Cadmos ("Cadmos", "we", "us", "our") respects the privacy of our Users. This Privacy Policy explains how we collect, use, disclose, and safeguard your Information when you visit our website at cadmos.finance, our mobile application, and any other media form, channel, or application related thereto (collectively, the "Site"). Please read it carefully. If you do not agree with the terms, please do not access the Site.

00 Introduction

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the "Last updated" date. Any changes are effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change.

You are encouraged to periodically review this Privacy Policy to stay informed. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted any revisions through your continued use of the Site after the revised version is posted.

01 Collection of your information

We may collect the following categories of Information when you use the Services.

1.1 Personal data

Personally identifiable Information — name, address, email address, telephone number.
Demographic Information — age, gender, hometown, interests — that you voluntarily give to us when you contact us or use the Site or mobile application.

You are under no obligation to provide us with personal Information of any kind; refusal may prevent you from using certain features of the Site or mobile application.

1.2 Derivative data

Log files — registries of events, processes, messages, and communication created when you view content or otherwise interact with the Services.
Cookies — small data blocks placed on your device by your web browser. We only include cookies that are necessary to access and interact with the Site; we do not use cookies to collect data not essential to the operation of the Site.
Other derivative data — wallet address, IP address, browser type, operating system, access times, and the pages you have viewed directly before and after accessing the Site.

If you use our mobile application, this Information may also include your device name and type, your operating system, your phone number, your country, and other interactions captured in server logs, plus any Information you choose to provide.

1.3 Mobile device data

Device Information such as your mobile device ID, model, and manufacturer, and Information about the location of your device, when you access the Site from a mobile device.

1.4 Third-party data

Information from third parties — such as personal Information you allow third parties to share with us when you connect your account to them and grant the Site permission to access this Information.

1.5 Mobile application data

Geo-location — we may request access or permission to track location-based Information from your mobile device, either continuously or while you use the application, to provide location-based services. You can change permissions in your device settings.
Mobile device access — we may request access to features such as bluetooth, calendar, camera, contacts, microphone, sensors, SMS messages, social media accounts, or storage. You can change permissions in your device settings.
Mobile device data — we may collect device Information, operating system, version, and IP address.
Push notifications — we may request to send you push notifications regarding your account or the application. You can opt out from your device settings.

02 Use of your information

We may collect and use Information about you via the Site or our mobile application to enable the use and proper functioning of the Services, including:

Operate and manage the Services — deliver the Services to you; administer the website; detect usage patterns; compile anonymous statistics for internal or third-party use; increase efficiency; process billing and collection of any fees; answer your comments, questions, and requests; send security alerts; detect, prevent, and address fraud, breach of Terms, and threats; resolve troubleshoot problems; comply with laws and regulations; perform other business activities as needed.
Protect the security and integrity of the Services — prevent fraudulent transactions, monitor against theft, and protect against criminal activity.

03 Disclosure of your information

We may share Information we have collected about you in certain situations, as follows.

3.1 By law or to protect rights

If we believe the release of Information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your Information as permitted or required by any applicable law, rule, or regulation. This includes exchanging Information with other entities for fraud protection.

3.2 Third-party service providers

We may share your Information with third parties that perform services for us or on our behalf — including fraud detection and prevention, payment processing, data analysis, customer support, and hosting. All service providers we engage are restricted to using the Information only on our behalf and in accordance with our instructions.

3.3 Affiliates

We may share your Information with our Affiliates and related entities, in which case we will require those affiliates to honour this Privacy Policy.

3.4 Business partners

We may share your Information with our business partners to offer you and improve certain products and services.

3.5 Sale or bankruptcy

If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your Information to the successor entity. If we go out of business or enter bankruptcy, your Information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline to honour commitments made in this Privacy Policy.

3.6 Consent and request

We may share Information about you with your consent or at your request. We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence from third parties, you are responsible for contacting them directly.

04 Tracking technologies

4.1 Cookies and web beacons

We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site and our mobile application. When you access the Site, your personal Information is not collected through tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but doing so could affect the availability and functionality of the Site or our mobile application. Web beacons can be rendered ineffective by declining all cookies or by configuring your browser to notify you each time a cookie is offered.

4.2 Website analytics

We may partner with selected third-party vendors to allow tracking technologies on the Site through first-party and third-party cookies — to analyse and track use of the Site and better understand online activity. By accessing the Site, you consent to the collection and use of Information by these third-party vendors. You are encouraged to review their privacy policies and contact them directly. We do not transfer personal Information to these third-party vendors. Note that getting a new device, installing or upgrading a browser, or clearing cookies may also clear opt-out settings.

05 Third-party websites

The Site and our mobile application may contain links to third-party websites and applications, including external services that are not affiliated with us. Once you have used these links to leave the Site, any Information you provide to those third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your Information. Before visiting and providing any Information to any third-party site, you should review the privacy policies and practices of the responsible third party. We are not responsible for the content or privacy and security practices of any third parties, including any sites, services, or applications that may be linked to or from the Site.

06 Security of your information

We use administrative, technical, and physical security measures to help protect your Information. While we have taken reasonable steps to secure the Information you provide, please be aware that no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against interception or other type of misuse. Any Information disclosed online is vulnerable to interception and misuse by unauthorised parties. We therefore cannot guarantee complete security if you provide personal Information.

07 Your rights and choices

7.1 Cookies. We will only use strictly necessary cookies. These are essential for you to browse the Site and use its features, including accessing secure areas of the Site.

7.2 Do Not Track. See section 08 below.

08 Controls for Do-Not-Track features

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature you can activate to signal your privacy preference not to have data about your online browsing activities monitored. No uniform technology standard for recognising and implementing DNT signals has been finalised. We do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted in future, we will inform you in a revised version of this Privacy Policy.

09 EEA & UK data subjects

The General Data Protection Regulation in the European Economic Area and the United Kingdom ("GDPR") distinguishes between organizations that process personal data for their own purposes ("controllers") and organizations that process personal data on behalf of other organizations ("processors"). We act as a controller with respect to personal data collected as you interact with the Services.

The following developments aim to bring this Privacy Policy into full compliance with the GDPR.

9.2 Lawfulness of processing

According to Article 6 of the GDPR, processing is legal if it is based on certain grounds qualified as lawful. Cadmos's lawful grounds for processing are:

9.2.1 you have given consent to the processing of your personal data and Information for one or more specific purposes, either to us or to our service providers or partners;
9.2.2 processing is necessary for the performance of the Services that you use;
9.2.3 processing is necessary for compliance with a legal obligation to which Cadmos may be subject;
9.2.4 processing is necessary for the purposes of the legitimate interests pursued by Cadmos or a third party, where your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third parties subject to appropriate or suitable safeguards, such as standard contractual clauses.

9.3 Your data subject rights

Under Article 3 of the GDPR, the regulation applies to the processing of personal data of data subjects who are in the Union or the United Kingdom by a controller not established in the Union. If you are a User in the EEA or the UK, you have certain rights:

9.3.1 request access and obtain a copy of your personal data;
9.3.2 request rectification or erasure of your personal data;
9.3.3 object to or restrict the processing of your personal data;
9.3.4 request portability of your personal data. Where we collected and processed your personal data with your consent, you have the right to withdraw your consent at any time;
9.3.5 right to object — on grounds relating to your particular situation — at any time to processing where your fundamental rights and freedoms override the legitimate interests pursued by Cadmos or by a third party.

Despite the above, we cannot edit or delete information that is stored on a blockchain. This information may include transaction data (purchases, sales, transfers) tied to your blockchain wallet address and any tokens held by it.

To exercise any of these rights, contact us at privacy@cadmos.finance and specify which right you are seeking to exercise. We will respond within thirty (30) days. We may require specific information from you to confirm your identity and process your request. We retain information as necessary to fulfill the purpose for which it was collected and may continue to retain and use information after a data subject request in accordance with our legitimate interests, including to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements. You also reserve the right to lodge a complaint with the data protection regulator in your jurisdiction.

10 Contact us

If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us:

By mail
Cadmos LTD · ΗΕ 457316
Tzon Kennenty 8, IRIS HOUSE, 3rd floor
3106 Limassol, Cyprus

By email · privacy@cadmos.finance