# Privacy Policy _Last updated: June 29, 2026_ ## Introduction Welcome to Hashgraph Online DAO LLC. Hashgraph Online DAO LLC ("us", "we", or "our") operates , the Hashgraph Online Points program, HOL Guard, our software, APIs, hosted dashboards, browser or desktop tools, affiliate program, and related products and services (the "Service"). This Privacy Policy governs your visit to and use of the Service and explains how we collect, safeguard, and disclose information that results from your use of it. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise noted, capitalized terms have the same meaning as in our Terms and Conditions. Our Terms and Conditions ("Terms") govern all use of the Service and together with this Privacy Policy constitute your agreement with us (the "Agreement"). ## Definitions - **Service**: The website, HOL Guard, the Points program, our affiliate program, software, APIs, hosted dashboards, browser or desktop tools, and related products and services operated by Hashgraph Online DAO LLC. - **Personal Data**: Data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession). - **Usage Data**: Data collected automatically, generated by the use of the Service or from Service infrastructure itself (for example, the duration of a page visit). - **Cookies**: Small files stored on your device (computer or mobile device). - **Data Controller**: A natural or legal person who determines the purposes for which and the manner in which any personal data are processed. For this Privacy Policy, we are the Data Controller of your data. - **Data Processors (or Service Providers)**: Any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers to process your data more effectively. - **Data Subject**: Any living individual who is the subject of Personal Data. - **The User**: The individual using our Service, corresponding to the Data Subject. ## Information Collection and Use We collect several different types of information for various purposes to provide and improve our Service to you. ### Types of Data Collected #### Personal Data While using our Service, we may ask you to provide certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to: - Email address and other contact information you provide when creating or accessing an account - Hedera wallet addresses (account IDs) you connect to your account - Telegram account identifiers, profile information, or metadata you authorize us to receive through Telegram login, such as your Telegram user ID or username - Twitter/X account information including username, profile data, and verification status when you link your account - GitHub account information including username and profile data when you link your account - LinkedIn account information when you link your account - Any verification status associated with those contact methods (for example, whether your email has been confirmed) - HOL Guard workspace identifiers, member roles, invitations, device names, agent identifiers, policy settings, approval records, security findings, evidence receipts, audit records, inventory metadata, package metadata, integration status, and configuration data - Content you choose to upload, capture, inspect, store, redact, or sync through HOL Guard features, including AIBOM content, prompts, agent output, logs, files, screenshots, snippets, hashes, and related metadata - Affiliate program application information, audience type, promotional channels, website and social profile URLs, content plans, disclosure confirmations, training progress, link slugs, attribution identifiers, commission records, payout status, and compliance review data - Billing, subscription, invoice, plan, tax, and payment processor records needed to provide paid products and affiliate payouts - Support communications or preferences tied to your contact information - Cookies and Usage Data #### Usage Data We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device ("Usage Data"). This Usage Data may include information such as: - Your computer's IP address (stored for security and session management purposes) - Browser type and version - The pages of our Service that you visit - The time and date of your visit - The time spent on those pages - Unique device identifiers - User agent strings - Referral URLs and attribution data (UTM parameters, campaign sources) - HOL Guard client, daemon, browser, device, command, policy, inventory, approval, package, audit, receipt, and integration event metadata - Affiliate click identifiers, landing pages, attribution session identifiers, hashed IP addresses, hashed user agents, bot or fraud signals, and conversion event metadata - Other diagnostic data When you access the Service with a mobile device, Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers, and other diagnostic data. #### Tracking Cookies Data We use cookies and similar tracking technologies to track the activity on our Service and hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags, and scripts to collect and track information and to improve and analyze our Service. **Cookie Consent**: If you are located in the European Union (EU), European Economic Area (EEA), United Kingdom, or Switzerland, we will obtain your explicit consent before placing non-essential cookies on your device. You can manage your cookie preferences at any time through the "Cookie Settings" link in our website footer or through your browser settings. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept essential cookies, you may not be able to use some portions of our Service. **Types of cookies we use:** - **Essential Cookies**: Required for basic site functionality, authentication, and security. Cannot be disabled. - **Analytics Cookies**: Used to understand how visitors interact with our Service. Requires consent in GDPR regions. - **Marketing Cookies**: Used to serve you with advertisements that may be relevant to you and your interests. Requires consent in GDPR regions. - **Affiliate and Attribution Cookies**: Used to remember eligible HOL Guard affiliate referrals, landing-page context, and checkout attribution for the stated attribution window. These cookies support commission reconciliation, fraud prevention, and compliance review. ## Lawful Basis for Processing (GDPR) Under the General Data Protection Regulation (GDPR), we process your personal data based on the following lawful bases: | Data Type | Lawful Basis | Purpose | |-----------|--------------|---------| | Account information (email, password) | Contractual necessity | To provide and maintain your account | | Session data (IP, user agent) | Legitimate interest | Security and fraud prevention | | Analytics data | Consent | To improve our Service | | Marketing communications | Consent | To send promotional content | | Task/points history | Contractual necessity | To provide the points system service | | Social account links | Consent | To verify identity and enable features | | HOL Guard workspace, policy, device, agent, evidence, and security event data | Contractual necessity and legitimate interest | To provide security workflow, audit, policy, and automation features | | Billing and subscription records | Contractual necessity and legal obligation | To process paid plans, invoices, taxes, disputes, and collections | | Affiliate application, attribution, compliance, commission, and payout data | Contractual necessity, legitimate interest, and legal obligation | To operate the affiliate program, review compliance, prevent fraud, and process payouts | ## Use of Data Hashgraph Online DAO LLC uses the collected data for various purposes: - To provide and maintain our Service - To authenticate you and allow you to access your account, including sending verification or transactional emails related to login or account activity - To process Telegram-based authentication, including verifying Telegram credentials and communicating app notifications permissible under Telegram's policies - To notify you about changes to our Service - To respond to inquiries or support requests you send via email or other contact channels - To allow you to participate in interactive features of our Service when you choose to do so - To provide customer support - To provide HOL Guard security workflow, policy, audit, evidence, agent-control, inventory, alerting, billing, and workspace-administration features - To process affiliate applications, track eligible referrals, perform compliance and fraud review, calculate commissions, manage payout readiness, and enforce program terms - To gather analysis or valuable information so that we can improve our Service - To monitor the usage of our Service - To detect, prevent, and address technical issues - To detect, prevent, investigate, and respond to abuse, fraud, spam, policy violations, payment disputes, unauthorized access, suspicious affiliate activity, security incidents, and other harmful activity - To fulfill any other purpose for which you provide data - To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection - To provide you with notices about your account and/or subscription, including expiration and renewal notices, email instructions, etc. - To provide you with news, special offers, and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information - In any other way we may describe when you provide the information - For any other purpose with your consent ## Data Retention Periods We retain your personal data for specific periods based on the type of data: | Data Type | Retention Period | Rationale | |-----------|------------------|-----------| | Active user accounts | Indefinite (until deletion requested) | Required to provide service | | Session tokens | 30 days | Security purposes | | Admin activity logs | 1 year | Audit and compliance | | Task submissions | 2 years | Historical record for points system | | Referral records | 2 years | Attribution tracking | | HOL Guard workspace, policy, inventory, receipt, and evidence records | Account or workspace lifetime unless a shorter product retention setting applies | Provide security history, auditability, policy enforcement, and customer-requested evidence | | HOL Guard security, abuse, fraud, and access logs | Up to 2 years, or longer if needed for an active investigation or legal obligation | Security, abuse prevention, incident response, and compliance | | Affiliate applications, terms acceptances, attribution records, commission records, compliance reviews, payout records, and fraud signals | Up to 7 years after the relevant program activity, or