Privacy Notice

Last Updated: March 14, 2024

Why Do You Need this Privacy Notice?

We encourage you to carefully read this Privacy Notice as it provides you with information about your personal data being processed in connection with:

  • your access to and use of the Products and Services; and
  • discussions for evaluating or pursuing our engagement by you and/or certain business relationships with us (the “Business Relationship”).

In this Privacy Notice, personal data and personal information are used as synonyms and mean any information that directly or indirectly identifies you as an individual. In this Privacy Notice we explain which types of personal data we hold on you, how we collect and process such data, how long we keep it, and so on.

Where Can You Find the Definitions?

Unless otherwise provided in this Privacy Notice, capitalized terms used in this Privacy Notice have the meaning determined in the Blockscout Terms & Conditions (the “Terms”). We encourage you to read the Terms carefully as they affect your obligations and legal rights.

Who Are We and How to Reach Us?

When we say “we”, “us”, or “our”, we mean Blockscout Limited, a Seychelles international business company. With respect to personal data collected when you access and use the Products and/or Services, we act as a data controller, meaning that we solely determine what data collected and the purposes and means of data processing.

We process your personal data in accordance with this Privacy Notice and we endeavor to comply with the applicable data protection legislation.

If you have any questions regarding this Privacy Notice or the processing of your personal data, do not hesitate to contact us via the following contact details:

  • Name: Blockscout Limited
  • Address: House of Francis, Room 303, Ile Du Port, Mahe, Seychelles
  • Email: info@blockscout.com

What Personal Data Do We Collect?

The categories of personal data we collect depend on how you interact with us, use the Products, and the requirements of the applicable laws. We collect and process the following types of personal data as outlined below. Please note that we may also collect certain other information, which may be required under the applicable laws.

Category of Data
Examples
Description
Other Comments
Business Relationship Data
full name
This includes your email address or Telegram handle
–
contact details
This includes your email address or Telegram handle
–
position within the company you represent
This includes information about your position or title within the company you represent, such as a director, manager, etc.
We collect this data if you represent the company, entering into the Business Relationship with us.
other information requested by us, or data that you choose to provide us with
This may include information about the name of the company or project you represent, etc.
Please do not provide personal data unless it is reasonably necessary or requested by us.
Wallet Data
Wallet Addresses
“Wallet Address” means a public address on the respective blockchain network associated with the relevant Wallet. It constitutes a random set of symbols assigned by the respective blockchain network.
While processing the Wallet Addresses and transactions associated therewith, we can not identify you as an individual, because it is impossible to identify you having only a random set of symbols.
Wallet balances
As the Wallet Address is publicly available, any person, including us, may see the amount of Digital Assets stored in the respective Wallet.
Therefore, generally, this data is not personal. However, under the applicable data protection legislation, if such data is combined with certain other data (such as a name, email address, nickname, etc.) it may become possible to identify you as an individual and thus, such a set of data may be deemed personal information.
information about transactions associated with the Wallet Address
This may include information about transaction amount, time and date, transaction ID and status, Wallet Addresses of sender and recipient, etc.
Account Data
email address
–
Email address may be considered personal data.
password
–
–
nickname
This does not have to be personal data.
The nickname is generated automatically based on your email address.
internal ID
When an Account is created, a unique internal ID, which essentially is a random identification number, will be automatically assigned to each such Account.
The internal ID is technically necessary to operate the Explorer and used for internal purposes to count the users. Without any other pieces of data, the internal ID does not identify you as an individual.
Third-Party Account Data
This may include your nickname, email address, authentication token or certain other data received from your Third-Party Account to the extent notified to you when you link such a Third-Party Account to the Account.
General. You may use a third-party account, such as GitHub Account (the “Third-Party Account”) to create, verify, and log in to your Account. In this case, we may access certain personal data associated with such Third-Party Account as described in this Privacy Notice.

Deactivation. You may deactivate the connection between your Account and Third-Party Account by contacting us or using the functionality of the respective Third-Party Account. In the latter case, as soon as we become aware of such deactivation, we will delete the respective information stored on our servers, except for the personal data that becomes a part of your Account, if any.

