Privacy Policy
1. Introduction
Ayeteasea ("we," "us," "our," or the "Company") operates decentralized finance protocols and services. This Privacy Policy ("Policy") describes our data practices when you interact with our services, including our website (https://www.ayeteasea.com), decentralized applications ("dApps"), smart contracts, and DeFi protocols including Gyndore and gynUSD (collectively, the "Services").
We maintain a strict principle of minimal data collection. The data practices described in this Policy are essential for our Services to function. By using our Services, you accept these practices.
2. Scope and Consent
This Policy applies to all users of Ayeteasea's Services. By using our Services, you consent to the data practices described in this Policy. These practices are fundamental to our service operation and are non-negotiable.
If you do not agree with this Policy, please do not use our Services.
3. Information We Collect
We collect only the minimum data necessary for our Services to function properly. The following describes all data collection practices:
3.1 Information Automatically Collected
3.1.1 Blockchain Data
When you interact with our smart contracts or protocols:
- Transaction Data: Wallet addresses, transaction hashes, token transfers, and amounts
- Contract Interactions: Function calls, parameters, and gas fees
- Position Data: Collateral deposits, debt positions, liquidation events (for CDP protocols)
- Timing Information: Block numbers and timestamps of interactions
Important Notice: All blockchain data is permanently public and visible to anyone. This is an inherent characteristic of blockchain technology and cannot be altered.
3.1.2 Website Analytics
When you visit our website or web interfaces:
- Device Information: Browser type, operating system, device type, screen resolution
- Usage Data: Pages viewed, time spent, click patterns, referring URLs
- Network Data: IP address (may be anonymized), approximate geographic location (country/region level)
- Cookies and Similar Technologies: Session cookies, local storage for interface preferences
These are standard technical operations necessary for website functionality.
3.2 Information You Provide
3.2.1 Communications
If you choose to contact us:
- Contact Information: Email address, name (if provided)
- Message Content: Your inquiries or feedback
- Social Media: Public interactions on our social channels
This information is only collected when you initiate contact.
3.2.2 Wallet Connections
When connecting wallets to our interfaces:
- Wallet Identifiers: Public wallet addresses
- ENS Names: If configured
- Network Selection: Which blockchain networks you interact with
This information is technically required for protocol interaction.
3.3 Information We DO NOT Collect
- Private keys or seed phrases
- Government-issued identification
- Bank account or credit card information
- Sensitive personal data (health, biometric, etc.)
- Know Your Customer (KYC) information
We operate on DeFi principles and do not require or collect traditional identity verification.
4. How We Use Information
4.1 Blockchain Data Uses
- Protocol Operation: Executing smart contract functions
- Security Monitoring: Detecting potential exploits and anomalies
- Analytics: Aggregating protocol metrics (TVL, usage statistics)
- User Interface: Displaying positions and transaction history
These uses are inherent to DeFi protocol operation.
4.2 Off-Chain Data Uses
- Service Provision: Operating our website and interfaces
- Communications: Responding to user inquiries
- Security: Preventing fraud and unauthorized access
- Legal Compliance: Meeting regulatory requirements
- Development: Improving service functionality
- Analytics: Understanding usage patterns
All data use is limited to operational necessities.
5. Legal Basis for Processing
We process data based on:
- Consent: Provided through your use of our Services
- Contractual Necessity: Required for Service provision
- Legal Obligations: When required by applicable law
- Legitimate Interests: For security and service improvement
These bases comply with international data protection standards including GDPR.
6. Data Sharing and Disclosure
6.1 Public Blockchain Data
All blockchain interactions are permanently public and accessible to:
- Any party viewing the blockchain
- Block explorers and analytics platforms
- Other protocols and smart contracts
- Researchers and data aggregators
This is an immutable characteristic of blockchain technology.
6.2 Third-Party Service Providers
We engage limited third-party services for:
- Infrastructure: Cloud hosting and content delivery networks
- Analytics: Privacy-focused analytics tools
- Security: Audit firms and monitoring services
- Communication: Email service providers (for user correspondence only)
Data sharing is strictly limited to operational requirements.
6.3 Legal and Compliance
We may disclose information when:
- Required by valid legal process
- Necessary to comply with applicable laws
- Required to protect safety or prevent harm
- Necessary to enforce our Terms of Use
We will resist overly broad requests and notify users when legally permitted.
6.4 Business Transfers
In the event of merger, acquisition, or asset sale, user information may transfer to the successor entity. Users will be notified of any such transfer.
6.5 Aggregated Data
We may share anonymized, aggregated statistics that cannot identify individual users.
7. Data Retention
7.1 Blockchain Data
On-chain data is permanent and immutable. We cannot delete blockchain records.
7.2 Off-Chain Data
- Website Analytics: Generally retained for 24 months
- Communication Records: Retained for legitimate business purposes or as legally required
- Technical Logs: Typically retained for 90 days for security purposes
- Cookies: Session cookies expire when browser closes; persistent cookies as specified
You may request deletion of off-chain personal data, subject to legal and legitimate business requirements.
8. Data Security
We implement appropriate technical and organizational measures to protect personal data:
8.1 Technical Measures
- Encryption in transit (TLS/SSL)
- Encryption at rest for sensitive data
- Regular security audits of smart contracts
- Access controls and authentication
- Regular security updates and patches
8.2 Organizational Measures
- Limited access on need-to-know basis
- Confidentiality agreements with team members
- Security training and awareness
- Incident response procedures
- Regular security assessments
8.3 Limitations
Despite our measures, no system is completely secure. We cannot guarantee absolute security of your information. Blockchain data is inherently public and permanent.
