Neutron Services. Use of Neutron may facilitate interaction with certain decentralized cryptographic protocols, apps, and blockchains, which we do not own or control (each, a “Protocol”). If you utilize Neutron services relating to the creation and management of digital assets, smart contracts will be employed that necessarily collect information, such as your digital wallet address (which some legal jurisdictions may consider personal information), and that information will be stored on a public blockchain that we do not control. A smart contract is computer code that automatically processes events when certain conditions are met; for example, when a transaction is conducted to add a token to a digital wallet, a smart contract would automatically execute the proposed action. In these situations, your personal information, such as a digital wallet address, will be stored on that blockchain through the execution of a smart contract and that personal information may not be able to be modified or deleted due to the immutable nature of the blockchain.
Please make sure to review our Terms of Service for more information, including specific terms and obligations for the use of our Services that may include dispute resolutions.
This Privacy Policy (the “Policy”) explains how the Neutron decentralized autonomous organization (“Neutron DAO”), the Neutron Foundation, and any subcontractors (collectively “Neutron”, “we”, “us” or “our”) collects, uses, and shares data in connection with use of the Neutron blockchain network and associated interfaces and user interfaces, including duality.xyz, app.duality.xyz, neutron.org, governance.neutron.org, forum.neutron.org, bridge.neutron.org, and other such Neutron ecosystem interfaces as may be launched in the future (the “Interface”). Your use of the open source software related to the Neutron Network (“Neutron”) is subject to this Policy as well as our Terms of Service.
Scope of Neutron’s Privacy Policy. This Privacy Policy applies to personal information processed by us, including on our websites, and other online or offline offerings (collectively called the “Services”).
The Neutron DAO does not collect and store personal data, such as first name, last name, street address, date of birth, email address, or IP address. All data collected is anonymized.
The Neutron DAO may use and/or collect, following due governance processes (voted in by the governance system), non-identifiable data, such as public on-chain data, and limited off-chain data like device type, browser version, interface usage, etc. This is to help drive production vision, not track users.
Neutron will offer opt-out options for data-tracking when applicable. Users are empowered to explore client-side privacy techniques and tools. Any material changes to privacy will be reflected in an updated version of this Privacy Policy.
Data Neutron Collects. Privacy and accessibility is central to the ethos of Neutron. Accordingly, we aspire to be transparent about what little data we do collect. We do not maintain user accounts and do not collect and store personal data, such as your name or email address. When you interact with the Interface and/or the Protocol, we collect only:
Publicly-available Blockchain Data. When you connect your non-custodial blockchain wallet to the Interface, we collect and log your publicly-available blockchain address to learn more about your use of the Interface and to screen your wallet for any prior illicit activity. We may screen your wallet using intelligence provided by leading blockchain analytics providers. Note that blockchain addresses are publicly-available data that are not created or assigned by us or any central party, and by themselves are not personally identifying.
Information from localStorage and Other Tracking Technologies. We and our third-party services providers may access and collect information from localStorage, mobile deviceID, cookies, web beacons, and other similar technologies to provide and personalize the Interface and features of the Interface for you across sessions. We may use this information to learn about your preferences and your use of the Interface. Information we collect from these technologies may include things such as browser type, referring/exit pages, operating system, device or browser language, and other device information. We may group and analyze these user journeys collectively, in the aggregate, to improve our product user experience. A user on specific web application properties may customize their level of tracking consent through an expicit action (eg. button click) on that application, a user may consent to:
no tracking: no off-chain data is collected from these user sessions
anonmymous user tracking: simple non-personally identifiable browser data as described in the section above is collected in aggregate for high-level application usage analytics. This data may include country identification through IP address information. This data does not include wallet addresses.
non-anonmymous user tracking: includes collection and analytics storage of any wallet addresseses connected to the application, and collection of more detailed application usage interactions that can be analyzed in detail such as specific button clicks or form input selections. Private wallet keys are never seen or collected by any implemented tracking technologies.
