Privacy Policy
Effective Date: April 5, 2025
1.
Introduction Escher Finance Ltd. ("Escher", "we", "us", or "our") is committed to protecting the privacy and personal data of individuals ("you", "your", or "Data Subject") who interact with our website at https://www.escher.finance and any related services, interfaces, applications, or decentralized software (collectively, the "Services"). This Privacy Policy ("Policy") outlines the manner in which we collect, use, disclose, retain, and protect your personal data, and is designed to comply with applicable data protection legislation, including:
- The European Union General Data Protection Regulation (EU GDPR)
- The United Kingdom General Data Protection Regulation (UK GDPR)
- The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA)
- Other applicable international data protection frameworks
By accessing or using the Services, you acknowledge that you have read, understood, and agree to the terms of this Policy.
2.
Definitions:
- "Personal Data" means any information relating to an identified or identifiable natural person.
- "Processing" means any operation performed on Personal Data, whether or not by automated means.
- "Controller" means the natural or legal person who determines the purposes and means of the Processing of Personal Data.
- "Processor" means a natural or legal person who processes Personal Data on behalf of the Controller.
3.
Data Controller Escher Finance Ltd., incorporated under the laws of the British Virgin Islands, is the data controller with respect to the Personal Data collected and processed through the Services. For inquiries or to exercise your data rights, you may contact us at info@escher.finance.
4.
Categories of Personal Data Collected We collect and process the following categories of Personal Data:
4.1
Identifiers
- Email address
- Public blockchain wallet address
- IP address
- Device identifiers (e.g., MAC address, device ID)
4.2
Technical and Usage Data
- Browser type, language, and version
- Operating system and platform
- Pages visited, clickstream data, session timestamps
- Referring and exit URLs
- Screen resolution and device type
- Geolocation data inferred from IP address
4.3
Communications and Metadata
- Contents of support tickets, emails, and messages
- Metadata from communications
- Files or documents voluntarily submitted
Note: We do not intentionally collect sensitive Personal Data such as information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or health data. Do not submit such data unless explicitly necessary and with your express consent.
5.
Methods of Data Collection We may collect Personal Data:
- Directly from you when you fill out forms, send communications, or connect a wallet
- Automatically through your interaction with the Services via cookies and similar technologies
- Through third-party integrations or analytics services
6.
Legal Basis for Processing We rely on one or more of the following lawful bases under the GDPR and UK GDPR to process your Personal Data:
- Consent: For marketing, analytics, and use of non-essential cookies.
- Contractual Necessity: To deliver the Services and execute user-initiated transactions.
- Legitimate Interests: To maintain and improve the security, functionality, and performance of our Services.
- Legal Obligation: To comply with applicable laws, regulations, or judicial orders.
7.
Purposes of Processing We process your Personal Data for the following purposes:
- To provide access to the Services and enable blockchain interactions
- To communicate with you and respond to inquiries
- To deliver marketing and promotional content (subject to your consent)
- To detect, prevent, and investigate fraud or abuse
- To comply with regulatory, legal, tax, or audit requirements
- To analyze user behavior and improve functionality and design
8.
Cookies and Tracking Technologies We use cookies and similar tracking technologies, including web beacons and pixels, to:
- Recognize and remember user preferences
- Enable core site functionality
- Conduct performance and analytics
- Deliver personalized content and advertising
You may control or disable cookies through your browser settings. More information is available at http://www.allaboutcookies.org
9.
Data Sharing and Disclosures We do not sell your Personal Data. We share your data only when necessary and with adequate safeguards:
- Service Providers: Vendors providing hosting, analytics, customer support, and technical infrastructure, bound by data processing agreements (DPAs)
- Corporate Affiliates: For internal operations and cross-border collaboration
- Legal Authorities: Where required by law or in response to lawful government requests
- Business Transfers: In the context of mergers, acquisitions, or restructuring
- With Your Consent: Where you have explicitly requested or authorized sharing
10.
Public Blockchain and On-Chain Data Due to the nature of public blockchains, any transactions initiated via the Services—including wallet addresses, transaction metadata, and token balances—are recorded publicly, immutably, and are outside the control of Escher Finance. These records:
- May be visible to any network participant
- Cannot be modified or deleted
- May be linkable to your identity when combined with off-chain data
Users should exercise caution and avoid associating Personal Data with wallet activity.
11.
International Data Transfers Where Personal Data is transferred outside the European Economic Area (EEA), United Kingdom, or other jurisdictions with data protection adequacy, we rely on the following mechanisms:
- Adequacy decisions by the European Commission
- Standard Contractual Clauses (SCCs)
- Binding Corporate Rules (BCRs)
- Other lawful transfer mechanisms under the GDPR/UK GDPR
12.
Data Retention We retain Personal Data only as long as necessary to:
- Fulfill the purpose for which it was collected
- Comply with legal, accounting, or audit requirements
- Enforce or defend legal rights
When no longer needed, data is securely deleted or anonymized. Retention periods vary depending on the data type and jurisdictional requirements.
13.
Data Subject Rights Subject to applicable law, you have the following rights:
- Right to Access: Obtain a copy of your Personal Data
- Right to Rectification: Request correction of inaccurate or incomplete data
- Right to Erasure: Request deletion under specific conditions ("right to be forgotten")
- Right to Restrict Processing: Limit the use of your data under certain conditions
- Right to Data Portability: Receive your Personal Data in a machine-readable format
- Right to Object: Object to data processing based on legitimate interests
- Right to Withdraw Consent: At any time, where processing is based on consent
- Right to Lodge a Complaint: With a supervisory authority in your jurisdiction
You may exercise these rights by contacting us at info@escher.finance. We may request proof of identity before fulfilling your request.
14.
Data Security We implement appropriate technical and organizational measures to protect your Personal Data, including:
- Encryption of data in transit and at rest
- Access control, authentication, and role-based permissions
- Periodic security audits and risk assessments
Despite our efforts, no system can guarantee absolute security. Users are responsible for safeguarding their private keys and access credentials.
15.
Children's Privacy Our Services are intended for users aged 18 and older. We do not knowingly collect data from individuals under this age. If we become aware that a minor has submitted Personal Data, we will delete it promptly.
16.
Automated Decision-Making We do not engage in automated decision-making or profiling that produces legal or similarly significant effects on you.
17.
Changes to this Policy We may revise this Privacy Policy periodically. When updates occur, we will:
- Post the revised version on our website
- Update the "Effective Date" at the top of this document
- Notify users where legally required
Your continued use of the Services after the posting of changes constitutes your acceptance of the revised Policy.
18.
Governing Law This Privacy Policy shall be governed and interpreted in accordance with the laws of the British Virgin Islands, without regard to conflicts of law principles.
19.
Contact Information For questions, requests, or complaints regarding this Privacy Policy, please contact: Email: info@escher.finance Website: https://www.escher.finance
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