Legal

Privacy Policy

Last updated: January 26, 2025 · Controller: CTX operator entity

This Policy describes how CTX collects, uses, and processes personal data from users of the CTX interface. Read it carefully before using the Interface.

Data We Collect

When you access, use, connect to, or interact with the CTX Interface, we may collect certain categories of information:

Information you provide

  • Wallet address: Your public blockchain address, provided when you connect your wallet to the Interface.
  • Transaction data: Your public blockchain transaction history and information associated with your wallet address.
  • Communications: If you contact us, we collect the content of that communication and any personal data within it, including your email address.

Information collected automatically

  • Date and time of access
  • Country from which the Interface is accessed
  • API endpoints accessed
  • User agent, browser type, version, and language
  • Operating system details
  • Transmission protocol (e.g., HTTP/1.1)

We may also use web beacons, geolocation, and tracking technologies when you visit the Interface. We may create aggregated, anonymized, or de-identified data from the above.

Third-party wallet connections

Certain features require connecting a third-party digital wallet. Your use of such wallets is governed by the applicable wallet provider's own terms and policies. Wallets are not maintained by CTX. We expressly disclaim liability for actions arising from your use of third-party wallets.

Why We Process It

Contract performance

We process data to perform our contract with you — primarily to enable your access to, use of, and connection with the Interface, and to identify whether you are a Restricted Person as defined in our Terms of Use.

Legitimate interests

We process data in our legitimate interests to:

  • Maintain system security and stability
  • Conduct troubleshooting, analytics, testing, and research
  • Enable optimization and internal statistical analysis
  • Maintain safety and security for users and the Interface
  • Improve and develop the Interface

Consent

With your consent, we may use data including Usage Data to tailor features and content to you. Analytics may be used to better understand your experience with the Interface.

Legal compliance

We may use your information to comply with applicable legal obligations, enforce terms of use, and protect the Interface and its users.

Cookie Policy

We use cookies to enhance your experience when using the Interface. The cookies we use are strictly necessary cookies that help ensure compliance with our Terms of Use and provide the best user experience. These cookies are not used for marketing purposes.

By continuing to use the Interface, you consent to the placement of these cookies.

Your Rights

Under applicable data protection laws, you may have certain rights in relation to your personal data:

  • Access: Request access to your personal data and information on how we use it.
  • Correction: Request correction of inaccurate or incomplete personal data.
  • Deletion: Request deletion or removal of your personal data, in certain circumstances.
  • Objection: Object to the processing of your personal data in certain circumstances.
  • Restriction: Request restriction of processing to storage only, in certain circumstances.
  • Portability: Request a copy of your data in a structured, machine-readable format.
  • Withdrawal of consent: Withdraw consent where we rely on it to process personal data.

Submit requests to contact@ctxapp.xyz. We will verify your identity before responding. We will respond within one month where required by applicable law (extendable by a further two months in certain circumstances).

These rights apply only in certain circumstances and may be limited by law — for example, where fulfilling your request would adversely affect others or conflict with legal obligations.

Sharing of Data

We may share your information in the following circumstances:

Service providers

Third-party processors who assist us with functions such as geo-blocking by IP address, analytics, screening, and content delivery. Such providers process data on our behalf and are bound by appropriate data protection agreements.

Professional advisors

In our legitimate interests or as required by law.

Legal and security reasons

To comply with legal obligations, protect the Interface, enforce our Terms, or protect the rights of our users.

International transfers

Your data may be transferred to and stored in countries outside your jurisdiction, including outside the EEA and UK. Where such transfers occur, we implement appropriate safeguards including Standard Contractual Clauses (SCCs) approved by the European Commission, or equivalent mechanisms for UK transfers.

Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including satisfying legal, accounting, or reporting requirements. Retention periods depend on the nature of the data and the purpose for which it was processed.

Children's Privacy

The Interface is not directed at persons under 18 years of age. If we become aware that we have unknowingly collected information about any person under 18, we will make commercially reasonable efforts to delete such data from our records.

Security Measures

We implement technical and organizational measures to protect your personal data. However, no method of transmission over the internet is perfectly secure. Despite our efforts, we cannot guarantee the absolute security of information transmitted through the Interface.

Any information you send to us electronically may not be secure while in transit. Transmission is at your own risk.

Third-Party Links

The Interface may include links to third-party websites or platforms, including social media platforms. We do not own, operate, or control such sites. If you follow links to sites not operated by us, you should review their privacy and security policies.

We do not guarantee and are not responsible for the privacy, security, or content of third-party sites. Our inclusion of links does not imply any endorsement of such sites, their owners, or their content.

When you open a link to a social media platform from the Interface, a direct connection may be established between your browser and that platform, potentially allowing it to associate your visit with your account on that platform.

Policy Updates

We may review and update this Policy from time to time. Updates apply only to information collected after the date of change. If we make material changes, we will update the "Last updated" date at the top of this Policy.

This Policy takes into account applicable data protection laws, including the EU GDPR (2016/679) and UK GDPR for users in those jurisdictions. You may file a complaint with the relevant data protection supervisory authority if you believe we have infringed applicable data protection laws.

Contact

Questions or complaints about our privacy practices, your personal data, or this Policy:

contact@ctxapp.xyz