Privacy Policy

1. Introduction

Fair Shares Ltd. (“Fair Shares,” “we,” “us,” or “our”) is committed to protecting your Personal Data and handling it responsibly in accordance with the EU General Data Protection Regulation (GDPR), the UK GDPR, and other applicable data protection laws in jurisdictions outside the United States.

This Privacy Policy applies to:

(1) Our websites displaying or linking to this Policy (the “Site”), (2) Our dashboards, interfaces, and developer tools, (3) And any services or features we make available through the Site (collectively, the “Services”).

This Policy describes how we collect, use, store, disclose, and protect your information — including Personal Data — when you access, interact with, or use our Services.

By accessing or using the Site or Services, you acknowledge and consent to the practices described in this Policy.

2. Information You Provide

We collect several categories of information that you voluntarily submit when interacting with the Services.

2.1 Contact Information

This includes identifiers that allow us to communicate with you or maintain your account record, such as:

(1) your name;

(2) your email address;

(3) your physical or mailing address;

(4) your organization or affiliated entity;

(5) your professional role or title;

(6) your communication or notification preferences.

2.2 Financial Information

We may collect blockchain-related and financial interaction data required for the use of our non-custodial Services, including:

(1) connected blockchain wallet addresses;

(2) publicly visible balances and asset holdings;

(3) transaction histories associated with your wallet;

(4) staking amounts and yield or reward information;

(5) gas fees or transaction-related costs.

Fair Shares never requests or stores private keys, seed phrases, or recovery information.

2.3 Transaction Information

We may collect information related to your interactions with Fair Shares smart contracts and systems, including:

(1) transaction types (e.g., deposit, stake, claim, withdrawal);

(2) amounts and assets involved;

(3) timestamps and confirmation data;

(4) smart contracts accessed;

(5) blockchain event logs generated during execution.

2.4 Compliance & Due Diligence Documentation

For enterprise accounts or where required by law, we may request documentation such as:

(1) government-issued identification (e.g., passport, national ID);

(2) proof of residence (e.g., utility bills, rental agreements);

(3) financial verification documents (e.g., proof of funds or income statements);

(4) organizational or incorporation documents;

(5) tax identification numbers.

This information is collected strictly to meet compliance, onboarding, and regulatory obligations.

2.5 Interaction & Communication Data

We may collect information arising from your communications with us, including:

(1) customer support messages or helpdesk interactions;

(2) feedback, comments, feature requests, or inquiries;

(3) survey responses or participation in research;

(4) chat logs with our support or technical teams;

(5) materials shared during enterprise onboarding or integration discussions.

3. Information We Collect Automatically

When you access or interact with the Site or Services, Fair Shares and its authorized service providers may automatically collect certain technical and behavioral information to ensure security, improve functionality, and enhance user experience.

3.1 Online Identifiers

We may collect device- and session-related identifiers, including:

(1) IP address;

(2) browser type, version, and configuration;

(3) operating system and device type;

(4) device IDs and hardware identifiers;

(5) mobile carrier information;

(6) language and region settings;

(7) referring URLs and exit pages;

(8) timestamps, session duration, and navigation timing;

(9) crash reports, error logs, and diagnostic data.

These identifiers help us maintain platform security, prevent abusive behavior, and support troubleshooting.

3.2 Usage Data

We automatically collect anonymized or aggregated interaction data, such as:

(1) pages or screens viewed;

(2) buttons, links, or features clicked;

(3) navigation paths and user flow;

(4) frequency and duration of interactions;

(5) performance, loading behavior, and latency patterns.

This information helps us understand usage trends, optimize the interface, and improve service quality.

3.3 Location Information

We may process coarse location data derived from your IP address (city-level accuracy only) for purposes including:

(1) fraud prevention and anomaly detection;

(2) compliance with regional restrictions and geoblocking obligations;

(3) improving service routing and network performance.

We do not collect precise GPS or device-based location data.

3.4 Cookies & Tracking Technologies

We use cookies and similar technologies—including:

(1) cookies and session tokens;

(2) web beacons and tracking pixels;

(3) embedded scripts and local storage;

(4) analytics and performance tags—

for purposes such as:

(1) session authentication and account continuity;

(2) analytics and usage measurement;

(3) fraud prevention and security enhancement;

(4) preference storage and functionality optimization.

You may disable cookies through your browser settings, but note that certain functionality or personalized features may become unavailable.

4. Blockchain Information We Process

Because Fair Shares operates non-custodial, on-chain infrastructure, certain information is inherently processed through interactions with public blockchain networks. This information is publicly accessible on the blockchain and is not created, controlled, or stored by Fair Shares outside of what is visible on-chain.

