Privacy Policy

This Privacy Policy describes how Parifi (“we”, “us”, or “Parifi”) collects, uses, discloses, and protects personal information when you use our Services. We are committed to protecting your privacy and complying with applicable data protection laws, including the EU General Data Protection Regulation (GDPR) and relevant U.S. privacy laws. By using the Parifi protocol website, application, or any related services, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree, please do not use our Services.

1. Scope of this Policy

This Privacy Policy applies to personal data that Parifi processes in relation to the use of the Parifi decentralized protocol and any official Parifi web or mobile interfaces (collectively, the “Services”). It covers information that you may provide to us directly, information collected automatically through your interaction with our Services, and information we may receive from third parties (such as integrated service providers). Since Parifi is a no-KYC, self-custodial platform, we strive to minimize the personal data we collect about users. The majority of interactions with Parifi (e.g. trading via smart contracts) do not require you to share personal identifying information like name or address. However, there are scenarios where we may process limited personal data, as outlined below.

Please note that this Policy does not apply to any third-party services that are not operated by Parifi but that you may access through our platform (such as fiat on-ramp providers or external wallet services). Each third-party service will have its own privacy practices, and you should review their privacy policies separately. Parifi is not responsible for the privacy or data security practices of unaffiliated third parties.

2. Data We Collect

2.1. Information You Provide to Us: Because Parifi does not require account registration or identity verification for core use, the personal information you directly provide is limited. However, you may choose to provide certain data in the following contexts:

• Contact or Support Requests: If you contact us (via email, support ticket, or community forums) with questions or for support, you may provide personal contact information (such as your email address, name or alias, and any information you choose to include in your message). We will collect whatever information you choose to share for the purpose of responding to you.

• Optional Identity/Authentication (Privy): Parifi integrates Privy as an optional user authentication and identity layer. For example, you might opt to link an email address, phone number, or Web2 account to your Parifi session via Privy for convenience (such as to recover settings, receive notifications, or access a non-custodial wallet created via Privy). If you choose to use Privy’s authentication option, you will provide that third-party (Privy) with the requested information (email, etc.). Privy, acting as our data processor, will securely store that information and share with Parifi a pseudonymous identifier or verification (e.g., confirmation that you have a valid email). Parifi may receive and retain your contact detail (like email) from Privy if needed to provide the service (for instance, to send you trade confirmations or alerts you signed up for). Providing this info is completely optional – you can use Parifi anonymously by connecting a web3 wallet of your choosing without using Privy’s features.

• Surveys, Feedback, or Beta Programs: From time to time, we may offer you the opportunity to participate in user surveys, provide feedback, or join beta testing programs. Participation is voluntary. If you choose to participate, you might provide information such as your email, opinions, or other responses. We will collect whatever data you provide in those contexts to improve our Services.

We do not collect any sensitive personal data such as government-issued IDs, financial account numbers, or biometric data. Parifi does not perform KYC (Know Your Customer) identity verification for use of the core protocol. Any request for such sensitive information is likely from a third party (such as a fiat gateway partner during a purchase) and not from Parifi directly.

2.2. Information We Collect Automatically: When you interact with our website or app, we (or authorized third-party tools on our behalf) may automatically collect certain technical and usage information. This may include:

• Device and Connection Information: Internet Protocol (IP) address, browser type and version, operating system, device type, unique device identifiers, and general geolocation (country or region) based on IP.

• Usage Data: Date and time of access, pages or screens viewed, features used (e.g., opening the trading interface, viewing analytics), the link that referred you to our site (if any), and your interaction with our interface components. For example, we might log when you connect a wallet, initiate a trade (though trade details are on-chain), or encounter an error.

• Cookies and Similar Technologies: We use a minimal number of cookies or local storage in our web interface, primarily for technical purposes (such as remembering your preferences or whether you acknowledged a disclaimer). We do not use cookies for advertising. Some cookies may be necessary for our site to function (e.g., to keep you logged in via Privy or to remember your selected network). We may also use analytics tools that rely on cookies or tracking pixels to understand how users navigate our site (see “Analytics” below). You can set your browser to refuse non-essential cookies; however, certain functionalities might be limited as a result.

This automatically collected data typically does not identify you by name, but it might be considered personal data in some jurisdictions (IP addresses, etc.). We use this information to ensure the Service functions correctly, to analyze usage trends, and to secure the platform (e.g., detecting anomalous activity).

2.3. Information from Third Parties: Parifi may receive some information indirectly:

• Fiat On-Ramp Partners: If you choose to use an integrated third-party fiat on-ramp/off-ramp service through Parifi (for example, a widget or link that allows you to purchase crypto with a credit card or bank transfer), you will be providing personal information (such as name, payment details, and possibly identity documents) directly to that third-party provider. Parifi does not receive the personal details you submit to the on-ramp provider. The on-ramp provider may notify us of transaction status (e.g., that a purchase was completed and an amount of crypto was delivered to your wallet address) or share minimal data needed to facilitate the transaction (such as your blockchain wallet address and the asset/amount purchased). We will treat any such data in accordance with this Policy. However, any personal information you give the on-ramp (such as your legal name, ID, or bank info) is governed by their privacy policy, not ours. We encourage you to review their privacy practices.