longer if required by law or dispute | Program administration, tax, payment, fraud prevention, audit, and dispute resolution | | Billing, invoice, tax, payment, refund, chargeback, and subscription records | Up to 7 years, or longer if required by law or dispute | Accounting, tax, payment processing, fraud prevention, and legal compliance | | Email verification tokens (consumed) | 7 days | Security cleanup | | Password reset tokens (consumed) | 7 days | Security cleanup | | Soft-deleted accounts | 30 days before permanent deletion | Allows account recovery if requested in error | After these retention periods, data is either permanently deleted or anonymized so it can no longer be associated with you, unless we need to retain it for legal, tax, accounting, security, fraud prevention, dispute resolution, or compliance purposes. Public blockchain records, third-party records, and data retained by workspace administrators or other users may remain outside our control. ## Transfer of Data Your information, including Personal Data, may be transferred to—and maintained on—computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. Hashgraph Online DAO LLC will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place, including the security of your data and other personal information. ## Disclosure of Data We may disclose personal information that we collect, or you provide: - **Disclosure for Law Enforcement**: Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities. - **Business Transaction**: If we or our subsidiaries are involved in a merger, acquisition, or asset sale, your Personal Data may be transferred. - **Workspace Administration**: If you use HOL Guard as part of a workspace, organization, team, or affiliate account, workspace administrators and authorized personnel may access, export, manage, or restrict certain account, member, device, agent, policy, billing, evidence, receipt, activity, and affiliate data. - **Service Providers and Integrations**: We may share data with vendors and integrations that help us provide hosting, analytics, authentication, support, billing, payout, affiliate attribution, fraud prevention, security, communications, storage, and product operations. - **Affiliate Program and Referred Customers**: We may use and disclose limited affiliate and referral data to validate attribution, prevent fraud, reconcile commissions, process payouts, resolve disputes, and enforce program terms. We do not disclose raw payment card details to affiliates. - **Security and Abuse Prevention**: We may disclose data when we believe it is necessary to investigate, prevent, or respond to fraud, spam, unauthorized access, security incidents, harmful automation, policy violations, payment disputes, or threats to rights, property, or safety. - **Other Cases**: We may disclose your information to our subsidiaries and affiliates and if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. ## Security of Data The security of your data is important to us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. Our security measures include: - Encryption of data in transit (HTTPS/TLS) - Secure password hashing using industry-standard algorithms - Regular security audits and vulnerability assessments - Access controls limiting who can view personal data HOL Guard may help you detect or document risks in your own environment, but our security features do not eliminate your responsibility to secure your systems, maintain backups, manage access, review policies, validate findings, and comply with your own legal and contractual obligations. ## HOL Guard Data and Customer Content HOL Guard may process data from systems you connect or configure, including repositories, agents, local devices, package managers, browser sessions, MCP servers, AI tools, command runners, workspace members, policy engines, logs, receipts, AIBOM content, and third-party integrations. Depending on your configuration, this data may include source material, prompts, agent output, package metadata, file names, screenshots, snippets, hashes, event history, decisions, approvals, and security findings. You control what systems and content you connect to HOL Guard. You are responsible for ensuring that you have authority to submit, inspect, store, redact, or sync that data and for configuring retention, role access, and redaction settings appropriate for your organization. We use HOL Guard customer content to provide, secure, troubleshoot, support, and improve HOL Guard and related services, and to comply with law and enforce our terms. ## Affiliate Program Privacy When you apply for, use, or interact with the HOL Guard affiliate program, we process application details, audience information, promotional channels, disclosure confirmations, attribution data, click identifiers, hashed IP addresses, hashed user agents, fraud or bot signals, conversion events, terms acceptance records, commission ledgers, compliance reviews, payout readiness, payout processor status, support communications, and related records. We use affiliate data to evaluate applications, provide tracking links, attribute eligible referrals, comply with advertising and endorsement rules, calculate and review commissions, prevent fraud and self-referrals, process