Privacy policy

§ 01

1. The starting point: your address is personal data

A public wallet address, linked to your account, allows you to be identified indirectly. The history derived from it (balances, counterparties, dates, frequencies) is just as identifying as the address itself. We therefore treat both with the same level of protection.

This is not an in-house precaution. The European data protection authority wrote, in its guidelines on blockchain, that a public key constitutes personal data as soon as it can be used to identify a person by means reasonably likely to be used. Here that means is not hypothetical: the mapping between an address and an account is our data model.

• No address ever appears in a URL, a campaign link, a page title or an e-mail subject.
• No address is sent to a third-party analytics, testing, support or marketing tool.
• Application logs contain only an internal identifier; the mapping table is isolated and encrypted.
• You can detach an address at any time: the link between that address and your account is erased.

§ 02

2. Who the controller is

The controller, within the meaning of the Swiss Federal Act on Data Protection and of the General Data Protection Regulation, is Delta-One Capital Sàrl, a Swiss limited liability company. That company decides the purposes and means of the processing described below, answers your access, rectification and erasure requests, and would issue any breach notification to the competent authority.

Full details are in the legal notice. Whether a representative must be appointed in Switzerland or in the European Union depends on the customers actually served; it is being examined with counsel and will be stated here once settled.

§ 03

3. What we process, why, on what basis and for how long

§ 04

4. What we do not do

This list matters as much as the previous one. Each of these practices would require a new purpose, a new legal basis and new information; none is planned.

• No enrichment of your profile from data brokers.
• No cross-referencing of two different customers’ addresses.
• No sale, sharing or making available of data to commercial third parties.
• No model training on identifiable customer data.
• No targeted advertising based on on-chain data.
• No retention of an address after you detach it.
• No use of the IP address kept as evidence of consent for any purpose other than that evidence.

§ 05

5. Automated decisions and the right to human review

The software produces automated verdicts. Some are adverse: a safety veto can stop you from continuing a mission, that is, stop you from obtaining what you are paying for.

For those adverse verdicts you can require re-examination by a natural person. That right is not an e-mail address buried in a document: it is a button on the screen that displays the refusal, and the re-examination ends in a reasoned answer.

A favourable verdict is not a validation. It means the checks performed found nothing known, not that an operation is safe, nor that it suits you.

§ 06

6. Processors, location and transfers

The service relies on a small number of technical providers: hosting, transactional e-mail, payment collection, blockchain access, providers of artificial-intelligence models and of public data. The named list, the actual location of each processing operation and the applicable transfer mechanism are published and kept up to date in a versioned annex.

We do not state that hosting sits in a given country until every link in the chain (database, backups, logs, e-mail, payments) has been verified individually. A location promise invalidated by a single processor is a false promise, and we would rather not make it.

The transfer mechanism outside Switzerland or the European Union is declared provider by provider: an adequacy decision or standard contractual clauses as the case may be. No general clause stands in for a mechanism; an undocumented transfer is an unauthorised transfer.

§ 07

7. Cookies and audience measurement

• The public site sets only the cookies strictly necessary to run, and calls no third-party domain: no external font, no advertising script, no delivery network.
• The authenticated area uses a session cookie, needed to keep you signed in, and a language and currency preference cookie.
• Audience measurement is limited to aggregated events from a closed list, with no persistent identifier and no third-party tool. A wallet address never appears in it.

§ 08

8. Your rights, and how to exercise them

You can ask for access to your data, its rectification, its erasure, its portability, the restriction of its processing, and object to processing based on legitimate interest. You can withdraw your consent to marketing communications at any time. You can require human review of an adverse automated decision.

Send your request to the contact shown on the Contact page, or use the corresponding functions in your account. We acknowledge receipt, verify your identity without collecting more than necessary, and state the applicable time limit. You may also bring the matter before the competent data protection authority, in Switzerland or in your country of residence.

• Some data cannot be erased immediately: accounting records are subject to a statutory retention period, and tamper-evident administration logs cannot be deleted; their link with your identity is severed instead.
• The full export of your data is guaranteed, available without going through support, and blocked by no service kill switch.

§ 09

9. Retention and deletion

Every piece of data has a retention period declared from the moment it is created: without one it would be kept indefinitely by accident, which is the most common and least visible failure mode.

Deletion follows a complete chain: primary database, replicas and caches, generated exports, backups purged at a declared deadline and never reindexed, application logs, and a request sent to each processor with the confirmation kept. That chain is tested at least once a year on a test account.

§ 10

10. Data protection impact assessment

The processing combines financial data linked to a person, outputs of artificial-intelligence models and automated decisions: it calls for a data protection impact assessment, and that assessment must be re-run on the current perimeter (second wallet, declared budget, mission history).

It is under way and will be completed before the service opens to the public. We write that rather than present it as done: an impact assessment announced and not produced would be exactly the kind of assertion this page exists to rule out.

§ 11

11. Data breach

In the event of a breach likely to result in a high risk to your rights, we inform the competent authority as soon as possible and inform you directly, stating what happened, which categories of data are affected, what we have done and what you can do.

We do not delay information on the ground that the investigation is ongoing: we publish what is established, then complete it. A late but complete notification is less useful than a fast and honest one about what it does not yet know.