Privacy Policy

Last Updated: July 17, 2023

This Privacy Policy (“Privacy Policy” or “Policy”) describes how Blade Labs Holdings Pte Ltd. (together with Blade Labs Inc., Blade Foundation Ltd. and our affiliates or subsidiaries, “Blade,” “we,” “us,” or “our”) collects, uses, shares, and stores personal information of visitors to our website at https://www.bladewallet.io/, https://www.bladelabs.io, https://www.bladefoundation.io, and https://www.bladegroup.io (collectively, the “Site”) and the services, such as the Wallet, available through our Site, including any mobile applications and browser extensions (collectively, the “Services”), and how we use and disclose that information. 

By visiting the Site, or using any of our Services, you agree that your Personal Data (defined below) will be handled as described in this Policy. Your use of our Site or Services, and any dispute over privacy, is subject to this Policy (including any applicable changes) and the Terms of Use, including its applicable limitations on damages and provisions for the resolution of disputes. 

IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS OF USE, THEN PLEASE DO NOT USE THE SITE OR ANY OF THE SERVICES.

This Privacy Policy should be read together with our Cookie Policy and Terms of Use. 

Overview

The Blade “Wallet” is a non-custodial, self-sovereign Web3 portal –originally launched on Hedera Hashgraph – that equips individuals with the ability to manage their digital assets. Specifically, the Blade Wallet allows individuals to:

• Create multiple Wallet accounts
• Store digital assets
• Access Hedera and Ethereum networks with dual network support
• Connect to and access decentralized applications (Dapps) built on Hedera and Ethereum
• Stake digital assets to help secure a network and participate in validating transactions for rewards
• Buy, sell, and swap digital assets via third party service providers
• Claim rewards from within the Wallet 
• Decentralized key recovery mechanism 

The Blade Wallet is currently available as an internet browser extension as well as iOS and Android mobile applications.

Blade does not take custody of any users’ digital assets. Users maintain their own cryptographic keys and retain exclusive access to their digital assets.

Scope of this Policy

This Policy applies to the Site, Services, and Blade Wallet. This Policy applies to everyone that accesses and uses the Services. Where Blade engages with an unaffiliated third-party to perform services on behalf of Blade in relation to the Blade Wallet, Blade will ensure the third-party has suitable internal controls to meet this Policy. 

Definitions

Term	Definition
“Data Processing”	Data Processing means performing any operation or set of operations on data, including: Obtaining, recording, or keeping data; Collecting, organizing, storing, altering, or adapting data; Retrieving, consulting, or using data; Disclosing the information or data by transmitting, disseminating, or otherwise making it available; or  Aligning, combining, blocking, erasing, or destroying data.
“Personal Data” or “Data”	Any information about an identifiable individual, as defined in the European Union General Data Protection Regulation (GDPR). Examples of Personal Data include, but are not limited to: Name, date of birth, and social security or other identity card number; Contact information such as mailing address, email address, and phone numbers;  Financial information such as credit card and account numbers; IP addresses Wallet ID and associated metadata; or Transaction information.
“User”	An individual who accesses, downloads and/or uses the Site, Wallet or Services.

Purpose

It is Blade’s policy to comply with all privacy and data protection-related regulatory requirements applicable to Blade in connection with the Site, Wallet, and Services. This Policy is intended to help Users understand:

• Data We May Collect About You
• Justifications for Engaging in Data Processing
• Who We May Share Your Data With
• How We Secure Data We Collect
• How to Access and Control Your Data
• What Choices Do I Have Regarding Use of My Personal Data for Marketing Purposes?
• How We May Transfer Data We Collect Internationally
• Your Rights if You Are a California Resident
• Rights Under General Data Protection Regulation
• Changes to this Policy
• Contact Us

The DataWe May Collect About You

We collect information about you when you provide it to us, either directly through the use of the Site or Services, or through a third parties, as well as information gathered during your tenure with Blade. 

Personal Data Collected Directly From You.  You may browse certain areas of the Site without registering with us or providing us Personal Data. We collect emails via our Site only to notify you about the existing and upcoming Services, as well as marketing and promotional campaigns. You may provide us with the following types of information- identity verification (such as email, phone number, social media handles, IP address, Wallet ID), feedback & correspondence (such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with Service, receive customer support or otherwise correspond with us), usage of the Site and Services, technical information (wallet address, API-key and network information regarding transactions, associated metadata), and marketing preferences.