payouts, resolve disputes, and enforce program terms. Affiliate tracking may not identify every eligible visit or conversion, and users may clear cookies, block tracking, withhold consent, use privacy tools, or interact through channels that prevent attribution. ## Your Data Protection Rights Under the General Data Protection Regulation (GDPR) If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights covered by the GDPR (). We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. ### Exercising Your Rights You can exercise most of your data rights directly through our platform: - **Data Export**: Visit your [Privacy Settings](/points/privacy-settings) page to download a copy of all your personal data in JSON format. - **Account Deletion**: Visit your [Privacy Settings](/points/privacy-settings) page to delete your account and remove your personal data. - **Cookie Preferences**: Click "Cookie Settings" in the website footer to manage your consent preferences. For other requests or if you need assistance, please email us at [help@hashgraphonline.com](mailto:help@hashgraphonline.com). ### Your Rights Include: - **Right of Access**: The right to obtain a copy of your personal data we hold about you. - **Right of Rectification**: The right to have inaccurate personal data corrected. - **Right of Erasure**: The right to have your personal data deleted ("right to be forgotten"). - **Right to Object**: The right to object to our processing of your personal data. - **Right of Restriction**: The right to request that we restrict the processing of your personal data. - **Right to Data Portability**: The right to receive your personal data in a structured, machine-readable format. - **Right to Withdraw Consent**: The right to withdraw consent at any time where we rely on consent to process your personal data. We may ask you to verify your identity before responding to such requests, and we may not be able to provide Service without some necessary data. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA). ## Your Data Protection Rights under the California Online Privacy Protection Act (CalOPPA) CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law's reach stretches well beyond California to require any person or company in the United States (and conceivable the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating the information being collected, with whom it is shared, and to comply with this policy. Learn more at . According to CalOPPA we agree to the following: - Users can visit our site anonymously. - Our Privacy Policy link includes the word "Privacy" and can easily be found on the page specified above on the home page of our website. - Users will be notified of any privacy policy changes on our Privacy Policy Page. - Users are able to change their personal information by emailing us at [help@hashgraphonline.com](mailto:help@hashgraphonline.com). ## Our Policy on "Do Not Track" Signals We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. ## Your Privacy Rights Under the California Consumer Privacy Act (CCPA/CPRA) If you are a California resident, you have specific rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act (collectively, "CCPA"). This section describes your CCPA rights and how to exercise them. ### Categories of Personal Information We Collect Under the CCPA, "personal information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. We collect the following categories of personal information: | Category | Examples | Collected | |----------|----------|-----------| | A. Identifiers | Email address, Hedera wallet address, IP address, username | Yes | | B. Personal Information (Cal. Civ. Code § 1798.80(e)) | Name, email address | Yes | | C. Protected Classification Characteristics | None | No | | D. Commercial Information | Points balance, task completions, giveaway entries, subscriptions, invoices, affiliate commissions | Yes | | E. Biometric Information | None | No | | F. Internet or Network Activity | Browsing history, page interactions, referral source | Yes | | G. Geolocation Data | IP-based country/region (not precise location) | Yes | | H. Sensory Data | None | No | | I. Professional or Employment Information | Affiliate applications, role or workspace details, business contact details you provide | Yes | | J. Non-Public Education Information | None | No | | K. Inferences from Personal Information | Account preferences, engagement patterns, fraud or risk signals, audience fit review | Yes | | L. Sensitive Personal Information | None | No | ### Purposes for Collection and Use We collect personal information for the following purposes: - To provide and maintain our Service - To process your transactions and manage your account - To communicate with you about your account - For analytics and service improvement - For security and fraud prevention - To comply with legal obligations ### Your CCPA Rights As a California resident, you have the following rights: 1. **Right to Know**: You have the right to request that we disclose: - The categories of personal information we have collected about you - The categories of sources from which personal information was collected - The business or commercial purposes for collecting or selling personal information - The categories of third parties with whom we share personal information - The specific pieces of personal information we have collected about you 2. **Right to Delete**: You have the right to request that we delete personal information we collected from you, subject to certain exceptions. 