• Analytics Providers: We may use third-party analytics or error-tracking services (for example, Google Analytics or similar) to help us understand user interactions and improve the Service. These providers might receive certain technical information about your device or usage via automated means (as described above). Such information is generally aggregated and not identifiable to you personally. We use configuration settings that respect privacy (for instance, IP anonymization where available).

• Blockchain Data: Parifi’s core operations involve reading and processing data from public blockchains (Ethereum and others). Public blockchain addresses and transactions are publicly visible. We may analyze on-chain activity associated with your wallet address to display information to you (for example, listing your current positions or past trades), or to enhance safety (such as scanning for known scam addresses). Note that blockchain data, even if linked to a pseudonymous address, could potentially be de-anonymized by others over time. Parifi will treat blockchain addresses and related data as personal data if it is combined with other identifying info or if required by law.

3. How We Use Your Information

Parifi uses the collected information for the following purposes, in accordance with applicable law and, where relevant, your consent:

• To Provide and Maintain the Services: We process technical data and any user-provided information to allow you to use the Parifi platform’s features. For example, using an email you provided via Privy to send you a login code or using your wallet address to retrieve and display your positions. We use usage and device data to ensure the interface loads correctly on your device and to troubleshoot issues you encounter. This processing is generally necessary to perform our contract with you (i.e., these Terms and providing the requested Services).

• Safety and Security: It is in our legitimate interest to ensure the security and integrity of Parifi. We may use IP addresses, device identifiers, and usage patterns to detect and prevent fraudulent or malicious activity. For instance, we may flag if multiple failed transactions or abnormal requests suggest a potential bot or attack. We also use data to enforce compliance with our Terms of Service (for example, using IP geolocation to help identify potential access from Restricted Territories and block or warn those users, as per our Terms).

• Communications and Customer Support: If you reach out with a question or issue, we will use your contact info and provided details to respond. We may also use your email (if provided) to send service-related messages, such as confirmations of a support ticket, critical updates about the Service, or notices about changes to terms or policies. These are not marketing communications but necessary information. For any optional newsletter or marketing updates, we would obtain your consent separately (and you can unsubscribe anytime).

• Improvement and Research: We may use aggregated and anonymized data about how users interact with Parifi to improve our Services. This can include analyzing which features are most used, where users encounter errors, or how performance varies. For example, understanding that many users drop off at a certain step may indicate we need to simplify that step. Any research or analytics is done in a way that does not identify you personally.

• Compliance with Legal Obligations: Although Parifi generally does not collect extensive personal data, we may process certain information as required by law or to comply with any legal obligations that may apply to us. For instance, if in the future Parifi is subject to anti-money laundering (AML) or sanctions screening requirements, we might need to use IP or other data to restrict usage, or in rare cases, request additional info from you. We will also use personal data to respond to lawful requests by public authorities (such as responding to court orders or regulators) or to exercise or defend legal claims.

4. How We Share or Disclose Information

Parifi does not sell your personal information to third parties. We also do not share data with third parties for their own marketing. We only share information in the following circumstances:

• Service Providers (Processors): We may employ third-party companies or individuals to facilitate our Services or perform certain functions on our behalf – for example, cloud hosting providers, analytics services, or email delivery services. These parties may have access to personal information solely to perform tasks for us and are obligated not to disclose or use it for other purposes. For instance, if our website is hosted on a cloud server, your IP and requests pass through that hosting provider; or if we use an email service to send support responses, your email and message will be processed by that service. We make reasonable efforts to contractually bind such service providers to appropriate confidentiality, security, and data protection commitments. Notably, Privy acts as a processor for optional user data (they store any personal info linked to your wallet such as email, under encryption, and we retrieve it as needed).

• Affiliates and Organizational Participants: Parifi may share data with affiliates or members of its DAO or foundation structure as needed to operate the Services. All such recipients will be bound by similar obligations of confidentiality and data protection. For example, if Parifi Foundation works with a developer entity or a support organization, your data may be shared within this group on a need-to-know basis.

• Legal and Compliance: We may disclose information about you if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to: (a) comply with a legal obligation, subpoena, or lawful request (we will attempt to notify you of requests for your info before disclosure, if allowed and feasible); (b) protect and defend our rights or property, or the rights, property, and safety of our users or the public; (c) investigate and address violations of our Terms of Service or other unauthorized access or misuse of the Services; or (d) cooperate with law enforcement regarding suspected illegal activities on the platform.

• Business Transfers: In the event that Parifi or its significant assets (for instance, the development organization or rights to the platform) are acquired by or merged with a third party, or in any similar transaction, user information may be transferred as part of the assets. We will ensure the acquirer is bound to respect your personal data in a manner consistent with this Privacy Policy, and we will notify users of any change in data handling or ownership as required by law.

