Centurion Privacy Policy
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This Privacy Policy (the "Policy") explains how [INSERT LEGAL ENTITY NAME] ("Centurion", the "Company", "we", "us" or "our") collects, uses, and shares data in connection with the Centurion website ([INSERT WEBSITE]), the Centurion app ([INSERT APP URL], if any), and all of our other properties, products, and services (collectively, the "Services"). Your use of the Services is subject to this Policy as well as our Terms of Service.
High Level Summary
- Centurion is operated by [INSERT LEGAL ENTITY NAME], an incorporated company based in [INSERT JURISDICTION], and complies with applicable laws and regulations.
- The Centurion Protocol is a decentralized set of smart contracts, blockchain infrastructure, and related network components deployed across one or more networks. It is not necessarily governed by the Company.
- Centurion does not collect and store personal data such as your first name, last name, street address, date of birth, or email address in connection with ordinary use of the Services, unless you specifically provide such information to us.
- Centurion may collect non-identifiable or pseudonymous data, such as public on-chain data and limited off-chain technical data like device type, browser version, and similar diagnostics. This helps us improve the Services, not track users as identified individuals.
- If you specifically sign up to receive emails or other communications from us, we will store your email address or other contact information to send those communications. You can unsubscribe at any time. We will not attempt to link your email address to your wallet address, IP address, or other personal data except as required by law or as necessary to provide a service you requested.
- Centurion may continue exploring methods to further protect user privacy, including privacy-preserving analytics, opt-out prompts, and infrastructure designs that reduce unnecessary data exposure.
- Users are empowered to explore client-side privacy techniques and tools.
- Any material changes to privacy practices will be reflected in an updated privacy policy.
Data We Collect
Privacy is important to Centurion. We aim to be transparent about the limited data we do collect. We do not maintain traditional user accounts unless expressly stated for a specific Service, and we do not collect and store personal data such as your name or home address merely because you use the Services. When you interact with the Services, we may collect only the following categories of information:
Publicly available blockchain data
When you connect a non-custodial blockchain wallet to the Services, we may collect and log your publicly available blockchain address, transaction data, and other on-chain activity to help us understand how the Services are used, support functionality, protect the Services, and comply with applicable laws. Blockchain addresses are publicly available data and are not created or assigned by us. By themselves, they are generally not directly identifying.
Information from localStorage and similar technologies
We and our third-party service providers may access and collect information from localStorage, cookies, web beacons, mobile device identifiers, and similar technologies to provide, maintain, personalize, and improve the Services and their features across sessions. For example, we may use such information to remember your settings, imported assets, saved preferences, or interface customizations. Information collected from these technologies may include browser type, device type, operating system, referring or exit pages, language preferences, and other device or browser information. We analyze these journeys in aggregate to improve user experience.
Information from service providers and compliance partners
We may receive information about wallet addresses, transactions, or interactions with the Services from service providers, analytics providers, infrastructure providers, or compliance partners where necessary to meet legal obligations, prevent fraud, or protect the Services and users.
Survey or usability information
If you participate in a survey, research interview, or usability study with us, we may collect the information you choose to provide, such as your name, email, job title, feedback, survey responses, and interactions with the Services.
Correspondence
We may receive communications and information you provide directly to us through email, support requests, forms, social media, community channels, surveys, questionnaires, or other contact methods.
Biographical or application information
If you apply for a job, grant, partnership, validator program, ecosystem program, or similar opportunity with Centurion, we may collect the information you submit, such as your name, email, phone number, work status, qualifications, and any resume, cover letter, or other materials you provide.
Information you specifically provide
If you choose to provide us with information such as your email address or contact details, we may use that information for the purposes described at the time you provide it. You do not need to provide personal data to use the core decentralized aspects of the Services unless a particular feature explicitly requires it.
How We Use Data
We use the data we collect in accordance with your instructions, our Terms of Service, and applicable law. We may also use data for the following purposes:
Providing the Services
We use collected data to provide, operate, maintain, customize, and improve the Services and their features.
Customer support
We may use information to respond to questions, investigate issues, and provide support relating to the Services.
Safety and security
We may use data to detect, investigate, prevent, and address fraudulent, unauthorized, harmful, or illegal activity. We may also use data to address bugs, security incidents, abuse, and enforcement of our agreements.
Legal compliance
We may use collected information as necessary or appropriate to comply with applicable laws, regulations, subpoenas, court orders, government requests, or legal process.
Analytics and aggregated insights
We may use certain information to create aggregated or de-identified analytics that help us understand how users interact with the Services and where we can improve product design, performance, and usability.
