.3.1. Aggregated Analytics: Anonymized data is aggregated for research and trend analysis to improve Platform efficiency and identify new user needs. Aggregated data cannot be used to identify individual Users.
Information Disclosure
Felix shares User data with third parties only in limited, controlled situations to protect User privacy and ensure compliance with legal obligations.
5.1. Public Disclosure of Blockchain Data
5.1.1. Blockchain Transparency: Transactions on the Platform are inherently public and recorded on blockchain networks. This transparency is fundamental to decentralised finance, and as such, wallet addresses and transaction metadata are viewable by any network participant. Felix does not control or modify this public record.
5.2. Disclosures to Service Providers and Legal Entities
5.2.1. Service Providers: We may share limited data with third-party vendors, including analytics providers and security experts, to help maintain, analyse, and optimise Platform performance.
5.2.2. Legal and Regulatory Disclosure: We may disclose Personal Data to comply with legal processes, court orders, or regulatory obligations. This includes responding to lawful requests by law enforcement authorities where there is a valid legal basis.
5.3. Business Transactions
5.3.1. Corporate Changes: In the event of a merger, acquisition, or sale of Felix, User data may be transferred to the acquiring entity as part of the transaction. In such cases, we will provide notice of any new or revised Privacy Policy applicable to Users.
Data Retention
Data collected on the Platform is retained only as long as necessary to fulfil the purposes outlined in this Privacy Policy or as required by law. Blockchain Data remains permanently recorded on the blockchain network, as is inherent to blockchain technology. Customer Support Data and other communication records are retained for reference, dispute resolution, and quality control for a period as specified by applicable laws, after which they may be anonymised or deleted.
Security Measures
7.1. We implement technical and organisational security measures to protect User data from unauthorised access, disclosure, alteration, or destruction. Measures include:
7.1.1. Encryption: Sensitive data is encrypted during transmission and storage where applicable.
7.1.2. Access Controls: Only authorised personnel have access to User data, and access is granted strictly on a need-to-know basis.
7.1.3. Regular Audits: We conduct security audits and vulnerability assessments to identify and address potential threats to data integrity.
7.1.4. User Responsibility: Users are advised to protect their private keys and wallet credentials diligently, as these are essential for accessing and securing their blockchain assets.
7.2. While we take comprehensive steps to secure data, Users should note that blockchain technology involves unique security risks, and no method of electronic storage is entirely secure.
International Data Transfers
Given the global nature of blockchain technology, User data may be processed on servers in jurisdictions outside the User’s home country. These jurisdictions may not have equivalent data protection laws, but we will take steps to ensure that any transfer of Personal Data is protected in line with applicable privacy standards. By using the Platform, you agree to such international data transfers.
User Rights and Choices
9.1. Depending on applicable laws, you may have the following rights concerning your Personal Data:
9.1.1. Right of Access: You may request access to your Personal Data and ask us to confirm whether we are processing it, along with information about the purposes of processing and any third-party data recipients.
9.1.2. Right to Correction: You can request that we correct or update any inaccurate or incomplete Personal Data.
9.1.3. Right to Deletion: Where feasible, you may request the deletion of your Personal Data. Note that data stored on the blockchain cannot be altered or deleted by the Platform.
9.1.4. Data Portability: You may request a copy of your Personal Data in a machine-readable format to transfer it to another service.
Children’s Privacy
The Platform is not intended for individuals under the age of 18, and we do not knowingly collect Personal Data from minors.
Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes in our practices, legal obligations, or technology. When updates are made, we will revise the “Last Updated” date at the top of this page.
Last updated