4.1 Account Addresses

We may process public wallet addresses that interact with Fair Shares smart contracts, including:

(1) externally owned accounts (EOAs);

(2) contract addresses;

(3) ENS or similar name-service identifiers linked to the wallet.

4.2 Wallet & Provider Information

During wallet connections, we may process limited metadata made available through standard wallet interfaces, such as:

(1) connected wallet provider (e.g., MetaMask, WalletConnect, etc.);

(2) wallet signature data confirming ownership;

(3) network information (e.g., Ethereum, Solana, or other supported chains).

No private keys are ever collected, transmitted, or accessible to Fair Shares.

4.3 Account Balances & On-Chain Assets

As part of on-chain interactions, publicly visible information may include:

(1) token balances;

(2) assets held within the wallet;

(3) staking positions and yield-generating allocations;

(4) rewards or distributions linked to supported smart contracts.

This data is inherent to blockchain transparency and may be viewable by anyone using blockchain explorers.

4.4 Transaction Data

We may process publicly available transaction details relevant to the Services, including:

(1) transaction hashes and unique identifiers;

(2) block numbers and confirmations;

(3) timestamps and ordering;

(4) amounts sent, received, or staked;

(5) sender and recipient wallet addresses;

(6) events emitted by smart contracts (e.g., staking, yield payouts, stock distribution).

4.5 Public & Immutable Nature of Blockchain Data

Information recorded on decentralized networks is:

(1) public and accessible to anyone;

(2) immutable and cannot be altered;

(3) governed by blockchain protocols rather than Fair Shares;

(4) outside the scope of deletion or modification requests.

Fair Shares cannot modify, erase, or restrict access to data already stored on a public blockchain.

5. How We Use Information

We use the information we collect — including Personal Data, technical data, and publicly available blockchain information — for the following operational, security, and compliance purposes. All processing is limited to what is necessary, proportionate, and permitted under applicable law.

5.1 Providing and Improving the Services

We process information to operate, maintain, and continuously enhance Fair Shares’ non-custodial financial infrastructure. This includes:

(1) enabling interactions with smart contracts, staking mechanisms, and supported protocols;

(2) delivering dashboards, analytics, and real-time reporting tools;

(3) optimizing product performance, interface usability, and reliability;

(4) testing features, conducting troubleshooting, and improving system functionality;

(5) tailoring user experience based on service usage patterns.

5.2 Security, Fraud Prevention & Compliance

We use data to protect the platform, its users, and integrated networks. This includes:

(1) detecting unauthorized access, malicious behavior, or protocol-level attacks;

(2) enforcing geolocation, sanctions, and regulatory restrictions;

(3) supporting AML/KYC processes where applicable for enterprise or regulatory requirements;

(4) identifying fraud, sybil attacks, yield manipulation, or suspicious activity;

(5) investigating potential violations of these Terms or legal requirements.

5.3 User Support

Information may be used to provide responsive and effective customer support. This includes:

(1) answering questions, handling inquiries, and resolving issues;

(2) routing support tickets to the appropriate internal team;

(3) diagnosing technical problems or transaction-related concerns;

(4) improving documentation, help materials, and support workflows.

5.4 Research & Development

We use anonymized or aggregated information to improve the Fair Shares ecosystem and develop institutional-grade financial infrastructure. This includes:

(1) performance analytics and system diagnostics;

(2) building new features, yield models, or risk intelligence tools;

(3) testing smart contract enhancements or protocol integrations.

We do not use Personal Data for R&D unless it is anonymized or aggregated.

5.5 Legal & Regulatory Compliance

We may process information as required to meet applicable legal, regulatory, and audit obligations. This includes:

(1) identity verification where mandated by law or enterprise agreements;

(2) responding to lawful government, regulatory, or supervisory requests;

(3) maintaining audit logs, transaction records, and risk assessments;

(4) complying with tax, AML, financial reporting, or sanctions requirements.

6. Data Security & Retention

Fair Shares implements a multi-layered, institutional-grade security framework designed to protect Personal Data, maintain service integrity, and ensure compliance with applicable regulations. While no digital system is entirely immune to risks, we employ industry best practices to safeguard all information processed through the Services.

6.1 Technical Safeguards

We apply advanced security technologies to protect data during transmission and system interactions, including:

(1) SSL/TLS encryption for all data transmitted between users and our infrastructure;

(2) secure cloud hosting environments with hardened configurations;

(3) intrusion detection and prevention systems to monitor suspicious activity;

(4) rate-limiting, request throttling, and anti-abuse protections to prevent automated attacks.