How We Share Data
We may share or disclose the data we collect in the following circumstances:
With service providers
We may share information with vendors, contractors, and service providers that help us operate, secure, deliver, and improve the Services. For example, we may share technical data with hosting providers, RPC providers, analytics providers, fraud-prevention vendors, blockchain infrastructure providers, or compliance partners as needed to provide the Services.
To comply with legal obligations
We may share information in connection with litigation, regulatory inquiries, investigations, compliance efforts, subpoenas, court orders, or other lawful requests, or where we believe disclosure is necessary to comply with applicable law.
For safety and security
We may share data where necessary to detect, investigate, prevent, or stop fraud, security threats, abuse, unauthorized activity, or other harmful conduct affecting users, the Services, the Company, or the broader ecosystem.
Business changes
We may transfer or share data in connection with a merger, acquisition, financing, reorganization, bankruptcy, dissolution, asset sale, or similar corporate transaction.
With your consent
We may share your information when you direct us to do so or otherwise give your consent.
We do not share your information with third parties for their own direct marketing purposes.
Cookies and Similar Technologies
We may use cookies, localStorage, SDKs, pixels, and other tracking technologies provided by us or third parties to collect information about your use of the Services and our interactions with you. You can often control these technologies by:
- Blocking cookies in your browser settings.
- Using browser privacy settings or extensions that limit third-party tracking.
- Limiting mobile advertising identifiers in your device settings.
- Using consent or opt-out tools where available.
Please note that disabling certain technologies may affect the functionality of some parts of the Services.
Third-Party Links and Sites
The Services may contain links to websites, applications, protocols, tools, or other services operated by third parties. If you interact with third-party services, those parties may independently collect information about you. We are not responsible for the privacy practices of third parties. You should review their privacy policies and terms before using their services.
Security
We implement and maintain reasonable administrative, physical, and technical safeguards designed to protect information from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. However, no method of transmission over the internet or method of storage is completely secure, and we cannot guarantee absolute security. You are responsible for the security of your devices, wallet software, private keys, seed phrases, and blockchain addresses.
Age Requirements
The Services are intended for a general audience and are not directed to children. We do not knowingly collect personal information from children under the age of 18, or such other age as required by applicable law. If you believe we have collected personal information from a child in violation of applicable law, please contact us at [INSERT PRIVACY EMAIL].
Additional Notice to California Residents
If applicable, California residents may have certain rights under the California Consumer Privacy Act, as amended ("CCPA"), regarding the collection, use, disclosure, and retention of personal information.
Privacy practices
We do not sell personal information as that term is defined under applicable California law, and we do not share personal information for cross-context behavioral advertising unless expressly stated otherwise.
Privacy rights
California residents may have the right to request access to, correction of, deletion of, or information about our handling of their personal information, subject to exceptions under applicable law.
Submitting a request
You may submit a privacy request by contacting us at [INSERT PRIVACY EMAIL].
Identity verification
We may need to verify your identity before responding to a request, to the extent required or permitted by law.
Authorized agents
California residents may designate an authorized agent to make requests on their behalf, subject to verification and applicable legal requirements.
Notice to European Economic Area, United Kingdom, and Similar Jurisdictions
Where applicable data protection law applies, we process personal data on one or more of the following legal bases:
- You have provided consent.
- Processing is necessary to perform a contract with you.
- Processing is necessary to comply with a legal obligation.
- Processing is necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your rights and freedoms.
Subject to applicable law, you may have the right to request access to, correction of, deletion of, restriction of, or portability of your personal data, and to object to certain processing. You may also withdraw consent where processing is based on consent.
Please note that we may not be able to edit or delete information recorded on a public blockchain. Information such as wallet addresses, transaction history, and blockchain state may be outside our direct control.
To exercise any applicable privacy rights, contact us at [INSERT PRIVACY EMAIL]. We may request additional information necessary to verify and process your request. We may retain information as needed to comply with legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
Data Retention
We retain information for as long as reasonably necessary for the purposes described in this Policy, including to provide the Services, comply with legal obligations, resolve disputes, prevent abuse, and enforce our agreements. Retention periods may vary depending on the type of information and the context in which it was collected.
International Transfers
If you use the Services from a jurisdiction other than where we or our service providers operate, your information may be transferred to, stored in, and processed in other jurisdictions. Where required by law, we will take appropriate steps to protect such transfers.
Changes to This Policy
If we make material changes to this Policy, we will notify users by updating the date above and, where appropriate, through the Services or other communications. Your continued use of the Services after any update indicates your review of and acceptance of the revised Policy, to the extent permitted by law.
Contact Us
If you have questions about this Policy or how we collect, use, or share information, please contact us at:
[INSERT LEGAL ENTITY NAME]
[INSERT CONTACT EMAIL]
[INSERT MAILING ADDRESS]
[INSERT COUNTRY / JURISDICTION]