Information from Other Sources. We may receive information about your wallet address or transactions made through the Interface and/or the Protocol from our service providers in order to operate in good faith and remain aligned with legal obligations and potentially prevent the use of our Interface or Protocol in connection with fraudulent or other illicit activities.
Survey or Usability Information. If you participate in a survey or usability study with us, any and all information provided to us may be analyzed by the Neutron DAO.
Correspondence. We will receive any communications and information you provide directly to us via email, social media, or another support channel (such as Twitter or Discord), or when you participate in any surveys or questionnaires.
Biographical Information. If you apply for a role with us, we collect all information provided, including name, email, Discord handle and any other resume, cover letter, or free form text you include.
How We Use Data. We use the data we collect in accordance with your instructions, including any applicable terms in our Terms of Service, and to operate in good faith. We may also use data for the following purposes:
Providing Access to the Protocol. We use the data we collect to provide, maintain, customize and improve our Interface and features of the Interface.
Customer Support. We may use information to provide customer support for and answer inquiries about the Interface or the Protocol.
Safety and Security. Neutron may use data to protect against, investigate, and stop fraudulent, unauthorized, or illegal activity. We may also use it to address security risks, solve potential security issues such as bugs, enforce our agreements, and protect community members.
Compliance with Applicable Law. We may use the information we collect as needed or requested by regulators, government entities, and law enforcement to comply with applicable laws and regulations.
Aggregated Data. We may use some of the information we collect or access to compile aggregated data that helps us learn more about how users use the Interface and where we can improve your experience.
User-Specific Data. When explicitly consented to on certain applications, we may use some of the information we collect or access to compile specific and detailed user case studies that helps us learn more about how users use the Interface and where we can improve your experience.
How We Share Data. We may share or disclose the data we collect:
With Service Providers. We may share your information with our service providers and vendors to assist us in providing, delivering, and improving the Interface.
To Comply with Applicable Law. We may share your data in the course of litigation, regulatory proceedings, compliance measures, and when compelled by subpoena, court order, or other legal procedure. We may also share data when we believe it is necessary to prevent harm to our users, the Neutron, or others, and to enforce our agreements and policies, including our Terms of Service.
Safety and Security. We may share data to protect against, investigate, and stop fraudulent, unauthorized, or illegal activity. We may also use it to address security risks, solve potential security issues such as bugs, enforce our agreements, and protect our users, Neutron, and ecosystem.
Business Changes. We may transfer or share data to another entity in the event of a merger, acquisition, bankruptcy, dissolution, reorganization, or other business transaction.
With Your Consent. We may share your information any other time you provide us with your consent to do so.
We do not share your information with any third parties for any marketing purposes whatsoever.
Third-Party Cookies. We may use services provided by third parties that use tracking technology such as cookies, deviceID, and localStorage, to collect information about your use of the Interface and our interactions with you. All logs are anonymized and users’ Do Not Track settings are respected.
You can opt out of having your online activity and device data collected through these third-party services, including by:
Blocking cookies in your browser by following the instructions in your browser settings. For more information about cookies, including how to see the cookies on your device, manage them, and delete them, visit allaboutcookies.org.
Blocking or limiting the use of your advertising ID on your mobile device through the device settings.
Using privacy plug-ins or browsers. Certain browsers and browser extensions can be configured to block third-party cookies and trackers.
Using any platform opt-out provided.
Using advertising industry opt-out tools on each device or browser where you use the Interface, available at optout.aboutads.info and optout.networkadvertising.org.
Third-Party Links and Sites. We may integrate technologies operated or controlled by other parties into parts of the Interface. For example, the Interface may include links that hyperlink to websites, platforms, and other services not operated or controlled by us. Please note that when you interact with these other parties, including when you leave the Interface, those parties may independently collect information about you and solicit information from you. You can learn more about how those parties collect and use your data by consulting their privacy policies and other terms.
Security. We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect data from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you. You are responsible for all of your activity on the Interface and the Protocol, including the security of your blockchain network addresses, cryptocurrency wallets, and their cryptographic keys.
Age Requirements. The Interface and the Protocol are intended for a general audience and are not directed at children under 18 years old or the minimum legal age to enter into a binding contract in each user’s jurisdiction. We do not knowingly receive personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA” or other applicable law) from children. If you believe we have received personal information about a child under the age of 18, please contact us at legal (at) neutron.org.
Additional Notice to California Residents (“CCPA Notice”). The California Consumer Privacy Act of 2018 (“CCPA”) requires certain businesses to provide a CCPA Notice to California residents to explain how we collect, use, and share their personal information, and the rights and choices we offer California residents regarding our handling of their information.
Privacy Practices. We do not “sell” personal information as defined under the CCPA. Please review the “Sharing and Disclosure of Information” section above for further details about the categories of parties with whom we share information.
Privacy Rights. The CCPA gives individuals the right to request information about how we have collected, used, and shared your personal information. It also gives you the right to request a copy of any information we may maintain about you. You may also ask us to delete any personal information that we may have received about you. Please note that the CCPA limits these rights, for example, by prohibiting us from providing certain sensitive information in response to access requests and limiting the circumstances under which we must comply with a deletion request. We will respond to requests for information, access, and deletion only to the extent we are able to associate, with a reasonable effort, the information we maintain with the identifying details you provide in your request. If we deny the request, we will communicate the decision to you. You are entitled to exercise the rights described above free from discrimination.
Submitting a Request. You can submit a request for information, access, or deletion to the Neutron community at legal (at) neutron.org.
Identity Verification. The CCPA requires us to collect and verify the identity of any individual submitting a request to access or delete personal information before providing a substantive response.
Authorized Agents. California residents can designate an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming their authority.
Disclosures for European Union Data Subjects. We process personal data for the purposes described in the section titled “How We Use Data” above. Our bases for processing your data include: (i) you have given consent to the process to us or our service provides for one or more specific purposes; (ii) processing is necessary for the performance of a contract with you; (iii) processing is necessary for compliance with a legal obligation; and/or (iv) processing is necessary for the purposes of the legitimate interested pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests.
Your rights regarding your data include the right to: (i) request access and obtain a copy of your personal data, (ii) request rectification or erasure of your personal data, (iii) object to or restrict the processing of your personal data; and (iv) request portability of your personal data. Additionally, you may withdraw your consent to our collection at any time. Nevertheless, we cannot edit or delete information that is stored on a particular blockchain. Information such as your transaction data, blockchain wallet address, and assets held by your address that may be related to the data we collect is beyond our control.
To exercise any of your rights under this Policy, please contact us at legal (at) neutron.org.
We may require additional information from you to process your request. Please note that we may retain information as necessary to fulfill the purpose for which it was collected and may continue to do so even 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.
Removal of Personal Identifying Data and Questions
For any questions regarding your personally-identifying information stored with Neutron, for removal requests or any other suggestions or issues, please send us an email at legal (at) neutron.org.
Changes to this Policy. If we make material changes to this Policy, we will notify you via the Interface. Nevertheless, your continued use of the Interface reflects your periodic review of this Policy and our Terms of Service, and indicates your consent to them.
Protection of Certain Personally-Identifying Information. Neutron will not rent or sell potentially personally-identifying and personally-identifying information to anyone.
If you are a registered user of Neutron and have supplied your email address, Neutron may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with Neutron and our products. We primarily use our website to communicate this type of information, so we expect to keep this type of email to a minimum.
Neutron takes all measures reasonably necessary to protect against the unauthorized access, use, alteration, or destruction of potentially personally-identifying and personally-identifying information.
Contact Us. If you have any questions about this Policy or how we collect, use, or share your information, please contact us at legal (at) neutron.org.
