Skip to main contentINTRODUCTION
This Privacy Policy describes how we, Wallchain (“we”, “our”, “us”), collect, use, process, and disclose your Personal Data in connection with your use of the Website and the Services, including our proprietary X Score and AttentionFi ecosystem.
This Policy is structured into three parts: the Privacy Notice, the Cookie Notice, and the Data Processing Agreement (DPA) Placeholder.
The Services are provided subject to our Terms and Conditions of Service (the “Terms”).
Children: The Website and Services are restricted to persons who are at least 18 years of age due to the complex and financial nature of the Web3 ecosystem. We do not knowingly collect personal data from people who are less than 18 years of age.
PART 1: PRIVACY NOTICE (DATA COLLECTION, PURPOSE, & RIGHTS)
Data Controller: Wallchain is the Controller of your Personal Data.
Contact Details: You can contact us with any inquiries or complaints in respect of your Personal Data or to exercise your rights:
Email: [email protected]
2. Sources of Personal Data
We collect your Personal Data from the following primary sources:
A. Data collected during account registration, when you connect your Digital Wallet, or when you submit support requests (e.g., email address, communications).
B. Log Files automatically collect data from your devices or software when you interact with the Website, including IP address, browser type, device details, usage logs, and timestamps.
C. Data collected from external platforms when you choose to link your social account to the Service.
D. Data collected from public ledgers, including transaction history, token holdings, and on-chain activity associated with your connected Digital Wallet.
3. Categories of Personal Data Collected
We collect and use the following types of your Personal Data in connection with your use of the Services:
A. Identity and Account Data (e.g., email address, password hash).
B. Web3 and Financial Data (e.g., Digital Wallet address, distribution records, public token holdings).
C. Social Engagement Data (e.g., public profile information, posts, followers, and engagement metrics).
D. Technical Data (e.g., IP address, device identifiers, operating system, and log statistics).
E. Customer Support Data (e.g., records of your communication with us).
F. Tracking Data (e.g., data collected through cookies and similar technologies, detailed in Part 2).
4. Purpose and Legal Ground for Processing Personal Data
We process your Personal Data only when it is lawful under the Applicable Data Protection Law and only to the extent necessary to achieve our purposes. The processing is based on the following legal grounds:
A. Contractual Necessity (Article 6(1)(b) GDPR): We process data to register your account, verify identity, operate the core Services (including X Score calculation and Quacks distribution), and provide customer support, as these are necessary to perform the contract with you.
B. Legitimate Interest (Article 6(1)(f) GDPR): We process data for internal Business Operations (audits, maintenance, and platform improvement), Analytics & Scoring (generating analytical insights and influence indicators), and Marketing (service notifications and brand promotion).
C. Legal Obligation (Article 6(1)(c) GDPR): We process data for Security & Compliance, including fulfilling AML/KYC requirements, preventing fraud, and complying with all applicable legal obligations (e.g., responding to data privacy requests).
D. Consent (Article 6(1)(a) GDPR): We rely on your consent for direct marketing activities and for the use of non-essential tracking cookies.
5. Data Recipients and Blockchain Disclosure
5.1. Categories of Data Recipients
We may disclose your Personal Data to the following recipients: Service Providers (cloud hosting, payment processing, analytics), Advertising Partners (ad networks for targeted advertising, subject to consent), Wallchain Group Entities (affiliates and subsidiaries), Professional Advisors (lawyers, accountants), and Public Authorities (where required by Applicable Law).
5.2. Blockchain Network Participants (CRITICAL DISCLOSURE)
Due to the nature of distributed ledger technology (DLT), any Personal Data recorded on a public blockchain network (such as your Digital Wallet address and associated transaction history) may be transparent, immutable, and accessible to third parties globally. We do not control or operate these decentralized networks.
5.3. Public Display (AttentionFi Mechanism)
As detailed in our Terms, by using the Service, you expressly consent to the public disclosure and display of your User Profile Data across our Platform, leaderboards, and related promotional materials as a core function of the AttentionFi mechanism.
6. Data Transfers, Security, and Retention
6.1. International Data Transfers
We transfer your Personal Data outside the European Economic Area (EEA) only when necessary and with an adequate level of protection, secured primarily by using Standard Contractual Clauses (SCCs) issued by the European Commission.
6.2. Data Retention
We store your Personal Data only as long as necessary for the purposes we collected it, or as long as your account is active. Retention may be extended when required by law (e.g., tax records) or when necessary to establish and assert legal claims.
7. Your Data Protection Rights
To exercise your rights, contact us using the contact details in Section 1.
GDPR Rights (EU/EEA Users): You have the right of access, rectification, restriction of processing, data portability, withdrawal of consent, and objection to processing.
CCPA Rights (California Residents): You have the right to request disclosure, deletion, and the Right to Opt-Out of the Sale or Sharing of Personal Information (the “Right to Opt-Out”).
7.1. Right to Erasure (Right to be Forgotten) Disclaimer
You have the right to ask us to erase your Personal Data in certain circumstances. However, you acknowledge that due to the nature of blockchain technology, it may be technically impossible, depending on the blockchain protocol, to delete or correct any information recorded on-chain in a public blockchain network. We do not control over these decentralized networks.
7.2. No Advice, Fiduciary Relationship, or AI/Model Integrity Warranty
Any information, Content, or X Score provided on the Platform shall not be considered or construed as financial advice, investment advice, tax advice, legal advice, or any other sort of advice. The Terms do not create or impose any fiduciary duties on Wallchain. All investment decisions are your sole responsibility.
Model Disclaimer: You acknowledge that the X Score, Generated Results, and all other outputs derived from our proprietary learning models are inherently experimental and subject to error, inaccuracy, or bias. We provide NO WARRANTY as to the accuracy, completeness, or integrity of any information, and we shall not be liable for any reliance placed upon such information or any resulting loss.
PART 2: COOKIE NOTICE (TRACKING TECHNOLOGIES)
1. Introduction
This Cookie Notice describes how Wallchain stores or accesses information on your terminal device in connection with your use of the Website and the Services, and how you can manage these technologies.
2. Categories of Cookies Used
We use cookies only when admissible by law, typically falling into the following categories: Strictly Necessary (Essential for technical function and security, Legal Ground: Legitimate Interest), Analytics/Performance (Collecting data to improve the Services, Legal Ground: Consent), and Targeting/Advertising (Used by us or our partners to track habits and deliver relevant ads, Legal Ground: Consent).
3. Your Cookie Choices and Management
Optional cookies (Analytics, Targeting) are only used with your Consent. You will be presented with a Cookie Consent Banner upon your first visit.
PART 3: DATA PROCESSING AGREEMENT (DPA) PLACEHOLDER
1. Processing Relationship
This section addresses the scenario where Wallchain provides its analytics service to a business client who acts as the primary Data Controller for their own users’ data, and Wallchain acts as a Data Processor on behalf of that client.
2. Availability of DPA
Wallchain agrees to enter into a Data Processing Agreement (DPA) with clients who use the Service in the capacity of a Controller. The terms and conditions for entrusting the processing of personal data, including the subject-matter, duration, nature, and purposes of the processing, are set out in our standard DPA, available upon request at [email protected].
Your use of Wallchain Services as a Data Controller is conditional upon signing and agreeing to the DPA. 
