Privacy Policy

1. Introduction

ClearCoin Foundation ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use ClearWallet Professional (the "Service"). Please read this policy carefully to understand our practices regarding your personal data.

By using the Service, you consent to the data practices described in this Privacy Policy. If you do not agree with this policy, please discontinue use of the Service immediately.

2. Information We Collect

2.1 Personal Information

We may collect the following personal information from you:

• Contact Information: Email address, name
• Identity Verification Data: Government-issued ID, proof of address, biometric data (when KYC/AML verification is required)
• Account Information: Username, encrypted passwords, security questions
• Transaction Data: Wallet addresses, transaction history, token balances

2.2 Automatically Collected Information

When you access the Service, we automatically collect certain information, including:

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages visited, time spent on the Service, clickstream data
• Log Data: Error logs, access times, referring URLs
• Cookies and Tracking Technologies: Session cookies, analytics cookies, preference cookies

2.3 Blockchain Data

As a blockchain-based service, certain information is inherently public and recorded on the Cosmos blockchain, including:

• Wallet addresses
• Transaction amounts and timestamps
• Smart contract interactions
• Token holdings and transfers

Important: Blockchain transactions are permanent and publicly visible. We have no control over this data once it is recorded on the blockchain.

3. How We Use Your Information

We use the collected information for the following purposes:

• Service Provision: To create and manage your wallet, process transactions, and provide customer support
• Security: To detect and prevent fraud, unauthorized access, and other illegal activities
• Compliance: To comply with legal obligations, including KYC/AML regulations and tax reporting requirements
• Communication: To send you service updates, security alerts, and administrative messages
• Improvement: To analyze usage patterns and improve the Service's functionality and user experience
• Legal Protection: To enforce our Terms of Use and protect our rights and property

4. How We Share Your Information

We may share your information with third parties in the following circumstances:

4.1 Service Providers

We may share your information with third-party service providers who perform services on our behalf, such as:

• Identity verification and KYC/AML screening services
• Cloud storage and hosting providers
• Analytics and monitoring services
• Customer support platforms

4.2 Legal Requirements

We may disclose your information if required to do so by law or in response to:

• Valid legal process (subpoenas, court orders)
• Government or regulatory requests
• Law enforcement inquiries
• Protection of our rights, property, or safety

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred to the acquiring entity, subject to this Privacy Policy.

4.4 With Your Consent

We may share your information with third parties when you explicitly consent to such sharing.

5. Data Security

We implement industry-standard security measures to protect your personal information, including:

• Encryption: AES-256 encryption for mnemonic phrases and sensitive data at rest; TLS/SSL for data in transit
• Access Controls: Role-based access controls and multi-factor authentication for administrative accounts
• Monitoring: Continuous security monitoring and intrusion detection systems
• Regular Audits: Periodic security assessments and vulnerability testing
• Secure Infrastructure: Use of secure cloud hosting with redundancy and backup systems

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

6. Data Retention

We retain your personal information for as long as necessary to:

• Provide the Service to you
• Comply with legal and regulatory requirements (typically 7 years for financial records)
• Resolve disputes and enforce our agreements
• Maintain security and prevent fraud

When personal information is no longer needed, we will securely delete or anonymize it in accordance with our data retention policies and applicable laws.

7. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information (subject to legal obligations)
• Data Portability: Request transfer of your data to another service provider
• Objection: Object to certain processing activities
• Restriction: Request restriction of processing in certain circumstances
• Withdrawal of Consent: Withdraw your consent for processing (where applicable)

To exercise these rights, please contact us at [email protected]. We will respond to your request within 30 days, as required by applicable law.

8. Children's Privacy

The Service is not intended for individuals under the age of 18 (or the age of majority in your jurisdiction). We do not knowingly collect personal information from children. If we become aware that we have collected information from a child without parental consent, we will take steps to delete such information promptly.

9. International Data Transfers

Your information may be transferred to, stored, and processed in countries other than your country of residence. These countries may have data protection laws that differ from those in your jurisdiction. By using the Service, you consent to the transfer of your information to these countries. We will take appropriate measures to ensure that your data receives an adequate level of protection in accordance with applicable data protection laws.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to:

• Maintain your session and keep you logged in
• Remember your preferences and settings
• Analyze usage patterns and improve the Service
• Detect and prevent fraud and security incidents

You can control cookie settings through your browser preferences. However, disabling cookies may affect the functionality of the Service.

11. Third-Party Links and Services

The Service may contain links to third-party websites or integrate with third-party services. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party sites or services before providing them with your information.

12. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know what personal information is collected, used, shared, or sold
• Right to delete personal information (subject to exceptions)
• Right to opt-out of the sale of personal information (we do not sell personal information)
• Right to non-discrimination for exercising your CCPA rights

To exercise these rights, contact us at [email protected] with "CCPA Request" in the subject line.

13. European Privacy Rights (GDPR)

If you are a resident of the European Economic Area (EEA), you have rights under the General Data Protection Regulation (GDPR), including:

• Right to access, rectify, or erase your personal data
• Right to restrict or object to processing
• Right to data portability
• Right to withdraw consent at any time
• Right to lodge a complaint with a supervisory authority

Our legal basis for processing your data includes: performance of a contract, compliance with legal obligations, legitimate interests, and consent (where required).

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by:

• Posting the updated Privacy Policy on the Service
• Updating the "Last Updated" date
• Sending notice to your registered email address (for significant changes)

Your continued use of the Service after such modifications constitutes your acceptance of the updated Privacy Policy.

15. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us: