Privacy Policy

Last updated on 11 March 2024

This Privacy Policy (“Policy”) describes how TruVenture Limited, a limited liability company incorporated in the British Virgin Islands, and its affiliates (“DYOR,”“we,”“us” or “our”) may collect, use and disclose information, and your choices regarding this information. Please read this Policy carefully and contact us with questions at hello@dyor.exchange.

1. Applicability of this policy

This Policy applies to the Site and the Services (in each case, as defined in our Terms of Use as made accessible within the DYOR mobile app). If you do not agree with the terms of this Policy, do not access or use the Services, the Site, or any other aspect of our business.

2. What we collect

When you interact with our Services, we may collect:

• Contact Information, such as your name, email address, physical address and country information.
• Financial Information, such as your cryptocurrency network address, cryptocurrency wallet information, transaction history, trading data and associated fees paid.
• Transaction Information, such as information about the transactions you make on our Services, such as the type of transaction, transaction amount, and timestamp.
• Correspondence, such as your feedback, questionnaire and other survey responses, and information you provide to our support teams, including via our help chat or social media messaging channels.
• Online Identifiers, such as your name, email address, physical address and country information.
• Usage and Diagnostics Data, such as conversion events, user preferences, crash logs, device information and other data collected via cookies and similar technologies.
• Information We Receive from Others. We may receive information about you from other sources as required or permitted by applicable law, including public databases. We may combine the information collected from these sources with the information we get from this Site in order to comply with our legal obligations and limit the use of our Services in connection with fraudulent or other illicit activities.
• Information from cookies and other tracking technologies. We, and third parties we authorize, may use cookies, web beacons, and similar technologies to record your preferences, track the use of our Site, including our mobile applications, and collect information about the use of the Services, as well as about our interactions with you. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, device information, date or time stamp, and clickstream data, and information about your interactions with the communications we send to you. We may combine this automatically collected log information with other information we collect about you. For more information on cookies see Article 10 of this Policy.

3. How we use information

We use your information in accordance with your instructions, including any applicable terms in the Terms of Use, and as required by applicable law. We may also use the information we collect for:

• Providing Services and Feature. We may use the information we collect to provide, personalize, maintain, and improve our products and Services, including as we described in our Terms of Use.
  
  This includes using information to:
  1. operate, maintain, customize, measure, and improve our Services, and manage our business;
  2. create and update user accounts;
  3. process transactions;
  4. send information, including confirmations, notices, updates, security alerts, and support and administrative messages;
  5. to create de-identified or aggregated data;
  6. implement the Waitlist & Referral Program of DYOR, as well as to ensure any other contests and the issuance of any related rewards for the users of DYOR Site and Services.
• Safety and Security. We may use your information to help maintain the safety, security, and integrity of you and our Services, including to:
  1. protect, investigate, and deter against fraudulent, unauthorized, or illegal activity;
  2. monitor and verify identity or service access, combat spam, malware or security risks;
  3. perform internal operations necessary to provide our Services, including to troubleshoot software bugs and operational problems;
  4. enforce our agreements with third parties, and address violations of our Terms of Use or agreements for other products or services;
  5. comply with applicable security laws and regulations.
• Customer Support. We may use information we collect to provide customer support, including to:
  1. direct questions to the appropriate customer support person;
  2. investigate and address user concerns;
  3. monitor and improve our customer support responses and processes.
• Research and Development. We may use the information we collect for testing, research, analysis, and product development to improve your experience. This helps us to improve and enhance the safety and security of our Services, improve our ability to prevent the use of our Services for illegal or improper purposes and develop new features and products relating to our Services.
• Legal and Regulatory Compliance. We may verify your identity by comparing the personal information you provide against third-party databases and public records. We may use the information we collect to investigate or address claims or disputes relating to use of our Services or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
• Direct Marketing. We may use the information we collect to market our Services to you. This may include sending you communications about our Services, features, promotions, surveys, news, updates, and events, and managing your participation in these promotions and events. If you do not want us to send you marketing communications, please opt out by selecting “unsubscribe” to any marketing email sent by us or by contacting us at hello@dyor.exchange.
• Email Communication and Notifications. By using the Site and the Services, you consent to receiving emails and in-app pop-up notifications from us. These communications may include but are not limited to updates, newsletters, transactions, promotional offers, and important announcements related to our Services. You can unsubscribe from these communications at any time by following the instructions provided in the emails or adjusting your notification settings within your account preferences. Please note that even if you opt out of receiving marketing communications, you may still receive transactional or Service-related messages from us.

