Privacy Policy.

This privacy policy explains how we process personal data in connection with Arkiv, our universal data layer for Ethereum. We are committed to protecting your privacy and complying with applicable data protection laws, including the General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (FADP).

We collect and process only the data necessary to provide our services, improve user experience, and comply with legal obligations.

We process personal data based on the following legal grounds:

• Consent: When you explicitly agree to data processing
• Contract performance: To provide Arkiv services you've requested
• Legal obligations: To comply with applicable laws and regulations
• Legitimate interests: For service improvement and security purposes

Website Usage

When you visit our website, we automatically collect technical information including IP addresses, browser types, device information, and usage patterns to ensure website functionality and security. This data is stored for a maximum of 30 days and processed based on our legitimate interest in maintaining website security and functionality.

Blockchain Address Processing

Data Categories: Wallet addresses, transaction hashes, block numbers, timestamps, gas fees, and smart contract interaction data.

Legal Basis: Contract performance (to provide Arkiv services) and legitimate interest (network security and fraud prevention).

Classification: Blockchain addresses are pseudonymous identifiers that may constitute personal data when they can be linked to an identifiable person through additional information.

On-Chain Data

• Cryptographic hashes
• Transaction metadata
• Smart contract addresses
• Block timestamps

Retention: Permanent (blockchain immutability)

Off-Chain Data

• Account preferences
• Communication data
• Support interactions
• Analytics data

Retention: Variable (can be deleted)

Smart Contract Processing

Smart contracts on Arkiv may automatically process data according to their programmed logic. This processing occurs without human intervention and is necessary for contract execution. Users should review smart contract code before interaction to understand automated processing implications.

Communication and Support

If you contact us or subscribe to updates, we process contact information and communication content to respond to inquiries and provide requested information. This data is retained for up to 3 years based on legal obligations and legitimate business interests.

Under applicable data protection laws, you have the following rights. Please note that blockchain technology limitations may affect our ability to fulfill certain requests for on-chain data:

Right to Access

You can request information about your personal data processing. For blockchain data, this includes publicly visible transaction information.

Right to Rectification

We can correct inaccurate off-chain data. For on-chain data, we can provide supplementary information but cannot modify blockchain records.

Right to Erasure (Limited)

Right to Restrict Processing

We can restrict processing of off-chain personal data. Blockchain processing cannot be restricted as it operates autonomously.

Right to Data Portability

Available for off-chain data in structured formats. Blockchain data is inherently portable through public blockchain explorers.

Right to Object

You can object to processing based on legitimate interests. Note that essential blockchain operations cannot be objected to as they're necessary for service provision.

Right to Withdraw Consent

You can withdraw consent for future processing. Past blockchain transactions cannot be reversed, but future processing can be stopped.

How to Exercise Your Rights

Contact us at privacy@golem.network with:

• Your specific request and preferred outcome
• Wallet address(es) or account identifiers (if applicable)
• Proof of identity (to prevent unauthorized requests)
• Timeframe for response (we respond within 30 days)

Right to Lodge a Complaint: You have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) or your local data protection authority.

Off-Chain Data Retention

• Website data: 30 days
• Support communications: 3 years
• Account preferences: Until account deletion
• Analytics data: 26 months (GDPR compliant)

On-Chain Data Retention

• Transaction data: Permanent
• Smart contract interactions: Permanent
• Blockchain addresses: Permanent
• Cryptographic hashes: Permanent

We retain personal data only as long as necessary for the purposes for which it was collected or as required by law. Blockchain data cannot be deleted due to the immutable nature of distributed ledger technology.

Data Minimization Strategy: We implement privacy-by-design principles to minimize personal data stored on-chain, using techniques such as hashing, encryption, and off-chain storage for sensitive information.

Blockchain Network Considerations

Blockchain networks are inherently global and decentralized. Data on Arkiv may be processed by network nodes worldwide, including outside the EEA. This is necessary for blockchain functionality and network security.

Safeguards for Data Transfers

• Standard Contractual Clauses (SCCs): For transfers to third-party service providers
• Adequacy Decisions: Transfers to countries with adequate data protection (e.g., Switzerland, UK)
• Consent: Explicit user consent for specific data transfers where required
• Derogations: Contract performance necessity for essential blockchain operations

Third-Party Service Providers

We may share data with carefully selected service providers for:

• Infrastructure hosting and maintenance
• Analytics and performance monitoring
• Customer support and communication
• Security and fraud prevention

All providers are contractually required to provide adequate data protection.

We may update this privacy policy from time to time. Material changes will be communicated through our website or other appropriate means. The effective date of the current policy is displayed at the top of this document.