Sovryn considers that the protection of your Personal Data and the respect of your privacy is of primary concern.

Sovryn, including its affiliates (hereafter "Sovryn", "us", "we", "our"), is committed to protecting the privacy of anyone who accesses and uses the different services offered through its App (www.sovryn.app) (the "App"), including providing access and information about the on-chain fully decentralized, community governed protocol deployed on the RSK blockchain (a Bitcoin side chain) for Bitcoin lending, borrowing, and margin trading (the “Protocol”, the "DAO"), (collectively, the "Services"). 

We have published this Privacy Policy ("Policy") to outline our practices with respect to collecting, processing, and disclosing the information collected from anyone who uses, accesses, or interacts with our App ("Users", "You", "Your"). By accessing or using the App, you agree to our collection, use, and disclosure practices, as well as any other activities described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, you should immediately discontinue the use of the Services and refrain from accessing the App. 

In this regard, please note that Sovryn is acting as a Data Controller while processing your Personal Data under your utilization of its Services.

This Policy applies to you in addition to our Terms of Service. We encourage you to read these Terms and Policy carefully before using our Services. 

Our Services may be connected by “hyperlinks” to other third parties sites. We are not responsible in any way for the privacy practices on other third parties' sites and advise you to review the privacy policies on those linked sites before using them.

If you have any questions or wish to exercise your rights and choices, please contact us at the email set forth in the "Contact Us" section below.

While you are using our Services, we collect and process your Personal Data ("Personal Data"). For the avoidance of any doubt, and pursuant to the definition provided by The Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data, and repealing Directive 95/46/EC ("General Data Protection Regulation", "GDPR"), "Personal Data" means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. 

Please note that the processing of your Personal Data could be, in certain cases, required to allow the performance of our Services or to respond to one of your inquiries. This is especially the case when you decide to directly contact, for example via mail or us through the use of a website form. In any case, we will specify to you when and where such a processing activity of your Personal Data is non-optional.

Furthermore, in the event where you would have to communicate us Personal Data from a third party, you commit yourself to making sure that this Data Subject has been duly informed of the processing activity over his or her Personal Data following the provisions of the present Privacy Policy.

This section sets out the types of data collected from you. 

2.1 IDENTIFICATION INFORMATION

When you are using our Services, we process some of your contact and identification information. This includes especially your name, wallet address, and your email address. 

We also collect some information from the device you are using to access our App that can indirectly identify you, especially your location data and IP address.

2.2 COMMUNICATION INFORMATION

When you send us an email or contact us via our App, we collect the Personal Data you provided us. This includes especially your name, email address, organization name, country of origin, phone number, address, and any other information that you chose to share with us.

2.3 USAGE INFORMATION

When you visit our website, we collect technical information about your interaction with our App. Such information may include geolocation data, IP address, unique identifiers (e.g., MAC address and UUID) as well as other information which relates to your activity through the Services. 

We may also utilize Tracking Technologies (defined below), including cookies, pixels, beacons, local storage, and similar technologies. Further information regarding the use of Tracking Technologies will be described in Section 7 hereinafter.

WHY DO WE PROCESS YOUR PERSONAL DATA?

The above-mentioned collected data is processed for the hereafter listed purposes and legal basis.

In any case, please note that we won't process your Personal Data for any incompatible purpose with the performance of our Services, its improvement, and the development of Sovryn activities.

We might have to share your Personal Data with various natural persons and/or individuals or in a specific situation as described below:

This section addresses the specific rights applying to residents of the EU or residents in other jurisdictions that afford the below rights.

4.1 YOUR RIGHTS 

The European and UK Data protection legal framework grants any European or UK Data Subject various rights over its processed data, especially:

(a) To receive confirmation as to whether or not your Personal Data is being processed, and access your stored Personal Data, together with supplementary information.
(b) To withdraw, at any time, your consent to the processing activity, when it was initially based on this very consent, without harming the legality of the prior processing activity.
(c) To receive a copy of Personal Data you directly volunteer to us in a structured, commonly used, and machine-readable format.
(d) To request a rectification of your Personal Data that is in our control.
(e) To request the erasure of your Personal Data.
(f) To object to the processing of your Personal Data.
(g) To request to restrict processing of your Personal Data.
(h) To request the transfer of your Personal Data.
(i) To determine what to do with the processed Personal Data after the death of the Data Subject.
(j) To lodge a complaint with a supervisory authority.

Please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. 

To exercise any of the above-mentioned Data Subject's rights, please directly address your request to:              

4.2 TRANSFER OF DATA OUTSIDE THE EU OR THE UK 

Any information that we collect (including your Personal Data) may be stored and processed in various jurisdictions around the world, for the purposes detailed in this Policy. However, we will only transfer your data to data recipients that are either (i) located in the European Economic Area (the “EEA”), either (ii) non-located in one of the EEA countries but rather in one that has been approved by the European Commission as providing an adequate level of data protection, or (iii) entered into legal agreements ensuring an adequate level of data protection following the definition approved by the European Commission the European applicable legal framework and the European Court of Justice relevant case-law, or the UK Information Commissioner's Office ("ICO"), as applicable, regarding data protection and privacy.

This section addresses the specific rights applying to residents of California, Virginia, Colorado, or other jurisdictions that afford the below rights. This section is based on the California Consumer Privacy Act of 2018 (“CCPA”), Virginia Consumer Data Protection Act ("VCDPA") and Colorado Consumer Privacy Act ("CPA"), (collectively, "US Regulations")

5.1 SELLING OF PERSONAL INFORMATION

We do not “sell” the personal information we collect (as such term is defined in the US Regulations) for monetary value. 

5.2 YOUR RIGHTS

As a resident of any of the US Regulations' jurisdiction we grant you various rights regarding the Personal Information we collect, especially the following:

(a) To request information regarding how we have collected, used and shared your Personal Information during the past 12 months.
(b) To access your information, by requesting a copy of your Personal Information.
(c) To delete the Personal Information, we maintain about you.
(d) If, in the future, we will sell your Personal Information, you will have the right to opt-out. In such case, there will publish a "Do Not Sell My Information" link in the App.
(e) To receive non-discriminatory treatment for the exercise of your privacy rights.

Please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. 

To exercise any of the above-mentioned Data Subject's rights, please directly address your request to:              

You may empower an "authorized agent" (as defined in the US Regulations) to submit requests on your behalf, subject to a written authorization.

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. 

While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. Such breaches can lead to things such as reputational harm, fraud, or identity theft. Therefore, we encourage you to exercise discretion regarding the Personal Data you choose to disclose. If you feel that your privacy was treated not in accordance with our Policy, or if any person attempted to abuse the App or acted inappropriately, please contact us directly through the contact details available below.

We will retain your Personal Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined to take into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

When you visit our App or access our Services, we use cookies, pixels, beacons, local storage, and similar technologies ("Tracking Technologies"). These allow us to automatically collect information about you, your device, and your online behavior, in order to enhance your navigation in our App, improve our Service's performance, perform analytics, customize your experience and offer you, for example, tailored content and advertisements that better correspond with your interests. 

8.1 WHAT TYPES OF TRACKING TECHNOLOGIES DO WE USE?

When you use or access our Services, we use the following categories of Tracking Technologies: 

(a) Strictly Necessary Tracking Technologies: these Tracking Technologies are automatically placed on your computer or device when you access our Services or take certain actions on our App. These Tracking Technologies are essential to enable you to navigate around and use the features of our Services. We do not need to obtain your consent in order to use these Tracking Technologies.

(b) Tracking and Advertising Tracking Technologies: these Tracking Technologies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The Tracking Technologies remember the websites you visit and that information is shared with other parties such as advertisers and/or publishers. Publishers, advertisers, and third-party ad networks may also utilize Tracking Technologies or similar technologies to deliver ads and monitor the performance of such ads. The collection of information through Tracking Technologies by such third parties will be governed by their own privacy policies/cookies policies and principles, which Sovryn does not control.

(c)  Functionality Tracking Technologies: these Tracking Technologies allow our Services to remember choices you make (such as your language) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged in) and support other features of our Services; 

(d) Performance Tracking Technologies: these Tracking Technologies collect information about your online activity (for example the duration of your visit to our Services), including behavioral data and content engagement metrics. These Tracking Technologies are used for analytics, research, and performing statistics (based on aggregated information). 

8.2 HOW AND BY WHOM TRACKING TECHNOLOGIES ARE STORED ON YOUR DEVICE?

We store Tracking Technologies on your device when you visit or access our Services (for example, when you are visiting our website) – these are called "First Party Tracking Technologies". In addition, Tracking Technologies are stored by other third parties (for example, our analytics service providers, business partners, and advertisers), who run content on our Services – these are called "Third Party Tracking Technologies". Both types of Tracking Technologies may be stored either for the duration of your visit to our Services or repeat visits.

8.3 HOW CAN YOU MANAGE YOUR TRACKING TECHNOLOGIES?

There are various ways in which you can manage and control your Tracking Technologies settings. You can change your preferences using our cookie settings tool (however, please note that this tool may only be available in certain jurisdictions). Other methods of managing your Tracking Technology preferences include: changing your browser settings to send a “Do-Not-Track” signal. In such a case, your browser will send us a special signal to stop tracking your activity; you may also install a browser extension, such as Disconnect or Ghostery, to block third party tracking cookies on our website. However, please note that certain features of the website may not work properly or effectively if you delete or disable cookies. 

To learn more about how can manage your cookies, below is a list of useful links that can provide you with more information on how to manage your cookies. However, please remember that by deleting or blocking cookies, some of the features of our Services may not work properly or effectively. 

You can learn more and turn off certain third party targeting and advertising cookies by visiting the following third party webpages:

We reserve the right to change this Policy at any time. The most current version will always be posted on our App (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.

If you have any further questions regarding the data collection, or how we use it, please contact us.