9. International Data Transfers
Ayeteasea is headquartered in the United Arab Emirates. By using our Services, you understand that your information may be:
- Processed in the UAE and other jurisdictions
- Accessed by our global team members
- Stored on distributed systems and blockchains worldwide
We ensure appropriate safeguards for international transfers through contractual measures and security standards.
10. Your Rights and Choices
10.1 Blockchain Data Rights
Due to the immutable nature of blockchain technology, we cannot:
- Delete or modify on-chain transactions
- Make blockchain activity private
- Alter transaction history
- Remove wallet addresses from the blockchain
These limitations are inherent to blockchain technology, not policy choices.
10.2 Off-Chain Data Rights
For off-chain data, you may have the right to:
- Access: Request information about data we hold
- Correction: Request correction of inaccurate data
- Deletion: Request deletion (subject to legal retention requirements)
- Portability: Receive your data in a structured format
- Objection: Object to certain processing activities
The availability of these rights depends on your jurisdiction.
10.3 Exercising Your Rights
To exercise any available rights, contact us at hello@ayeteasea.com. We will verify your identity before processing requests.
10.4 Cookie Preferences
You may control cookies through browser settings. Disabling cookies may affect website functionality but will not prevent protocol use.
11. Privacy by Design
Our services incorporate fundamental privacy principles:
- Data Minimization: Collection limited to operational necessities
- Pseudonymization: Using wallet addresses rather than personal identifiers
- Decentralization: No central data repository
- User Control: Self-custody and direct protocol interaction
- Transparency: Open-source code and public blockchain records
These principles are embedded in our technical architecture.
12. Children's Privacy
Our Services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If we learn we have collected information from a child under 18, we will take steps to delete such information.
13. Third-Party Links and Services
Our Services may contain links to third-party websites, protocols, or services, including:
- Other DeFi protocols
- Blockchain explorers
- Wallet providers
- Bridge services
We are not responsible for the privacy practices of these third parties. Review their privacy policies before providing any information.
14. Marketing and Communications
14.1 Marketing
We do not sell, rent, or trade your personal information for marketing purposes. We may send service-related communications if you've provided contact information.
14.2 Opting Out
You may opt out of communications by:
- Following unsubscribe links in emails
- Contacting us directly at hello@ayeteasea.com
15. Data Protection Officer
While not legally required to appoint a Data Protection Officer, privacy inquiries can be directed to:
Email: hello@ayeteasea.com
Subject Line: Privacy Inquiry
16. Regulatory Compliance
We comply with applicable data protection laws, including:
- UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection
- DIFC Data Protection Law (where applicable)
- Other relevant international standards
Users are responsible for ensuring their use of our Services complies with local laws in their jurisdiction.
17. Special Considerations for DeFi Users
17.1 Wallet Privacy
- Blockchain transactions create permanent linkages between activities
- Using the same wallet across protocols reduces privacy
- Consider using separate wallets for different purposes
- All transaction history remains permanently traceable
17.2 MEV and Front-Running
- Pending transactions are visible in the public mempool
- This visibility may enable front-running attempts
- Consider using MEV protection services if required
- This is standard for decentralized exchange operations
17.3 Compliance Tools
- Blockchain analytics firms actively monitor and categorize wallet activity
- Centralized exchanges may use these tools for compliance decisions
- DeFi activity may impact access to centralized services
- This reflects current regulatory and compliance practices
18. Updates to This Policy
We may update this Policy periodically to reflect:
- Changes in our data practices
- New features or services
- Legal or regulatory requirements
- Industry best practices
We will notify you of material changes through:
- Website notice
- Interface notification
- Email (if you've provided contact information)
Your continued use after changes constitutes acceptance of the updated Policy.
19. Jurisdiction-Specific Rights
19.1 European Economic Area (EEA) and United Kingdom
If you are located in the EEA or UK, you have additional rights under GDPR/UK GDPR:
- Right to lodge complaints with supervisory authorities
- Right to withdraw consent (though this may limit service access)
- Right to object to processing based on legitimate interests
- Right to restriction of processing
- Enhanced rights regarding automated decision-making
Our lawful bases for processing are outlined in Section 5.
19.2 California Residents (CCPA/CPRA)
California residents have additional rights including:
- Right to know categories of personal information collected
- Right to deletion (subject to exceptions)
- Right to opt-out of sale (we do not sell personal information)
- Right to non-discrimination for exercising privacy rights
- Right to correct inaccurate information
- Right to limit use of sensitive personal information (we do not collect such information)
19.3 Other U.S. States
Residents of Virginia, Colorado, Connecticut, Utah, and other states with comprehensive privacy laws have similar rights to access, deletion, correction, and portability as provided under applicable state law.
19.4 Asia-Pacific
- Singapore: We comply with the Personal Data Protection Act (PDPA)
- Japan: We respect rights under the Act on Protection of Personal Information (APPI)
- South Korea: We comply with the Personal Information Protection Act (PIPA)
- Australia: We respect rights under the Privacy Act and Australian Privacy Principles
19.5 Middle East and Africa
- UAE: We comply with Federal Decree-Law No. 45 of 2021
- Saudi Arabia: We respect the Personal Data Protection Law (PDPL)
- South Africa: We comply with the Protection of Personal Information Act (POPIA) where applicable
19.6 General Compliance
We strive to comply with applicable data protection laws in all jurisdictions where our Services are accessed. The specific rights available to you depend on your location.
20. Contact Information
For privacy-related questions, concerns, or requests:
Email: hello@ayeteasea.com
Subject Line: "Privacy Policy Inquiry"
When contacting us, please:
- Clearly describe your request or concern
- Include enough information for us to verify your identity (if applicable)
- Note if your request is time-sensitive
This Privacy Policy describes our minimal data collection practices. By using our Services, you accept these practices as described. If you do not agree with these practices, you should not use our Services.