1. Introduction
This Privacy Policy explains how personal data is collected, used, and processed in connection with access to the Multyr interface and related services (the “Interface”).
The Multyr protocol itself operates on public blockchain infrastructure and does not inherently collect or control personal data.
This Privacy Policy applies only to off-chain interactions with Multyr-controlled interfaces.
2. Data Controller
For the purposes of applicable data protection laws:
- Multyr Foundation (Panama) acts as the primary data controller in relation to the Interface
- Multyr Labs Ltd (Switzerland) may act as a data processor or sub-processor providing technical services, infrastructure, and development support
Where third-party services are used, such providers may act as independent data controllers.
3. Scope and Limitations
This Privacy Policy does not apply to:
- blockchain transactions
- public wallet activity
- third-party protocols or applications
Blockchain data is:
- public
- immutable
- not controlled by Multyr
Users should understand that blockchain activity cannot be modified or deleted.
4. Categories of Data Collected
4.1 Information Provided by Users
We may collect personal data voluntarily provided, including:
- email address
- communication content
4.2 Automatically Collected Data
When accessing the Interface, certain information may be collected automatically:
- IP address
- browser and device information
- usage and interaction data
- timestamps and session data
4.3 Wallet and Blockchain Data
When connecting a wallet:
- your public wallet address may be processed
- transaction activity may be referenced
Wallet addresses are pseudonymous but may be considered personal data under certain regulations.
4.4 Wallet Analytics and Tracking
The Interface may integrate with wallet connectivity and analytics providers (e.g., WalletConnect or similar services).
These services may collect:
- wallet connection metadata
- session identifiers
- interaction data
Such providers operate independently and may process data according to their own privacy policies.
Multyr does not control how third-party wallet services process data.
4.5 Cookies and Similar Technologies
The Interface may use cookies or similar technologies to:
- maintain session functionality
- analyze usage patterns
- improve user experience
Users may disable cookies through browser settings.
5. Purpose of Processing
Personal data may be processed for the following purposes:
- operating and maintaining the Interface
- improving performance and functionality
- analyzing usage and engagement
- ensuring security and preventing abuse
- communicating with users where applicable
6. Legal Basis (GDPR)
Where applicable, data is processed on the basis of:
- legitimate interests (e.g., maintaining and improving the Interface)
- consent (e.g., cookies, optional communications)
- legal obligations
7. Data Sharing
Personal data may be shared with:
- service providers (hosting, analytics, infrastructure)
- wallet providers and integration partners
- legal or regulatory authorities when required
We do not sell or rent personal data.
8. Third-Party Services
The Interface may rely on third-party providers, including:
- wallet connection providers (e.g., WalletConnect)
- analytics services
- hosting and infrastructure providers
These entities operate independently and are responsible for their own data processing practices.
9. Data Retention
Personal data is retained only as long as necessary for:
- operational purposes
- legal obligations
- legitimate interests
Retention periods may vary depending on the nature of the data.
10. Data Security
We implement reasonable technical and organizational measures to protect personal data.
However:
- no system is completely secure
- blockchain data is inherently public
- users are responsible for securing their wallets
11. International Data Transfers
Data may be processed in jurisdictions outside your country of residence.
This may include transfers to:
- Panama
- Switzerland
- other locations where service providers operate
By using the Interface, you acknowledge and accept such transfers.
12. Your Rights
Depending on applicable law, you may have rights to:
- access your data
- request correction
- request deletion
- restrict or object to processing
Requests may be submitted via contact details below.
13. Children
The Interface is not intended for individuals under 18.
We do not knowingly collect personal data from minors.
14. Changes to This Policy
This Privacy Policy may be updated at any time.
Continued use of the Interface constitutes acceptance of any updated version.
15. Contact
For privacy-related inquiries:
info@multyr.fi
16. Important Notice on Blockchain Data
The Multyr protocol operates on public blockchain infrastructure.
As a result:
- transaction data is publicly visible
- data cannot be deleted or altered
- Multyr has no control over blockchain records
Users should carefully consider this before interacting with the protocol.
