Privacy Policy

This Privacy Policy (“Policy”) for Sharewoods Finance Limited, a company having its registered office at First Floor, La Chasse Chambers, Ten La Chasse, St. Helier, Jersey (“Sharewoods”, “we”, “our”, or “us”) describes the basis on which we may use and process personal information we may collect from users of Sharewoods’ website(s), web applications, and any tools, products, services, features, and functionalities available through them (collectively, the “Sites” and “Services”), in accordance with applicable law, including the Data Protection (Jersey) Law 2018 and other relevant data protection legislation.

For purposes of applicable data protection laws, Sharewoods is the data controller. For the purposes of this Policy, “you” and “your” refers to you as the user of the Services.

Read this Policy carefully so that you understand why and how we collect and use your personal data (hereinafter referred to as “Personal Information”). If you do not agree to this Policy, do not use, access, connect to, interact with, or download any of the Services or otherwise provide your information to us.

1. Personal information we collect about you, why we process it, and the legal basis for processing

When you access, use, connect to, or interact with the Sites and/or Services, we may collect certain categories of information about you, including personal data, from a variety of sources.

Information you provide to us

Personal data may include:

• any digital-asset, smart-contract, or protocol address (“Wallet”) information, associations, and/or identifiers
• geolocation data
• any information you may provide in connection with submitting a job application for any position with Sharewoods, or when contacting us

When connecting your Wallet to the Sites, Sharewoods may view, access, and/or collect your publicly-available blockchain address and are able to read publicly available information, including without limitation your blockchain data or history (such as your blockchain transaction history and other information associated with a linked address or Wallet), certain information needed to transfer or allocate tokens, token holdings (including ERC-20 tokens such as tokenized stocks), and any other information collected through the Services.

Should you contact us through email, social media, or other support channels (such as X, Discord, or Telegram), or engage in surveys or questionnaires, we will collect the content of the communications we have with you and any personal data contained within. Your interaction with these channels is governed by the privacy policies of those third-party companies. We are not affiliated with them.

We use third-party providers to manage support and inbound requests. When you contact us, we may collect your name, email address, and any information you choose to provide.

We process this information to perform our contract with you (to provide the Services), and where applicable to process and evaluate job applications, verify identity and qualifications, and comply with legal obligations. This may include communicating with you, conducting interviews and background checks, and considering you for suitable roles. Where permitted, we may also use your information to improve our recruitment process and inform you of future opportunities.

Information we collect automatically

When you visit certain pages on our Sites or access, use, connect to, or interact with certain Services, our servers may collect the following information:

• any internet-protocol address (“IP Address”) of the requesting computer or device
• the date and time of access
• the country from which the Sites are accessed
• any API endpoint
• cookies and/or web beacons
• information from localStorage and/or mobile device ID

The processing of this data is carried out for the business purpose of enabling your access to, use of, connection to, and interaction with the Services, including (i) to facilitate your connection to the Sites, and/or (ii) to identify if you are likely to be a Prohibited Person (as defined in our Terms of Use) or subject to any prohibitions with respect to the Services. This processing is necessary for the performance of our contract with you and in our legitimate interests to provide effective Services.

We may also process this data in our legitimate interests to provide effective Services by assisting with system security and stability, troubleshooting, data analytics, testing, research, optimization, internal statistical analysis, maintaining the safety and security of our users, the Sites and Services (including protecting against, investigating, and stopping fraudulent, unauthorized, or illegal activity), and improving and developing our Services and Sites.

Sharewoods may use cookies, web beacons/clear gifs, geolocation and tracking technologies, and other applications when you visit the Sites, including technologies collecting certain Usage Data that may be integrated with third-party service providers.

With your consent (where required), we may use any data collected, including Usage Data, to tailor features and content to you, ensure content is presented effectively for you and your device, run analytics, better understand your user experience, and (if you have opted into marketing) for marketing purposes.

We may also use your information to provide the Services and perform our contract with you.

In addition, we may use any of your information to comply with applicable legal obligations, to enforce our Terms of Use, and to protect or defend the Services, our rights, and the rights of our users or others.

Information we may collect from third-party wallet extensions or connections

Certain transactions conducted via our Services may require you to connect a compatible third-party digital Wallet to the Services. By using such Wallet to conduct transactions via the Services, you agree that your access to, use of, connection to, and/or interactions with such third-party Wallets are governed by the privacy policy of the applicable Wallet provider, and you agree that you are using the Wallet in accordance with the terms and conditions of that third-party provider.

Wallets are not maintained or supported by, or associated or affiliated with, Sharewoods. We expressly disclaim any and all liability for actions arising from your use of third-party Wallets, including without limitation actions relating to the use and/or disclosure of personal information by such third-party Wallets.

