Privacy Policy

1. Information We Collect

As a No-KYC platform, DeShare minimizes data collection to only what is technically necessary for the operation and security of the Platform. We categorize the information we may collect as follows:

1.1 Wallet and Blockchain Data

• Public Wallet Addresses: When you connect a Web3 wallet (e.g., MetaMask, Rabby, or via WalletConnect), your public blockchain address is transmitted to the Platform. This address is inherently public on the blockchain and is not treated as private personal data.
• Transaction Data: Records of transactions you execute through the Platform, including buy and sell orders, token transfers, swap amounts, timestamps, and associated smart contract interactions. All on-chain transaction data is publicly accessible on the respective blockchain.
• Wallet Balances: Token balances associated with your connected wallet address, as read from the public blockchain, to facilitate Platform functionality such as order validation.

1.2 Device and Technical Information

• Device Information: Device type, operating system and version, browser type and version, screen resolution, and device language settings.
• Network Information: IP address (which may be anonymized or aggregated), internet service provider, and general geographic location inferred from IP address (country or region level only).
• Connection Data: Information about your Web3 wallet provider, wallet connection method, and blockchain network selected.

1.3 Usage and Analytics Data

• Interaction Data: Pages visited, features used, buttons clicked, time spent on the Platform, navigation paths, and session duration.
• Performance Data: Page load times, errors encountered, crash reports, and diagnostic data necessary to maintain and improve the Platform.
• Referral Data: Information about the source that directed you to the Platform (e.g., referral links, campaign identifiers, or referring websites).

1.4 Voluntary Communications

• Support Requests: If you contact our support team, we may collect the email address or communication channel identifier you use, along with the content of your correspondence.
• Feedback and Surveys: Any information you voluntarily provide through surveys, feedback forms, or community channels.

2. How We Use Your Information

We use the information we collect for the following purposes:

1. Platform Operations: To facilitate tokenized securities trading, process transactions, validate orders, and deliver core Platform functionality.
2. Security and Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, unauthorized access, market manipulation, and other malicious activities that may threaten the Platform or its users.
3. Platform Improvement: To analyze usage patterns, diagnose technical issues, optimize performance, and develop new features and services.
4. Compliance: To comply with applicable legal obligations, respond to lawful requests from regulatory or law enforcement authorities, and enforce our Terms of Service.
5. Communication: To respond to your support requests, send critical service-related notifications (e.g., security alerts, protocol updates), and provide information about material changes to the Platform.
6. Analytics and Research: To conduct aggregated, anonymized analysis of Platform usage trends for internal research and reporting purposes.

3. Information Sharing and Disclosure

DeShare does not sell, rent, or trade your information to third parties for marketing purposes. We may share information in the following limited circumstances:

3.1 Third-Party Brokerage Partners

To facilitate the purchase and custody of underlying real-world securities, certain transaction data (e.g., order type, asset, quantity, and execution price) may be shared with our third-party brokerage partners. These partners are bound by contractual obligations to use such data solely for the purpose of executing and settling trades and maintaining custody of underlying assets. Brokerage partners do not receive your wallet address or any identifying information beyond what is strictly necessary for trade execution.

3.2 Service Providers

We may engage trusted third-party service providers to assist with infrastructure hosting, analytics, security monitoring, and customer support. These providers are contractually obligated to protect your information and may only use it to perform services on our behalf.

3.3 Legal Requirements

We may disclose information if required to do so by law or in the good-faith belief that such disclosure is necessary to:

• Comply with a legal obligation, court order, or governmental request under BVI law or other applicable jurisdiction.
• Protect and defend the rights, property, or safety of DeShare, our users, or the public.
• Investigate potential violations of our Terms of Service.
• Detect, prevent, or address fraud, security issues, or technical problems.

3.4 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, information collected through the Platform may be transferred to the acquiring entity. We will provide notice of any such transfer and any choices you may have regarding your information.

3.5 Aggregated and De-Identified Data

We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify any individual. Such data may be used for industry analysis, market research, and Platform benchmarking.

4. Cookies and Tracking Technologies

The Platform may use the following technologies to collect usage and technical information:

• Essential Cookies: Small data files stored on your device that are strictly necessary for the Platform to function, such as maintaining your wallet connection state and session preferences.
• Analytics Cookies: Used to collect anonymized usage data to help us understand how users interact with the Platform. These may be provided by third-party analytics services.
• Local Storage and Session Storage: Browser-based storage mechanisms used to maintain user preferences, theme settings, and cached data for improved performance.

You may control or disable cookies through your browser settings. Please note that disabling essential cookies may impair your ability to use certain features of the Platform. We do not use cookies for advertising or cross-site tracking purposes.

5. Data Security

We implement commercially reasonable technical and organizational measures designed to protect the information we collect against unauthorized access, alteration, disclosure, or destruction. These measures include, but are not limited to:

• Encryption of data in transit using TLS/SSL protocols.
• Encryption of sensitive data at rest.
• Regular security audits and penetration testing of Platform infrastructure.
• Access controls and role-based permissions for internal systems.
• Continuous monitoring for suspicious activity and intrusion detection.
• Use of audited smart contracts for on-chain operations.

However, no method of transmission over the Internet or method of electronic storage is completely secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security. You are responsible for maintaining the security of your Web3 wallet and private keys.

