Privacy Policy

Last Updated: June 6, 2025

We are the team behind decentralized Web3 products and services. We respect your right to privacy and process personal data with due responsibility in compliance with applicable laws.

We value the trust you place in us by using our websites, applications, and services. This Privacy Policy (hereinafter referred to as the "Policy") applies to all our online resources, including the Cellframe.net website(s), mobile applications, and other products where this Policy is posted, referenced, or linked.

By using our online resources, the User unconditionally agrees to this Policy and the terms of processing their personal information as set forth herein. If the User disagrees with these terms, they must refrain from using our services.

This Policy explains:

• How we collect, use, and process your personal information;
• What rights you have regarding your data;
• How to contact us regarding privacy matters.

1. Definition of "Personal Information"

For the purposes of this Policy, "personal information" means any data relating to an identified or identifiable natural person, including:

Personal information voluntarily provided by the User when registering (creating an account) or while using the online resources, including the User's personal data. Mandatory information required for accessing the online resources is marked accordingly.

Data automatically transmitted to the online resources during their use via the software installed on the User's device, including:

• IP address,
• Cookie data,
• User's browser (or other program used to access the online resources) information,
• Technical specifications of the User's hardware and software,
• Date and time of access to the services,
• Addresses of requested pages,
• Other similar information.

2. Minimization of Personal Information Collection

We minimize the collection of personal information.

We only collect and retain personal information that is necessary to:

• Provide our services (including core functionalities and support);
• Fulfill agreements and contracts with the User, including compliance with sanctions restrictions and other legal requirements, except where the law mandates the retention of personal data for a specified period.

We retain personal data only for as long as required to:

• Maintain wallet functionality;
• Process your requests;
• Comply with legal obligations (e.g., legal claims or regulatory inquiries);
• Ensure platform security and stability.

Additionally, we automatically collect technical data essential for the basic operation of the wallet.

3. Withdrawal of Consent to Personal Data Processing

Upon receiving a User's notice withdrawing consent to the processing of their personal data, our online servers will cease processing such data within no more than 10 (ten) business days of receipt.

The withdrawal notice must be submitted:

• Via email to: pr@cellframe.net;

4. Purposes of Processing User Personal Information

The online resources process User personal information for the following purposes:

1. User Identification: In rare cases (e.g., for corporate features), we may request identity verification. This occurs only when necessary, with transparent notice.
2. Providing Core Wallet Functionality: Including transaction creation, network connectivity, balance display, and access to personalized online resources.
3. Communication with the User: Including service-related notifications, requests, and processing User inquiries.
4. Location Detection: To enhance security and prevent fraud.
5. Verification of Accuracy: Ensuring the completeness and correctness of User-provided data.
6. Account Creation: If the User consents to registering an account.
7. Customer & Technical Support: When contacting support, you may provide your name, contact details, and issue description. This data is used solely to resolve your request.
8. Service Updates: Notifying Users about new features, improvements, or updates.
9. Marketing Activities: Conducted only with the User's explicit consent.
10. Payment Processing: For paid features (e.g., wallet purchases), payment details may be required. We do not store payment information.

5. Implications for Wallet and Product Users

If you use our wallet or other products, note the following:

• We do not collect your private keys.
• We do not share your personal information.
• We do not retain or process more data than necessary for functionality and user experience enhancement.
• We temporarily process IP addresses only when required for:
  • Core service operations;
  • DDoS attack prevention;
  • Performance optimization (e.g., routing requests via nearby servers);
  • Legal compliance (e.g., sanctions enforcement);
  • Proxy infrastructure integration (to mask your IP when interacting with third-party services).

To limit device data transmission, you may use a Virtual Private Network (VPN).