2. Your rights

Under applicable data protection laws (including the Data Protection (Jersey) Law 2018 and, where applicable, other regimes such as the UK GDPR or relevant U.S. state privacy laws), you may have certain rights in relation to your personal data. You can exercise these rights by writing to us using the contact details below. We may ask you to provide additional information or documents to prove your identity. These rights may include:

• Access to your personal data that Sharewoods holds, and information on how we use it and who we share it with
• Correction of your personal data that Sharewoods holds
• Deletion or removal of your personal data (“Right to be Forgotten”), in certain circumstances
• Objection to and restriction of processing of your personal data, in certain circumstances
• Right to lodge a complaint with a competent supervisory authority (in Jersey, the Jersey Office of the Information Commissioner)
• Portability of your personal data – we will endeavor to provide you, or a third party, with a copy of the personal data that we hold about you in a structured, commonly used, machine-readable format
• Objection to marketing communications – you may opt out of any marketing communications at any time by using any unsubscribe or opt-out functionalities displayed in such communications
• Notice of a personal data breach (unless the breach is unlikely to be prejudicial to you)
• Withdrawal of consent, where we are relying on consent to process personal data (this will not affect processing carried out before consent is withdrawn or on other legal bases)
• Right to appeal (where available under applicable law, for example certain U.S. state laws)

Note that data recorded on a public blockchain (including Wallet addresses and transaction history) is public, immutable, and outside our control. We are generally unable to rectify, erase, or restrict the processing of such on-chain data.

3. Disclosure of personal data

In certain circumstances, we may disclose your information to third parties with your consent, as necessary, or as otherwise required or permitted by law. Specifically, we may disclose your personal data:

• To service providers and vendors: Sharewoods may share your personal data with third parties that process data on our behalf. Such third parties may include blockchain analysis service providers, screening service providers, developers, content delivery service providers, and data analytics service providers. These providers may assist us with functions including determining eligibility with respect to participation in certain Services.
• To professional advisors, in our legitimate interests or as required by law: auditors, law firms, cybersecurity specialists, data analysis providers, and/or consulting or accounting firms.
• For legal and security reasons and to protect our services and business, in our legitimate interests or as required by law.
• To law enforcement and regulatory authorities, in order to comply with applicable legal and regulatory requirements or to respond to mandatory legal or governmental requests.
• To our affiliates, in our legitimate interests.
• In connection with an asset sale or purchase, merger, bankruptcy, or other business transaction or re-organization, in our legitimate interests: we will disclose your personal data to relevant third parties as necessary while negotiating or in relation to a change of corporate control.

Your personal information may be transferred to and stored or processed in countries outside Jersey (including outside the European Economic Area and United Kingdom), including to the United States or other jurisdictions, in order to provide the Services. We will take steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy and applicable data protection laws. Where we transfer personal information outside Jersey to countries that do not provide an adequate level of protection, we will put in place appropriate safeguards (such as standard contractual clauses or equivalent mechanisms) as required by applicable law.

4. Retention

We will retain your personal data only for so long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements, or as otherwise required by law. The length of time we retain your data will depend on the nature of the data and the purpose for which it was processed. We expect to delete your personal data once there is no longer any legal or regulatory requirement or legitimate business purpose for retaining it.

5. Children’s privacy and data protection

Persons under the age of eighteen (18) are not permitted to use the Services, and we do not seek to or knowingly collect any personal data about children under thirteen (13) years of age (or the equivalent age under applicable local law). If we become aware that we have unknowingly collected information about any person under eighteen (18) years of age, we will make commercially reasonable efforts to delete such personal data from our records.

6. Security measures taken to protect personal data

We take reasonable steps to protect your Personal Information from misuse, loss, unauthorised access, modification or disclosure, including implementing appropriate technical and organisational security measures. These measures are reviewed from time to time in line with legal and technical developments. However, we give no guarantee that such misuse, loss, unauthorised access, modification or disclosure will not occur. You are responsible for all of your activity on the Services, including the security of your blockchain network addresses, cryptocurrency wallets, and their cryptographic keys.

7. Links

There may be links from our Sites to other websites and resources provided by third parties. This Privacy Policy applies only to our Sites. Accessing those third-party websites or sources requires you to leave our Sites. We do not control those third-party sites or any of the content contained therein, and you agree that we are in no circumstances responsible or liable for any of those third-party sites, including their content, policies, products, services, or actions. We encourage you to review the privacy policies of each site that you visit.

8. Changes to Policy

We may modify this Policy at any time, in particular in order to comply with any regulatory, jurisprudential, editorial, or technical change. These modifications will apply on the date of entry into force of the modified version. The date the Policy was last updated is identified at the top of this page. Your continued use of the Services after any changes constitutes acceptance of the updated Policy.

9. Contact

Should you have any questions or complaints about our privacy or data-protection practices, your personal data, or this Policy, you can contact us at:

Sharewoods Finance Limited
First Floor, La Chasse Chambers
Ten La Chasse
St. Helier
Jersey

Email: contact@sharewoods.xyz

You also have the right to lodge a complaint with the Jersey Office of the Information Commissioner if you believe your data protection rights have been infringed.