3. **Right to Correct**: You have the right to request that we correct inaccurate personal information we maintain about you. 4. **Right to Opt-Out of Sale/Sharing**: You have the right to opt out of the "sale" or "sharing" of your personal information for cross-context behavioral advertising purposes. 5. **Right to Limit Use of Sensitive Personal Information**: If we collected sensitive personal information, you would have the right to limit its use. However, we do not currently collect sensitive personal information as defined by the CCPA. 6. **Right to Non-Discrimination**: We will not discriminate against you for exercising any of your CCPA rights. ### Exercising Your Rights To exercise your CCPA rights, you may: - **Self-Service**: Visit your [Privacy Settings](/points/privacy-settings) page to download your data or delete your account - **Email**: Submit a request to [help@hashgraphonline.com](mailto:help@hashgraphonline.com) with "CCPA Request" in the subject line We will verify your identity before processing your request. For requests submitted via email, we may ask you to provide information that matches information we have on file. **Response Time**: We will respond to verifiable requests within 45 days. If we need additional time (up to 90 days total), we will inform you of the reason and extension period in writing. ### Sale and Sharing of Personal Information **We do not sell your personal information** as defined by the CCPA. We do not receive monetary consideration in exchange for your personal information. **Sharing for Cross-Context Behavioral Advertising**: We may share certain information with analytics providers (such as Google Analytics) for analytics purposes. You can opt out of this sharing by: - Adjusting your Cookie Preferences via the "Cookie Settings" link in the footer - Using the [Google Analytics Opt-out Browser Add-on](https://tools.google.com/dlpage/gaoptout) ### Authorized Agents You may designate an authorized agent to submit CCPA requests on your behalf. To do so, you must provide the authorized agent written permission to submit requests on your behalf and verify your identity directly with us. ### Financial Incentives We do not offer financial incentives for the collection, sale, or deletion of personal information. ## California's "Shine the Light" Law California Civil Code Section 1798.83 permits users who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes. ## Privacy Rights for Residents of Other US States Several US states have enacted comprehensive privacy laws similar to the CCPA. If you are a resident of a US state with a comprehensive privacy law, you may have rights under your state's privacy law. These states currently include, as applicable, California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, and other states as their laws become effective. ### Common Rights Under State Privacy Laws Residents of states with comprehensive privacy laws generally have the following rights: 1. **Right to Access**: The right to confirm whether we are processing your personal data and to access that data. 2. **Right to Delete**: The right to request deletion of your personal data. 3. **Right to Correct**: The right to correct inaccurate personal data. 4. **Right to Data Portability**: The right to obtain a copy of your data in a portable format. 5. **Right to Opt-Out**: The right to opt out of: - Targeted advertising - Sale of personal data (where applicable) - Profiling in furtherance of decisions that produce legal or similarly significant effects ### State-Specific Information | State | Applicable Law | Effective Date | |-------|----------------|----------------| | Virginia | Virginia Consumer Data Protection Act (VCDPA) | January 1, 2023 | | Colorado | Colorado Privacy Act (CPA) | July 1, 2023 | | Connecticut | Connecticut Data Privacy Act (CTDPA) | July 1, 2023 | | Utah | Utah Consumer Privacy Act (UCPA) | December 31, 2023 | | Texas | Texas Data Privacy and Security Act (TDPSA) | July 1, 2024 | | Oregon | Oregon Consumer Privacy Act (OCPA) | July 1, 2024 | | Montana | Montana Consumer Data Privacy Act (MCDPA) | October 1, 2024 | | Delaware | Delaware Personal Data Privacy Act (DPDPA) | January 1, 2025 | | Iowa | Iowa Consumer Data Protection Act (ICDPA) | January 1, 2025 | | Nebraska | Nebraska Data Privacy Act (NDPA) | January 1, 2025 | | New Hampshire | New Hampshire Data Privacy Act | January 1, 2025 | | New Jersey | New Jersey Data Privacy Act | January 15, 2025 | | Tennessee | Tennessee Information Protection Act (TIPA) | July 1, 2025 | | Minnesota | Minnesota Consumer Data Privacy Act (MCDPA) | July 31, 2025 | | Maryland | Maryland Online Data Privacy Act (MODPA) | October 1, 2025 | | Indiana | Indiana Consumer Data Protection Act (INCDPA) | January 1, 2026 | | Kentucky | Kentucky Consumer Data Protection Act (KCDPA) | January 1, 2026 | | Rhode Island | Rhode Island Data Transparency and Privacy Protection Act | January 1, 2026 | ### How to Exercise Your Rights To exercise your