4. How we share and disclose information

We may share your information in the following circumstances:

• With Your Consent. For example, you may let us share personal information with others for their own marketing uses. Those uses will be subject to their privacy policies.
• To Comply with Our Legal Obligations. We may share your information: (a) to cooperate with government investigations; (b) when we are compelled to do so by a subpoena, court order, or similar legal procedure; (c) when we believe in good faith that the disclosure of personal information is necessary to prevent harm to another person; (d) to report suspected illegal activity; or (e) to investigate violations of our Terms of Use, agreements for other products or services, or any other applicable policies.
• With DYOR-Affiliated companies, Service Providers or Other Third Parties. We may share your information with our affiliated companies (especially the entities foreseen under the Terms of Use), service providers or other third parties who may perform processing activities such as those described in this Privacy Policy in connection with your use of our products and services and may help facilitate business and compliance operations, including but not limited to marketing services, technology and cloud services, consultancy and legal services.
• During a Change to Our Business. If we engage in a merger, acquisition, bankruptcy, dissolution, reorganisation, sale of some or all of our assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all of your information may be shared or transferred, subject to standard confidentiality arrangements.
• Aggregated or De-identified Data. We may share aggregated or anonymized data with other persons for their own uses.

5. Data retention

To view or update your information, contact us at hello@dyor.exchange. We store your information throughout the life of your use of the Services and thereafter.

6. Security

We maintain administrative, technical and physical safeguards designed to protect the personal information we maintain against unauthorized access or disclosure and require our third-party service providers to have appropriate safeguards. No system can be completely secure. Therefore, although we take steps to secure your information, we cannot guarantee that your information, searches, or other communication will always remain secure. You are responsible for all activity on the DYOR protocol relating to any of your Ethereum network addresses or cryptocurrency wallets.

7. Age limitations

To the extent prohibited by applicable law, we do not allow use of our Services or Site by anyone younger than 18 years old. If you learn that anyone younger than 18 years old has unlawfully provided us with personal data, please contact us at hello@dyor.exchange and we will take steps to delete such information, close any such accounts, and, to the extent possible, prevent the user from continuing to use our Services.

8. Changes to this policy

If we make any changes, we will change the Last Updated date above. We encourage you to review this Policy to stay informed. If we make material changes, we will provide additional notice, such as via the email specified in your account or through the Services or Site.

9. Notice to European Union Residents (“GDPR Notice”)

In accordance with the General Data Protection Regulation (the “GDPR”), we are providing this GDPR Notice to European Union (“EU”) residents to explain how we collect, use and share their personal data (as defined in the GDPR), and the rights and choices we offer EU residents regarding our handling of their personal information. We process personal data for the purposes described in the How We Use Information section of this Policy. As an EU resident, you have various rights in connection with the processing of your personal data as follows:

• You have the right to information about your personal data processed by us and to the following information: (a) the processing purposes; (b) the categories of personal data being processed; (c) the recipients or categories of recipients to whom the personal data have been or are being disclosed, in particular recipients in third countries or international organizations; (d) if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration; (e) the existence of a right to rectification or deletion of your personal data, to restricting the processing of your personal data or to objecting to such processing; (f) the existence of a right of appeal to a supervisory authority; (g) if the personal data is not collected from you, all available information about the origin of the data; (h) the existence of automated decision-making and, at least in these cases, meaningful information on the logic involved and the scope and intended impact of such processing on the data subject; and (i) in the case of the transfer of personal data to a third country or an international organization, on the appropriate safeguards in relation to the transfer.
• You have the right to immediately request the rectification of inaccurate personal data concerning you and, taking into account the purposes of the processing, the completion of incomplete personal data, by means of providing a supplementary statement.
• You have the right to request the immediate erasure of personal data concerning you and we are obliged to delete this data immediately if one of the following reasons applies: (i) the personal data are no longer necessary for the purposes for which they were collected or otherwise processed; (ii) you revoke your consent on which the processing was based under Article 6(1)(a) or Article 9(2)(a) of the GDPR and there is no other legal basis for the processing; (iii) you object to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for processing or you object to the processing pursuant to Article 21(2) of the GDPR; (iv) your personal data has been processed unlawfully; (v) the deletion of your personal data is necessary to fulfill a legal obligation under EU law or the law of the member states to which we are subject; (vi) the personal data have been collected in relation to information society services provided in accordance with Article 8(1) of the GDPR. If we have made personal data public and are obliged to erase personal data in accordance with Article 17(1) of the GDPR, we will take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform controllers who process the personal data you have requested the erasure by such controllers of any links to or copies or replications of, such personal data.
• The rights in the foregoing paragraph do not apply to the extent that processing is necessary (A) to exercise the right of freedom of expression and information; (B) to fulfill a legal obligation required for processing under EU law or the law of the member states to which we are subject; or (C) to assert, exercise or defend legal claims.
• You have the right to request us to restrict processing if one of the following conditions is met: (1) the accuracy of the personal data is contested by you, for a period of time that enables us to verify the accuracy of the personal data; (2) the processing is unlawful and you oppose to delete the personal data and instead requests the restriction of the use of your personal data; (3) we no longer need your personal data for the purposes of processing, but you do need it to assert, exercise or defend legal claims; or (4) you have objected to the processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate interests of our company override your legitimate interests.
• You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit this data to another controller without hindrance, provided that the processing is based on a consent pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR or on a contract pursuant to Article 6(1) (b) of the GDPR and the processing is carried out by automated means. When exercising your right to data portability, you have the right to have your personal data transferred directly by us to another controller, to the extent that such transfer is technically feasible.
• You have the right to object at any time, for reasons arising from your particular situation to the processing of personal data concerning you which is based on Article 6(1)(e) or (f) of the GDPR, including profiling based on these provisions. We will no longer process your personal data unless we can demonstrate compelling legitimate reasons for the processing that override your interests, rights and freedoms or the processing serves to assert, exercise or defend legal claims.
• You have the right to revoke your consent to the processing of your personal data at any time. The revocation of consent does not affect the legality of the processing carried out on the basis of the consent until revocation.

If you wish to assert your rights to information, correction, deletion or restriction of processing, object to data processing or revoke your consent to data processing, please send an email to hello@dyor.exchange. If you consider that the processing of personal data concerning you infringes the GDPR, then you can lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, your place of work or the place of the alleged infringement.

10. Cookies

Cookies are files that websites place on users’ computers to collect standard Internet log information and visitor behaviour information, and in order to identify the user and make it easier for the user to use the website. When you visit our Site, we may collect information from you automatically through cookies or similar technology.

We may use cookies to improve your experience on the Site, incl. to understand how you use our Site and to optimise the Site for better user experience.

Internet browsers can be configured to warn the website visitor about the use of cookies and allow the website visitor to choose whether it agrees to accept them. Refusing cookies will not prevent a website visitor from using the website, however it may limit some functionality of the website. Please note, that if cookies are refused, some parts of our Site or Services may not function properly. You can view and change cookie settings in the settings section of your web browser.

For more information about cookies, visit allaboutcookies.org.

Our Site may use the following types of cookies:

• Functionality cookies – used to recognize you on the Site and remember your previously selected preferences. These could include what language you prefer and location you are in.
• Advertising cookies – used to collect information about your visit of the Site, the content you viewed, the links you followed and information about your browser, device, and your IP address.
• Analytical cookies – used to count visits and traffic sources so we can measure and improve the performance of our Site. These cookies help us to know which pages are the most and least popular and see how visitors move around the site. All information that we receive from these cookies are in aggregated form.

11. Contact us

Please contact us if you have any questions about this Policy or if you are seeking to exercise any of your statutory rights. We will respond within a reasonable timeframe. You may contact us at hello@dyor.exchange.

Mailing address: TruVenture Limited, 2nd Floor, Ellen L. Skelton Building, Fishers Lane, Road Town, Tortola, British Virgin Islands, VG 1110