Role. With respect to the Third-Party Account Data, we act as a data controller. However, the respective service provider of such a Third-Party Account may use your personal data for any of its own purposes, in which case, it acts as an independent data controller. We encourage you to review the privacy policy, notice, or statement of every service provider whose Third-Party Account you use.
Cookies Data
As outlined in “What Types of Cookies Do We Collect and Use?” Section.
You may find a detailed description in “What Types of Cookies Do We Collect and Use?” Section.
When you access and use the Products, certain data may be collected automatically via Google, Clearbit and/or Mixpanel.
Marketing Data
email address
Email addresses may be considered personal data.
–
full name
This may include your first name, last name and middle name, if any.
Please do not provide it unless it is reasonably necessary or requested by us.
Contact Data
full name
This includes your first name, last name and middle name, if any.
Please do not provide it unless it is reasonably necessary or requested by us.
contact details
This may include your email address or social media contacts, such as a Telegram handle.
–
any other data requested by us or data that you choose to provide us with
–
Please do not provide personal data unless it is reasonably necessary or requested by us.

How Do We Use Personal Data?

Category of Data
Description
Lawful Basis for Processing
Business Relationship Data
To establish and maintain a Business Relationship with you or the company you represent, if any, including to execute the relevant agreements, such as a service level agreement, engagement offer, etc., in connection with the Business Relationship
To take steps at your request prior to entering into a contract

perform a contact with you.

legitimate interests to enter and perform the Business Relationship with such company.
To publish and publicly display testimonials made by you regarding our Products and Services.
Our legitimate interests to promote and market the Products and Services.
Wallet Data
To ensure the operation of the Products and enable you to use their functionality.
To perform a contract with you.
Account Data
To create and register an Account to access and use certain functionality of the Explorer.
To perform a contract with you.

legitimate interest to ensure the access and use of the Blockscout Explorer by the legal entity you represent.
Cookies Data
As outlined in “What Types of Cookies Do We Collect and Use?” Section below.
Your consent.
Marketing Data
To provide you with marketing and newsletter emails concerning the Products and/or Services.
Our legitimate interest to provide you, as our former or current user, with information regarding the Products and/or Services.

You may unsubscribe from receiving marketing and newsletter emails from us at any time by (i) contacting us; or (ii) clicking the unsubscribe button available at the bottom of each marketing and newsletter email. In this case, we will delete your email address from the respective marketing database.

Please note that administrative or service-related communications (email verifications, maintenance notifications, etc.) are not considered marketing and such communications may not offer an option to unsubscribe.
Contact Data
To respond to your inquiry.
Our legitimate interest to respond to your inquiry.

How Long Do We Process Your Data?

As a general rule, we keep personal data as long as it is necessary for the purposes it was collected. We may process certain personal data longer than outlined below, if it is necessary:

  • (a) to meet our legal obligations under the applicable law;
  • (b) in relation to anticipated or pending legal proceedings; or
  • (с) to protect our rights and legitimate interests or those of third parties.
Category of Data
Storage Period
Rationale
Business Relationship Data
Pending discussions of and as long as we maintain our Business Relationship and for five (5) years after the end of the respective fiscal year, when the Business Relationship expires or terminates.
We set these retention periods to:

• keep and retain the business records to comply with the applicable laws;

• perform a contract with you;

• maintain information about you as a representative of your company;

• protect our or third-party rights in case of any violation of your confidentiality or other obligations in relation to the Business Relationship; and

• resolve disputes, establish, exercise or defend legal claims or lawsuits arising out or in connection with the Business Relationship.
We set this retention period due to the statutes of limitations established in the Terms.
Wallet Data
As long as you keep your Wallet connected to the Explorer.

Please note that due to the nature of a blockchain, the Wallet Data may be stored permanently on the applicable blockchain (not by us).
We need such data for the purposes outlined above.
Account Data
As long as you keep your Account within the Explorer
We process your Account Data as long as it is necessary for the operation of your Account.
Cookies Data
Please note that we do not establish any storage period with respect to the Cookies Data that is anonymous, aggregated and does not allow us to identify any particular person.

If and to the extent we become able to identify any particular person, we will promptly update this Privacy Notice and establish a certain limitation period for processing the Cookies Data.
We need such data for the purposes outlined by us in “What Types of Cookies Do We Collect and Use?” Section
Marketing Data
As long as you remain a subscriber.
We process such data until you opt out from receiving our marketing and newsletter emails.
Contact Data
For one (1) year from the last date when you contacted us regarding the same matter.
We set this retention period due to the statutes of limitations established in the Terms.

How Do We Share Your Data?

General

We do not sell or rent out your data. However, we may share your personal data in accordance with this Privacy Notice, applicable legislation, or with your consent, in each case for the purposes of and if it is reasonably necessary:

  • to provide you with access to the Products and performance of our undertakings with you;
  • to enter into and perform the Business Relationship with you or the company you represent;
  • for compliance with the applicable laws and regulations; or
  • for our legitimate interest to maintain, improve and develop the Products.