privacy rights under any state law: - **Self-Service**: Visit your [Privacy Settings](/points/privacy-settings) page - **Email**: Contact us at [help@hashgraphonline.com](mailto:help@hashgraphonline.com) with your state and request type in the subject line ### Appeals Process If we decline to take action on your request, you have the right to appeal our decision. To appeal, please email [help@hashgraphonline.com](mailto:help@hashgraphonline.com) with "Privacy Appeal" in the subject line within 60 days of receiving our response. We will respond to your appeal within 60 days. If you are not satisfied with our appeal response, you may contact your state's Attorney General to file a complaint. ## Service Providers We may employ third-party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services, or assist us in analysing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. ### Third-Party Data Processors We use the following third-party service providers who may process your personal data: #### Analytics | Provider | Purpose | Data Processed | Privacy Policy | |----------|---------|----------------|----------------| | Google Analytics / Google Tag Manager | Website analytics and event tracking | Page views, events, device info | [Google Privacy Policy](https://policies.google.com/privacy) | | Umami Analytics | Privacy-focused analytics | Anonymized page views, referrers | [Umami Privacy](https://umami.is/privacy) | | Microsoft Clarity | Session recordings and heatmaps (with consent) | Mouse movements, clicks, page interactions | [Microsoft Privacy](https://privacy.microsoft.com/) | #### Email Services | Provider | Purpose | Data Processed | Privacy Policy | |----------|---------|----------------|----------------| | Brevo (formerly Sendinblue) | Transactional and marketing emails | Email address, name, subscription status | [Brevo Privacy Policy](https://www.brevo.com/legal/privacypolicy/) | #### Infrastructure | Provider | Purpose | Data Processed | Privacy Policy | |----------|---------|----------------|----------------| | Google Cloud Storage | File and media storage | Uploaded files, profile images | [Google Cloud Privacy](https://cloud.google.com/terms/cloud-privacy-notice) | | DigitalOcean | Hosting infrastructure | Server logs, IP addresses | [DigitalOcean Privacy](https://www.digitalocean.com/legal/privacy-policy) | #### Authentication | Provider | Purpose | Data Processed | Privacy Policy | |----------|---------|----------------|----------------| | GitHub OAuth | Account linking and verification | GitHub username, profile info | [GitHub Privacy](https://docs.github.com/en/site-policy/privacy-policies/github-privacy-statement) | | Google OAuth | Account authentication | Email, profile info | [Google Privacy Policy](https://policies.google.com/privacy) | All third-party service providers are contractually bound to protect your data and use it only for the specific purposes outlined. Where required, we have Data Processing Agreements (DPAs) in place with these providers. ### CI/CD Tools #### GitHub GitHub, provided by GitHub, Inc., is a development platform to host and review code, manage projects, and build software. For more information on what data GitHub collects, for what purpose, and how the protection of the data is ensured, please visit the GitHub Privacy Policy page: . ## Payments We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g., payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information. The payment processors we work with are: - **Stripe**: - **PayPal or Braintree**: - **Apple Store In-App Payments**: / - **Google Play In-App Payments**: / Affiliate payouts may be processed through third-party payout providers. Those providers may collect identity, tax, bank, card, sanctions-screening, and payout information directly from affiliates under their own terms and privacy policies. ## Links to Other Sites Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. ## Children's Privacy Our Services are not intended for use by children under the age of 13 ("Children"). We do not knowingly collect personally identifiable information from Children under 13. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers. For users in the European Union, the minimum age for consent to data processing is 16 years (or lower as specified by individual EU member states, but not below 13 years). ## Data Breach Notification In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will: 1. Notify the relevant supervisory authority within 72 hours of becoming aware of the breach 2. Notify affected individuals without undue delay if the breach is likely to result in a high risk to their rights and freedoms 3. Document the breach, its effects, and the remedial action taken ## Changes to This Privacy Policy We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. ## Contact Us If you have any questions about this Privacy Policy, please contact us: - **Email**: [help@hashgraphonline.com](mailto:help@hashgraphonline.com) - **Data Protection Inquiries**: For GDPR-specific inquiries, please include "GDPR Request" in your email subject line. ### Response Times We aim to respond to all data protection requests within: - **GDPR requests**: 30 days (as required by law) - **General inquiries**: 5 business days