• Aggregated or Anonymized Data: We may share aggregated, anonymized usage statistics or insights (information that cannot reasonably be used to identify you) publicly or with partners. For example, we might publish trends such as “Total number of monthly Parifi traders” or “Percentage of users by continent.” Such information contains no personal details and is used for transparency or research.

Third-Party Links: Our site or app may contain links to external sites (for example, documentation pages, community forums, or an integrated on-ramp webpage). If you follow a link to any external site, you will be subject to that third party’s privacy policy, not ours. We are not responsible for the content or privacy practices of external sites.

5. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. Because Parifi’s default approach collects minimal personal data, our retention practices are as follows:

• Technical logs (which may include IP addresses and usage data) are generally retained for a short period (e.g., a few weeks up to a few months) for troubleshooting and security monitoring, after which they are either deleted or anonymized. Summary analytics may be kept longer in aggregated form (without personal identifiers).

• Contact information (like emails) and communications you send us for support are kept as long as needed to address your inquiry and for our records. Typically, support emails and their metadata are retained for a period (e.g., 1-2 years) in case you have follow-up issues or to improve our support processes, unless you request deletion sooner (where feasible).

• If you opted to provide an email via Privy for login/notifications, we will retain that until you unlink or request deletion, since it’s needed to provide the service. If you stop using Parifi or unlink your email/Privy account, we or Privy will delete or anonymize the personal data after a period of inactivity (we may define a reasonable period such as 1 year of no activity before removal, unless law requires earlier deletion).

• Any information we are required to retain for legal reasons (e.g., records of opt-outs, or data involved in a legal dispute) will be kept for as long as the law requires or until the dispute is resolved, and then deleted or archived as appropriate.

When we no longer have a legitimate need or legal obligation to retain your personal data, we will securely delete it or anonymize it. Because blockchain transactions are permanent, we cannot delete or alter data that is stored on a public blockchain (like your trade history or asset balances on-chain); such data will persist publically, but it is not under our control.

7. International Data Transfers

Parifi is a global service. The personal information we collect (which is minimal) may be transferred to and stored on servers in countries outside of your own jurisdiction. Specifically, if you are located in the European Union or UK, be aware that we (and our service providers like Privy or cloud hosts) might process data in the United States or other jurisdictions that may not provide the same level of data protection as your home country. We take steps to ensure that appropriate safeguards are in place to protect your data in such cases.

For transfers from the EEA/UK to third countries, we rely on legal transfer mechanisms such as the European Commission’s Standard Contractual Clauses (SCCs) or other adequate safeguards (GDPR Art. 46) where applicable. For example, if our cloud provider is in the US, we likely have SCCs in place in our contract with them, binding them to protect EU personal data. By using our Services or submitting information to us, you consent to the transfer of your personal data abroad, including to the BVI (where Parifi is based) and the United States (where some infrastructure may be), as needed to provide the Services.

We will always protect your information as described in this Policy, regardless of where it is processed. If you have questions about our data transfer safeguards, you can contact us as noted below.

8. Data Security

We take reasonable and appropriate security measures to protect the personal information we hold from loss, misuse, unauthorized access, disclosure, alteration, or destruction. These measures include technical, administrative, and physical safeguards tailored to the sensitivity of the data. For example:

• We limit access to personal data to personnel and service providers who need to know it for operational purposes, and these parties are subject to confidentiality obligations.

• We employ encryption and secure protocols. Any sensitive communications with our site (such as if you submit info via a form) are encrypted via HTTPS/TLS. Data stored by Privy for authentication is encrypted.

• We monitor our systems for possible vulnerabilities and attacks, and we maintain an incident response plan. We also encourage responsible disclosure of any security issues by the community (e.g., via a bug bounty program).

However, please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Decentralized applications also involve user-side security responsibilities. Your role in security is crucial: you must protect your wallet credentials, use strong passwords for any linked accounts, and be vigilant against phishing or social engineering. Parifi will never ask for your private keys or seed phrases. If you suspect any unauthorized access to your account or personal data, please notify us immediately.

In the event of a data breach that affects your personal information, we will act promptly to mitigate the harm and, where required by law, notify you and relevant authorities of the breach.

9. Children’s Privacy

Parifi is not intended for use by anyone under the age of 18 (or the age of majority in your jurisdiction). We do not knowingly collect personal information from children. If you are under 18, you must not use our Services or submit any personal data to us. If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete such information as soon as possible. Parents or guardians who believe that their child may have provided us with personal information can contact us to request deletion of that information.

10. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will revise the “Last Updated” date at the top of this Policy. If the changes are material, we will provide a more prominent notice (such as posting a notice on our website or sending an email/notification if appropriate). Your continued use of the Services after the effective date of an updated Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically to stay informed about how we are protecting your information.

If you do not agree with any updates to the Policy, you should discontinue use of the Services and may request that we remove your personal data as outlined above.