Privacy Policy

1. Introduction

Analog Engineering OÜ ("Analog," "we," "our," or "us"), a company registered in Estonia (registration code 17429345), is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our decentralized finance platform and services (the "Service"). Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the Service.

Data Controller: Analog Engineering OÜ, Tartu mnt 67/1-13b, Kesklinna linnaosa, Tallinn, 10115, Estonia. Email: ops@analog.money

2. Information We Collect

2.1 Information You Provide to Us

We collect information that you voluntarily provide when creating an account or using our Service:

• Account Information: Name, email address, phone number (depending on authentication method)
• Profile Information: Country of residence
• Authentication Data: OAuth tokens from Google, Apple, or other sign-in providers
• Communications: Information you provide when contacting us for support

2.2 Information Collected Automatically

When you access our Service, we automatically collect certain information:

• Blockchain Data: Wallet addresses, transaction hashes, smart contract interactions, and on-chain activity
• Usage Data: Pages visited, features used, time spent on pages, and interaction patterns
• Device Information: IP address, browser type and version, operating system, device identifiers
• Log Data: Access times, error logs, and performance data
• Cookies and Tracking: We use cookies and similar technologies to track activity and enhance user experience

2.3 Information from Third Parties

We may receive information from third-party services:

• Coinbase Developer Platform: Wallet information, authentication data, and account details
• OAuth Providers: Profile information from Google, Apple, or other sign-in services
• Payment Processors: Transaction status and payment information from Apple Pay, card networks, and exchanges
• Blockchain Networks: Publicly available on-chain data from Base Chain and other networks

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 Service Provision

• Create and manage your account
• Authenticate your identity
• Deploy and manage your smart contracts
• Process deposits and withdrawals
• Execute yield optimization strategies
• Provide customer support

3.2 Service Improvement

• Analyze usage patterns to improve our platform
• Develop new features and services
• Monitor and improve platform performance
• Conduct research and analytics

3.3 Security and Compliance

• Detect and prevent fraud, abuse, and illegal activity
• Comply with legal obligations and regulatory requirements
• Enforce our Terms of Service
• Protect the security and integrity of our Service
• Verify your country of residence for compliance purposes

3.4 Communication

• Send service-related notifications and updates
• Respond to your inquiries and support requests
• Provide important security alerts
• Send marketing communications (with your consent)

4. How We Share Your Information

We may share your information in the following circumstances:

4.1 Service Providers

We share information with third-party service providers who perform services on our behalf:

• Coinbase Developer Platform (wallet and authentication services)
• Cloud hosting providers
• Analytics providers
• Customer support tools
• Payment processors

4.2 Blockchain Networks

Transaction data is recorded on public blockchains and is permanently visible to anyone. This includes wallet addresses, transaction amounts, smart contract interactions, and timestamps. This information cannot be deleted or modified once recorded on the blockchain.

4.3 Legal Requirements

We may disclose your information if required by law or in response to:

• Valid legal process (subpoenas, court orders, etc.)
• Government or regulatory requests
• Investigations of potential violations of our Terms of Service
• Protection of our rights, property, or safety

4.4 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control.

4.5 With Your Consent

We may share your information for other purposes with your explicit consent.

5. Data Retention

We retain your information for as long as necessary to:

• Provide our Service to you
• Comply with legal obligations
• Resolve disputes
• Enforce our agreements

When you close your account, we will delete or anonymize your personal information within 90 days, except where we are required to retain it for legal or regulatory purposes. Blockchain data is permanent and cannot be deleted.

6. Data Security

We implement appropriate technical and organizational measures to protect your information, including:

• Encryption of data in transit and at rest
• Secure authentication through trusted OAuth providers
• Regular security audits and assessments
• Access controls and authentication mechanisms
• Monitoring for suspicious activity

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

7. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information:

7.1 General Rights

• Access: Request access to the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information (subject to legal requirements)
• Portability: Request a copy of your information in a portable format
• Objection: Object to our processing of your information
• Restriction: Request restriction of processing of your information

7.2 GDPR Rights (European Union)

As an EU-based company, we process all personal data in compliance with the General Data Protection Regulation (GDPR). All users benefit from GDPR protections, including:

• The right to withdraw consent at any time
• The right to lodge a complaint with a supervisory authority
• The right to be informed about data processing activities
• The right to object to processing based on legitimate interests

Supervisory Authority: Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), Tatari 39, 10134 Tallinn, Estonia. Website: www.aki.ee

7.3 CCPA Rights (California)

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA):

• Right to know what personal information we collect and how it's used
• Right to delete personal information
• Right to opt-out of the sale of personal information (we do not sell your information)
• Right to non-discrimination for exercising your privacy rights

7.4 Exercising Your Rights

To exercise any of these rights, please contact us at ops@analog.money. We will respond to your request within 30 days (or within one month for GDPR requests, extendable by two further months where necessary).

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to:

• Essential Cookies: Required for the Service to function properly (authentication, security)
• Analytics Cookies: Help us understand how users interact with our Service
• Functional Cookies: Remember your preferences and settings

You can control cookies through your browser settings. However, disabling certain cookies may limit your ability to use some features of our Service.

9. International Data Transfers

As an EU-based company, your personal data is primarily processed within the European Economic Area (EEA). When we transfer data outside the EEA, we ensure adequate protection through:

• Transfers to countries with an EU adequacy decision
• Standard Contractual Clauses (SCCs) approved by the European Commission
• Binding Corporate Rules where applicable
• Other legally recognized transfer mechanisms under GDPR Article 46

You may request information about the safeguards in place for any specific transfer by contacting us at ops@analog.money.

10. Children's Privacy

Our Service is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If you become aware that a child has provided us with personal information, please contact us, and we will take steps to delete such information.

11. Third-Party Links and Services

Our Service may contain links to third-party websites and integrates with third-party services (such as Coinbase, DeFi protocols, and payment processors). We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing them with any information.

12. Marketing Communications

With your consent, we may send you marketing communications about our products, services, and features. You can opt out of marketing emails at any time by clicking the "unsubscribe" link in the email or by contacting us. Note that you cannot opt out of service-related communications, such as security alerts and transaction confirmations.

13. Do Not Track Signals

Some web browsers have a "Do Not Track" feature that signals to websites that you do not want to have your online activity tracked. Our Service does not currently respond to Do Not Track signals.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website and updating the "Last Updated" date. We encourage you to review this Privacy Policy periodically. Your continued use of the Service after changes are posted constitutes your acceptance of the updated Privacy Policy.

15. Contact Information

If you have questions or concerns about this Privacy Policy or our data practices, please contact us:

For data protection inquiries related to GDPR, you may contact our Data Protection Officer at ops@analog.money.

16. California Shine the Light

California Civil Code Section 1798.83 permits California residents to request information regarding our disclosure of personal information to third parties for direct marketing purposes. We do not share personal information with third parties for their direct marketing purposes.

17. Data Protection Officer

We have appointed a Data Protection Officer to oversee our compliance with EU data protection laws. If you have any questions about our data practices or wish to exercise your privacy rights, you may contact our Data Protection Officer at ops@analog.money.