Please note that if we share any portion of your personal data with third persons, we will endeavor to secure such transfer using appropriate legal, organizational, and technical measures.

Recipients

Given the purposes outlined above, your personal information is shared with the following categories of recipients:

  • Affiliates;
  • our personnel, contractors and consultants, who are required to have such information in connection with the Business Relationship and on a “need-to-know” basis, such as legal team for conducting the paperwork, financial team for administering payments, etc;
  • analytical solution providers, such as Google, Clearbit and Mixpanel;
  • email delivery service providers;
  • support and technical teams;
  • marketing teams;
  • hosting service providers;
  • government authorities, upon their request or if necessary to comply with our legal obligations;
  • online forms/surveys service providers;
  • another entity if we sell or otherwise transfer the Products or their part; and
  • other third-party solutions, which may be from time to time integrated in relation to the Products.

What Are the Features of Blockchain Data Processing?

Please note that Wallet Data may interact with public decentralized blockchain infrastructures and blockchain-based software, including smart-contracts, that work autonomously. The data entered in a public decentralized blockchain is distributed via the nodes that simultaneously store all records entered into the blockchain.

By design, blockchain records cannot be changed or deleted and are said to be “immutable”. Please be aware that any transaction within a blockchain may be irreversible and information entered into a blockchain cannot be deleted or changed. Therefore, your ability to exercise certain data protection rights or abilities may be limited.

In addition, due to the blockchain’s nature, the information that was entered in a blockchain will be publicly available and we may neither control such information nor manage access to it. Once you start carrying out transactions, certain data, which may be considered personal, will become publicly available on a blockchain. The ultimate decision whether to transact on a blockchain or carry out any transactions rests with you.

Are You Subject to Automated Decision-Making?

Automated decision-making is the process of making a decision by automated means without any human influence on the outcomes. We do not make any automated decisions based on your personal data. If we intend to process your personal data by any automated means, we will do our best to inform you about the same prior to such processing.

What About Interacting with Third-Party Links?

The Website may include links and social media plugins to third-party websites and applications. Clicking on those links or enabling those connections may allow third parties to collect or share certain data about you. We do not control these third-party websites and applications, and are not responsible for their privacy statements. When you leave the Website, we encourage you to read the privacy policy/notice/statement of every website or application you visit.

What Data Subject Rights Do You Have?

General

According to the applicable data protection legislation, you may have the rights outlined below. In order to exercise your rights as a data subject, we may request certain information from you to verify your identity and confirm that you have the right to exercise such rights.

Blockchain Data Processing

Please note that when you interact with a blockchain, we may not be able to exercise certain rights that you may have pursuant to the applicable data protection legislation with respect to the Wallet Data. For instance, we may not be able to ensure that such personal data is deleted, corrected, or restricted. You may learn more above in the “What Are the Features of Blockchain Data Processing?” section of this Privacy Notice.

Data Subject Rights

According to the applicable legislation, you may have the following rights:

Rights
Description
Right to access your personal data
This enables you to ask us whether we process your personal data. If we process your data, you may request certain information about the processing activity and/or a copy of the personal data we hold about you, and check that we are lawfully processing it.
Right to rectification of the personal data
This enables you to have any incomplete or inaccurate data we hold about you completed or rectified, though we may need to verify the accuracy of the new data you provide to us.
Right to erasure of your personal data (commonly known as a “right to be forgotten”)
This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.

Note, however, that we may not always be able to comply with your request of erasure for specific legal or technical reasons which will be notified to you, if applicable, at the time of your request
Right to object to processing of your personal data
This enables you to object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Right to restrict the processing of your personal data
This enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish the data’s accuracy, (ii) where our use of the data is unlawful but you do not want us to erase it, (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims, (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data (commonly known as a “right to the data portability”)
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to withdraw consent
You may withdraw your consent at any time where we are relying on consent to process your personal data.
Right not to be subject to automated decision-making
If and to the extent applicable, you reserve the right not to be subject to a decision based solely on automated processing of data, including profiling, which produces legal effects concerning you or similarly significantly affecting you.
Right to file a complaint
You may file a complaint with a relevant supervisory authority in case we violate your rights or obligations imposed on us under the applicable legislation. The relevant supervisory authority will particularly depend on where you are located.