6. Automatically Collected Information

• IP Address and Technical Data: When using the wallet, we may automatically collect your IP address, device type, OS version, error logs, and timestamps of activity. This data is essential for security, diagnostics, and product improvement.
• Cookies and Similar Technologies: When visiting our web interface, we may use cookies for anonymous analytics and storing user preferences.
• Location Data: We do not collect precise geolocation data. Approximate location (e.g., derived from IP addresses) may be used for interface regionalization or security purposes.
• Third-Party Integrations: When logging in via external platforms (e.g., Web3 services), we may receive limited authorization-related data.

7. Storage of User Personal Information

The website stores Users' personal information per the internal regulations of specific services.

User personal information remains confidential unless voluntarily disclosed by the User for unrestricted public access. By using certain services, the User acknowledges that some personal data may become publicly available.

8. Data Sharing with Third Parties

We do not sell your personal data. However, in limited cases, we may share information with third parties strictly to:

• Maintain Cellframe's functionality;
• Comply with legal obligations.

The website may disclose User personal information to third parties in these cases:

1. The User has explicitly consented;
2. Disclosure is necessary for:
   • Service provision (e.g., to subsidiaries, partners, or vendors providing technical/operational support);
   • Fulfillment of agreements with the User;
3. Required by Russian or other applicable laws via legally established procedures;
4. In case of a website sale, the acquirer assumes all obligations under this Policy regarding the inherited personal data.

9. Processing Methods and Duration

User personal data is processed indefinitely and may involve:

• Collection, recording, systematization, storage;
• Updating, modification, retrieval, use;
• Transfer (distribution, provision, access);
• Anonymization, blocking, deletion, or destruction;
• Via automated or non-automated means in personal data information systems.

10. Data Breach Notification

In the event of loss or unauthorized disclosure of personal data, the Site Administration shall notify the User of such incident.

We implement necessary organizational and technical measures to protect User personal information against:

• Unlawful or accidental access;
• Destruction, alteration, blocking, or copying;
• Unauthorized distribution;
• Other unlawful actions by third parties.

We will cooperate with the User to take all reasonable steps to mitigate damages or other negative consequences resulting from the loss or disclosure of the User's personal data.

11. Rights and Obligations of the Parties

User Obligations:

• Provide accurate personal data required to use the online resources;
• Promptly update personal data if changes occur.

User Rights:

• Access: Request access to your personal data and information about its processing.
• Rectification: Correct or update inaccurate or incomplete data.
• Erasure/Anonymization: Request deletion or anonymization if no legal basis for retention exists.
• Objection: Object to processing if you believe it is unjustified.
• Restriction: Temporarily restrict processing during dispute resolution.
• Portability: Receive a machine-readable copy of your data.
• Withdrawal: Withdraw consent at any time (does not affect pre-withdrawal processing).
• Complaint: Lodge a complaint with your local data protection authority.
• Non-Discrimination: Not face discrimination for exercising these rights.
• Opt-Out of Targeted Ads: Disable such ads (not applicable by default in our services).

Site Administration Obligations:

• Use collected information only for purposes specified in this Policy.
• Maintain confidentiality and refrain from unauthorized disclosure, sale, or exchange of User data, except as permitted herein.
• Implement legal, organizational, and technical measures to protect personal data against:
  • Unauthorized access;
  • Destruction, alteration, or blocking;
  • Unlawful copying or distribution.
• Block personal data upon User request (or by competent authorities) during investigations into inaccuracies or unlawful processing.

To exercise your rights, contact us at pr@cellframe.net. Identity verification may be required.

12. Third-Party Links and Platforms

Cellframe services may contain links to:

• Third-party websites;
• Decentralized applications (dApps).

We:

• Do not control their privacy practices;
• Assume no liability for their data processing.

When interacting with dApps via our wallet, we minimize data transfer using:

• Proxy mechanisms;
• Anonymous identifiers (where feasible).

Caution: Pages displaying the Cellframe logo may have separate privacy policies. Review them before use.

13. Policy Updates

We may amend this Policy without User consent. Updates will be:

• Published on our website/wallet interface;
• Dated at the top of the document.

Continued use of services constitutes acceptance of the revised Policy.