6. Data Retention

We retain the information we collect for as long as reasonably necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by applicable law. Specifically:

• Transaction Data: Retained for the duration required by applicable financial regulations and for the maintenance of accurate platform records. On-chain transaction data exists permanently on the blockchain and is beyond our ability to delete.
• Device and Technical Information: Generally retained for up to 12 months from collection, unless required for ongoing security investigations.
• Usage and Analytics Data: Aggregated and anonymized analytics data may be retained indefinitely. Raw usage data is typically retained for no more than 24 months.
• Support Communications: Retained for as long as necessary to resolve your inquiry and for a reasonable period thereafter for quality assurance and legal purposes.

When information is no longer required for its stated purpose, we will securely delete or anonymize it in accordance with our data management procedures.

7. International Data Transfers

DeShare is incorporated in the British Virgin Islands and operates infrastructure that may be distributed across multiple jurisdictions. By using the Platform, you acknowledge and consent to the transfer, processing, and storage of your information in the BVI and other countries where our servers, service providers, or brokerage partners are located.

These jurisdictions may have data protection laws that differ from those in your country of residence. We take reasonable steps to ensure that your information receives an adequate level of protection in the jurisdictions in which we process it, including through the use of contractual data protection provisions with our service providers.

8. Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding the information we hold about you. Given our No-KYC model and the minimal data we collect, many traditional data subject rights have limited applicability. However, you may exercise the following where applicable:

• Access: You may request confirmation of whether we process information associated with your wallet address and, where applicable, request a copy of such information.
• Correction: You may request correction of any inaccurate information we hold about you.
• Deletion: You may request deletion of off-chain information we hold that is associated with your wallet address, subject to our legal retention obligations. Please note that on-chain data recorded on public blockchains cannot be deleted or modified by DeShare or any party.
• Objection: You may object to certain processing activities, such as the use of analytics cookies, by adjusting your browser settings.
• Wallet Disconnection: You may disconnect your wallet from the Platform at any time, which will cease the collection of new data associated with your wallet address going forward.

To exercise any of these rights, please contact us using the details provided in Section 13 below. We will respond to your request within a reasonable timeframe and in accordance with applicable law.

9. Children's Privacy

The Platform is not intended for use by individuals under the age of 18 (or the age of majority in their jurisdiction of residence). We do not knowingly collect information from children. If we become aware that we have inadvertently collected information from a child under the applicable age threshold, we will take reasonable steps to delete such information promptly. If you believe that a child has provided us with information through the Platform, please contact us at the address provided in Section 13.

10. Third-Party Services and Links

The Platform may integrate with or contain links to third-party services, including but not limited to:

• Web3 Wallet Providers: MetaMask, Rabby, WalletConnect, and other wallet services that facilitate blockchain interactions.
• Blockchain Networks: Public blockchain networks on which transactions are recorded and smart contracts are deployed.
• Brokerage Partners: Third-party brokerage firms that execute and settle trades in underlying real-world securities.
• Analytics Providers: Third-party services that assist with usage analytics and performance monitoring.
• External Websites: Links to external resources, documentation, or community channels.

Each of these third-party services operates under its own privacy policy and terms of service. DeShare is not responsible for the privacy practices, data collection methods, or content of any third-party service. We encourage you to review the privacy policies of any third-party service before providing information to or interacting with such service.

11. Blockchain Data Disclaimer

By using the Platform, you acknowledge and agree that:

• Public Transactions: All transactions executed on public blockchains are permanently recorded on the distributed ledger and are publicly visible to anyone. This includes your wallet address, transaction amounts, token types, and timestamps.
• Immutability: Once a transaction is confirmed on the blockchain, it cannot be altered, reversed, or deleted by DeShare or any other party. This is a fundamental characteristic of blockchain technology and is outside our control.
• Pseudonymity, Not Anonymity: While blockchain addresses are pseudonymous, they are not anonymous. It may be possible for third parties to associate your blockchain address with your identity through analysis of on-chain activity, off-chain data, or other means. DeShare makes no representations regarding the anonymity of your blockchain transactions.
• Third-Party Analysis: Blockchain analytics companies and other third parties may independently monitor, index, and analyze public blockchain data, including your transactions on the Platform. DeShare has no control over such third-party activities.
• No Deletion of On-Chain Data: DeShare cannot fulfill requests to delete, modify, or restrict access to data that has been recorded on a public blockchain. Any data rights described in this Privacy Policy apply only to off-chain data within our control.

12. Changes to This Policy

We reserve the right to update or modify this Privacy Policy at any time at our sole discretion. When we make changes, we will:

• Update the "Effective Date" at the top of this page.
• Post the revised Privacy Policy on the Platform.
• For material changes, provide notice through prominent posting on the Platform or, where feasible, through other available communication channels.

Your continued use of the Platform after the posting of a revised Privacy Policy constitutes your acceptance of the changes. We encourage you to periodically review this page for the latest information on our privacy practices. If you do not agree with any modifications to this Privacy Policy, you must discontinue your use of the Platform.

13. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

We will endeavor to respond to all legitimate inquiries within a reasonable timeframe. For the avoidance of doubt, all inquiries and disputes related to this Privacy Policy shall be governed by and construed in accordance with the laws of the British Virgin Islands, without regard to its conflict-of-law provisions.