6.2 Access Controls

Access to Personal Data is strictly limited and monitored. Measures include:

(1) role-based access permissions ensuring only authorized personnel may access sensitive information;

(2) enforcement of least-privilege access principles;

(3) mandatory multi-factor authentication for administrative accounts;

(4) immediate revocation of access upon personnel changes or termination.

6.3 Internal Policies

We maintain internal governance procedures to ensure consistent and compliant data handling. These include:

(1) documented and audited privacy, security, and data-handling policies;

(2) periodic penetration tests and security assessments conducted by internal or external teams;

(3) mandatory employee training on data protection, operational security, and incident response practices.

6.4 Encryption

To protect confidentiality and integrity, we apply encryption and cryptographic protections where applicable:

(1) encryption of data in transit using secure SSL/TLS protocols;

(2) hashing or pseudonymization of sensitive metadata when technically suitable.

Fair Shares does not store or request private keys.

6.5 Retention Policy

Personal Data is retained only for as long as necessary to fulfill legitimate purposes, including:

(1) performing operational functions and delivering Services;

(2) meeting legal, regulatory, and compliance obligations;

(3) supporting audit, accounting, and financial reporting needs;

(4) resolving disputes and enforcing our Terms.

Once information is no longer required, it is securely deleted or anonymized, unless applicable law requires extended retention.

Important: On-chain data recorded on public blockchains cannot be deleted, altered, or suppressed due to the immutable nature of blockchain technology. This includes wallet addresses, transaction history, and other events permanently stored on decentralized networks.

7. Your Rights

Depending on your jurisdiction and applicable data protection laws (including GDPR and similar frameworks), you may have certain rights regarding your Personal Data. Fair Shares is committed to enabling these rights in a lawful, secure, and transparent manner.

7.1 Right of Access

You may request confirmation as to whether we process your Personal Data and, where applicable, obtain a copy of the data we hold about you, together with any legally required supplementary information.

7.2 Right to Correction

You may request that we correct, update, or complete any inaccurate, outdated, or incomplete Personal Data relating to you.

7.3 Right to Deletion (“Right to Be Forgotten”)

Where permitted by law, you may request deletion of your Personal Data, including in situations where:

• the data is no longer required for its original purpose,

• you withdraw consent (where applicable),

• processing is unlawful, or

• deletion is legally required.

We may retain certain data for audit, compliance, legal, or security reasons where allowed by law.

7.4 Right to Restrict Processing

You may request that we limit the processing of your Personal Data where:

• you contest its accuracy,

• processing is unlawful but you oppose deletion,

• data is no longer needed except for legal claims, or

• you have submitted an objection request pending our verification of overriding legitimate grounds.

7.5 Right to Data Portability

Where legally applicable, you may request a transferable, structured, commonly used, and machine-readable copy of the Personal Data you have provided, or request that we transmit it directly to a third party where technically feasible.

7.6 Right to Object

You may object to processing of your Personal Data where such processing is based on our legitimate interests, if you believe your rights and freedoms override those interests.

We may continue processing only if we demonstrate compelling legitimate grounds.

7.7 Direct Marketing Opt-Out

You may opt out of receiving marketing or promotional communications at any time. Your request will be processed promptly, though system updates may take several business days to take effect.

7.8 Submitting Requests

You may exercise any of the rights listed above by contacting us at:

📩 [e-mail]

We may request reasonable verification of identity before fulfilling any rights requests to ensure the security and integrity of Personal Data.

8. Cookies & Tracking Technologies

We use cookies and similar tracking technologies to enhance functionality, improve performance, and support security monitoring.

You may manage or disable cookies through your browser settings or through our on-site cookie consent banner.

Please note that disabling certain cookies may limit functionality or reduce the quality of your user experience.

9. Children’s Privacy

The Services are not directed to individuals under the age of 16 (or the age of majority in your jurisdiction).

We do not knowingly collect, store, or process Personal Data from minors.

If we become aware that data has been collected from a minor without appropriate consent, we will take reasonable steps to delete such information promptly.

10. Policy Updates

We may update or revise this Privacy Policy from time to time to reflect changes in our Services, legal requirements, or operational practices.

When material changes occur, we will notify users through website notices, in-product alerts, or email where appropriate.

Your continued use of the Services after any update constitutes acceptance of the revised Privacy Policy.

11. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your data protection rights, you may contact us at:

📩 [e-mail]

We will make reasonable efforts to respond promptly and in accordance with applicable data protection laws.