In addition, if you are providing Personal Data for third parties in connection with using our Services, you are responsible for ensuring that you have all required permissions and consents to provide such personal information to us for use in connection with the Services and that our use of such personal information to provide the Services does not violate any applicable law, rule, regulation or order.

Personal Data Collected Automatically. We may automatically collect the following information about your use of our Site or Services through cookies and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our Site or use our Services; and the referring URL, or the webpage that led you to our Site. Furthermore, by creating a new account through the Wallet, your Wallet ID, system fingerprint, and any Dapp referral information, if available, may be automatically collected to track account creations and source of the creation as Blade limits 2 account creations per device.

Please note, our third party service providers may use cookies and other tracking mechanisms to track information about your use of our Site and Services. We may combine this information with other personal information we collect from you (and our third party service providers may do so on our behalf). You can learn more about what cookies are, the types of cookies enabled, and how we use them in the Cookies Policy. 

Justifications for Engaging in Data Processing

Some of the justifications for engaging in Data Processing include, but are not limited to:

• Consent is provided by the User;
• The performance of a contract to which the data subject is a party (eg. employment contracts);
• Compliance with a legal obligation; or
• For the legitimate interests of the data controller, unless such interests are overridden by the interests or rights of the data subject. 

How We Use the Data Collected

We use your Personal Data, for various reasons, including but not limited to:

• To enhance security and mitigate fraud we verify a User’s and link the Wallet account ID to the device ID.
• To communicate with you about your use of the Site and Services, respond to inquiries, and other customer customer service purposes.
• To tailor the content and information that we may send or display to you, offer location customization, and personalized help and instructions, and otherwise personalize your experience while using the Site and Services.
• To ensure our Site and Services are working as intended, to better understand how users access and use our Site and Services, both on an aggregated and individual basis, to make improvements to our Services, develop new features, tools, products and services, and for other related research and analytical purposes. 
• To offer promotions; for example, we may use your information, such as your email address, to send you news and newsletters, special offers, conduct contests and sweepstakes, or to otherwise contact you about products or information we think may interest you. 
• To provide you with feedback on incidents (including, but not limited to, questions, bugs or complaints) you raise directly with us.
• To enforce any applicable Terms of Use, comply with the law, legal process or legal obligations, exercise or defend legal claims, detect, prevent or address fraud, security or technical issues, or otherwise protect our property, legal rights, or that of others.
• To provide you with updates on changes (including bug fixes, new features and revised content) where you have already engaged with us by raising an incident.
• To track account creations and source of the creation to ensure no User has more than 2 account creations per device.
• For job candidates, we seek specific consent on the application to assess candidate suitability for an open role, and to verify information provided during the recruitment process.
• To perform accounting and other record-keeping functions.
• To provide personnel, payroll, and other administration services.
• To record your employment history with Blade.
• To record any training, professional development, and performance metrics.
• To exhibit your profile (name, picture, role) on our website team page.

Who We May Share Your Data With 

• Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries solely for the purpose of providing Services to you; however, if we do so, their use and disclosure of your Personal Data will be maintained by such affiliates and subsidiaries in accordance with this Policy and applicable data protection laws, regulations, and statutes.

• Services Providers. We may disclose the Personal Data we collect from you to third party vendors and service providers who help provide the Services, as well as contractors or agents who perform functions on our behalf.  Some of these third parties include, but are not limited to:
  • Moonpay
  • Banxa
  • OnMeta
  • Alchemy Pay
  • Ramp
  • Intercom
  • C14
  • Poko
  • Changelly
  • SendX
  • Bounty Blox
  • Google Cloud
  • Google Analytics
  • Google Firebase
  • Siteground
  • Credo Labs
  • Arkhia

• Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, or are in negotiations for any of these types of transactions, we may transfer the Personal Data we have collected from you to the other company.

Third Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site and our Services. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our Services, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your personal information with these third parties.

Third Party Links. Our Site and Services may contain links to third party websites (for example, decentralized applications, Dapps, such as SlimeWorld, Koala Hash Klub, Karate Combat, etc) and third party vendors (for example, payment service providers (PSPs) like Moonpay, Banxa, C14, etc). Any access to and use of such linked websites, Dapps, and PSPs  is not governed by this Policy, but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third parties. The inclusion of a link on our Site, or in the Services, does not imply that we or our affiliates endorse the practices of the linked website, PSP, or Dapp.