Do We Process Children’s Personal Data?

The Products are not intended for the use of children (under 18 years old or older, if the country of your residence determines a higher age restriction). We do not knowingly market to, solicit, process, collect, or use personal data of children.

If we become aware that a child has provided us with personal information, we will use commercially reasonable efforts to delete such information from our database. If you are the parent or legal guardian of a child and believe that we have collected personal information from your child, please contact us.

What Types of Cookies Do We Collect and Use?

General

Cookies are, in effect, small data files that are placed on the browser of a visitor’s device (such as computer, smartphone, tablet, etc.) when accessing online content and by which it is possible to recognise that device when it interacts with or returns to the Website (the “Cookies”). Cookies and similar technologies use unique codes that act as an identifier and, in certain circumstances, may be treated as personal data under the applicable data protection legislation. This is because they can enable the user of a device to be uniquely recognised as the same user, even if their “real world” identity is unknown. Please note that we may involve third-party service providers to collect and process certain Cookies.

Cookies Types

We collect essential and non-essential Cookies. Essential Cookies are required for the Website to operate properly. We do not need your consent to operate essential Cookies since these Cookies ensure basic functionalities and security features of the Website, anonymously. We are required to get your consent to operate the non-essential Cookies, used to analyse your behaviour on the Website (e.g., analytical cookies).

Third-Party Service Providers

More information regarding cookies placed by Google, Clearbit and Mixpanel is provided below.

Google Data

When you access and use the Website, certain data may be collected automatically via Google Analytics. More information regarding Google Analytics is available here.

We collect the following information via Google Analytics: (i) internet protocol (IP) address, (ii) device details, (iii) operating system, (iv) browser details, (v) information regarding your use of the Website, for instance, when you clicked a certain button or made some input. After collecting the personal data, Google creates reports about the use of the Website, which contain the aggregated information where we do not see any data pertaining to a particular person. In other words, we cannot identify you from other Website visitors. For better understanding, IP address means an “online address” of a device, which may help to identify your approximate location (e.g, country, city or region, ZIP code). The IP addresses are expressed as a set of numbers, for example: 194.150.2.33. Please note that according to Google’s documentation, the IP address is anonymised (masked), so neither we nor Google can identify the IP address and precise location of a particular visitor.

Google Analytics is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, and its affiliates including Google LLC, 1600, Amphitheatre Parkway, Mountain View, CA, 94043, USA (“Google”).

To our knowledge, the data collected via Google Analytics is not anonymised (with the exception of the IP address) and will be transmitted to, processed and stored by Google in the United States. You can learn more about how Google processes personal data in Google’s privacy policy. Note that competent US state authorities may have access to personal data collected by Google.

With respect to personal data collected via Google Analytics, Google acts as our data processor. However, Google may use this personal data for any of its own purposes, such as profiling and cross-platform tracking. In this case, Google acts as an independent data controller. You can learn more about Google tools here.

Clearbit Data

The following information may be collected via Clearbit Tag: (i) a unique identification number (ID) used to attribute the respective web page views and other activities to the Website visitor; and (ii) information about an account that a Website visitor belongs to or a company they work for.

More information regarding Clearbit Tag is available here. Clearbit Tag is operated by API Hub, Inc., 548 Market St. #95879, San Francisco, CA 94104, USA (“Clearbit”).

Mixpanel Data

Mixpanel provides us with the analytics regarding how users visited the Website, how long they stayed on the Website, etc. This helps us to provide a better experience and to understand the content you find useful.

More information regarding Mixpanel is available here. The Mixpanel solution is operated by Mixpanel, Inc., One Front Street, 28th Floor, San Francisco, CA 94111, USA (“Mixpanel”).

How Can You Control Cookies?

When you first access the Website, you have the right to decide whether to accept or reject non-essential Cookies. You do not need to allow non-essential Cookies to access and use the Website. However, enabling non-essential Cookies may allow for a more tailored browsing experience.

You can also disable non-essential Cookies within the Cookies preference centre available within the Website, if any, or by changing your browser settings at any time. How you can do this will depend on the browser you use. Most browsers (for example, Microsoft and Google) have dedicated privacy pages that explain how websites collect, handle, and pass on information to third parties.

Can We Modify and Update this Privacy Notice?

We keep our Privacy Notice under regular review and we may update it at any time. If we make any changes to this document, we will change the “Last Updated” date above. Please review this Privacy Notice to check for the updates. If we make substantial changes to the way we treat your personal information, we will display a notice on the Website.