How We Secure Data We Collect

We have implemented commercially reasonable precautions to protect the Personal Data we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Security measures will be reviewed from time to time, having regard to the technology available, the cost, and the risk of unauthorized access. You should take steps to protect against unauthorized access to your password, phone, and computer. Where possible we recommend implementing 2-factor authorization and making sure to back-up your cryptographic keys and recovery phrase. We are not responsible for any lost, stolen, or compromised passwords, cryptographic keys, and recovery phrases, or for any activity on your account via unauthorized password activity.

How to Access and Control Your Data

You may request access, a copy, modification or deletion of Personal Data that you have submitted to us by contacting us at policies@bladelabs.io. We will use reasonable efforts to accommodate such requests to the extent required by law, provided that we may be required to retain Personal Data to comply with legal obligations, accounting requirements, or for other business purposes. There is no charge for requesting this Data. You are only entitled to access Data about yourself and will not be provided with Data relating to other people or third parties. Please note, we may request additional information to verify the identity of the requesting party before responding to a request.

If Blade does not own or control the information you request, we will inform you.

What Choices Do I have Regarding Use of My Personal Data for Marketing Purposes?

You may instruct us not to use your Data to contact you regarding services, promotions, surveys and special events that might appeal to your interests by contacting us using the information below. You can also opt out by following the instructions located at the bottom of any commercial emails messages you may receive.

Please note that, regardless of your request, we may still use and share certain information as permitted by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you, or important notifications regarding the Services we are providing to you, such as service-related announcements (e.g., if our Services are temporarily suspended for maintenance).

Or, if you have downloaded our mobile application and enabled push notifications on your mobile device, we may send you alerts and notifications through push notifications, for example, to communicate status updates on our Services. However, you may choose to disable these notifications on your mobile device.

How We May Transfer Information We Collect Internationally

Blade operates internationally, so it may be necessary in the course of business to transfer a person’s Personal Data within the organization. The transfer of such Data is necessary for the management and administration of your Data within the group. When this is necessary, the organization will take steps to ensure that the Data has the same level of protection at all times. For more information, please contact us at policies@bladelabs.io.

Your Rights if You Are a California Resident

If you are a California resident, you have certain rights with respect to your personal information pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) and California Privacy Rights Act of 2020 (“CPRA”). This section applies to you.

We are required to inform you of: (i) what categories of information we collect about you, including during the preceding 12 months, (ii) the purposes for which we use your personal data, including during the preceding 12 months, and (iii) the purposes for which we share your personal data, including during the preceding 12 months. 

You have the right to: (i) request a copy of the personal information that we have about you; (ii) request that we delete your personal information; (iii) opt-out of the sale of your personal information; (iv) correct inaccuracies; and (v) restrict any sharing of your data with third parties. These rights are subject to limitations as described in the CCPA and CPRA.

We will not discriminate against any consumer for exercising their CCPA and CPRA rights.

If you would like to exercise any of these rights, please contact us at policies@bladelabs.io 

Rights Under General Data Protection Regulation

If you are a citizen or resident of a member country of the European Union (EU) or the European Economic Area (EEA), you have certain data protection rights. Blade aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data that Blade holds about you and if you want it to be removed from our systems, please contact us at policies@bladelabs.io.  

In certain circumstances, you have the following data protection rights:

• The right to access. You have the right to request information concerning the Personal Data we hold that relates to you.
• The right of rectification. You have the right to have your Data rectified if that Data is inaccurate or incomplete.
• The right to object. You have the right to object to your Personal Data being used for a particular purpose and you can exercise these rights, for example, via an unsubscribe link at the bottom of any email.
• The right of restriction. You have the right to request that Blade restrict the processing of your Data.
• The right to data portability. You have the right to be provided with a copy of the Personal Data collected and processed by Blade in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where Blade relied on your consent to process your Personal Data.

Please note that Blade may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the EU or EEA.

Changes to this Policy

We may change this privacy policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make any changes, we will change the Last Updated date above.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the changes to the Sites (or as otherwise indicated at the time of posting). In all cases, your continued use of the Sites or Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

Contact Us

If you have questions about the privacy aspects of our Site or Services or would like to make a complaint, please contact us at policies@bladelabs.io.